IFC

Red LineText of policiesCommentsScore (Well Protected, Partly Protected, Not Protected)
Regulatory requirements
Ensure LegalityPS on environmental and social sustainability
5. In addition to meeting the requirements under the Performance Standards, clients must comply with applicable national law, including those laws implementing host country obligations under international law.(p2)
compliance with national and internation laws is requiredwell
No Corruption and Tax EvasionNot covered in publicly available policies and documentation.not
Ensure ESIA for mills and plantationsPerformance Standard 1 - Assessment and Management of Environmental and Social Risks and Impacts
PS 1. 5. The client (...) will conduct a process of environmental and social assessment
PS 1.7 (...) The process may comprise a full-scale environmental and social impact assessment, a limited or focused environmental and social assessment, or straightforward application of environmental siting, pollution standards, design criteria, or construction standards.
The policy requires clients to conduct an assessment, but it is no clear when this should be a full fledged ESIA. There is also no clear requirement to publish this ESIA.partly
Social requirements
Ensure FPICPS 1. 32. For projects with adverse impacts to Indigenous Peoples, the client is required to engage them in a process of ICP and in certain circumstances the client is required to obtain their Free, Prior, and Informed Consent (FPIC). The requirements related to Indigenous Peoples and the definition of the special circumstances requiring FPIC are described in Performance Standard 7.

PS 7. 13 and 14. Circumstances Requiring Free, Prior, and Informed Consent - Impacts on Lands and Natural Resources Subject to Traditional Ownership or Under Customary Use
PS 7 13 and 14 only apply to indigenous people, not other traditional communities. FPIC is also only required for projects located on Indigenous People's lands, not for those that are outside these lands, yet will impact them, for example by polluting the river that crosses these landspartly
Respect Human RightsPS 1. 3. Business should respect human rights (...) Due diligence against these Performance Standards will enable the client to address many relevant human rights issues in its project.

PS 2. 21. The client will not employ children in any manner that is economically exploitative, or is likely to be hazardous or to interfere with the child’s education, or to be harmful to the child’s health or physical, mental, spiritual, moral, or social development;

PS 2. 22. The client will not employ forced labor, which consists of any work or service not voluntarily performed that is exacted from an individual under threat of force or penalty.
The policy requires respect for human rights, and it requires clients to assess the risk of breaching human rights.well
Respect Indigenous rights and customary land use rightsPS 7. 14. If the client proposes to locate a project on, or commercially develop natural resources on lands traditionally owned by, or under the customary use of, Indigenous Peoples, and adverse impacts can be expected, the client will take the following steps (...) ; 16 (...) Where significant project impacts on critical cultural heritage are unavoidable, the client will obtain the FPIC of the Affected Communities of Indigenous Peoples.Rights of Indigenous People are failry well protected when the project is located on their land, but not when it is located outside it, eventhough it may impact the area. There are no safeguards for the rights of traditional, non-indigenous, communities.partly
No forced resettlementPS 5. 3. To help avoid expropriation and eliminate the need to use governmental authority to enforce relocation, clients are encouraged to use negotiated settlements meeting the requirements of this Performance Standard, even if they have the legal means to acquire land without the seller’s consent.
PS 5. 8. The client will consider feasible alternative project designs to avoid or minimize physical and/or economic displacement
PS 7. 13 and 14. Circumstances Requiring Free, Prior, and Informed Consent - Impacts on Lands and Natural Resources Subject to Traditional Ownership or Under Customary Use (applies to indigenous people)
Though the PS5 desencourages forced resettlement, but it is not clearly prohibited. FPIC requirements are not mentioned in PS 5. PS 7 requires FPIC in the case indigenous people are impacted, but it does not apply for other communities.partly
Environmental Requirements
No forest degradation and deforestationPS 6. 14. The client will not significantly convert or degrade natural habitats, unless all of the following are demonstrated:
 No other viable alternatives within the region exist for development of the project on modified habitat;
 Consultation has established the views of stakeholders, including Affected Communities, with respect to the extent of conversion and degradation;
 Any conversion or degradation is mitigated according to the mitigation hierarchy.
PS 6. 16. Critical habitats (...) including (i) habitat of significant importance to Critically Endangered and/or Endangered species; (As listed on the IUCN Red List of Threatened Species).
PS 6. 17. In areas of critical habitat, the client will not implement any project activities unless all of the following are demonstrated:
 No other viable alternatives within the region exist for development of the project on modified or natural habitats that are not critical;
 The project does not lead to measurable adverse impacts on those biodiversity values for which the critical habitat was designated, and on the ecological processes supporting those biodiversity values;
 The project does not lead to a net reduction in the global and/or national/regional population of any Critically Endangered or Endangered species over a reasonable period of time
PS 6. 20. In circumstances where a proposed project is located within a legally protected area or an internationally recognized area, the client will meet the requirements of paragraphs 13 through 19 of this PS, as applicable.
There is no full protection against degradation and deforestation. The "no other alternative" requirement only makes sense for projects that are of important national interest, not for pulp mills. Consultation is required, but it does no require FPIC. There is also no full protection for protected areas or critical habitatspartly
Protect endangered speciesPS 6. 16. Critical habitats are areas with high biodiversity value, including (i) habitat of significant importance to Critically Endangered and/or Endangered species; (As listed on the International Union for the Conservation of Nature (IUCN) Red List of Threatened Species).
PS 6. 17. In areas of critical habitat, the client will not implement any project activities unless all of the following are demonstrated:
 No other viable alternatives within the region exist for development of the project on modified or natural habitats that are not critical;
 The project does not lead to measurable adverse impacts on those biodiversity values for which the critical habitat was designated, and on the ecological processes supporting those biodiversity values;
 The project does not lead to a net reduction in the global and/or national/regional population of any Critically Endangered or Endangered species over a reasonable period of time
There is no full prohibition for the harvest and/or trade in IUCN listed speciespartly
No high-risk speciesPS 6. 22. The client will not intentionally introduce any new alien species (not currently established in the country or region of the project) unless this is carried out in accordance with the existing regulatory framework for such introduction. (...) Notwithstanding the above, the client will not deliberately introduce any alien species with a high risk of invasive behavior regardless of whether such introductions are permitted under the existing regulatory frameworkThe policy does offer recommendations against introducing alien species, but it is allowed, in compliance with the law. There is no mention of GMOs.partly
No fireNot covered in publicly available policies and documentation.not
Protect peatNot covered in publicly available policies and documentation.not
No persistent pollutionPS 3.4 4. During the project life-cycle, the client will consider ambient conditions and apply technically and financially feasible resource efficiency and pollution prevention principles and techniques that are best suited to avoid, or where avoidance is not possible, minimize adverse impacts on human health and the environment (...) consistent with good international industry practice (GIIP), as reflected in various internationally recognized sources, including the World Bank Group Environmental, Health and Safety Guidelines (EHS Guidelines).

