| Red Line | Text of policies | Comments | Score |
|---|---|---|---|
| Regulatory requirements | |||
| Ensure Legality | 13. Adherents should undertake an environmental and social review of projects, in accordance with the international standards applied to the project as set out in paragraphs 21-26 of this Recommendation 17 (...) The standards, practices and processes that the parties involved in the project intend to apply, including information that the project complies with local legislation and other host country relevant regulations. 21. When undertaking a review, Adherents should benchmark: non-project finance projects, against the relevant aspects of all ten World Bank Safeguard Policies, or all eight IFC Performance Standards, (...) limited or non-recourse project finance projects, against the relevant aspects of all eight IFC PSs. 28. Projects should, in all cases, comply with host country standards. Adherents should, therefore, seek assurance that the project complies with local legislation and other relevant host country regulations. 29. Projects should also meet the international standards against which they have been benchmarked (...) 30. In exceptional cases, however, an Adherent may decide to support a project that does not meet the relevant aspects of the international standards (...) In such cases, the (...) related justification for supporting the project, and any related monitoring procedures must be reported to the ECG (...) | requires compliance with IFC PS, which require compliance with national legislation and international conventions. | well |
| No Corruption and Tax Evasion | OECD Guidelines Multi National Enterprises VII. Combating Bribery, Bribe Solicitation and Extortion Enterprises should not, directly or indirectly, offer, promise, give, or demand a bribe or other undue advantage to obtain or retain business or other improper advantage. Enterprises should also resist the solicitation of bribes and extortion. XI. Taxation 1. It is important that enterprises contribute to the public finances of host countries by making timely payment of their tax liabilities. In particular, enterprises should comply with both the letter and spirit of the tax laws and regulations of the countries in which they operate. | Requires clients to comply with the spiriti of tax legislation and companies should not allow corruption. | well |
| Ensure ESIA for mills and plantations | 18. For a Category A project, Adherents should require an ESIA to be undertaken; Annex I - Category A projects: 15. Industrial plants for the production of pulp, paper and board from timber or similar fibrous materials. 20. Large-scale logging. | requires ESIA for Category A projects, which incude pulp mills and large scale logging, but not necessarily the third party suppliers for the pulp mill | partly |
| Social requirements | |||
| Ensure FPIC | 17 (...) The results of any public consultations with local communities directly affected by the project and/or their legitimate representatives and of any engagement with other parties, such as civil society organisations, that have expressed an interest in the project. It is the responsibility of the buyer/project sponsor to undertake any such public consultations and/or engagements with interested parties. For the purposes of public consultations, environmental and social impact information should be made available to affected communities in a language accessible to them. 8. Appendices - Record of interagency and consultation meetings, including consultations for obtaining the informed views of the affected communities and/or their legitimate representatives and other interested parties, such as civil society organisations. The record specifies any means other than consultations (e.g. surveys) that were used to obtain the views of affected groups. 48. Adherents shall give further consideration to the issue of human rights (...) applying relevant due diligence tools and international standards. Consider further issues relating to policy coherence with the OECD Guidelines for Multinational Enterprises and with the ‘Guiding Principles on Business and Human Rights: Implementing the United Nations “Protect, Respect and Remedy” Framework’. | It recommends consultation, but there is no clear mention to FPIC or indigenous people's rights. | not |
| Respect Human Rights | Adherents should: iv) Encourage protection and respect for human rights, particularly in situations where the potential impacts from projects or existing operations pose risks to human rights. 14. Where there is a high likelihood of severe project-related human rights impacts occurring, the environmental and social review of a project may need to be complemented by specific human rights due diligence. 48. Adherents shall give further consideration to the issue of human rights, with the aim of reviewing how project-related human rights impacts are being addressed and/or might be further addressed in relation to the provision of officially supported export credits. To facilitate this work, Adherents shall: Share approaches to and experience of, inter alia, screening and assessing applications for potential severe project-related human rights impacts, reviewing projects where there is a high likelihood of such impacts occurring, and applying relevant due diligence tools and international standards. Consider further issues relating to policy coherence with the OECD Guidelines for Multinational Enterprises and with the ‘Guiding Principles on Business and Human Rights: Implementing the United Nations “Protect, Respect and Remedy” Framework’. | Policy requires respect internationally recognised human rights. | well |
| Respect Indigenous rights and customary land use rights | 17 (...) The results of any public consultations with local communities directly affected by the project and/or their legitimate representatives and of any engagement with other parties, such as civil society organisations, that have expressed an interest in the project. It is the responsibility of the buyer/project sponsor to undertake any such public consultations and/or engagements with interested parties. For the purposes of public consultations, environmental and social impact information should be made available to affected communities in a language accessible to them. 8. Appendices - Record of interagency and consultation meetings, including consultations for obtaining the informed views of the affected communities and/or their legitimate representatives and other interested parties, such as civil society organisations. The record specifies any means other than consultations (e.g. surveys) that were used to obtain the views of affected groups. 48. Adherents shall give further consideration to the issue of human rights (...) applying relevant due diligence tools and international standards. Consider further issues relating to policy coherence with the OECD Guidelines for Multinational Enterprises and with the ‘Guiding Principles on Business and Human Rights: Implementing the United Nations “Protect, Respect and Remedy” Framework’. | It requires consultation of affecte communities. but not FPIC. | partly |
