Andrew Cave- Head corporate responsibility RBS, UK
bank public comment:
The Group currently has a number of overarching policies, particularly our Environmental and Human Rights Policies which address many of these issues. It is not in our interest to enter into unsustainable commercial agreements, or to lend to organisations, or individuals, which could damage the Bank's reputation. We assess specific sector lending, investment and services decision and on an individual basis through our defined risk and credit committee procedures and take into account relevant social, ethical and environmental issues as a part of that process. We continually review our mechanism for assessing and reducing environment related risk in the projects and clients we lend to.
Further more we recognise the importance of ensuring we conduct our business scrupulously according to the laws and regulations laid down by governments and contained within internationally accepted codes and standards, and expect that all our customers conduct their business strictly in accordance with the relevant legal and regulatory frameworks.
energy, fossil fuel based oil and gas transport and infrastructure
ownership
RBS has been effectively nationalised by the UK government, who has a 85 percent stake in the bank
about RBS
RBS was founded in 1727 and is one of the major UK banks. RBS has 40 million customers using the financial services of over 30 brands, including NatWest, Direct Line, Churchill, Coutts, Ulster Bank and Citizens. After a massive bailout in 2008, RBS is now a UK government owned institution.
The CDP impels organisations to record their carbon footprint in daily activities. Encouraging enterprises to calculate and disclose their carbon impact, this initiative highlights the challenge for financial institutions to determine exactly how much carbon output can be attributed to financing.
Voluntary framework to guide the finance sector in tackling the challenge of climate change. They address the management of operational greenhouse gas (GHG) emissions and provide direction on managing climate change in research activities; asset management; retail banking; insurance & re-insurance; corporate banking; investment banking & markets; project finance.
The EPs are a set of guidelines, based upon the Performance Standards and guidelines from the IFC, the World Bank's private sector lending arm for private banks to asesses and mitigate risks in project finance. Banks use the Principles to guide internal operating procedures for transaction for specific projects. Although the EPs are an important step to raise overall standards of financiers and projects in the developing world, they currently fall short on transparency and governance requirements.
The verification and full publication of company payments and government revenues from oil, gas and mining is supported by the EITI. Financial institutions can participate and encourage resource-rich countries to support the initiative that aims to defeat poverty, corruption and conflict caused by weak transparency and accountability.
As the name suggests, the GRI aims to standardise good practice in transparency. GRI provides companies with guidelines to organise their annual report with reporting indices and standards addressing environmental, social and economic issues that business ought to address when telling the world about its performance.
The UN Global Compact is a set of ten principles that companies may sign voluntarily. Signatories promise to avoid complicity in human rights violations, adhere to labour standards, protect the environment and avoid corruption. The G8 countries urge companies to participate in this initiative, and with over 2900 companies signing up, the Global Compact has momentum. A voluntary and network based framework, the Global Compact actively promotes peer review and stakeholder participation.
UNEP is the 'voice of the environment' for the United Nations system, promoting international cooperation in the field of the environment. Issues concerning the financial community are addressed by the UNEP Finance Initiative which promotes investment in clean and renewable energy by financial institutions and other investors. Financial insititutions wishing to join must sign one of two Statements (for financial institutions and a separate one for the insurance industry).
UNPRI is a set of six principles direct institutional investors may adopt to consider environmental, social and corporate governance issues when investing. Voluntary and aspirational in nature, UNPRI has since its inception in 2006 attracted 200 signatories, representing US$8 trillion worth of investments.
Since the turn of the century a group of twelve banks known as the Wolfsberg Group have collaborated to improve ethical standards. The principles provide guidance on money laundering, corruption and the financing of terrorism. They have been produced to address deficiencies in areas 'yet to be fully articulated by lawmakers or regulators'.
