Crédit Agricole

Red Line	Text of policies	Comments	Score
Regulatory requirements
Ensure Legality	CSR page A group with a long-standing commitment For over 20 years, Crédit Agricole has demonstrated its involvement through its various commitments, many of which have focused on the development of “climate finance”. Signatory of the: • United Nations Global Compact since 2003; • Equator Principles since 2003; • Principles for Responsible Investment since 2006; • Diversity Charter since 2008; • Sustainable Purchasing Charter since 2010; • Charter for the energy efficiency of commercial buildings since 2013; • Science Based Targets since 2016; • RE 100 since 2016. Forestry policy: The Bank will not participate in transactions linked to this sector if aware of the following characteristics:  illegal operation;	The policy requires compliance with national laws and international regulations	well
No Corruption and Tax Evasion	Fight against corruption page (...) Crédit Agricole Group obtaining ISO 37001 certification for its anti-corruption management system. It is the first French bank to comply with this international standard.	The bank has earned a certification for its policies to fight corruption, however, these could not be found on the website. Neither could policies on tax evasion/avoidance	partly
Ensure ESIA for mills and plantations	Forestry policy The Bank will analyze every transaction linked to the Forestry and Palm Oil sector according to the following criteria: Capacity and commitment of the project or client to manage environmental and social risks and engage with stakeholders:  quality of the environmental and social impacts assessment; In particular, the Bank will consider whether the assets of the clients are certified (FSC, national certification endorsed by PEFC, RSPO as the case may be). If the client has not committed to a plan targeting the certification of most of its assets within a reasonable period of time, the Bank will expect them to demonstrate implementing an impact assessment and management system of equivalent stringency and covering all the criteria listed above.	Though the policy mentions analysis of the ESIA, it does not clearly require one for all projects, especially for those where it is not legally required by the host country. It also accepts certification as a proxy for an ESIA. However, this does not cover pulp mills.	partly
Social requirements
Ensure FPIC	Forestry policy: The Bank will not participate in transactions linked to this sector if aware of the following characteristics: (...) when a significant non-compliance risk has been identified, unless it has received according to its own judgment, a satisfactory reply concerning: (...) - public consultation or, when necessary, consent from affected indigenous peoples;	The policy requires FPIC, 'when necessary', and it does not explain what that means. There are also no details about requirements for the FPIC procedures	partly
Respect Human Rights	Forestry policy: The Bank will not participate in transactions linked to this sector if aware of the following characteristics: (...) when a significant non-compliance risk has been identified, unless it has received according to its own judgment, a satisfactory reply concerning: (...)  the IFC Performance Standards3 (or similar standards when an export credit agency or a multilateral institution is involved in the financing) or the Environment, Health and Safety Guidelines, in particular with respect to establishing an ESMS4, protection of the fundamental rights of the workers, forced displacement of population, rehabilitation and closure plans, biodiversity conservation, impact on critical natural habitats, consent from Indigenous People5,protection of cultural heritage;	The policy references IFC and protects human rights well.	well
Respect Indigenous rights and customary land use rights	Forestry policy: The Bank will not participate in transactions linked to this sector if aware of the following characteristics: (...) when a significant non-compliance risk has been identified, unless it has received according to its own judgment, a satisfactory reply concerning: (...)  the IFC Performance Standards3 (or similar standards when an export credit agency or a multilateral institution is involved in the financing) or the Environment, Health and Safety Guidelines, in particular with respect to establishing an ESMS4, protection of the fundamental rights of the workers, forced displacement of population, rehabilitation and closure plans, biodiversity conservation, impact on critical natural habitats, consent from Indigenous People5,protection of cultural heritage;	See IFC - it partly protects against violations of indigenous rights and customary rights	partly
No forced resettlement	Forestry policy: The Bank will not participate in transactions linked to this sector if aware of the following characteristics: (...) when a significant non-compliance risk has been identified, unless it has received according to its own judgment, a satisfactory reply concerning: (...)  the IFC Performance Standards3 (or similar standards when an export credit agency or a multilateral institution is involved in the financing) or the Environment, Health and Safety Guidelines, in particular with respect to establishing an ESMS4, protection of the fundamental rights of the workers, forced displacement of population, rehabilitation and closure plans, biodiversity conservation, impact on critical natural habitats, consent from Indigenous People5,protection of cultural heritage;	The policy references IFC which partly protects this criteria.	not
Environmental Requirements
No forest degradation and deforestation	Forestry policy: The Bank will not participate in transactions linked to this sector if aware of the following characteristics:  conversion of lands having a high conservation value with respect to biodiversity (protected area listed under the categories I to IV of IUCN, primary forests or High Conservation Value Forests according to FSC, sites listed per the Alliance for Zero Extinction, peatlands);  location within wetlands of international importance covered by the Ramsar Convention5,  location within a site listed on the UNESCO World Heritage list,	It protects at least 5 of the criteria: * HCV; * Primary forests; * HCS; * Unesco and Ramsar sites; * habitats for protected species	well
Protect endangered species	Forestry policy: The Bank will not participate in transactions linked to this sector if aware of the following characteristics:  conversion of lands having a high conservation value with respect to biodiversity (protected area listed under the categories I to IV of IUCN, primary forests or High Conservation Value Forests according to FSC, sites listed per the Alliance for Zero Extinction, peatlands);  location within wetlands of international importance covered by the Ramsar Convention5,  location within a site listed on the UNESCO World Heritage list,	it prohibits conversion of land where endangered species occur, but it does not explicitly prohibit trade in IUCN listed species	partly
No high-risk species	Forestry policy: The Bank will analyze every transaction linked to the Forestry and Palm Oil sector according to the following criteria:. Environmental commitments:  introduction of invasive species and management of pesticides	The commitment of the client on the introduction of invasive species is analysied, but there are no minimum requirements, no prohibition for the use of GE. It also does not explicitly cover third party operations	partly
No fire		No publicly available policies or documentation were found that cover this criteria.	not
Protect peat	Forestry policy: The Bank will not participate in transactions linked to this sector if aware of the following characteristics:  conversion of lands having a high conservation value with respect to biodiversity ( (...) , peatlands);	It does not prohibit financing to plantations that are already established on peatlands (where no further conversion is happening)	partly
No persistent pollution	Forestry policy: The Bank will analyze every transaction linked to the Forestry and Palm Oil sector according to the following criteria:. Environmental commitments:  introduction of invasive species and management of pesticides	There are no clear requirements regarding pesticides nor regarding the technology used in the mill	not
Corporate association / scope of the policy
Corporate association / scope of the policy	Forestry and Palm oil policy: The present policy (the “Policy”) applies to all financings and investments activities and more broadly involvements of Crédit Agricole CIB (the “Bank”) that directly relate to the forestry and palm oil sector. As part of the Policy, the forestry and palm oil sector covers oil palms plantations and timber harvesting as well as palm oil production. Trading and usage of wood and palm oil are not covered by the present Policy.	As trading in wood is not included, the policy does not cover sourcing from third parties. It also does not mention the application to parent, sister nor subsidiary companies, nor does it clearly apply to pulp mills.	not

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