Campaign
BankTrack's Human Rights Response Tracking Database
BankTrack
"Actions speak louder" report cover. Photo: BankTrack
BankTrack
Why this campaign?
BankTrack's Response Tracking database covers instances in which civil society organisations have sought responses from banks regarding alleged human rights impacts associated with their finance.
Each response was assessed against BankTrack's Response Tracking criteria, which evaluate whether a bank responded substantively, addressing the allegations raised; whether it took appropriate action to prevent, mitigate, or address the impact; and whether the bank has monitored the effectiveness of its actions.
Scores of 0, 0.5, or 1 were assigned to each criterion for every bank's response, following the methodology first outlined in BankTrack’s Actions Speak Louder report, updated in 2024, and later integrated into BankTrack's Global Human Rights Benchmark.
This database contains 281 communications between civil society groups and banks, covering 22 different cases of human rights allegations involving 61 banks since 2021. The information provided here was last updated in April 2025.
Bank
Impacts reviewed
Responded?
Total score
Response
Action
Monitoring
Response
0
Out
of
1
Rationale for score
The bank publicly responded providing details of its policies related to the sector, but it did not acknowledge its link to the impact or comment on or respond to the substance of the issues raised. Action
0
Out
of
1
Rationale for score
The bank publicly explains its engagement process within the sector, but does state whether it engaged directly with its client requiring them to take specific actions. The bank has not detailed any appropriate action taken by the bank itself. Monitoring
0
Out
of
1
Rationale for score
No information available on whether the bank monitored progress. More info
Response
0
Out
of
1
Rationale for score
The bank only provided a confidential response and engagaged with some of the members of the DBIO Coalition on the impacts raised in a confidential meeting. This is not eligible for a score. Action
0
Out
of
1
Rationale for score
No public information available on whether the bank engaged with its client or took appropriate action. Monitoring
0
Out
of
1
Rationale for score
No public information to indicate the bank is monitoring the actions of its clients, or actions it might itself have taken in response to the impacts raised. More info
Response
0
Out
of
1
Rationale for score
The bank did not respond. Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or took appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information available on whether the bank monitored measures taken by its client to address the impacts associated with the project. Response
0
Out
of
1
Rationale for score
It was reported in June 2024 that the bank had rejected the complaint, on the basis that the bank may only accept a complaint where “the customer consents to the disclosure of a current or former lending relationship and to participate.” This disappointing outcome points to a severe limitation of the bank’s mechanism, and the need for the development of grievance mechanisms to be accompanied by a change to banks’ onboarding processes. Action
0
Out
of
1
Rationale for score
The bank has not stated whether it engaged with its client or took appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information available on whether the bank monitored progress. More info
Response
0.5
Out
of
1
Rationale for score
The bank publicly responded acknowledging its link to the impact, however it did not comment on or respond to the substance of the issues raised. Action
0.5
Out
of
1
Rationale for score
The bank stated that it had engaged with the companies and is "satisfied they understand their responsibilities to respect human rights, and are seeking to engage on the issue using whatever leverage they have". The bank did not state whether it required the company to take specific actions or if the bank itself took appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information available on whether the bank monitored progress. More info
Response
0.5
Out
of
1
Rationale for score
The bank's response confirms that it has engaged with the commpany, but does not comment on the substance of the issues raised. Action
0.5
Out
of
1
Rationale for score
The bank states that it has engaged with the company, and comments on the result of the engagement. Tthe bank states is "satisfied" that the client understands its responsibilities. However it does not set out any specific actions or requitements discussed with the company. Monitoring
0
Out
of
1
Rationale for score
No information to indicate the bank is monitoring the actions of its clients, or actions it might itself have taken in response to the impacts raised. More info
Response
0
Out
of
1
Rationale for score
The bank did not respond. Action
0
Out
of
1
Rationale for score
No information is available on whether the bank engaged with its client or took appropriate action. Monitoring
n/a
Rationale for score
The impact was not raised over a year ago and therefore is not scored on monitoring progress. More info
Response
0
Out
of
1
Rationale for score
The bank's response neither acknowledges its link to the impact, nor addresses the issues raised. Action
0
Out
of
1
Rationale for score
No information is available on whether the bank engaged with its client or took appropriate action. Monitoring
n/a
Rationale for score
The impact was not raised over a year ago and therefore is not scored on monitoring progress. More info
See the letter we sent the bank here.
