By: Amanda Starbuck, RAN
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Earlier this year, thousands of RAN supporters wrote to Deutsche Bank boss Josef Achermenn to urge that his bank cease financing mountaintop removal coal mining in Appalachia. Deutsche Bank have given us their first response, however... it's a little dry. So I'm going to have a go at translating the ‘bankers-speak' into plain English.
Deutsche Bank's words are in italics, my ‘translations' are in bold.
Deutsche Bank regards the responsible treatment of the environment as an integral part of its corporate identity. Within the framework of our certified sustainability management system we take environmental, social and governance issues very seriously, and we therefore take your concerns equally seriously. We have carefully studied your letter and consulted internally with the relevant business units.
Deutsche Bank thinks it is important to be environmentally-friendly, and so we have read and discussed your letter.
Please note that we only do business with companies that fully comply with national and local laws and standards. In 2010, we welcomed the US Environmental Protection Agency's decision to announce a set of actions to further clarify and strengthen environmental permitting requirements. We believe that these new requirements will help to reduce the environmental impacts of mining activities in the US.
We only do business with companies that obey the law and we think that the EPA will make mining more eco-friendly.
Being aware of the possible implications of our business activities, we have integrated environmental, social, and governance aspects in Deutsche Bank's risk management principles and guidelines. We use a systematic due diligence process, starting at the relevant business unit and involving internal control functions such as Compliance, Legal, Credit Risk Management, and Group Sustainability, to assess new clients as well as the engagement in potential business deals. If a case is especially complex and entails substantial risks, the case is escalated to senior management.
Deutsche Bank has a process to examine the environmental, social and legal impacts of new clients and business deals. And, if we spot these risks, then it is up to senior management to judge whether / how we do business.
Deutsche Bank only participates in financing, when the transaction complies with all the Bank's relevant internal standards and when it fulfils legal and regulatory requirements. We have also integrated a "Green Filter" into our Group Reputational Risk Management Program policy, in order to evaluate whether a transaction is in line with the Bank's objective to contribute towards a low carbon society. This approach is particularly relevant in carbon-intensive industries.
Deutsche Bank has a goal to help society reduce carbon emissions and so we look at new clients and deals to see whether this helps us get to that goal.
Business relationships with companies involved in potentially controversial environmental or social practices, are carefully considered and reviewed in depth and a company's environmental, social and governance risks will be assessed against external standards and internal requirements. If gaps are identified, Deutsche Bank will aim to work with the company to improve such practices or policies, or may indeed define conditions which the company must meet before the Bank will enter into a client relationship.
When we spot a company who is not being as environmentally friendly as the law or as Deutsche Bank would like to see, we will try to work with them to improve. We might set a standard for the company to meet before we will do business with them.
We are constantly working towards further enhancing our due diligence process and expertise, and we therefore appreciate your input.
We would like our process to go further, thank you for your comments.
Whichever version you read, the bank avoids any mention of mountaintop removal (MTR). But if Deutsche Bank is true to its word, then they should not do business with any MTR company, as they all systematically break the law (see today's article by Ken Ward in the West Virginia Gazette that demonstrates legal compliance is getting worse, not better, in Kentucky).
What do you think of Deutsche Bank's response?