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New human rights assessment of banks shows slow progress and lack of action to address key gaps on reporting and remedy

BankTrack’s 2022 Global Human Rights Benchmark finds reporting at a standstill, remedy still lacking and no clear leaders
2022-11-17
By: BankTrack
Contact:

Giulia Barbos: giulia@banktrack.org
Ryan Brightwell: ryan@banktrack.org

The BankTrack Global Human Rights Benchmark 2022: Cover image. Photo: BankTrack
2022-11-17
By: BankTrack
Contact:

Giulia Barbos: giulia@banktrack.org
Ryan Brightwell: ryan@banktrack.org

The fourth edition of BankTrack’s Global Human Rights Benchmark, published today, finds that 38 out of 50 of the world’s largest commercial banks are implementing less than half of human rights responsibilities, as set out in the UN Guiding Principles on Business and Human Rights (UNGPs). In addition, a new assessment of banks on their response to specific human rights violations as part of the benchmark shows they failed to provide a constructive response to the allegations raised three quarters of the time.

“As the UNGPs outline a minimum expected standard of corporate behaviour, these findings are worrying”, said Giulia Barbos, Human Rights Campaigner and Policy Researcher at BankTrack, the lead author of the report. “The results indicate that even eleven years after the unanimous endorsement of the UNGPs, the global banking sector is consistently lagging behind.”

Among the poorest performers, scoring 3 points or less out of 14 available points on the benchmark, are US banks Goldman Sachs and JPMorgan Chase, Germany’s DZ Bank and Commerzbank, as well as France’s Groupe BPCE. Even the top performing banks, including Citi from the US, Japan’s Mizuho, and Australia’s Westpac, fail to meet their responsibilities for many criteria, missing the mark to be ranked as a ‘leader’. See the summary table of results below.

Most banks are dragging their heels on implementation of the UNGPs, especially when it comes to human rights reporting and enabling access to remedy for harms. All but eight out of 50 banks fall short of reporting on specific human rights impacts they identified and the steps taken to address them. And while there have been positive developments on accountability, such as ANZ’s launch of a well-elaborated grievance mechanism to evaluate and respond to human rights related complaints associated with its corporate lending customers, very few other banks are so far following suit.

More positively, the report shows some improvement since BankTrack’s last global human rights benchmark in 2019, with the average score rising from 4 to 5 points out of 14. This progress, while limited, is particularly welcome after little to no improvement being found in the 2019 benchmark. Also positive is the unprecedented number of banks that provided feedback into the process, with 36 out of 50 banks providing comments on draft scores during the research process.

The benchmark also finds that more banks now have well developed human rights due diligence processes in place, and include, at least to some degree, consultation with rights holders and other stakeholders. Banks are also doing more to monitor the effectiveness of actions taken to address adverse impacts, though approaches are often limited to certain sectors, and are lacking strong indicators.

The report also considers the need for bank action to protect human rights defenders, including Indigenous peoples, who play a critical role in protecting communities, the environment, and natural resources, and in many cases are harmed in the course of fighting projects financed by commercial banks. Only three banks included any consideration of human rights defenders in their due diligence processes, the report reveals.

BankTrack’s Giulia Barbos added: “These results show the urgent need for banks to show leadership and scale up respect for human rights, including by improving disclosures, meaningfully responding to allegations, and taking appropriate action to address impacts, if better outcomes for people and the planet are to be achieved.”

Nadia Bernaz, Associate Professor at Wageningen University Law Group, a member of the report's Independent Academic Advisory Panel, commented:  “This report underlines the urgent need for strong legislation to ensure that banks conduct ongoing human rights and environmental due diligence across all of their provision of financial services, and to ensure that victims of human rights violations can seek remedy, including from banks that facilitated the harms.”

Anita Dorett, Director at the Investor Alliance for Human Rights, commented: “BankTrack’s Human Rights Benchmark provides critical human rights performance data and analysis for investors to engage with their own portfolio banks on the steps they're taking to meaningfully implement human rights policies. As the "oxygen supply" for all financial activity, it is incumbent on banks to ensure they are doing everything in their power to prevent and mitigate potential and actual human rights harms connected to their lending, including in financing and enabling the just transition to renewable energy.”

Download the report here

View the webinar

BankTrack held two webinars following the publication of the report to present the Benchmark's methodology and results, on 22nd and 24th November. The webinar from 24th November can be viewed online here (YouTube, 38 minutes).