Response
0
Out
of
1
Rationale for score
The bank did not respond. Action
0
Out
of
1
Rationale for score
No information is available on whether the bank engaged with its client or took appropriate action. Monitoring
n/a
Rationale for score
The impact was not raised over a year ago and therefore is not scored on monitoring progress. More info
Complicity in Destruction IV: Mining and Indigenous Rights in the Amazon (March 2022)
0
0
0
0
0
Response
0
Out
of
1
Rationale for score
The bank did not respond. Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or took appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information available on whether the bank monitored progress. More info
Complicity in Destruction IV: Mining and Indigenous Rights in the Amazon (March 2022)
0
0
0
0
0
Response
0
Out
of
1
Rationale for score
The bank did not respond. Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or took appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information available on whether the bank monitored progress. More info
Response
0
Out
of
1
Rationale for score
The bank does not acknowledge its link to the impacts or ArcelorMittal, citing that "The Bank’s consistent practice is not to comment on information relating to clients or specific transactions." Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or took appropriate action. Monitoring
n/a
Rationale for score
The impact was not raised over a year ago and therefore is not scored on monitoring progress. More info
Response
0
Out
of
1
Rationale for score
The bank did not respond. Action
0
Out
of
1
Rationale for score
No information is available on whether the bank engaged with its client or took appropriate action. Monitoring
n/a
Rationale for score
The impact was not raised over a year ago and therefore is not scored on monitoring progress. More info
See the letter BankTrack sent the bank here.https://www.banktrack.org/download/letter_from_banktrack_to_bank_mandiri_on_finance_to_pln/bank_mandiri_finance_for_pln.pdf
Impacts of Indonesia’s state electricity company PLN (March 2025)
0
0
0
0
n/a
Response
0
Out
of
1
Rationale for score
The bank did not respond. Action
0
Out
of
1
Rationale for score
No information is available on whether the bank engaged with its client or took appropriate action. Monitoring
n/a
Rationale for score
The impact was not raised over a year ago and therefore is not scored on monitoring progress. More info
See the letter BankTrack sent the bank here.
Response
0
Out
of
1
Rationale for score
The bank publicly responded stating that it "does not comment on past or present client relationships". A representative of the bank arranged to speak with BankTrack by telephone, but asked that the discussion remain confidential. Action
0
Out
of
1
Rationale for score
The bank provided no details publicly on whether it engaged with its client or took appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information available on whether the bank monitored progress. More info
Myanmar: Equity exposure to companies linked to the military regime (October 2021)
1
0
0
0
0
Response
0
Out
of
1
Rationale for score
The bank responded to say that unlike other large investment firms, they do not have mutual funds that they manage. The response, which was publicly provided to the Business and Human Rights Resource Centre, does not speak to the subtance of the issues raised or acknowledge a link to the companies mentioned in the report. Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or investee companies or took appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information available about whether the bank monitored progress. More info
Response
0
Out
of
1
Rationale for score
The bank did not respond. Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or took appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information available on whether the bank monitored progress. More info
Complicity in Destruction IV: Mining and Indigenous Rights in the Amazon (March 2022)
0
0
0
0
0
Response
0
Out
of
1
Rationale for score
The bank did not respond. Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or took appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information available on whether the bank monitored progress. More info
Response
0
Out
of
1
Rationale for score
The bank did not respond. Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or took appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information available on whether the bank monitored progress. More info
Response
0
Out
of
1
Rationale for score
The bank did not respond. Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or took appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information available on whether the bank monitored measures taken by its client to address the impacts associated with the project. Response
0
Out
of
1
Rationale for score
The bank did not respond. Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or took appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information to indicate the bank is monitoring the actions of its clients, or actions it might itself have taken in response to the impacts raised. More info
Response
0
Out
of
1
Rationale for score
The bank did not respond Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or took appropriate action. Monitoring
n/a
Rationale for score
The impact was not raised over a year ago and therefore is not scored on monitoring progress. More info
See the summary of bank responses here.