RBS has also developed additional sustainability policies. You can find them below, or under 'documents' in the menu.
bank feedback:
The Group is also a member of the Climate Wise Initiative:
http://www.climatewise.org.uk
The planet’s biological diversity is an integrated and intricate web of life that provides essential economic, cultural, recreational and ecological benefits to humanity. The relentless and accelerating loss of this biodiversity is one of the world’s most pressing environmental problems.
The bank’s policy should ensure that it will only be involved in the financing of companies which have adopted the prevention of biodiversity loss as a leading principle and be systematically incorporating action into practice. Find here what BankTrack considers 'best practice' in preserving biodiversity.
scoring method
The bank has no policy on this issue;
The bank’s policy makes a general commitment to the protection of biodiversity in its financing activities, but does not commit to clear steps;
The bank’s policy makes a clear commitment - in line with the recommendations as in the chapter on biodiversity - to one of the main elements of biodiversity protection (ecosystem and habitat protection; species protection and genetic materials protection);
The bank’s policy makes a clear commitment - in line with the recommendations as in the chapter on biodiversity - to at least two of the three main elements of biodiversity protection (ecosystem and habitat protection; species protection and genetic materials protection);
The bank’s policy is fully in line with the recommendations as in the chapter on biodiversity for the three main elements of biodiversity protection (ecosystem and habitat protection; species protection and genetic materials protection).
The climate is rapidly changing as a result of human activity. Temperature and water levels are rising. Ecosystems are altering rapidly as a result and societies run the risk of being hit by floods and cyclones. If continued unchecked, climate change threatens to change life on earth beyond recognition.
As financiers of many investment projects, banks should play a leading role in reducing climate change, by promoting the shift towards a carbon extensive economy. Find here what BankTrack considers 'best practice' in climate change policy.
scoring method
The bank has no policy on this issue or has a policy that deals only with operational emissions;
The bank’s policy acknowledges the bank has a responsibility for its financed emissions, but does not commit to clear steps;
The bank’s policy aims to measure and reduce the bank’s financed emissions OR takes concrete steps to shift its financing to renewable energy and a carbon-extensive economy (excluding unacceptable alternatives);
The bank’s policy aims to measure and reduce the bank’s financed emissions AND takes concrete steps to shift its financing to renewable energy and a carbon-extensive economy (excluding unacceptable alternatives);
The bank’s policy sets ambitious (about 90%) portfolio-level reduction targets and is actively shifting its portfolio towards renewable energy and a carbon-extensive economy (excluding unacceptable alternatives).
additional information
The Environmental Policy as stated by RBS does not regard the effect of RBS’ financing activities in industries that have a large impact on climate change, such as extractive industries or agriculture.
Business has the potential to impact upon human right, both positively and negatively, in a multiplicity of ways. The manner by which a company hires and fires its workers, structures and manages its production processes, purchases supplies and services, conducts itself in its host community can all profoundly affect the promotion or realisation of human rights.
Banks need to develop a policy that ensures they will only be involved in the financing of companies which act in line with what is captured in the draft UN Human Rights Norms for Business. Find here what BankTrack considers 'best practice' for human rights and compare to the score given below.
scoring method
The bank has no policy on this issue;
The bank’s policy is vaguely worded or aspirational, for instance by endorsing the Global Compact or the Universal Declaration of Human Rights, with no clear commitments;
The bank’s policy defines a bottom-line on human rights-related activities and practices which will not be financed OR requires a Human Rights Impact Assessment for relevant transactions, sectors and countries;
The bank’s policy defines a bottom-line on human rights-related activities and practices which will not be financed AND requires a Human Rights Impact Assessment for relevant transactions, sectors and countries;
The bank’s policy is fully in line with the UN Human Rights Norms for Business.
See the full chapter on human rights and the document "Scoring collective policies" for more information.
Throughout the world indigenous peoples are disproportionately vulnerable to human rights abuses, loss of culture, loss of land and access to territories, and even to the threat of extinction.
