Rabobank

Red LineText of policiesCommentsScore
Regulatory requirements
Ensure LegalitySustainability Policy Framework
The expectations of our clients outlined in this policy are always applicable, regardless of the sector or industry in which they operate. Specifically, we
expect them to:
•comply with all applicable local, nationally and internationally ratified laws and regulations and other statutory requirements and be able to show the legality of their operations.
• influence their supply chain to promote sustainable development
•be aware of their sustainability risks, including those in their supply chain
• use good industry practices
The Rabobank sustainability policies include binding conditions between the bank and its clients based on potential adverse impacts that we consider to be material. Contractual clauses regarding compliance with our sustainability policies may be inserted into the relevant contracts or letters for prospects.
Should serious issues that breach our policy and/or international norms and standards not be rectified through engagement, Rabobank may
decide to terminate the client relationship.
Rabobank expects clients to comply with national and international laws, and to ensure their suppliers do as well.well
No Corruption and Tax EvasionSustainability Policy Framework
We are committed to preventing corruption and bribery in all its forms and do not tolerate it in our business or in those with whom we do business.

Rabobank endorses the OECD Guidelines and is guided by its principles.
Rabobank’s expectations of its clients regarding sustainability align with the OECD Guidelines for Multinational Enterprises and the principles of the UN
Global Compact. We therefore expect them to contribute to economic, environmental and social progress with a view to achieving sustainable development.
Our clients should avoid causing or contributing to adverse social and environmental impacts, they should seek to prevent or mitigate an adverse impact when the impact is directly linked to their operations or products and services, and they should account for how they address their actual and potential adverse impacts.

Tax Policy Statement
Rabobank takes the position that its clients are responsible for their own decisions regarding tax. We do count on our clients’ integrity. This does (...) entail an assumption that each client complies with generally accepted social norms. Actions that are commonly viewed as fraud (tax evasion) are not acceptable to Rabobank. In addition, Rabobank expects customers to be transparent towards the bank, as well as the tax authorities. Rabobank will for example not engage in a transaction in case of doubt on the tax intentions of its counterpart.
Partly protected, as customers are not expected to apply the same tax norms and values as the bank itselfpartly
Ensure ESIA for mills and plantations· Sustainability Policy Framework
We expect our clients to (...) conduct independent social and environmental impact assessments, human rights impact assessments and/or household livelihood impact assessments; (p27)
Though ESIAs are required in some cases, they are not required for tree plantations (as they are for ex for sugar cane plantations), and there is no requirement to publish them.partly
Social requirements
Ensure FPICSustainability Policy Framework
Exclusion list: logging or purchase of logging equipment for use in primary tropical moist forest; (...)with regard to biodiversity we specifically expect our clients to:
• obtain Free, Prior and Informed Consent (FPIC) of local indigenous peoples when developing plans that could adversely impact biodiversity or ecosystem services;

Land Governance Policy
In addition to our Sustainable Development Policy and our core sustainability policies, with regard to land governance we specifically commit to:
• recognize legitimate land tenure and the rights of local communities and individuals;
• promote sound and fair land governance practices, including the Voluntary Guidelines on the Responsible Governance of Tenure of Land, Fisheries and Forests in the context of national food security (VGGT);
• encourage clients to deal responsibly with land governance, including respecting land tenure and land rights and the right to FPIC of all stakeholders regarding changes in land ownership or land use, addressing gender issues in land governance, and implementing proper grievance and dispute resolution mechanisms which are communicated in a culturally appropriate and understandable way;
• encourage clients to respect rights of indigenous peoples, vulnerable groups and local communities and ensure that their concerns are properly addressed.
FPIC: when communities of indigenous peoples are affected by the potential project of the client, FPIC of these affected communities must be obtained before the project can proceed. (p27)
Encourages, but doesnt require, FPIC of all stakeholderspartly
Respect Human Rights· Sustainability Policy Framework
with regard to human rights we expect all of our clients to:
•• respect and uphold all human rights as described in the UN Declaration of Human Rights, and related international legislation and regulations;
•• avoid causing or contributing to human rights violations;
•• identify, prevent, mitigate and account for any actual or potential adverse human rights impacts that are directly linked to their operations, products and services through business relationships including customers, as well as business associates and society;
•• be transparent about their risks of causing or contributing to adverse human rights impacts and how they manage those risks;
•• be transparent about any violations of human rights;
•• operate effective stakeholder engagement including an operational-level grievance mechanism for any adverse human rights impacts for which they have caused or contributed to, and involve affected stakeholders before establishing new operations in a process of free, prior, and informed consultation and duly record the process;
•• provide for or cooperate in remediation through legitimate processes for violations of human rights that it has caused or contributed to. (p18)
Requires clients to respect human rightswell
Respect Indigenous rights and customary land use rights· Sustainability Policy Framework