Summary table of results


Bank
Policy
Due dilligence
Reporting
Remedy
Total
Change
Response tracking
Bank profile
Full results
Front runners 7 - 10 points
Bank
Policy
Due dilligence
Reporting
Remedy
Total
Change
Response tracking
Bank profile
Full results
Citi
Mizuho Financial Group
Westpac
ANZ
ABN AMRO
Barclays
Rabobank
ING Group
Standard Chartered
BBVA
BNP Paribas
Deutsche Bank
2.5
3.5
2
1
9
+2
0.6
Profile
3
3
2
1
9
+5
0.3
Profile
3
3.5
2
0.5
9
+2.5
0
Profile
3
2.5
1.5
1.5
8.5
+1
1
Profile
2.5
3.5
2
0.5
8.5
-1
0
Profile
3
2.5
1.5
1
8
+1
0.3
Profile
2.5
2.5
2
1
8
0
0
Profile
2.5
3
1.5
0.5
7.5
+0.5
1
Profile
3
2
2
0.5
7.5
+2.5
0.5
Profile
3
2.5
1
1
7.5
0
0.3
Profile
2.5
3
2
0
7.5
+1.5
0.8
Profile
2
3
1.5
0.5
7
+1
0.2
Profile
Followers 3.5 - 6.5 points
Bank
Policy
Due dilligence
Reporting
Remedy
Total
Change
Response tracking
Bank profile
Full results
Morgan Stanley
National Australia Bank
Société Générale
Intesa Sanpaolo
UniCredit
Bank of America
UBS
Banco Santander
Itaú Unibanco
Wells Fargo
Banco Bradesco
Nordea Bank
Commonwealth Bank
Sumitomo Mitsui Financial
HSBC
Credit Suisse
CaixaBank
Toronto-Dominion Bank
Bank of Nova Scotia
Sumitomo Mitsui Trust Holdings
NatWest
Banco do Brasil
BMO Financial Group
Royal Bank of Canada
Crédit Agricole
Lloyds Banking Group
Canadian Imperial Bank
Mitsubishi UFJ
3
2.5
1
0
6.5
+1
0
Profile
3
2
0.5
1
6.5
0
0
Profile
2
3
1
0
6
+3
0.7
Profile
2.5
1.5
1.5
0.5
6
0
0.3
Profile
2.5
2.5
0.5
0.5
6
0
0.3
Profile
2
3
1
0
6
+4.5
0
Profile
3
1.5
1.5
0
6
+0.5
0
Profile
2.5
1.5
1.5
0.5
6
+2.5
0
Profile
2
2
1
0.5
5.5
+0.5
n/a
Profile
3
1.5
1
0
5.5
+0.5
0
Profile
2
1.5
1.5
0.5
5.5
+3
0
Profile
2
1
1.5
1
5.5
-1
0
Profile
2.5
1
1.5
0
5
0
0
Profile
2
2
0.5
0.5
5
+3
0
Profile
3
1.5
0.5
0
5
+1
0.2
Profile
2
1.5
1
0.5
5
-0.5
0.3
Profile
3
1
0.5
0
4.5
NEW
n/a
Profile
2
1.5
0.5
0.5
4.5
+3
0
Profile
2.5
1
0.5
0.5
4.5
+2
0
Profile
2.5
1
1
0
4.5
+0.5
0
Profile
3
1
0.5
0
4.5
+1
0
Profile
1.5
1.5
1.5
0
4.5
+0.5
0
Profile
2
1.5
0.5
0.5
4.5
+2.5
0
Profile
2.5
0.5
0.5
0.5
4
+3.5
0.6
Profile
1.5
2
0.5
0
4
+2
0.2
Profile
2.5
1
0.5
0
4
+2.5
0
Profile
2
1.5
0.5
0
4
+2.5
0
Profile
2
1
0
0.5
3.5
+1.5
0
Profile
Laggards 0 - 3 points
Bank
Policy
Due dilligence
Reporting
Remedy
Total
Change
Response tracking
Bank profile
Full results
JPMorgan Chase
BPCE Group
Goldman Sachs
Commerzbank
DZ Bank
State Bank of India
ICBC
Agricultural Bank of China
China Construction Bank
Bank of China
1.5
1.5
0
0
3
-0.5
0.6
Profile
1.5
1
0.5
0
3
+0.5
0.3
Profile
1.5
1
0
0
2.5
0
0
Profile
1.5
1
0
0
2.5
NEW
0
Profile
0.5
0.5
0.5
0
1.5
NEW
0.8
Profile
0
0
1
0
1
0
n/a
Profile
0
0.5
0
0
0.5
0
0
Profile
0
0
0.5
0
0.5
+0.5
0
Profile
0
0
0.5
0
0.5
+0.5
0
Profile
0
0
0
0
0
0
0
Profile
Australia
Bank
Policy
Due dilligence
Reporting
Remedy
Total
Change
Response tracking
Bank profile
Full results
ANZ
Commonwealth Bank
National Australia Bank
Westpac
3
2.5
1.5
1.5
8.5
+1
1
Profile
2.5
1
1.5
0
5
0
0
Profile
3
2
0.5
1
6.5
0
0
Profile
3
3.5
2
0.5
9
+2.5
0
Profile
Brazil
Bank
Policy
Due dilligence
Reporting
Remedy
Total
Change
Response tracking
Bank profile
Full results
Banco Bradesco
Banco do Brasil
Itaú Unibanco
2
1.5
1.5
0.5
5.5
+3
0
Profile
1.5
1.5
1.5
0
4.5
+0.5
0
Profile
2
2
1
0.5
5.5
+0.5
n/a
Profile
Canada
Bank
Policy
Due dilligence
Reporting