Businesses need to respect and guarantee the rights of indigenous peoples to protect their land, societies, cultures and livelihoods by acknowledging their sovereignty and self-determination. The bank’s policy should ensure that it will only be involved in the financing of companies which respect and guarantee these rights. Find here what BankTrack considers 'best practice' in dealing with indigenous peoples.
scoring method
The bank has no policy on this issue;
The bank’s policy endorses the UN Draft Declaration on the Rights of Indigenous peoples or a similar statement but is not precise on what this means in practice;
The bank’s policy defines a bottom-line on human rights-related activities and practices which will not be financed OR requires an impact assessment with respect to the rights of indigenous peoples for relevant transactions, sectors and countries;
The bank’s policy defines a bottom-line on human rights-related activities and practices which will not be financed AND requires an impact assessment with respect to the rights of indigenous peoples for relevant transactions, sectors and countries;
The bank’s policy is fully in line with the UN Draft Declaration on the Rights of Indigenous Peoples and requires an impact assessment with respect to its elements for all relevant transactions. The policy puts a ban on the bank’s direct, indirect and silent complicity with the violation of the rights of indigenous peoples.
Protecting people in the workplace is a fundamental responsibility of companies and governments. All businesses should ensure that workers have the right to be free from discrimination and abuse, to work in a safe environment, to associate freely with co-workers and representative organisations, and to earn fair wages and benefits.
Banks must develop a policy that ensures that they will only be involved in the financing of companies which fully respect workers' rights. Find here what BankTrack considers 'best practice' for labour rights.
scoring method
The bank has no policy on this issue;
The bank’s policy stimulates its clients to adhere to the four ILO fundamental principles and rights at work and/or the Tripartite Declaration, but does not make clear how this affects the bank’s financial services;
The bank’s policy defines a bottom-line on labour-related activities and practices which will not be financed OR requires an assessment of the client’s adherence to the four ILO fundamental principles and rights at work and/or the Tripartite Declaration for relevant transactions, sectors and countries;
The bank’s policy defines a bottom-line on labour-related activities and practices which will not be financed AND requires an assessment of the client’s adherence to the four ILO fundamental principles and rights at work and/or the Tripartite Declaration for relevant transactions, sectors and countries;
The bank’s policy ensures respect for local, national and international law and adherence to the four ILO fundamental principles and rights at work and the Tripartite Declaration in all its spheres of influence.
Stimulated by global competition, the liberalization of capital markets and developments in information and communication technologies, corporations are increasingly pursuing aggressive tactics to avoid or sometimes even evade paying taxes.
All businesses should pay all appropriate taxes in the countries they are operating in, to finance essential public goods such as health care, infrastructure and social security. A bank’s policy should ensure that it will only be involved in the financing of companies which are living up to this fundamental principle and refrain from facilitating tax evasion. Find here what BankTrack considers 'best practice' on taxation policies.
scoring method
The bank has no policy on tax compliance;
The bank’s policy on tax compliance in its financing activities is vaguely worded or aspirational, with no clear commitments other than that the bank ensures legal compliance (no tax evasion);
The bank’s policy on tax compliance includes some important elements, including statements on legal compliance and on tax compliance to the spirit of the law (no tax avoidance), but is not sufficiently consistent;
The bank’s policy on tax compliance sets as precondition for all its financing services one of the following three conditions: transparency and country-by-country reporting, compliance to local regulations OR refraining from aggressive tax avoidance schemes;
The bank’s policy on tax compliance in its financing activities is completely consistent with world-class standards, setting as precondition for financing transparency and country-by-country reporting, compliance to local regulations AND refraining from aggressive tax avoidance schemes.
Man-made chemicals are all around us. During their manufacture and use, toxics are released into the environment. Hazardous man-made chemicals have contaminated every environment and up to 300 man-made toxics have been found in humans.