Response
0
Out
of
1
Rationale for score
The bank did not respond. Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or took appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information available on whether the bank monitored progress. More info
Response
0
Out
of
1
Rationale for score
The bank did not respond. Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or took appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information available on whether the bank monitored measures taken by its client to address the impacts associated with the project. Response
0
Out
of
1
Rationale for score
The bank did not respond. Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or took appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information available on whether the bank monitored progress. More info
Response
0
Out
of
1
Rationale for score
The bank did not respond. Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or took appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information to indicate the bank is monitoring the actions of its clients, or actions it might itself have taken in response to the impacts raised. More info
Response
0
Out
of
1
Rationale for score
The bank did not respond. Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or took appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information available on whether the bank monitored progress. More info
Response
0
Out
of
1
Rationale for score
The bank did not respond. Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or took appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information to indicate the bank is monitoring the actions of its clients, or actions it might itself have taken in response to the impacts raised. More info
Response
0
Out
of
1
Rationale for score
The bank responded publicly but did not speak to the substance of the issues raised nor did it acknowledge a link to the impacts; rather, it referenced its relevant human rights policies and procedures. Action
0
Out
of
1
Rationale for score
The bank does not indicate whether it will engage its clients or investee companies on this issue, it only references its policies and procedures. Monitoring
0
Out
of
1
Rationale for score
No information to indicate the bank is monitoring the actions of its clients, or actions it might itself have taken in response to the impacts raised. More info
Response
0
Out
of
1
Rationale for score
The bank publicly responded providing details of its policies related to the sector, but it did not acknowledge its link to the impact or comment on or respond to the substance of the issues raised. Action
0
Out
of
1
Rationale for score
The bank does not detail whether or how it has engaged with its clients in the sector nor detailed whether the bank itself took appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information available on whether the bank monitored progress. More info
Response
0
Out
of
1
Rationale for score
The bank did not respond publicly. Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or took appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information to indicate the bank is monitoring the actions of its clients, or actions it might itself have taken in response to the impacts raised. More info
Response
0.5
Out
of
1
Rationale for score
The bank responded publicly by confirming it would not finance the project in question. It did not comment on or respond to the substance of the issues raised. Action
0.5
Out
of
1
Rationale for score
The bank took appropriate action by stating that it would not provide finance to the project; however, the bank remains exposed to TotalEnergies, the project developer, and it has not (yet) set out specific actions that it requires (or will require) the company to take to address the impacts raised. Monitoring
0
Out
of
1
Rationale for score
No information available on whether the bank monitored measures taken by its client to address the impacts associated with the project. Response
0
Out
of
1
Rationale for score
The bank publicly responded, but stated that it is "not able to comment on individual client relationships or transactions for reasons of client confidentiality". Action
0
Out
of
1
Rationale for score
The bank did not detail whether or how it engaged with its client, nor detailed whether the bank itself took appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information available on whether the bank monitored the impacts or actions of its client. More info
Response
0
Out
of
1
Rationale for score
The bank did not respond. Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or took appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information available on there the bank monitored the impacts or the actions of its clients More info
Response
0
Out
of
1
Rationale for score
The bank did not respond. Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or took appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information available on whether the bank monitored progress.
Following the bank's response: The bank has not provided details on how it monitored the progress of specific companies or how the bank monitored the impact on rights-holders involved in raising the issue with the bank of its own action of updating the Agriculture sector policy. Therefore, the score remains unchanged.
More info
Response
0
Out
of
1
Rationale for score
The bank did not respond. Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or took appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information available on whether the bank monitored progress. More info
Myanmar: Equity exposure to companies linked to the military regime (October 2021)
0
0
0
0
0
Response
0
Out
of
1
Rationale for score
The bank did not respond. Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or investee companies or took appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information available about whether the bank monitored progress. More info
Response
0
Out
of
1
Rationale for score
The banks responded, stating: "We cannot comment on individual clients, entities or projects for confidentiality reasons." Action
0
Out
of
1
Rationale for score
No information is available on whether the bank engaged with its client or took appropriate action. Monitoring
n/a
Rationale for score
The impact was not raised over a year ago and therefore is not scored on monitoring progress. More info
Response
0
Out
of
1
Rationale for score
The bank did not respond. Action
0
Out
of
1
Rationale for score
No information is available on whether the bank engaged with its client or took appropriate action. Monitoring
n/a
Rationale for score
The impact was not raised over a year ago and therefore is not scored on monitoring progress. More info
See the letter BankTrack sent the bank here.
Response
0
Out
of
1
Rationale for score
The bank responded publicly without speaking to the substance of the issues raised or acknowledging a link to the impact; instead, it said it has "no direct exposure" to the issues raised and referenced its relevant policies. The allegation raised is based on research showing a financial link (in loans, underwriting and/or shareholdings) between the bank and specific companies with operations in the construction and hospitality sectors in Qatar. As the bank's response fails to address its indirect financial links to the impact (i.e. corporate finance to the companies mentioned), it does not get a score. Action
0
Out
of
1
Rationale for score
The bank does not indicate whether it plans to engage or has already engaged its clients or investee companies on this issue. Monitoring
0
Out
of
1
Rationale for score
No information to indicate the bank is monitoring the actions of its clients, or actions it might itself have taken in response to the impacts raised. More info
Response
0
Out
of
1
Rationale for score
The bank only provided a confidential response and engagaged with some of the members of the DBIO Coalition on the impacts raised in a confidential meeting. This is not eligible for a score. Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or took appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information to indicate the bank is monitoring the actions of its clients, or actions it might itself have taken in response to the impacts raised. More info
Response
0.5
Out
of
1
Rationale for score
The bank publicly responded confirming that "Drummond Company is currently a BBVA Compass customer", therefore acknowledging its link to the impact, and outlined details of its policy framework and corporate values. However, it did not comment on or respond to the substance of the issues raised. Action
0
Out
of
1
Rationale for score
The bank provided no detail on whether it engaged with its client or took any appropriate action.
