The secretariat of the Equator Principles has refused to investigate the first complaint filed to the Equator Complaints channel established by BankTrack, or even to speak with the complainants. The complaint, raised by a coalition of six groups in December 2025, concerns the risks to biodiversity, climate and human rights from extraction and production from the TotalEnergies-led Papua LNG project.[1]

However, despite the lack of investigation from the Equator Principles apex body, 27 signatories of the Equator Principles – over a fifth of the initiative’s 127 members – have already ruled out direct financing to Papua LNG, including 14 since the complaint was filed.[2]

Ryan Brightwell, human rights lead at BankTrack, commented: “We set up the Equator Complaints channel in frustration that the Equator Principles had failed to establish their own, despite a crystal-clear requirement from the UN to do so. The action this first complaint has spurred from banks underscores the importance of this. Accountability isn’t a threat, it’s an opportunity for banks to hear concerns from groups and communities on the ground before they escalate. It should be an urgent priority for the Equator Principles.”

Peter Bosip, Executive Director, Center for Environmental Law and Community Rights Inc (CELCOR), stated: “The silence on the Papua LNG complaint not only is disheartening but expresses a clear indication of an oversight in accountability by financial institutions failing our communities. The Equator Principle's lack of response to the risks of human rights, climate, biodiversity protection, and Free Prior Informed Consent abandons the safeguards meant to protect indigenous and local rights. Our communities will be at risk of enduring escalating, project-related impacts when institutions do not uphold their roles in oversight and choose to remain silent.”

Shona Hawkes, Director of Environmental Justice at Jubilee Australia, noted: “The Equator Principles' failure to investigate only adds to the risk for financial institutions. If Papua LNG goes ahead – and has the environmental and human rights impacts we fear – it's not unimaginable that communities could seek damages from financiers ignoring these extensive concerns. More than 1 in 5 Equator Principles Financial Institutions are known to have ruled out financing. To the best of our knowledge, MUFG itself has ignored the 60 pages of information in the complaint, yet it remains as training lead for the Equator Principles.”

Eri Watanabe, Japan Energy Finance Campaigner at Market Forces, said: “MUFG’s refusal to engage with the complaint reduces the endorsement of Equator Principles to a checkbox exercise. This failure by MUFG and the Equator Principles damages investor trust and corporate value. The Board must recognise legitimate human rights and environmental concerns over Papua LNG and take urgent, transparent action.”

In response to the complaint, an Equator Principles representative stated that they were unable to handle complaints linked to financial services. The only action the organisation has disclosed was to forward the complaint to “the respective EPFI ”, understood to refer to the project’s lead financial arranger, Japanese bank MUFG. MUFG – a bank facing at least five separate formal human rights-related complaints since 2023 – is also in charge of training Equator banks on implementation.

End notes

[1] The complainants are: the Asian Peoples’ Movement on Debt and Development (APMDD), Centre for Environmental Law and Community Rights (PNG), Japan Center for a Sustainable Environment and Society, Jubilee Australia Research Centre, Market Forces & Reclaim Finance. The complaint can be downloaded here.

The Equator Principles (EPs) are a risk management framework, created and adopted by financial institutions, for determining, assessing and managing environmental and social risks in financing projects. As of April 2026, 127 Equator Principles Financial Institutions (EPFIs) worldwide have officially adopted the EPs. The number of signatories has fallen from 138 following the departure of the largest US banks, in 2024. Since their introduction in 2003, the Principles have become the de facto standard for banks on managing social and environmental impacts in project finance.

[2] The 27 Equator Principles signatories that have ruled out financing the project are: ABN Amro, ANZ, Banco de Bogotá, Banco de Crédito del Peru, BNDE, BNP Paribas, Bpifrance Assurance Export, CIFI (Corporacion Interamericana Para El Financiamiento de Infraestructura), Commonwealth Bank of Australia, Crédit Agricole, Export Finance Australia, Export Finance Norway, ING Bank, Instituto de Crédito Oficial (ICO), Intesa Sanpaolo, KfW IPEX Bank, La Banque Postale, National Australia Bank (NAB), Natixis/BPCE, NWB Bank, Rabobank, Société Générale, Standard Bank, Swedish Export Credit Corporation (SEK), UK Export Finance, UniCredit, Westpac.

Four non-signatory financial institutions have also ruled out the project. These are: Asian Development Bank (ADB), CIC (Crédit Mutuel group), Bank of the South Pacific, Kina Bank.

The full list of financial institutions that have ruled out financing the project is available on the Defund TotalEnergies website here.