The bank’s policy should ensure that it will only be involved in the financing of companies which only use toxics in production processes when their safety is scientifically proven. Find here what BankTrack considers 'best practice' in toxics.
scoring method
The bank has no policy on this issue;
The bank’s policy is vaguely worded or aspirational, with no clear commitments;
The bank’s policy on toxics contains several standards included in either REACH or SAICM;
The bank’s policy requires all clients in sectors producing and consuming chemicals to comply fully to REACH or to SAICM;
The bank’s policy requires all clients in sectors producing and consuming chemicals to comply to the precautionary principle, which means that toxics can only be used in production processes when their safety is proven scientifically.
Demand for agricultural commodities is growing faster than the global population. The world faces the crucial challenge to feed the 6 billion inhabitants of our planet in a socially and environmentally sustainable way.
Banks active in the agricultural sector should develop a comprehensive agriculture policy that helps to meet this challenge. Find herewhat BankTrack considers 'best practice' in agriculture.
scoring method
The bank has no policy on this sector;
The bank’s policy is vaguely worded or aspirational, with no clear commitments;
The bank’s policy sets as precondition for its financial services the best international standards for at most three elements as listed in the paragraph 1.3 in the chapter on agriculture";
The bank’s policy sets as precondition for its financial services the best international standards for at least three elements as listed in the paragraph 1.3 in the chapter on agriculture;
The bank’s policy is fully in line with all international standards and guidelines for all elements as listed in the paragraph 1.3 in the chapter on agriculture.
Weapons are designed and developed to kill, maim or destroy. They are used in wars and other armed conflicts, killing civilians as well as combatants. The international community has so far been unable to control the proliferation of arms to non-state actors and oppressive regimes. Without a profound structural reform of the military industry, financing any military company will continue to entail a heavy risk of involving a bank in corrupt practices, dealings with oppressive regimes and the production of controversial weapons.
Banks need to carefully screen their clients in the military industry against the best international standards available as described here.
scoring method
The bank has no policy on this sector;
The bank’s policy on this sector is vaguely worded or aspirational, with no clear commitments;
The bank’s policy on this sector excludes financial services to producers of specific, clearly defined types of weapon systems or to the most controversial forms of arms trade or to companies deriving more than 50% of their turnover from weapons;
The bank’s policy on this sector limits financial services to clients which were found to be fully compliant to the letter and spirit of all international arms control treaties (including the cluster munitions and arms trade treaties which are under development);
The bank’s policy on this sector excludes providing any financial services to clients in the military industry.
Large dams are one of the most controversial and potentially destructive infrastructure projects. Dams have already displaced many millions of people, left riverine ecosystems irreversibly damaged and the trickle-down economic benefits are often elusive.
Banks that finance dam construction projects should adopt a comprehensive policy that ensures minimizing the risks involved. Find here what BankTrack considers 'best practice' for dam construction and financing.
scoring method
The bank has no policy on this sector;
The bank’s policy is vaguely worded or aspirational, with no clear commitments;
The bank’s policy includes elements such as options assessment, steps to ensure dam safety, and consultation with neighbouring states, but does not commit to the World Commission on Dams (WCD) strategic priorities and supporting principles;
The bank’s policy commits to the WCD strategic priorities and supporting principles;
The bank’s policy commits to the WCD strategic priorities and supporting principles for all dams and precludes support for dam projects that are located in, or substantially impact upon, critical natural habitats.
Many of the world's fish stocks are in dire condition. A large number of species are either over-fished and exploited to the limit or recovering from overfishing. Unsustainable practices such as drift-net fishing and bottom-trawling have huge impacts on the marine ecosystem.
Banks active in the fisheries sector should develop a policy that ensures sustainable fishing practices throughout the entire supply chain. Find here what BankTrack considers 'best practice' in fisheries.
scoring method
The bank has no policy on this sector;
The bank’s policy is vaguely worded or aspirational, with no clear commitments;
The bank’s policy includes specific elements to identify better fisheries such as minimising by-catch and a preference for certifying sustainable marine fisheries, but does not commit univocally to the goal of the sustainable management and use of fisheries;
The bank’s policy commits to the UN Food and Agriculture (FAO) Code of Conduct for Responsible Fisheries for financial services provided to the fisheries sector directly;
The bank’s policy commits to the FAO Code of Conduct for Responsible Fisheries and the International Principles for Responsible Shrimp Farming, for its financial relationships with all companies throughout the seafood chain of custody.