Following the bank's response: The bank stated that ""Drummond is no longer a BBVA customer"" following the sale of BBVA's US subsidiary in November 2020. Whilst the bank has disengaged with the company, this does not consitute appropriate action according to rights-holders involved in raising the issue with the bank as the bank has merely sold the subsidiary that maintains the financial relationship between the bank and the company, rather than ensuring that finance for Drummond was suspended. Therefore, the score remains unchanged.
Monitoring
0
Out
of
1
Rationale for score
No information available on whether the bank monitored progress.
Following the bank's response: The bank noted that ""Drummond is no longer a BBVA customer"" and therefore the bank was not in a position to monitor the progress of the company. As the bank did not provide any details on whether it monitored the impact on rights-holders involved in raising the issue with the bank of its own action of disengaging from the company, the score remains unchanged.
More info
Response
0
Out
of
1
Rationale for score
The bank did not respond. Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or took appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information available on whether the bank monitored progress.
Following the bank's response: The bank has not provided details on how it monitored the progress of specific companies or how the bank monitored the impact on rights-holders involved in raising the issue with the bank of its own action of updating the Agriculture sector policy. Therefore, the score remains unchanged.
More info
Response
0.5
Out
of
1
Rationale for score
The bank responded publicly acknowledging that ArcelorMittal is a client of theirs, but without speaking to the substance of the issues raised. Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or took appropriate action. Monitoring
n/a
Rationale for score
The impact was not raised over a year ago and therefore is not scored on monitoring progress. More info
Response
0
Out
of
1
Rationale for score
The bank did not respond. Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or took appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information to indicate the bank is monitoring the actions of its clients, or actions it might itself have taken in response to the impacts raised. More info
Response
0
Out
of
1
Rationale for score
The bank did not respond. Action
0
Out
of
1
Rationale for score
No information is available on whether the bank engaged with its client or took appropriate action. Monitoring
n/a
Rationale for score
The impact was not raised over a year ago and therefore is not scored on monitoring progress. More info
Response
0
Out
of
1
Rationale for score
The bank did not publicly respond.
Following the bank's response: Although it responded, the bank required it to be kept confidential. As this is not a public response, the score remains unchanged.
Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or took appropriate action.
Following the bank's response: The bank has not provided any public information on its engagement with the company or whether it took any appropriate action, therefore the score remains unchanged.
Monitoring
0
Out
of
1
Rationale for score
No information available on whether the bank monitored progress. More info
Response
0
Out
of
1
Rationale for score
The bank responded publicly but did not speak to the substance of the issues raised; rather, the bank notes that it "cannot provide any comment on the relations and dialogue we have with our clients", it took note that "the research focuses on the provision of loans, underwriting services and other credits, as well as investments in the share and bonds issued by the targeted companies, and does not distinguish which of these financial services are dedicated to activities in Qatar", and it referenced its relevant human rights policies and procedures. Action
0
Out
of
1
Rationale for score
The bank does not indicate whether it plans to engage or has already engaged its clients or investee companies on this issue. Monitoring
0
Out
of
1
Rationale for score
No information to indicate the bank is monitoring the actions of its clients, or actions it might itself have taken in response to the impacts raised. More info
Response
0
Out
of
1
Rationale for score
The bank publicly responded providing details of its policies related to the sector, but it did not acknowledge its link to the impact or comment on or respond to the substance of the issues raised.
Following the bank's response: The score remains unchanged as the required elements of the response are not present.
Action
0.5
Out
of
1
Rationale for score
The bank does not detail whether or how it has engaged with its clients in the sector, nor whether it took appropriate action in the specific case that was raised.
The bank's response stated that in 2021 it revised its Agriculture sector policy, resulting in it only providing financial products or services to companies with a strategy to achieve zero deforestation in their production and supply chains by 2025 at the latest. This constitutes evidence that the bank has reviewed its management systems to prevent such impacts from occuring in the future. However this is not considered an appropriate and sufficient remedy by rights-holders involved in raising the issue with the bank as the policy does not include the commitments requested by them in the report; therefore it receives a half score.