Land Governance Policy
In addition to our Sustainable Development Policy and our core sustainability policies, with regard to land governance we specifically commit to:
• recognize legitimate land tenure and the rights of local communities and individuals;
• promote sound and fair land governance practices, including the Voluntary Guidelines on the Responsible Governance of Tenure of Land, Fisheries and Forests in the context of national food security (VGGT);
• encourage clients to deal responsibly with land governance, including respecting land tenure and land rights and the right to free, prior and
informed consent of all stakeholders regarding changes in land ownership or land use, addressing gender issues in land governance, and implementing
proper grievance and dispute resolution mechanisms which are communicated in a culturally appropriate and understandable way;
• encourage clients to respect rights of indigenous peoples, vulnerable groups and local communities and ensure that their concerns are properly addressed.
Encourages, but doesnt require, FPIC of all stakeholderspartly
No forced resettlement· Sustainability Policy Framework

Land Governance Policy
In addition to our Sustainable Development Policy and our core sustainability policies, with regard to land governance we specifically commit to:
• recognize legitimate land tenure and the rights of local communities and individuals;
• promote sound and fair land governance practices, including the Voluntary Guidelines on the Responsible Governance of Tenure of Land, Fisheries and Forests in the context of national food security (VGGT);
• encourage clients to deal responsibly with land governance, including respecting land tenure and land rights and the right to free, prior and informed consent of all stakeholders regarding changes in land ownership or land use, addressing gender issues in land governance, and implementing proper grievance and dispute resolution mechanisms which are communicated in a culturally appropriate and understandable way;
• encourage clients to respect rights of indigenous peoples, vulnerable groups and local communities and ensure that their concerns are properly addressed.
FPIC: when communities of indigenous peoples are affected by the potential project of the client, the Free Prior and Informed Consent of these affected communities must be obtained before the project can proceed. (p27)
Encourages, but doesnt require, FPIC of all stakeholderspartly
Environmental Requirements
No forest degradation and deforestationSustainability Policy Framework
Exclusion list: logging or purchase of logging equipment for use in primary tropical moist forest; (...)with regard to biodiversity we specifically expect our clients to:
• know their potential impacts on biodiversity and ecosystem services;
• not damage, cause or contribute to the conversion of high conservation value areas (HCV) or high carbon stock-areas (HCS);
• not to operate in national or international legally-protected or preserved areas and areas containing globally, regionally or nationally significant
concentrations of biodiversity values;
• not operate in legally protected areas, UNESCO World Heritage sites and RAMSAR wetlands unless the development is legally permitted (...)
• not cause or contribute to a net reduction in the population of endangered species;
• not intentionally introduce alien species and implement measures to avoid (...) unintended introductions (...);
• seek to avoid causing or contributing to adverse impacts on biodiversity and ecosystem services, or when avoidance is not possible, minimize these impacts. (...);
• implement a mitigation strategy with a mitigation hierarchy that seeks as a preference to avoid impacts then to mitigate unavoidable impacts, and as
a last resort, to compensate for unavoidable residual impacts ( ...);
• implement good industry practices and adaptive management so that implementation of mitigation and management measures is responsive
to changing conditions;
all critical areas are protectedwell
Protect endangered species· Sustainability Policy Framework
Exclsusion list: trade in or unauthorized catching of wildlife or wildlife products regulated under CITES or species on the IUCN Red List of threatened species;
IUCN red list species are protectedwell
No high-risk species· Sustainability Policy Framework
not intentionally introduce alien species and implement measures to avoid the potential for accidental or unintended introductions including via the
transportation of alien species;
Rabobank strongly believes that the application of gene technology can offer a solution to the requirement to continue to feed the rapidly growing
world population into the long-term future.
The policy does not prohibit the use of GE treespartly
No fire· Sustainability Policy Framework
avoid all uncontrolled and illegal use of fires for clearing of forest;
The policy provides some protection, but still allows the use of controlled firepartly
Protect peat· Sustainability Policy Framework
Exclusion list: logging or purchase of logging equipment for use in primary tropical moist forest; (...)with regard to biodiversity we specifically expect our clients to:
• not damage, cause or contribute to the conversion of (...) high carbon stock-areas (HCS);
Conversion of peatlands is not allowed, but continuing operations on peatlands is. It does not require clients to have an NDPE policy, as is required for palm oilpartly
No persistent pollutionExclusion list: production or trade in pesticides/herbicides subject to international phase outs or bans;There are requirements that limit the use of pesticides but there are no requirement for the technologies used in the millpartly
Corporate association / scope of the policy
Corporate association / scope of the policyLand governance policy
(...) expects our business clients to do the same in their own operations and in their relationships with business partners and supplies
The policies aply to a clients business partners, whcih includes suppliers, parent, sister and daughter companieswell