PS 3. 4. (...) World Bank Group Environmental, Health and Safety Guidelines (EHS Guidelines); 13. The client will avoid the manufacture, trade, and use of chemicals and hazardous materials subject to international bans or phase-outs due to their high toxicity to living organisms, environmental persistence, potential for bioaccumulation, or potential for depletion of the ozone layer.16 (6 Consistent with the objectives of the Stockholm Convention on Persistent Organic Pollutants);

EHS Guidelines Pulp and Paper Mills:
Specific recommended applications common in the paper and pulp industry are as follows:
· Primary mechanical treatment: (...)
· Secondary treatment: (..)
The EHS for pulp and paper have detailed guidelines for waste water treatment. However, there is no clear prohibition of the use of elemental chlorine.partly
Corporate association / scope of the policy
Corporate association / scope of the policyPS 2. 27. Where there is a high risk of child labor or forced labor in the primary supply chain, the client will identify those risks consistent with paragraphs 21 and 22 above. If child labor or forced labor cases are identified, the client will take appropriate steps to remedy them.

PS 6. 30. Supply Chain
30. Where a client is purchasing primary production (especially but not exclusively food and fiber commodities) that is known to be produced in regions where there is a risk of significant conversion of natural and/or critical habitats, systems and verification practices will be adopted as part of the client’s ESMS to evaluate its primary suppliers.21 The systems and verification practices will (i) identify where the supply is coming from and the habitat type of this area; (ii) provide for an ongoing review of the client’s primary supply chains; (iii) limit procurement to those suppliers that can demonstrate that they are not contributing to significant conversion of natural and/or critical habitats (this may be demonstrated by delivery of certified product, or progress towards verification or certification under a credible scheme in certain commodities and/or locations); and (iv) where possible, require actions to shift the client’s primary supply chain over time to suppliers that can demonstrate that they are not significantly adversely impacting these areas. The ability of the client to fully address these risks will depend upon the client’s level of management control or influence over its primary suppliers.
Scope is only extended to suppliers for PS2 (Labour) and PS6 (Ecosystems). For PS2, clients are require to take action, but there are no guidelines on what that means. For PS6, clients have to assess their supply chain, but rely on certification schemes, for which there is no minimum criteria, and transition phases without timelimits.partly