Following the response: The bank's score was amended to 0.5.
Monitoring
0
Out
of
1
Rationale for score
No information available on whether the bank monitored progress.
Following the bank's response: The bank has not provided details on how it monitored the progress of specific companies or how the bank monitored the impact on rights-holders involved in raising the issue with the bank of its own action of updating the Agriculture sector policy. Therefore, the score remains unchanged.
More info
Response
0
Out
of
1
Rationale for score
The bank responded publicly but without acknowledging the bank's link to the impact. Action
0
Out
of
1
Rationale for score
The bank provides no information on whether it has engaged with its clients or took appropriate action. Monitoring
0
Out
of
1
Rationale for score
The bank provided no information to indicate it is monitoring the actions of its clients, or actions it might itself have taken in response to the impacts raised. More info
Response
1
Out
of
1
Rationale for score
The bank publicly responded acknowledging its link to the company and commenting on and responding to the specific issues raised. The bank provided detailed information regarding its decision to stop providing finance to the company after its due diligence "flagged the company for ongoing ESG (including human rights) controversies". Action
1
Out
of
1
Rationale for score
The bank stated that after financing Drummond in 2010, it declined to provide further finance in 2012, and decided in 2014 not to provide financial service to the company until further notice, due to "ongoing ESG (including human rights controversies". This is considered as appropriate action taken by the bank itself. Monitoring
0
Out
of
1
Rationale for score
No information available on there the bank monitored the impacts or the actions of its clients More info
Response
0.5
Out
of
1
Rationale for score
BNP Paribas confirmed in January 2020 that it was not involved in the project. It did not comment on whether it may become involved in the project in future. This is sufficient for a half score. Following media reporting: News sources subsequently reported that the bank will not finance the project, however, the bank has not responded to stakeholders or confirmed its position publicly, so there is no change in score.
Action
0.5
Out
of
1
Rationale for score
The bank confirmed it was not financing the project, although it did not provide detail on its future position. This is credited with a half score. Following media reporting: Media reports suggest the bank has taken appropriate action by refusing to provide finance to the project, however, the bank has not set this position out publicly, so there is no change in score.
Monitoring
0
Out
of
1
Rationale for score
No information available on whether the bank monitored measures taken by its client to address the impacts associated with the project. Finance for JBS and links to deforestation in the Brazilian Amazon (March 2023)
1
0
0
0
0
Response
0
Out
of
1
Rationale for score
The bank responded citing client confidentiality saying it "cannot comment the data linked to our clients". The bank provided a list of its applicable policies but failed to acknowledge a link to the company or impacts raised. Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or took appropriate action. The bank mentions it has "ongoing dialogue" with its clients on the issue of deforestation more broadly, but it is not clear the bank has engaged JBS specifically on the impacts raised. Monitoring
0
Out
of
1
Rationale for score
No information available on whether the bank monitored progress. More info
Myanmar: Equity exposure to companies linked to the military regime (October 2021)
1
1.5
1
0.5
0
Response
1
Out
of
1
Rationale for score
The bank publicly responded by providing an overview of its policies, acknowledging the existence of links with some companies listed. Action
0.5
Out
of
1
Rationale for score
The bank publicly explains its compliance with ESG policies and with the international sanctions imposed. The bank states whether it engaged directly with companies by either entering into dialogue, scoring the companies or excluding them. Nonetheless the bank does not set out what specific actions they have sought from those companies. Monitoring
0
Out
of
1
Rationale for score
No information available about whether the bank monitored progress. More info
UN human rights complaint regarding Saudi Aramco and its financiers (July 2023)
1
0
0
0
0
Response
0
Out
of
1
Rationale for score
The bank responded publicly but it did not acknowledge a link to the impacts raised or to the company in question. Action
0
Out
of
1
Rationale for score
The bank did not provide information on whether it has engaged with its client or took appropriate action on the impacts raised. In its response, the bank outlined its approach to climate change and human rights more broadly. Monitoring
0
Out
of
1
Rationale for score
No information available on whether the bank monitored progress. More info
Response
0
Out
of
1
Rationale for score
The bank did not respond publicly. Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or took appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information available on whether the bank monitored progress.
Following the bank's response: The bank has not provided details on how it monitored the progress of specific companies or how the bank monitored the impact on rights-holders involved in raising the issue with the bank of its own action of updating the Agriculture sector policy. Therefore, the score remains unchanged.