Forest ecosystems are the most biodiverse terrestrial ecosystems, home to at least 80% of all land-based plants and animals. Forests are home to 350 million inhabitants whose life and well-being is inextricably linked to an intact environment. Forests also play a crucial role in storing carbon, thus buffering the effects of climate change.
By financing companies in the forestry sector, banks can have a significant impact on forest conversion, degradation and destruction. Banks providing services to this sector must develop policies that ensure the preservation and sustainable use of forests. Find here what BankTrack considers 'best practice' in foresty.
scoring method
The bank has no policy on this sector;
The bank’s policy is vaguely worded or aspirational, with no clear commitments;
The bank’s policy excludes companies from financing that are involved in corrupt practices, illegal logging, forest conversion activities which undermine the rights of local communities or operate in specified ‘no-go zones’;
The bank’s policy sets FSC or equivalent certification as pre-condition for clients operating in the forestry sector and commits to all conditions mentioned in paragraph 4.3 in the chapter on forestry for other companies which impact forests;
The bank’s policy sets FSC or equivalent certification as pre-condition for clients operating in the forestry sector and commits to all conditions mentioned in paragraph 4.3 in the chapter on forestry for other companies which impact forests. Additionally, the bank has a clear preference to finance small-scale and community-based forestry operations, offering favourable financing conditions.
Mining and ore processing are high risk activities that may lead to a number of serious problems such as contamination of land and water, conflicts with communities over land and water rights in addition to cultural intrusions, corruption and even macroeconomic distortion in developing countries.
Banks involved in the mining sector should adopt a comprehensive policy to address all social and environmental risks. Find here what BankTrack considers 'best practice' in mining.
scoring method
The bank has no policy on this sector;
The bank’s policy is vaguely worded or aspirational, with no clear commitments;
The bank’s policy sets as precondition for its financial services the best international standards for at least three of the elements listed in paragraph 6.3 in the chapter on mining;
The bank’s policy sets as precondition for its financial services the best international standards for at least five of the elements listed in paragraph 6.3 in the chapter on mining;
The bank’s policy is fully in line with all international standards and guidelines for all elements listed in paragraph 6.3 in the chapter on mining.
The oil and gas sector poses major threats to the environment and local populations from massive infrastructure construction, gas flaring, oil spills, risks of accidents with tankers to name a few. Regular oil and gas production facilities, flaring installations and refineries also pollute land, air and water.
A bank involved in the sector should ensure that it will only be involved in the financing of companies which meet 'best practices' in the oil and gas sector. Banks should also develop a -climate- policy to plan a withdrawal from this unsustainable sector. Find here what BankTrack considers best practice in the oil and gas sector.
scoring method
The bank has no policy on this sector;
The bank’s policy is vaguely worded or aspirational, with no clear commitments;
The bank’s policy sets as precondition for its financial services the best international standards for at least three of the elements listed in paragraph 7.3 in the chapter "oil and gas";
The bank’s policy sets as precondition for its financial services the best international standards for at least five of the elements listed in paragraph 7.3 in the chapter "oil and gas";
The bank’s policy is fully in line with all international standards and guidelines for all elements listed in paragraph 7.3 in the chapter "oil and gas".
The bank’s clients carry first responsibility in dealing with environmental or social problems arising from their activities and should establish and manage community grievance mechanisms.
