Commerzbank

Red Line	Text of policies	Comments	Score
Regulatory requirements
Ensure Legality	Commerzbank Environmental Policy Naturally, we are committed to comply with all applicable environmental and energy related regulations. But, in addition, all divisions of the company are bound by strategic and operational objectives.	The policy requires compliance with national laws, but does not reference international conventions.	partly
No Corruption and Tax Evasion	Code of conduct Tax evasion and tax evasion aid It is our legal obligation and part of our social responsibility to contribute to the financing of public budgets with our taxes. For this reason alone, we reject any form of tax evasion, whether on the part of our clients, ourselves as a company or our business partners. It also violates the law. Bribery and corruption We firmly believe that our business success rests solely on the quality of our products and services, which is why we do not promise or award any payments or valuable gifts to employees of regulatory authorities or companies as a way to induce them to provide us with an unfair business advantage. Under no circumstances is the following permitted: • To use money of the Commerzbank Group for purposes that are not fully and properly documented. • To enter into contracts or agreements that have not been approved in accordance with the policies and guidelines of the Commerzbank Group. • To work with consultants or third parties who have not pledged to reject bribery and corruption.	The policy rejects any form of tax evasion and corruption, both on part of the bank and the client	well
Ensure ESIA for mills and plantations		No publicly available policies or documentation were found that cover this criteria.	not
Social requirements
Ensure FPIC	Policy Framework for handling ES risks in its core business (Feb 2019) 2. Cross-sectoral requirements - Indigenous people Indigenous peoples warrant special protection. In its transactions and business relationships, Commerzbank takes into account the potential impact on indigenous peoples, in particular:  compliance with their human rights,  observance of their land rights,  dispersion and forced resettlement,  environmental impact on the region.	Does not require FPIC	not
Respect Human Rights	Policy Framework for handling ES risks in its core business (Feb 2019) Commerzbank’s position on human rights Commerzbank is committed to respecting human rights. Commerzbank’s position on human rights is derived from the internationally accepted human rights standards, including the Universal Declaration of Human Rights, the International Covenant on Civil and Political Rights (ICCP), the International Covenant on Economic, Social and Cultural Rights (ICESCR), and the International Labour Standards of the ILO. As a company headquartered in Germany, Commerzbank is tied to the Guidelines for Multinational Enterprises of the OECD. Furthermore, the Bank follows the UN Guiding Principles for Business and Human Rights. Commerzbank has been committed to the UN Global Compact since 2006 ( ...) Position on Human Rights 2.3 Clients - Commerzbank also factors in human rights aspects in its business activities with its clients. Universal human rights are protected by national and international laws. Commerzbank is vigilant about its customers not breaching any human rights when conducting business. (...)Furthermore, the Reputational Risk Management department intensively researches, analyses, and assesses transactions and business relationships in which human rights play a significant role (e.g. mining, resource extraction or cotton production). This may lead to the rejection of the relevant transaction or even the termination of a relationship.	Compliance with ILO and other conventions is required, which provide respect for human rights	well
Respect Indigenous rights and customary land use rights	Policy Framework for handling ES risks in its core business (Feb 2019) Indigenous peoples warrant special protection. In its transactions and business relationships, Commerzbank takes into account the potential impact on indigenous peoples, in particular:  compliance with their human rights,  observance of their land rights,  dispersion and forced resettlement,  environmental impact on the region.	The policy does not explicitly respect the land right of indigenous and local communities	partly
No forced resettlement		No publicly available policies or documentation were found that cover this criteria.	not
Environmental Requirements
No forest degradation and deforestation	Policy Framework for handling ES risks in its core business (Feb 2019) Commerzbank examines the following factors when assessing proposed transactions and business relationships in the wood industry:  illegal logging by companies;  compliance with requirements in the wood industry, e.g. the Forest Stewardship Council (FSC) and the Programme for the Endorsement of Forest Certification Schemes (PEFC);  the protection of plants included in the Red List of Threatened Species by the International Union for Conservation of Nature (IUCN). Environmental and Social Framework; Commerzbank investigates:  protection of High Conservation Value Areas (HCVAs) and UNESCO World Cultural Heritage sites or similar protected areas (if applicable, with the involvement of local specialists or NGOs);  illegal or uncontrolled clear-cutting of forests by companies.	The policy requires assessment of risks to a variety of areas, but does not clearly protect them. It does not mention HCS nor natural forests.	partly
Protect endangered species	Policy Framework for handling ES risks in its core business (Feb 2019) Commerzbank examines the following factors when assessing proposed transactions and business relationships in the wood industry:  illegal logging by companies;  compliance with requirements in the wood industry, e.g. the Forest Stewardship Council (FSC) and the Programme for the Endorsement of Forest Certification Schemes (PEFC);  the protection of plants included in the Red List of Threatened Species by the International Union for Conservation of Nature (IUCN).	The policy requires assessment of risks to IUCN red list species, but does not clearly protect them.	partly
No high-risk species		No publicly available policies or documentation were found that cover this criteria.	not
No fire	In case of proposed business activities connected to agriculture or forestry, Commerzbank investigates (...)  illegal or uncontrolled burning of forests by companies.	The policy does not allow uncontrolled fires, but still does not forbid their use	partly
Protect peat		No publicly available policies or documentation were found that cover this criteria.	not
No persistent pollution	Commerzbank therefore takes into account (...) the use of environmentally harmful chemicals in the pulp and paper industry.	The policy asseses the use of harmful chemicals, but does not set any criteria regarding what is not allowed.	partly
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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