More info
Response
0.5
Out
of
1
Rationale for score
The bank responded publicly acknowledging that ArcelorMittal is a client of theirs, but without speaking to the substance of the issues raised. Action
0.5
Out
of
1
Rationale for score
The bank stated that it has engaged with ArcelorMittal on the impacts raised. However, it did not set out how it has exercised its leverage or taken any further steps to address the impacts. Monitoring
n/a
Rationale for score
The impact was not raised over a year ago and therefore is not scored on monitoring progress. More info
Response
0
Out
of
1
Rationale for score
The bank responded, stating: "for confidentiality reasons we do not communicate on our relationship with companies beyond what is already public." Action
0
Out
of
1
Rationale for score
The bank stated that the information we provided "is very valuable in the framework of the engagement dialogue we have with our clients." However, no information is available on whether the bank engaged with its client or took appropriate action. Monitoring
n/a
Rationale for score
The impact was not raised over a year ago and therefore is not scored on monitoring progress. More info
Response
0
Out
of
1
Rationale for score
The bank responded, stating: "For banking confidentiality reasons, we are not able to comment on our current relationship with any specific company, regardless of them being our clients or not." Action
0
Out
of
1
Rationale for score
No information is available on whether the bank engaged with its client or took appropriate action. Monitoring
n/a
Rationale for score
The impact was not raised over a year ago and therefore is not scored on monitoring progress. More info
See the letter BankTrack sent the bank here.
Response
1
Out
of
1
Rationale for score
The bank publicly responded confirming its link to the company and commenting on the issues raised. The bank stated that it "acknowledge[s] the importance of the issue raised by Public Eye as there is no doubt on the effects on human health of high-sulphur fuel, as globally any form of air pollution" and that it believes that "the whole international community (including industry players, governments of exporting countries, and supra-governmental unions) has to play a role in addressing the issue of the fuel quality in Africa". Action
0
Out
of
1
Rationale for score
The bank explains its client-onboarding and engagement process but this is not in relation to the specific companies involved in the impact and there is no detail on whether the bank itself took appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information available on whether the bank monitored progress. More info
Response
0
Out
of
1
Rationale for score
The bank responded publicly saying it has no direct exposure to the issues raised, and referenced its policies without speaking to the substance of the issues raised.The allegation raised is based on research showing a financial link (in loans, underwriting and/or shareholdings) between the bank and specific companies with operations in the construction and hospitality sectors in Qatar. As the bank's response fails to address its indirect financial links to the impact (i.e. corporate finance to the companies mentioned), it does not get a score. Action
0
Out
of
1
Rationale for score
The bank does not indicate whether it plans to engage or has already engaged its clients or investee companies on this issue. Monitoring
0
Out
of
1
Rationale for score
No information to indicate the bank is monitoring the actions of its clients, or actions it might itself have taken in response to the impacts raised. More info
Myanmar: Equity exposure to companies linked to the military regime (October 2021)
1
0
0
0
0
Response
0
Out
of
1
Rationale for score
The bank, in response to an inquiry from the Business and Human Rights Resource Centre, asserted that all its investment activities adhere to all applicable laws and regulations. However, Groupe BPCE did not acknowledge its association with companies linked to the Myanmar junta and did not respond to the substance of the issues raised. Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or investee companies or took appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information available about whether the bank monitored progress. More info
Response
0
Out
of
1
Rationale for score
The bank did not respond. Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or took appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information to indicate the bank is monitoring the actions of its clients, or actions it might itself have taken in response to the impacts raised. More info
Response
0
Out
of
1
Rationale for score
The bank did not respond. Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or took appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information to indicate the bank is monitoring the actions of its clients, or actions it might itself have taken in response to the impacts raised. More info
Response
0
Out
of
1
Rationale for score
The bank's response neither acknowledges its link to the impact, nor addresses the issues raised citing that "we are not able to comment on any existing or potential client relationships." Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or took appropriate action. Monitoring
n/a
Rationale for score
The impact was not raised over a year ago and therefore is not scored on monitoring progress. More info
Response
0
Out
of
1
Rationale for score
The bank did not respond. Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or took appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information available on whether the bank monitored measures taken by its client to address the impacts associated with the project. Response
0
Out
of
1
Rationale for score
The bank did not respond. Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or took appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information to indicate the bank is monitoring the actions of its clients, or actions it might itself have taken in response to the impacts raised. More info
Response
0
Out
of
1
Rationale for score
The bank did not respond. Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or took appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information to indicate the bank is monitoring the actions of its clients, or actions it might itself have taken in response to the impacts raised. More info
Response
1
Out
of
1
Rationale for score
The bank publicly responded confirming its link to the company and commenting on the issues raised. The bank referenced a "number of public statements" made by the company in response to the issues raised in the report on Vitol and Trafigura. Action
0.5
Out
of
1
Rationale for score
The bank confirmed that it has engaged with its client on the issues raised, however it did not outline any specific actions it sought from the company. The bank also did not detail any appropriate action taken by the bank itself. Monitoring
0
Out
of
1
Rationale for score
No information available on whether the bank monitored progress. More info
Response
0
Out
of
1
Rationale for score
The bank did not respond.
