Skandinaviska Enskilda Banken (SEB)

Red Line	Text of policies	Comments	Score
Regulatory requirements
Ensure Legality	Corporate Sustainability Policy International Commitments. Seb recognizes the importance of participating in and supporting international commitments that enable businesses to operate in a more sustainable way. SEB is committed to: ● UN Global Compact ● Universal Declaration of Human Rights ● The 8 ILO core conventions ● International Covenant on Economic, Social and Cultural Rights ● International Covenant on Civil and Political Rights ● UN Convention on the Rights of the Child ● UN guiding principles on business and human rights ●The children's rights and business principles ●OECD guidelines for multinational enterprises ●UN supported principles for responsible investments (PRI) ● UN environment program finance initiative (UNEPFI) ● Equator Principles	The SEB is commited to these international commitments, but there are no explicit requirements for clients to be so as well	partly
No Corruption and Tax Evasion	Tax Policy 5. SEB must not use, encourage or facilitate products or services in conflict with tax legislation and anti-tax avoidance law. SEB must not co-operate with external parties to facilitate products or services in conflict with tax legislation and anti-tax avoidance law. SEB works actively with risk assessments, frameworks and controls in order to ensure compliance by SEB; SEB has adopted a Transfer Pricing policy at group level, which is in line with current best practice guidance issued by the OECD (Tax Policy) 7. Transfer Pricing (...) In addition to compliance with applicable laws and regulations, SEB encourages adherence to the principles espoused in the OECD Transfer Pricing Guidelines by customers that are multinational enterprises in order to ensure a fair and sustainable tax base and tax footprint in the countries in which such enterprises operate.	SEB has clear requirements for its clients regarding taxes, however no such policy was found on corruption	partly
Ensure ESIA for mills and plantations	Forestry policy SEB is also a signatory of the Equator Principles (...)	ESIA requirements may apply if the EP apply. But o publicly available SEB policies or documentation were found that cover this criteria.	not
Social requirements
Ensure FPIC	Forestry policy With regards to forest harvesting operations, encompassing both plantation and natural forests, SEB expects our clients and portfolio companies to have sufficient internal controls and polices in place, or in development, to address the issues listed below. We note that the list is not exhaustive and may change over time. • Respect for any customary land tenure and use rights of indigenous people • Respect for the rights of workers, and compliance with occupational health and safety measures • Measures for community and stakeholder engagement	No strict requirement to obtain FPIC	not
Respect Human Rights	Human Rights Policy: SEB has established and maintains procedures to assess clients and portfolio companies, based in human rights, environmental and social aspects, and to monitor their processes and performance where appropriate. SEB exercises active ownership consistent with international norms and guidelines. Human rights aspects are also considered in SEB's product development and offerings. (...) Postion Child labour (...) SEB is committed to the principles of protecting children from any forms of child labour and exploitation. Our sustainability efforts are manifested by various guiding principles within SEB, where we: • acknowledge the role as financial intermediary and its potential impact on child labour issues; • strive to identify and mitigate the exposure to risks related to child labour; and • influence our clients and portfolio companies to have appropriate child labour policies and monitoring systems of sufficient quality. Forestry policy (...) SEB expects our clients and portfolio companies to (...) to address the issues listed below. We note that the list is not exhaustive and may change over time. • Respect for any customary land tenure and use rights of indigenous people • Respect for the rights of workers, and compliance with occupational health and safety measures • Measures for community and stakeholder engagement	There is no strict requirement for clients to demonstrate they comply with Human Rights, nor a strict requirement for clients to have a policy that prohibts slave and child labour	partly
Respect Indigenous rights and customary land use rights	Forestry policy: With regards to forest harvesting operations, encompassing both plantation and natural forests, SEB expects our clients and portfolio companies to have sufficient internal controls and polices in place, or in development, to address the issues listed below. We note that the list is not exhaustive and may change over time. • Respect for any customary land tenure and use rights of indigenous people • Respect for the rights of workers, and compliance with occupational health and safety measures • Measures for community and stakeholder engagement	There is no strict requirement for clients to demonstrate they respect indigenous rights and customary land rights	partly
No forced resettlement		No publicly available policies or documentation were found that cover this criteria.	not
Environmental Requirements
No forest degradation and deforestation	Environmental Policy (...) We encourage them to implement FSC, or an equivaent certification scheme where this is practical and reasonable to do. (...) SEB will not provide financial products or services to operations negatively impacting: ●UNESCO world heritage sites ●wetlands covered by the Ramsar Convention ●International Union for the Conservation of Nature and Red list Species ● National Parks and nature reserves ●High conservation value forests Forestry policy With regards to forest harvesting operations, encompassing both plantation and natural forests, SEB expects our clients and portfolio companies to have sufficient internal controls and polices in place, or in development, to address the issues listed below. We note that the list is not exhaustive and may change over time. (...) • Conservation of biodiversity and protection of critical habitat • Maintenance of environmentally-sound multiple benefits from the forest • Prevention or minimization of adverse environmental and social impacts • Effective forest management planning • Active monitoring and assessment of relevant forest management areas.	It covers part of the requirements, but not the protection of HCS, natural forests or places where restauration is taking place	partly
Protect endangered species	Environmental Policy SEB will not provide financial products or services to operations negatively impacting: (...) ●International Union for the Conservation of Nature and Red list Species (...) SEB will also not trade in, or contribute to trade in, endangered plant and animla species that are n the CITES unless it is autorized through CITES licensing system. Forestry policy With regards to forest harvesting operations, encompassing both plantation and natural forests, SEB expects our clients and portfolio companies to have sufficient internal controls and polices in place, or in development, to address the issues listed below. We note that the list is not exhaustive and may change over time. (...) • Conservation of biodiversity and protection of critical habitat	It protect species listed on the IUCN Red list	well
No high-risk species		No publicly available policies or documentation were found that cover this criteria.	not
No fire		No publicly available policies or documentation were found that cover this criteria.	not
Protect peat		No publicly available policies or documentation were found that cover this criteria.	not
No persistent pollution	With regards to paper and pulp mills, wood processors and relevant suppliers, SEB expects our clients and portfolio companies to incorporate the best available pollution prevention and control technology available within the given technical and financial constraints. In addition, we expect companies to utilise energy and any relevant raw material in an effective way, preferably with goals to increase conversion efficiency.	The policy has requirement with regard to pollution prevention measures for pulp mills, but does not clearly prohibit the use of elemental chlorine. Also, no policy requirement were found regarding the use of pesticides.	well
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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