However, a bank has a duty to ensure that its clients comply with the standards set in the bank’s sector and issue financing policies. Banks should therefore establish a Complaint Mechanism for local and other stakeholders who are affected by bank-financed activities. That mechanism is different from a client complaints mechanism. Find here what BankTrack considers 'best practice' for deal accountability.
scoring method
The bank has no Bank Policy Complaint Mechanism at all;
The bank has an informal Bank Policy Complaint Mechanism in place which is not independent or has no authority within the bank;
The bank has set up an independent Bank Policy Complaint Mechanism for a specific field of financing activity (e.g. project finance);
The bank has set up an independent Bank Policy Complaint Mechanism for all deals in which the bank is involved;
The bank has set up an independent Bank Policy Complaint Mechanism for all deals in which the bank is involved and reports publicly on the complaints filed, the responses and the steps taken to address problems.
The most convincing proof of a bank's commitment to transparency and sustainability lies in the disclosure of all deals the bank is involved in. This includes corporate loans, project finance, investment banking services and other types of deals, with corporate clients and governments.
Find here what BankTrack considers 'best practice' for deal transparency.
scoring method
The bank is not transparent about deals at all;
The bank provides sectoral and regional breakdowns of the deals it was involved in (in the reporting period), by financial product or service;
The bank provides sectoral and regional breakdowns of the deals it was involved in and a list with the basic details of the deals it was involved in (in the reporting period);
The bank provides sectoral and regional breakdowns of the deals it was involved in and a list with the basic details of the deals it was involved in (in the reporting period). It also requires clients (in some or all cases) to disclose environmental and social assessment reports, reviews and management plans to affected people;
The bank provides sectoral and regional breakdowns of the deals it was involved in and a list with the basic details of the deals it was involved in (in the reporting period). It also requires clients (in some or all cases) to disclose environmental and social assessment reports, reviews and management plans to affected people. The bank also discloses information on pending deals and on deals rejected because they do not meet the criteria in the bank’s issue and sector policies.
Institutional accountability refers to all mechanisms and procedures the bank has adopted to ensure that its sustainability commitments are implemented throughout the entire organisation and applied to all relevant financial services.
Find here what BankTrack considers 'best practice' for institutional accountability.
scoring method
The bank has no institutional accountability mechanism at all;
The bank conducts internal audits of its sector and issue financing policies;
The bank hires external auditors to audit its sector and issue financing policies;
The bank publicly publishes the results of the audits of its sector and issue financing policies;
The bank publicly publishes the results of the audits of its sector and issue financing policies and conducts stakeholder engagement processes on its sector and issue policies that comply with the AA1000 Series of Standards or similar standards.
Each bank is expected to report in an open and systematic way on the steps it has taken on the road towards sustainability. Publications on sustainability should clearly describe which priorities banks have formulated on social and environmental issues, which steps have been taken towards reaching them and what have been the results so far.
Find here what BankTrack considers 'best practice' for institutional transparency.
scoring method
The bank does not publish an annual sustainability report or does not include sustainability information in its annual report;
The bank publishes an annual sustainability report, which does not meet GRI Sustainability Reporting Guidelines in terms of reviewing its performance on social and environmental issues;
The bank publishes an externally verified annual sustainability report, which meets the basic requirements of the GRI Sustainability Reporting Guidelines and its Financial Services Sector Supplements;
The bank publishes an externally verified annual sustainability report, which meets the basic requirements of the GRI Sustainability Reporting Guidelines and its Financial Services Sector Supplements. Additionally, the bank publishes in their entirety all of its sector and issue financing policies;
The bank publishes an externally verified annual sustainability report, which meets the basic requirements of the GRI Sustainability Reporting Guidelines and its Financial Services Sector Supplements. Additionally, the bank publishes in their entirety all of its sector and issue financing policies and reports on cases of non-compliance with its policies.
As a result of legal and contractual obligations the bank can not comment on individual companies or projects. However, after receiving a more detailed version of the Report in December we may be able to offer further detail.
print
Further more we recognise the importance of ensuring we conduct our business scrupulously according to the laws and regulations laid down by governments and contained within internationally accepted codes and standards, and expect that all our customers conduct their business strictly in accordance with the relevant legal and regulatory frameworks.
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