Following the bank's response: The bank publicly responded citing client confidentiality. It did not acknowledge its link to the company and, although the bank provided ""general context on how we approach our relationships with different sovereigns around the world"", it did not comment on or respond to the specific issues raised. Therefore the score remains unchanged.
Action
0
Out
of
1
Rationale for score
The bank provided no information on whether it engaged with its client or took appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information available on there the bank monitored the impacts or the actions of its clients More info
Response
0
Out
of
1
Rationale for score
The bank publicly responded providing details of its policies related to the sector, but it did not acknowledge its link to the impact or comment on or respond to the substance of the issues raised. Action
0.5
Out
of
1
Rationale for score
The bank engaged with its clients, stating that in early 2019 it initiated a reivew into "clients in the soy and beef sectors to evaluate their efforts at monitoring deforestation in their operations and supply chain". The bank did not detail whether it required the company to take specific actions or outlined any appropriate action taken by the bank itself. Monitoring
0
Out
of
1
Rationale for score
No information available on whether the bank monitored progress. More info
Response
1
Out
of
1
Rationale for score
The bank publicly responded acknowledging its link to the company and commenting on the specific issues raised. The bank stated that prior to providing finance to the company, it conducted due diligence "specifically on the issues related to the civil suit against Drummond". Action
0.5
Out
of
1
Rationale for score
The bank outlined details of its engagement with the company on human rights issues, stating that the company is "adequately managing human rights issues". However, the bank has not indicated that it required the company to take specific actions or outlined whether the bank itself took appropriate action, i.e. by ensuring or encouraging remedy for the victims of human rights violations. Monitoring
0
Out
of
1
Rationale for score
No information available on whether the bank monitored progress. More info
Response
0
Out
of
1
Rationale for score
The bank publicly responded citing client confidentiality. It did not acknowledge its link to the company nor comment on or respond to the specific issues raised.
Following media reporting: In May 2022, the Financial Times reported that the bank has ruled out financing for the project; however, the bank did not put out a public statement on the matter, so it does not receive a score.
Action
0
Out
of
1
Rationale for score
The bank did not provide information on whether it engaged with its client or took appropriate action.
Following media reporting: No change in score.
Monitoring
0
Out
of
1
Rationale for score
No information available on whether the bank monitored measures taken by its client to address the impacts associated with the project. Response
0.5
Out
of
1
Rationale for score
The bank publicly responded outlining details of its policy and due diligence process, and confirmed that "IOI Corporation is a client of Citi". The bank did not comment on or respond to the substance of the issues raised. Action
0.5
Out
of
1
Rationale for score
The bank stated that it had shared BankTrack's letter with the company as part of its engagement with the company. The bank did not outline any specific actions it sought from the company or detail appropriate action taken by the bank itself. Monitoring
0
Out
of
1
Rationale for score
No information available on whether the bank monitored progress. More info
Response
0
Out
of
1
Rationale for score
The bank did not acknowledge a link to the company or the adverse human rights impacts raised. Action
0
Out
of
1
Rationale for score
The bank did not state that it has engaged its client on the issues raised. Monitoring
0
Out
of
1
Rationale for score
No information available on whether the bank monitored progress. More info
Complicity in Destruction IV: Mining and Indigenous Rights in the Amazon (March 2022)
0
0
0
0
0
Response
0
Out
of
1
Rationale for score
The bank did not respond. Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or took appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information available on whether the bank monitored progress. More info
Response
0
Out
of
1
Rationale for score
The bank did not respond. Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or took appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information to indicate the bank is monitoring the actions of its clients, or actions it might itself have taken in response to the impacts raised. More info
Response
0
Out
of
1
Rationale for score
The bank did not respond. Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or took appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information available on whether the bank monitored progress. More info
Response
0
Out
of
1
Rationale for score
The bank did not respond Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or took appropriate action. Monitoring
n/a
Rationale for score
The impact was not raised over a year ago and therefore is not scored on monitoring progress. More info
See the summary of bank responses here.
