Barclays

Red Line	Text of policies	Comments	Score
Regulatory requirements
Ensure Legality	Forestry and Palm Oil Statement (2019) Barclays has no appetite for (...): I. Illegal logging or trading activities. IV. Operations or business practices that do not comply with all applicable local, national, and international laws and regulations	The policy requires compliance with local, national and international law.	well
No Corruption and Tax Evasion	Tax Policy We believe that tax planning, for clients and on our own account, must...  Support genuine commercial activity  Comply with generally accepted custom and practice, in addition to the law and the UK Code of Practice on Taxation for Banks  Be of a type that the tax authorities would expect  Only take place with customers and clients sophisticated enough to assess its risks  Be consistent with, and seen to be consistent with, our purpose and values. Financial Crime Statement We will not tolerate any deliberate breach of financial crime laws and regulations (e.g. bribery, corruption, and money laundering, sanctions, or tax evasion facilitation) that apply to our business and the transactions we undertake. Tax evasion is a financial crime and a predicate offence to money laundering in the UK and in many other countries in which we operate. Barclays is committed to:  Dealing only with customers who have appropriately declared their assets to the relevant tax authorities	Barclays does not allow its clients to be involved in tax evasion. It is less clear on the requirements to clients regarding involvement in corruption.	partly
Ensure ESIA for mills and plantations		No publicly available policies or documentation were found that cover this criteria.	not
Social requirements
Ensure FPIC	Forestry and Palm Oil Statement (2019) We require all forestry, pulp and paper and palm oil clients to: V. Obtain the consent of indigenous and local communities affected by their operations through a credible “free, prior and informed consent” process.	FPIC is required for all impacted communities	well
Respect Human Rights	Forestry and Palm Oil Statement (2019) Barclays has no appetite for (...): III. Acts of violence against or exploitation of people and local communities, including through forced or child labour, modern slavery and human trafficking. Statement on Human Rights As a responsible corporate citizen we are committed to operating in accordance with the International Bill of Human Rights (comprising the Universal Declaration of Human Rights (UDHR), the International Covenant on Economic, Social and Cultural Rights and the International Covenant on Civil and Political Rights). We also take into account the UN Framework and Guiding Principles and other internationally accepted human rights standards including the OECD Guidelines for Multinational Enterprises and the International Labour Organisation (ILO) Declaration on Fundamental Principles and Rights at Work and other Core Conventions. We monitor all current and emerging human rights-related regulation including the UK Modern Slavery Act 2015 and ensure that our policies and practices are adapted accordingly.	The policy upholds key international conventions on human rights	well
Respect Indigenous rights and customary land use rights	Forestry and Palm Oil Statement (2019) We require all forestry, pulp and paper and palm oil clients to: V. Obtain the consent of indigenous and local communities affected by their operations through a credible “free, prior and informed consent” process.	FPIC is required for all impacted communities. This covers land rights	well
No forced resettlement	Forestry and Palm Oil Statement (2019) We require all forestry, pulp and paper and palm oil clients to: V. Obtain the consent of indigenous and local communities affected by their operations through a credible “free, prior and informed consent” process. Statement on Human Rights 3.3.2. Provision of project finance must be consistent with Barclays’ own Environmental and Social Risk Standard and with the Equator Principles, which include specified human rights/social risk management criteria. Issues in scope for due diligence include health and safety of communities and workers, protection of cultural heritage, involuntary resettlement and compensation, community engagement and grievance mechanisms for affected groups.	FPIC is required for all impacted communities. This covers resettlement	well
Environmental Requirements
No forest degradation and deforestation	Forestry and Palm Oil Statement (2019) Barclays has no appetite (...) I. Illegal logging or trading activities. ; (...) we require all forestry, pulp and paper (...) clientes to: (...) VI. Prohibit the conversion or degradation of primary tropical forests, High Conservation Value (HCV) or High Carbon Stock (HCS) areas and peatlands. VII. Achieve full certification of all owned production and primary processing facilities: (...) b) For forestry and pulp and paper companies this means Forest Stewardship Council (FSC) or comparable certification of owned logging sites in lower income countries, where such schemes are established. c) In the absence of certification, we require the client to develop a time-bound action plan to achieve this within three years, which will be monitored annually by Barclays World Heritage Site and Ramsar Wetlands Statement (2018) Barclays has no appetite for the following scenarios: • Project finance transactions that support the development or expansion of projects in World Heritage Sites and/or within their buffer zones, unless there is prior consensus with both the host country and UNESCO that such development will not adversely affect the Outstanding Universal Value of the site; • Project finance transactions that support the development or expansion of projects situated in Ramsar Wetlands, unless there is prior consensus with the host country that such development will not adversely affect the special characteristics of a Ramsar designated site	Protect some but not all types of areas. Considering the scope of the policy, non tropical forests and those in high income countries are not protected either	partly
Protect endangered species	Forestry and Palm Oil Statement (2019) (...) we require all forestry, pulp and paper (...) clientes to: (...) VI. Prohibit the conversion or degradation of primary tropical forests, High Conservation Value (HCV)	The protection of HCV areas includes the protection of areas that contain protected species. It does not explicitly prohibit the trade in IUCN red list species	partly
No high-risk species		No publicly available policies or documentation were found that cover this criteria.	not
No fire	Forestry and Palm Oil Statement (2019) Barclays has no appetite for (...): II. Use of illegal or uncontrolled fire in forestry or plantation operations, including for land clearance and preparation.	The policy provides some protection, but still allows the use of controlled fire	partly
Protect peat	Forestry and Palm Oil Statement (2019) Barclays has no appetite (...) I. Illegal logging or trading activities. ; (...) we require all forestry, pulp and paper (...) clientes to: (...) VI. Prohibit the conversion or degradation of primary tropical forests, High Conservation Value (HCV) or High Carbon Stock (HCS) areas and peatlands.	Prohibits conversion of peatlands, but does not protect peat where conversion has already occured.	partly
No persistent pollution		No publicly available policies or documentation were found that cover this criteria.	not
Corporate association / scope of the policy
Corporate association / scope of the policy		No publicly available policies or documentation were found that cover this criteria.	not

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