BTG Pactual

Red Line	Text of policies	Comments	Score
Regulatory requirements
Ensure Legality	Socio Environmental and Corporate Governance Policy Avaliamos riscos de ESG de acordo com os princípios da relevância e da proporcionalidade, sempre considerando a legislação aplicável e as melhores práticas de ESG. Responsible Investment Policy Strictly comply with environmental, social, health and safety laws, regulations and standards	BTG requires compliance with national laws, but it does not mention international conventions.	partly
No Corruption and Tax Evasion	Responsible Investment Policy Strictly comply with anti-corruption and bribery regulations TIG avoids corruption in all forms, including extortion and bribery, upholding compliance standards, and organizational integrity by complying with relevant antifraud and money-laundering regulations. Service providers are responsible for ensuring all anti-corruption and fraud compliance of their employees when performing operations and sourcing sub-contractors or materials on properties where TIG manages timberland.	The policy has anti-corruption measures, but does not mention tax avoidance or evasion.	partly
Ensure ESIA for mills and plantations		No publicly available policies or documentation were found that cover this criteria.	not
Social requirements
Ensure FPIC		No publicly available policies or documentation were found that cover this criteria.	not
Respect Human Rights	Global Environmental Social and Corporate Governance Policy Foster, protect and respect human rights in respect to business activities and in all stakeholder relationships, including our Staff Members, partners, clients, shareholders, counterparties, authorities and the society. Responsible Investment Policy Respect and uphold human rights in all operations and contracts. It is mandatory for all TIG employees and third-party service providers to respect and uphold human rights in all regions where we manage timberland. BTG Pactual and TIG are committed to the United Nations Global Compact and encourage every stakeholder to engage in these principles. We encourage the support, respect, and furtherance of internationally proclaimed human rights to help ensure there are no human rights abuses.	BTG states it respects human rights and that this policy also applies to its clients. It does not require clients to demonstrate compliance.	partly
Respect Indigenous rights and customary land use rights	ESG Annual Report 2017-18 Indigenous Rights In some regions where TIG is managing timberland assets, indigenous people are present and often have outstanding claims of rights to land in the area. Before an asset is acquired, the potential for a claim on the property by indigenous people is considered on 100% of the properties. For those properties located in regions with recognized indigenous populations, the history and potential for claims to assets by the community is diligently examined in the title search. Pre-Acquisition Traditional Community Check (Brazil KPI) In Brazil, in addition to indigenous populations, descendants of escaped slaves often reside in communities known as quilombolas. The quilombolas frequently have claim to rights over assets near their communities. Acquisition due diligence within Brazil requires a third-party examination of the potential for claims by both indigenous communities and quilombolas for 100% of the properties purchased.	The text, which is not a policy but from an ESG report, only requires the bank to check if there are indigenous or quilobola communities. It does not guarantee their rights to land.	partly
No forced resettlement		No publicly available policies or documentation were found that cover this criteria.	not
Environmental Requirements
No forest degradation and deforestation	Responsible Investment Policy TIG is committed to the enhancement of biodiversity in all regions where it manages property and promotes this initiative through the forest management supply chain by ensuring preferred positions to companies who demonstrate their commitment to ESG matters.	No clear requirements for the protection of any type of area	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	Responsible Investment Policy Develop supply chain and prioritize local hiring Service providers must comply with all applicable laws related to ESG and TIG also expects service providers to develop training programs focused on enhancing suppliers’ qualifications and workforce competency. When possible, local suppliers should be hired as a means to positively impact local communities.	Policies apply to the supply chain, but not to mother/daughter/sister companies	partly

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