JP Morgan Chase

Red LineText of policiesCommentsScore
Regulatory requirements
Ensure LegalityEnvironmental and Social Policy Framework
We adhere to a range of internationally-recognized principles of best practice to assess E&S impacts and promote responsible performance. These include:
 The United Nations Universal Declaration of Human Rights
 The Wolfsberg Principles (anti-money laundering)
 The Equator Principles
 The Green Bond Principles
 The Extractive Industries Transparency Initiative
 Soft Commodities Compact
 United Nations Principles for Responsible Investment
(...)
* Illegal Logging: Transactions with entities or projects that collude with or are knowingly engaged in illegal logging. Clients that process, purchase, or trade wood products from high risk countries (i.e., where more than 50% of the harvest is illegal) will have certifiable systems in place to ensure that the wood they process or trade comes from legal sources. Due diligence includes company representations as to its practices, monitoring and chain of custody certification (e.g., Forest Stewardship Council controlled wood standard) for illegal logging;
The policy requires the bank to uphold a set of international conventions, but it does not mention key ones, like to ILO core conventions. It also does not clearlu require its clients to uphold these international conventionspartly
No Corruption and Tax EvasionCode of Conduct
Comply with applicable government laws, rules and regulations of federal, state and local governments and other appropriate regulatory agencies (CoC page)
AML
• Make sure you accurately complete all “know your customer” requirements.
• If your job requires more detailed knowledge of anti-money laundering, counter-terrorist financing and sanctions rules, talk to your manager to
receive and complete the necessary training.
• Be alert to — and report — any unusual or suspicious activity to your manager, Anti-Money Laundering Investigations, the Global Financial Crimes Compliance Office or the Risk Manager responsible for anti-money laundering and sanctions compliance.
• Complete all required Compliance training on a timely basis.
We must never compromise our reputation by engaging in, or appearing to engage in, bribery or any form of corruption.
JPMorgan Chase is committed to complying with both the letter and the spirit of applicable tax laws wherever we operate and ensuring accuracy in the tax-related records we produce and the tax information we are required to report. You may not facilitate any client activities intended to breach applicable tax laws, which may include engaging in activities that would assist a client in evading the payment of taxes that are due and payable or concealing information from tax authorities.
The policy is focused on the involvement of the bank itself in financial crime, not that of clients.partly
Ensure ESIA for mills and plantationsNo publicly available policies or documentation were found that cover this criteria.not
Social requirements
Ensure FPICEnvironmental and Social Policy Framework
For transactions where we can identify that the use of proceeds may have the potential to impact Indigenous Peoples, we expect our clients to demonstrate alignment with the objectives and requirements of IFC Performance Standard 7 on Indigenous Peoples, including with respect to circumstances requiring Free, Prior and Informed Consent. These objectives include:
 Ensuring that the development process fosters full respect for the human rights, dignity, aspirations, culture, and natural resource-based livelihoods of Indigenous Peoples;
 Anticipating and avoiding adverse impacts of projects on communities of Indigenous Peoples, or when avoidance is not possible, to minimize and/or compensate for such impacts;
 Promoting sustainable development benefits and opportunities for Indigenous Peoples in a culturally appropriate manner;
 Establishing and maintaining an ongoing relationship based on informed consultation and participation with the Indigenous Peoples affected by a project throughout the project’s life- cycle;
 Ensuring the Free, Prior and Informed Consent of the Affected Communities of Indigenous Peoples when the circumstances described in Performance Standard 7 are present; and
 Respecting and preserving the culture, knowledge, and practices of Indigenous Peoples.
IFC standards do not require FPIC for non-indigenous communities.partly
Respect Human RightsHuman Rights Page
JPMorgan Chase supports fundamental principles of human rights across all our lines of business and in each region of the world in which we operate.
JPMorgan Chase complies with applicable international and local legal requirements in the countries in which we operate. Where local law conflicts with the principles contained in this Human Rights Statement, JPMorgan Chase complies with local requirements while, at the same time, seeking ways to uphold the principles set forth in this Human Rights Statement.

Environmental and Social Policy Framework
The following section outlines transactions that we will not finance:
 Modern Slavery and Child Labor: Transactions where there is evidence of modern slavery, such as forced labor and human trafficking, or child labor;
(...) we assess management commitment to respect human rights through a policy or recognition of international standards and a client’s capacity to effectively implement such a policy with appropriate management systems or governance approaches. In particular, we look for evidence that the company is assessing compliance with its policies and procedures within its own supply chain, typically by operating an internal audit process.
Clients must have a human rights policy which also applies to their supplierswell
Respect Indigenous rights and customary land use rightsEnvironmental and Social Policy Framework
For transactions where we can identify that the use of proceeds may have the potential to impact Indigenous Peoples, we expect our clients to demonstrate alignment with the objectives and requirements of IFC Performance Standard 7 on Indigenous Peoples, including with respect to circumstances requiring Free, Prior and Informed Consent. These objectives include:
 Ensuring that the development process fosters full respect for the human rights, dignity, aspirations, culture, and natural resource-based livelihoods of Indigenous Peoples;
 Anticipating and avoiding adverse impacts of projects on communities of Indigenous Peoples, or when avoidance is not possible, to minimize and/or compensate for such impacts;
 Promoting sustainable development benefits and opportunities for Indigenous Peoples in a culturally appropriate manner;
 Establishing and maintaining an ongoing relationship based on informed consultation and participation with the Indigenous Peoples affected by a project throughout the project’s life- cycle;
 Ensuring the Free, Prior and Informed Consent of the Affected Communities of Indigenous Peoples when the circumstances described in Performance Standard 7 are present; and
 Respecting and preserving the culture, knowledge, and practices of Indigenous Peoples.
