| Red Line | Text of policies | Comments | Score |
|---|---|---|---|
| Regulatory requirements | |||
| Ensure Legality | Social and Environmental Responsibility Policy Principles: to proactively work in alignment with Brazilian public policies and standards and observe international behavioral regulations. SocioEnvironmental Policy • To act in line with current Brazilian legislation and public policies, in particular with the provisions set out in the National Environmental Policy and, abroad, with the laws applicable in each country; | The policy requires compliance with national laws, but does not mention which international conventions should be respected. | partly |
| No Corruption and Tax Evasion | Anti corruption policy. Art. 4 The PCA is applicable in Brazil and abroad to all Participants of the BNDES System and to people with which they maintain relations. Art. 3 The PCA’ objectives include: II - Reinforcing the BNDES System’s commitment to proactively cooperate with national and international initiatives to prevent and combat corruption, in all its forms; | BNDES has a Corporate Anti-corruption Policy, which aims to protect, detect and punish corruption and which applies to all of its stakeholders. BNDES also has a detailed questionnaire on integrity for its clients, which, among others, asks companies if they have an anti-corruption policy. Furthermore, on its website it states its commitment to the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions. But, the BNDES does not have a clear policy on tax evasion or avoidance. | partly |
| Ensure ESIA for mills and plantations | SocioEnvironmental Policy • Category A projects - Activity intrinsically linked to the risk of significant environmental impacts or those covering a regional scale. Licensing requires impact studies, preventive measures and mitigating actions. | Both pulp mills and forestry projects are category A, thus require an ESIA. It does not specifically require all stakeholders to have been consulted, nor for the study to be published online. | partly |
| Social requirements | |||
| Ensure FPIC | No publicly available policies or documentation were found that cover this criteria. | not | |
| Respect Human Rights | Social and Environmental Responsibility Policy Principles:to respect human rights while fighting and condemning any practices that result in any type of discrimination or violation of these rights; SocioEnvironmental Policy • cadastral research about the beneficiary, which includes verifying registers of work that is equivalent to slavery (consulting the public records or other official means) and environmental crimes; Social Clause With the Social Clause, BNDES can act with greater speed and accuracy to curb any criminal practices in projects funded by it. In other words, when noting non-compliance with the legislation that deals with fighting against discrimination of race or gender, child labor and slave labor, BNDES can transparently and more rapidly suspend or require early maturity of the financing agreement, requiring immediate payment of the disbursements made. | The policy requires respect for human rights, but does not reference key international conventions. | partly |
| Respect Indigenous rights and customary land use rights | Socioenvironmental Policy – Annex I (projects that require an ESIA) Enterprises that have the below listed characteristics in relation to sectors, location or generated impacts should be classified in Socioenvironmental Category A, except for those whose negative impacts are limited and reversible, of low relevance or that involve easily identifiable mitigating measures. In respect to these last cases, the enterprises can be classified in Socioenvironmental Category B: Located in socially and environmentally sensitive areas, such as: * areas of archaeological or cultural importance; and * areas of importance for indigenous peoples and other vulnerable groups. | The policy require an ESIA for these cases, it does not set any further requirements | not |
| No forced resettlement | Socioenvironmental Policy – Annex I (projects that require an ESIA) Enterprises that have the below listed characteristics in relation to sectors, location or generated impacts should be classified in Socioenvironmental Category A, except for those whose negative impacts are limited and reversible, of low relevance or that involve easily identifiable mitigating measures. In respect to these last cases, the enterprises can be classified in Socioenvironmental Category B: Other characteristics of the enterprise result in social and environmentally sensitive impacts, such as: * enterprises with large-scale involuntary resettlement, as a result of the interventions; | The policy require an ESIA for these cases, it does not prohibit it | not |
| Environmental Requirements | |||
| No forest degradation and deforestation | Socioenvironmental Policy – Annex I (projects that require an ESIA) Enterprises that have the below listed characteristics in relation to sectors, location or generated impacts should be classified in Socioenvironmental Category A, except for those whose negative impacts are limited and reversible, of low relevance or that involve easily identifiable mitigating measures. In respect to these last cases, the enterprises can be classified in Socioenvironmental Category B: Located in socially and environmentally sensitive areas, such as: * national parks and other protected areas identified by national or international law; * sensitive sites of international importance (Ramsar Convention sites, IUCN protected areas – International Union for Conservation of Nature and UNESCO World Heritage sites); * primary forests or natural forests in tropical areas, as well as other forests with high biodiversity value; Other characteristics of the enterprise result in social and environmentally sensitive impacts, such as: * enterprises involving large-scale logging or intense deforestation for other purposes | The policy require an ESIA for these cases, but it does not provide any clear protection | not |
| Protect endangered species | No publicly available policies or documentation were found that cover this criteria. | not | |
| No high-risk species | No publicly available policies or documentation were found that cover this criteria. | not | |
| No fire | No publicly available policies or documentation were found that cover this criteria. | not | |
| Protect peat | No publicly available policies or documentation were found that cover this criteria. | not | |
| 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 |