| No forced resettlement | Category A projects are (...) 31. Projects involving land acquisition and involuntary resettlement of a significant number of affected people. 14. Where there is a high likelihood of severe project-related human rights impacts occurring, the environmental and social review of a project may need to be complemented by specific human rights due diligence. | Enhanced due diligence is required in the case of resettlements, but FPIC is not required | partly |
| Environmental Requirements | |||
| No forest degradation and deforestation | 21. When undertaking a review, Adherents should benchmark: non-project finance projects, against the relevant aspects of all ten World Bank Safeguard Policies, or all eight IFC Performance Standards, in particular where justified and/or practicable due to the size and/or structure of the transaction such as, but not limited to, certain types of structured finance transactions that share characteristics with project finance, and/or where other financial institutions forming a significant part of the project are applying these same standards; limited or non-recourse project finance projects, against the relevant aspects of all eight IFC Performance Standards. | IFC PS and EHS partly protect this criteria | partly |
| Protect endangered species | 21. When undertaking a review, Adherents should benchmark: non-project finance projects, against the relevant aspects of all ten World Bank Safeguard Policies, or all eight IFC Performance Standards, in particular where justified and/or practicable due to the size and/or structure of the transaction such as, but not limited to, certain types of structured finance transactions that share characteristics with project finance, and/or where other financial institutions forming a significant part of the project are applying these same standards; limited or non-recourse project finance projects, against the relevant aspects of all eight IFC Performance Standards. | IFC PS and EHS partly protect this criteria | partly |
| No high-risk species | 21. When undertaking a review, Adherents should benchmark: non-project finance projects, against the relevant aspects of all ten World Bank Safeguard Policies, or all eight IFC Performance Standards, in particular where justified and/or practicable due to the size and/or structure of the transaction such as, but not limited to, certain types of structured finance transactions that share characteristics with project finance, and/or where other financial institutions forming a significant part of the project are applying these same standards; limited or non-recourse project finance projects, against the relevant aspects of all eight IFC Performance Standards. | IFC PS and EHS partly protect this criteria | partly |
| No fire | 21. When undertaking a review, Adherents should benchmark: non-project finance projects, against the relevant aspects of all ten World Bank Safeguard Policies, or all eight IFC Performance Standards, in particular where justified and/or practicable due to the size and/or structure of the transaction such as, but not limited to, certain types of structured finance transactions that share characteristics with project finance, and/or where other financial institutions forming a significant part of the project are applying these same standards; limited or non-recourse project finance projects, against the relevant aspects of all eight IFC Performance Standards. | IFC PS and EHS do not protect this criteria | not |
| Protect peat | 21. When undertaking a review, Adherents should benchmark: non-project finance projects, against the relevant aspects of all ten World Bank Safeguard Policies, or all eight IFC Performance Standards, in particular where justified and/or practicable due to the size and/or structure of the transaction such as, but not limited to, certain types of structured finance transactions that share characteristics with project finance, and/or where other financial institutions forming a significant part of the project are applying these same standards; limited or non-recourse project finance projects, against the relevant aspects of all eight IFC Performance Standards. | IFC PS and EHS do not protect this criteria | not |
| No persistent pollution | 21. When undertaking a review, Adherents should benchmark: non-project finance projects, against the relevant aspects of all ten World Bank Safeguard Policies, or all eight IFC Performance Standards, in particular where justified and/or practicable due to the size and/or structure of the transaction such as, but not limited to, certain types of structured finance transactions that share characteristics with project finance, and/or where other financial institutions forming a significant part of the project are applying these same standards; limited or non-recourse project finance projects, against the relevant aspects of all eight IFC Performance Standards. | IFC PS and EHS partly protect this criteria | partly |
| Corporate association / scope of the policy | |||
| Corporate association / scope of the policy | 21. When undertaking a review, Adherents should benchmark: non-project finance projects, against the relevant aspects of all ten World Bank Safeguard Policies, or all eight IFC Performance Standards, in particular where justified and/or practicable due to the size and/or structure of the transaction such as, but not limited to, certain types of structured finance transactions that share characteristics with project finance, and/or where other financial institutions forming a significant part of the project are applying these same standards; limited or non-recourse project finance projects, against the relevant aspects of all eight IFC Performance Standards. | IFC PS and EHS partly protect this criteria | partly |