IFC standards do not protect the rights of non-indigenous communities.partly
No forced resettlementEnvironmental and Social Policy Framework
For transactions where we can identify that the use of proceeds may have the potential to impact Indigenous Peoples, we expect our clients to demonstrate alignment with the objectives and requirements of IFC Performance Standard 7 on Indigenous Peoples, including with respect to circumstances requiring Free, Prior and Informed Consent. These objectives include:
 Ensuring that the development process fosters full respect for the human rights, dignity, aspirations, culture, and natural resource-based livelihoods of Indigenous Peoples;
 Anticipating and avoiding adverse impacts of projects on communities of Indigenous Peoples, or when avoidance is not possible, to minimize and/or compensate for such impacts;
 Promoting sustainable development benefits and opportunities for Indigenous Peoples in a culturally appropriate manner;
 Establishing and maintaining an ongoing relationship based on informed consultation and participation with the Indigenous Peoples affected by a project throughout the project’s life- cycle;
 Ensuring the Free, Prior and Informed Consent of the Affected Communities of Indigenous Peoples when the circumstances described in Performance Standard 7 are present; and
 Respecting and preserving the culture, knowledge, and practices of Indigenous Peoples.
IFC standards do not require FPIC for non-indigenous communities.partly
Environmental Requirements
No forest degradation and deforestationEnvironmental and Social Policy Framework
A. Transactions Pertaining to Forests and Enhanced Review
 Internationally recognized areas: Internationally recognized areas are defined as UNESCO Natural World Heritage Sites, UNESCO Man and the Biosphere Reserves, Key Biodiversity Areas, and wetlands designated under the Ramsar Convention.
 Legally protected areas: (...) This covers the IUCN categories I-VI.
 Critical habitats: Critical habitats are areas with high biodiversity value, including (i) habitat of significant importance to Critically Endangered and/or Endangered species; (ii) habitat of significant importance to endemic and/or restricted-range species; (iii) habitat supporting globally significant concentrations of migratory species and/or congregatory species; (iv) highly threatened and/or unique ecosystems; and/or (v) areas associated with key evolutionary processes.
 HCV forests: (...) When we finance forestry projects that impact HCV forests, we prefer FSC certification, unless a comparable assessment process underpins a conservation plan. For operations that are not already certified, we will (...) help establish a (...) time-bound, (...) approach to achieve certification within five years.
B. Prohibited Transactions Pertaining to Forests
 JPMorgan Chase will not finance commercial logging operations or the purchase of logging equipment for use in primary tropical moist forests. Any other type of transaction in a primary tropical moist forest will be subject to Enhanced Review.
 JPMorgan Chase will finance plantations only on non-forested areas (...) or on heavily degraded forestland.
The policy requires enhanced due diligence for fragile areas, but only prohibits operations in primary tropical moist forests and the conversion of forests to plantations.partly
Protect endangered speciesA. Transactions Pertaining to Forests and Enhanced Review
Transactions where we are able to identify that the client has operations in one of the following locations, or transactions where the use of proceeds is designated for assets to be developed in one of the following locations, will be subject to Enhanced Review (See Section II. E. Transaction Reviews):
 Critical habitats: Critical habitats are areas with high biodiversity value, including (i) habitat of significant importance to Critically Endangered and/or Endangered species; (ii) habitat of significant importance to endemic and/or restricted-range species; (iii) habitat supporting globally significant concentrations of migratory species and/or congregatory species; (iv) highly threatened and/or unique ecosystems; and/or (v) areas associated with key evolutionary processes.
There is some protection for endangered species, but the policy does not prothibit the trade in IUCN red list speciespartly
No high-risk speciesNo publicly available policies or documentation were found that cover this criteria.not
No fireEnvironmental and Social Policy Framework
 Uncontrolled Fire: Transactions with entities or projects that lack an explicit policy against the uncontrolled and/or illegal use of fire in their forestry, plantation or extractive operations.
The policy provides some protection, but still allows the use of controlled firepartly
Protect peatNo publicly available policies or documentation were found that cover this criteria.not
No persistent pollutionNo publicly available policies or documentation were found that cover this criteria.not
Corporate association / scope of the policy
Corporate association / scope of the policyEnvironmental and Social Policy Framework
 The set of relationships the Firm has with clients in a given sector constitutes a sector portfolio. In addition to reviewing specific transactions within a given sector, we have expanded our risk management approach to include portfolio-wide reviews of companies engaged in certain industries. We undertake these reviews where the Firm has significant financial exposure, and there are particular activities which may present an increased level of E&S risk. In addition to industry-specific considerations, we examine client management of impacts on air quality, water, biodiversity, GHG emissions, worker safety, labor, and community relations
A company wide review is required in some cases. The policy falls short of requiring that all the client's third parties, parent, sister and daughter companies comply with the policy.partly