Remedy
Total
Change
Response tracking
Bank profile
Full results
BMO Financial Group
Bank of Nova Scotia
Canadian Imperial Bank
Royal Bank of Canada
Toronto-Dominion Bank
2
1.5
0.5
0.5
4.5
+2.5
0
Profile
2.5
1
0.5
0.5
4.5
+2
0
Profile
2
1.5
0.5
0
4
+2.5
0
Profile
2.5
0.5
0.5
0.5
4
+3.5
0.6
Profile
2
1.5
0.5
0.5
4.5
+3
0
Profile
China
Bank
Policy
Due dilligence
Reporting
Remedy
Total
Change
Response tracking
Bank profile
Full results
Agricultural Bank of China
Bank of China
China Construction Bank
ICBC
0
0
0.5
0
0.5
+0.5
0
Profile
0
0
0
0
0
0
0
Profile
0
0
0.5
0
0.5
+0.5
0
Profile
0
0.5
0
0
0.5
0
0
Profile
Finland
Bank
Policy
Due dilligence
Reporting
Remedy
Total
Change
Response tracking
Bank profile
Full results
Nordea Bank
2
1
1.5
1
5.5
-1
0
Profile
France
Bank
Policy
Due dilligence
Reporting
Remedy
Total
Change
Response tracking
Bank profile
Full results
BNP Paribas
BPCE Group
Crédit Agricole
Société Générale
2.5
3
2
0
7.5
+1.5
0.8
Profile
1.5
1
0.5
0
3
+0.5
0.3
Profile
1.5
2
0.5
0
4
+2
0.2
Profile
2
3
1
0
6
+3
0.7
Profile
Germany
Bank
Policy
Due dilligence
Reporting
Remedy
Total
Change
Response tracking
Bank profile
Full results
Commerzbank
DZ Bank
Deutsche Bank
1.5
1
0
0
2.5
NEW
0
Profile
0.5
0.5
0.5
0
1.5
NEW
0.8
Profile
2
3
1.5
0.5
7
+1
0.2
Profile
India
Bank
Policy
Due dilligence
Reporting
Remedy
Total
Change
Response tracking
Bank profile
Full results
State Bank of India
0
0
1
0
1
0
n/a
Profile
Italy
Bank
Policy
Due dilligence
Reporting
Remedy
Total
Change
Response tracking
Bank profile
Full results
Intesa Sanpaolo
UniCredit
2.5
1.5
1.5
0.5
6
0
0.3
Profile
2.5
2.5
0.5
0.5
6
0
0.3
Profile
Japan
Bank
Policy
Due dilligence
Reporting
Remedy
Total
Change
Response tracking
Bank profile
Full results
Mitsubishi UFJ
Mizuho Financial Group
Sumitomo Mitsui Financial
Sumitomo Mitsui Trust Holdings
2
1
0
0.5
3.5
+1.5
0
Profile
3
3
2
1
9
+5
0.3
Profile
2
2
0.5
0.5
5
+3
0
Profile
2.5
1
1
0
4.5
+0.5
0
Profile
Netherlands
Bank
Policy
Due dilligence
Reporting
Remedy
Total
Change
Response tracking
Bank profile
Full results
ABN AMRO
ING Group
Rabobank
2.5
3.5
2
0.5
8.5
-1
0
Profile
2.5
3
1.5
0.5
7.5
+0.5
1
Profile
2.5
2.5
2
1
8
0
0
Profile
Spain
Bank
Policy
Due dilligence
Reporting
Remedy
Total
Change
Response tracking
Bank profile
Full results
BBVA
Banco Santander
CaixaBank
3
2.5
1
1
7.5
0
0.3
Profile
2.5
1.5
1.5
0.5
6
+2.5
0
Profile
3
1
0.5
0
4.5
NEW
n/a
Profile
Switzerland
Bank
Policy
Due dilligence
Reporting
Remedy
Total
Change
Response tracking
Bank profile
Full results
Credit Suisse
UBS
2
1.5
1
0.5
5
-0.5
0.3
Profile
3
1.5
1.5
0
6
+0.5
0
Profile
United Kingdom
Bank
Policy
Due dilligence
Reporting
Remedy
Total
Change
Response tracking
Bank profile
Full results
Barclays
HSBC
Lloyds Banking Group
NatWest
Standard Chartered
3
2.5
1.5
1
8
+1
0.3
Profile
3
1.5
0.5
0
5
+1
0.2
Profile
2.5
1
0.5
0
4
+2.5
0
Profile
3
1
0.5
0
4.5
+1
0
Profile
3
2
2
0.5
7.5
+2.5
0.5
Profile
United States
Bank
Policy
Due dilligence
Reporting
Remedy
Total
Change
Response tracking
Bank profile
Full results
Bank of America
Citi
Goldman Sachs
JPMorgan Chase
Morgan Stanley
Wells Fargo
2
3
1
0
6
+4.5
0
Profile
2.5
3.5
2
1
9
+2
0.6
Profile
1.5
1
0
0
2.5
0
0
Profile
1.5
1.5
0
0
3
-0.5
0.6
Profile
3
2.5
1
0
6.5
+1
0
Profile
3
1.5
1
0
5.5
+0.5
0
Profile

