Royal Bank of Scotland (RBS)

Red Line	Text of policies	Comments	Score
Regulatory requirements
Ensure Legality	Environment Statement RBS aims to ensure that all of our operations worldwide operate in compliance with local laws and regulations. Human Rights Statement Our commitment to human rights is in alignment with the following standards and principles; The Equator Principles, International Labour Organisation’s Declaration of Fundamental Principles and Rights at Work, OECD Guidelines for Multinational Enterprises, United Nations Global Compact, Universal Declaration of Human Rights, United Nations Guiding Principles on Business and Human Rights, Women Empowerment Principles and the Living Wage Foundation. Forestry, Fisheries and Agribusiness Sectors Policy Our policies reflect adherence to national and international laws and regulations, wherever they apply. We have also incorporated a number of voluntary standards such as the Equator Principles and the UN Global Compact. Prohibited activities: Direct involvement in illegal logging or the purchase of illegally harvested timber or companies using illegal and/or uncontrolled use of fire for land clearance. (...) Customers engaged in restricted activities undergo enhanced due diligence including review by a reputational risk forum or approver and evaluation every one or two years. Restricted activities include: (...) material violations of environmental and social laws (...)	The policy requires compliance with all national laws and key international conventions.	well
No Corruption and Tax Evasion	Statement on Tax Evasion We intend to only deal with customers, suppliers and other associated persons who are tax compliant and we will not knowingly facilitate any transactions that seek to circumvent or abuse tax laws. We expect the reasonable assistance of our customers and suppliers with our due diligence AML policy The AML programme includes, but is not limited to:  Established AML policy and local procedures to ensure compliance with AML laws and regulations;  Customer identification and verification;  The identification of beneficial owners;  Enhanced due diligence for high-risk clients; Anit Bribary and Corruption Statement RBS has zero tolerance to actions and activities that knowingly breach bribery and corruption regulations, laws, and disregard for the ABC Policy	Srong tax requirements for clients, and zero tolerance for corruption	well
Ensure ESIA for mills and plantations		No publicly available policies or documentation were found that cover this criteria.	not
Social requirements
Ensure FPIC	Human Rights Statement We conduct due diligence on clients relating to human rights standards, and expect our clients to share our commitment to respecting human rights associated with their operations. Forestry, Fisheries and Agribusiness Sectors Restricted: Clear evidence of the direct displacement of indigenous peoples without free prior and informed consent or resettlement of large numbers of people relating to a single project	Not covered in the applicable policies and documentation.	partly
Respect Human Rights	Forestry, Fisheries and Agribusiness Sectors Prohibited: Use of harmful child labour, forced labour, modern slavery or human trafficking (as defined by international standards, including the International Labour Organization and the UK Modern Slavery Act 2015) Human Rights Statement We conduct due diligence on clients relating to human rights standards, and expect our clients to share our commitment to respecting human rights associated with their operations. Our commitment to human rights is in alignment with the following standards and principles; The Equator Principles, International Labour Organisation’s Declaration of Fundamental Principles and Rights at Work, OECD Guidelines for Multinational Enterprises, United Nations Global Compact, Universal Declaration of Human Rights, United Nations Guiding Principles on Business and Human Rights, Women Empowerment Principles and the Living Wage Foundation.	Clients are expected to comply with a number of international conventions, including ILO	well
Respect Indigenous rights and customary land use rights		No publicly available policies or documentation were found that cover this criteria.	not
No forced resettlement	Forestry, Fisheries and Agribusiness Sectors Restricted: Clear evidence of the direct displacement of indigenous peoples without free prior and informed consent or resettlement of large numbers of people relating to a single project	There is some protection against forced restettlement, but it is not prohibited	partly
Environmental Requirements
No forest degradation and deforestation	Forestry, Fisheries and Agribusiness Sectors Prohibited: Direct involvement in illegal logging or the purchase of illegally harvested timber or companies using illegal and/or uncontrolled use of fire for land clearance; Restricted: Tree felling or clearance within High Conservation Value Forests, UNESCO World Heritage Sites or International Union for the Conservation of Nature IUCN (I – IV) Protected Sites  Operations in Ramsar Convention Sites, UNESCO Man & Biosphere Sites, or Marine Protected Areas The following prohibitions apply when lending to a specific project:  projects involving unsustainable vegetation clearance or peatland clearance/extraction. Our definition is projects involving: - Degradation of areas (often forests) necessary to protect High Conservation Value areas; - The conversion of primary tropical forests; or land clearance by burning. - The conversion of High Carbon Stock tropical forests. - Clearance of peatlands, including peat extraction.	Some areas are protected, but the policy does not prohibit activities in HCV areas, or protected areas	partly
Protect endangered species	Forestry, Fisheries and Agribusiness Sectors Prohibited: Harvesting or trade of species listed under the Convention of International Trade of Endangered Species (CITES)	The policy prohibits trade in CITES species but does not mention IUCN red list	partly
No high-risk species		No publicly available policies or documentation were found that cover this criteria.	not
No fire	Forestry, Fisheries and Agribusiness Sectors Prohibited: Direct involvement in (...) or uncontrolled use of fire for land clearance;	The policy provides some protection, but still allows the use of controlled fire	partly
Protect peat	· Environmental, Social and Ethical Risk Policy Summary: Forestry, Fisheries and Agribusiness Sectors (2018) Restricted: Clearing of peat lands for commercial plantations [by draining and/or burning] unless a clear and stringent peat land management procedure is in place	The policy provides some protection, but does not prohibit activities on peatlands	partly
No persistent pollution	Forestry, Fisheries and Agribusiness Sectors Policy Prohibited:  Manufacture of pesticides banned under the Stockholm Convention	The policy provides some protection, but has no requirements for mill technology	partly
Corporate association / scope of the policy
Corporate association / scope of the policy		No publicly available policies or documentation were found that cover this criteria.	not

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