Goldman Sachs

Red Line	Text of policies	Comments	Score
Regulatory requirements
Ensure Legality	Environmental Policy Framework For forestry transactions (including logging and primary processing of forest products), we will not knowingly finance companies or projects that collude with or are engaged in illegal logging or utilize illegal or uncontrolled fire.  As part of our enhanced due diligence, we examine whether clients that process, purchase or trade wood products from particularly high-risk countries have certifiable systems in place to ensure that the wood they process, purchase or trade comes from legal sources. This includes understanding clients’ supply chain monitoring systems and chain of custody certification. Furthermore, we will not finance projects that contravene any relevant international environmental agreement which has been enacted into the law of, or otherwise has the force of law in, the country in which the project is located	The policy requires clients to respect national law and international agreements, but the latter only if they have the force of law in the host country.	partly
No Corruption and Tax Evasion	Code of Conduct You must comply with all applicable laws, rules and regulations, including those related to insider trading, financial reporting, money laundering, fraud, bribery and corruption. Detailed rules regarding applicable laws are included in the Compendium. Generally, if you are aware of material nonpublic information relating to the firm, any of our clients or any other private or governmental issuer of securities, Goldman Sachs Code of Business Conduct and Ethics you cannot buy or sell any securities of those issuers or recommend that another person buy, sell or hold the securities of those issuers.	The bank has policies against financial crimes and will not trade in securities of companies that are involved in these. But it does not have clear requirements towards clients.	partly
Ensure ESIA for mills and plantations		No publicly available policies or documentation were found that cover this criteria.	not
Social requirements
Ensure FPIC	Environmental Policy Framework Indigenous People: Goldman Sachs recognizes that the identities and cultures of indigenous peoples are inextricably linked to the lands on which they live and the natural resources on which they depend. We recognize the rights of these communities regarding issues affecting their lands and territories, traditionally owned or otherwise occupied and used. For transactions where the use of proceeds may have the potential to directly impact indigenous peoples, we expect our clients to demonstrate alignment with the objectives and requirements of IFC Performance Standard 7 on Indigenous Peoples, including free, prior and informed consent.	FPIC is required for indigenous people but not for other affected communities	partly
Respect Human Rights	Human Rights Statement We place a high priority on the identification of potential human rights issues in the due diligence that precedes our business transactions. The Firm analyzes new and existing clients for a wide array of possible human rights-related issues, including labor practices, impacts on indigenous peoples, and proximity to conflict regions. This process informs our business decisions. We also engage with our clients in certain cases, encouraging them to consider adopting more sustainable practices and to take human rights issues into consideration in conducting their business. Child Labor, Forced Labor and Human Trafficking: We will not knowingly finance any potential transactions where there is credible evidence of child labor, forced labor or human trafficking.	Human rights are taking into account, but clients are not required to have a policy that also applies to third parties	partly
Respect Indigenous rights and customary land use rights	Environmental Policy Framework  We also recognize the significance of cultural and natural heritage and will not knowingly finance extractive projects, commercial logging or other environmentally sensitive projects in prescribed UNESCO World Heritage sites. Indigenous People: Goldman Sachs recognizes that the identities and cultures of indigenous peoples are inextricably linked to the lands on which they live and the natural resources on which they depend. We recognize the rights of these communities regarding issues affecting their lands and territories, traditionally owned or otherwise occupied and used. For transactions where the use of proceeds may have the potential to directly impact indigenous peoples, we expect our clients to demonstrate alignment with the objectives and requirements of IFC Performance Standard 7 on Indigenous Peoples, including free, prior and informed consent.	The policy recognizes the rights of indigenous people, but not that of local communities	partly
No forced resettlement	Environmental Policy Framework Stakeholder engagement and resettlement: For certain transactions where there could be material effects on local communities, we expect our clients to demonstrate an appropriate stakeholder engagement process. In cases where there is large-scale resettlement, we will closely evaluate the stakeholder engagement process and, if appropriate, work with the company to improve aspects such as compensation measures and/or community engagement.	The policyaddresses resettlement but does not require FPIC.	partly
Environmental Requirements
No forest degradation and deforestation	Environmental Policy Framework  We will not finance any projects or initiate loans where the specified use of proceeds would significantly convert or degrade a critical natural habitat.  We also recognize the significance of cultural and natural heritage and will not knowingly finance extractive projects, commercial logging or other environmentally sensitive projects in prescribed UNESCO World Heritage sites.	Some areas are protected, but the policy does not prohibit conversion of natural forests, nor does it necessarily protect HCV areas, HCS areas, peatlands or primary forests.	partly
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	Environmental Policy Framework For forestry transactions (including logging and primary processing of forest products), we will not knowingly finance companies or projects that collude with or are engaged in illegal logging or utilize illegal or uncontrolled fire.	The policy provides some protection, but still allows the use of controlled fire	partly
Protect peat	(Palm oil policy: Furthermore, we require clients to have a commitment to no net deforestation, no peatland development and no human rights violations.)	Though the palm oil policy does provide protection for peat areas, this does not apply to platantations for pulp production. So it is not covered in the applicable policies and documentation.	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	Environmental Policy Framework  As part of our enhanced due diligence, we examine whether clients that process, purchase or trade wood products from particularly high-risk countries have certifiable systems in place to ensure that the wood they process, purchase or trade comes from legal sources. This includes understanding clients’ supply chain monitoring systems and chain of custody certification.	There are some requirements for wood suppliers, but the GS policies do not generally apply to all the clients suppliers, parent, sister or daughter operations.	partly

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