Infographics

11517
score_distrob.jpg
center
Many followers: 2022 Global Human Rights Benchmark infographic 1 .
Photo: BankTrack

 

11516
sankeyalluvialb.jpg
center
Some progress: 2022 Global Human Rights Benchmark infographic 2 .
Photo: BankTrack

 

11518
scorespercategoryb.jpg
center
Banks per category: 2022 Global Human Rights Benchmark infographic 3 .
Photo: BankTrack

 

11515
calltoactionb.jpg
center
Call to action: 2022 Global Human Rights Benchmark infographic 4.
Photo: BankTrack

 

Banks

ABN AMRO

Netherlands
Active

Agricultural Bank of China

China
Active

ANZ

Australia
Active

Banco Bradesco

Brazil
Active

Banco do Brasil

Brazil
Active

Banco Santander

Spain
Active

Bank of America

United States
Active

Bank of China

China
Active

Bank of Montreal (BMO)

Canada
Active

Barclays

United Kingdom
Active

BBVA

Spain
Active

BNP Paribas

France
Active

BPCE

France
Active

CaixaBank

Spain
Active

Canadian Imperial Bank of Commerce (CIBC)

Canada
Active

China Construction Bank

China
Active

Citi

United States
Active

Commerzbank

Germany
Active

Commonwealth Bank

Australia
Active

Crédit Agricole

France
Active

Danske Bank

Denmark
Active

Deutsche Bank

Germany
Active

DZ Bank

Germany
Active

Goldman Sachs

United States
Active

HSBC

United Kingdom
Active

Industrial and Commercial Bank of China (ICBC)

China
Active

ING

Netherlands
Active

Intesa Sanpaolo

Italy
Active

Itaú-Unibanco

Brazil
Active

JPMorgan Chase

United States
Active

Lloyds Banking Group

United Kingdom
Active

Mitsubishi UFJ Financial Group (MUFG)

Japan
Active

Mizuho Financial Group

Japan
Active

Morgan Stanley

United States
Active

National Australia Bank (NAB)

Australia
Active

NatWest Group

United Kingdom
Active

Nordea

Finland
Active

Rabobank

Netherlands
Active

Royal Bank of Canada (RBC)

Canada
Active

Sberbank

Russian Federation
Active

Scotiabank

Canada
Active

Société Générale

France
Active

Standard Chartered

United Kingdom
Active

State Bank of India

India
Active

Sumitomo Mitsui Financial Group

Japan
Active

Sumitomo Mitsui Trust Holdings

Japan
Active

Toronto-Dominion Bank (TD Bank)

Canada
Active

UBS

Switzerland
Active

UniCredit

Italy
Active

Wells Fargo

United States
Active

Westpac

Australia
Active

Credit Suisse

Switzerland
On record
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