Response
0
Out
of
1
Rationale for score
The bank did not respond. Action
0
Out
of
1
Rationale for score
No information is available on whether the bank engaged with its client or took appropriate action. Monitoring
n/a
Rationale for score
The impact was not raised over a year ago and therefore is not scored on monitoring progress. More info
Response
0
Out
of
1
Rationale for score
The bank responded, stating: "Citi maintains a general practice of not commenting on specific companies, projects, or transactions out of respect for confidentiality." Action
0
Out
of
1
Rationale for score
No information is available on whether the bank engaged with its client or took appropriate action. Monitoring
n/a
Rationale for score
The impact was not raised over a year ago and therefore is not scored on monitoring progress. More info
See the letter BankTrack sent the bank here.
Response
0
Out
of
1
Rationale for score
The bank responded publicly denying the allegation and citing client confidentiality. In its response, the bank did not respond to the substance of the issues raised, and it did not acknowledge a link to companies mentioned which are active in Qatar. Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client(s) or took appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information to indicate the bank is monitoring the actions of its clients, or actions it might itself have taken in response to the impacts raised. More info
Complicity in Destruction IV: Mining and Indigenous Rights in the Amazon (March 2022)
1
0
0
0
0
Response
0
Out
of
1
Rationale for score
The bank does not confirm or deny its finance for the mining companies included in the report. Its response neither acknowledges its link to the impacts, nor details specific actions taken, and is therefore not sufficient to score. Action
0
Out
of
1
Rationale for score
No action taken is detailed in the response. Monitoring
0
Out
of
1
Rationale for score
No information available on whether the bank monitored progress. More info
Response
0
Out
of
1
Rationale for score
The bank responded publicly stating that it "cannot make any statements about actual or even possible individual business relationships", and without acknowledging a link to the impact raised Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or took appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information to indicate the bank is monitoring the actions of its clients, or actions it might itself have taken in response to the impacts raised. More info
Response
0
Out
of
1
Rationale for score
The bank did not respond. Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or took appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information to indicate the bank is monitoring the actions of its clients, or actions it might itself have taken in response to the impacts raised. More info
Response
0
Out
of
1
Rationale for score
The bank publicly responded but cited that they "cannot make any statements about actual or possible individual client relationships." Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or took appropriate action. Monitoring
n/a
Rationale for score
The impact was not raised over a year ago and therefore is not scored on monitoring progress. More info
Response
0.5
Out
of
1
Rationale for score
The bank responded confirming a link to the company (confirming it provided a loan to the company in question together with a syndicate of banks), but it did not acknowledge the human rights impacts raised. Action
0.5
Out
of
1
Rationale for score
The bank stated that it has engaged with its client on the impacts raised, and it accepted to meet with the impacted rightsholders. However, it did not set out how it has exercised its leverage or taken any further steps to address the impacts. Monitoring
0
Out
of
1
Rationale for score
No information available on whether the bank monitored progress. More info
Response
0
Out
of
1
Rationale for score
The bank publicly responded citing client confidentiality. Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or took appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information available on whether the bank monitored progress. More info
Response
0
Out
of
1
Rationale for score
The bank did not respond in writing, but agreed to a meeting, in which it did not confirm its relationship with the business. Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or took appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information to indicate the bank is monitoring the actions of its clients, or actions it might itself have taken in response to the impacts raised. More info
Response
0
Out
of
1
Rationale for score
The bank publicly responded citing client confidentiality. Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or took appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information available on whether the bank monitored progress. More info
Banks profiting from the construction and hotel boom in Qatar (November 2022)
1
0
0
0
0
Response
0
Out
of
1
Rationale for score
The bank responded publicly but did not speak to the substance of the issues raised nor did it acknowledge a link to the impacts raised; rather, it referenced its relevant human rights policies and procedures. Action
0
Out
of
1
Rationale for score
The bank does not indicate whether it plans to engage or has already engaged its clients or investee companies on this issue. Monitoring
0
Out
of
1
Rationale for score
No information to indicate the bank is monitoring the actions of its clients, or actions it might itself have taken in response to the impacts raised. More info
Complicity in Destruction IV: Mining and Indigenous Rights in the Amazon (March 2022)
1
0
0
0
0
Response
0
Out
of
1
Rationale for score
The bank refutes the findings of the report, but it is not clear why. It does not confirm or deny its finance for the mining companies included in the report, for which it is the largest financier identified. Its response neither acknowledges its link to the impacts, nor details specific actions taken, and is therefore not sufficient to score. Action
0
Out
of
1
Rationale for score
No action taken is detailed in the response. Monitoring
0
Out
of
1
Rationale for score
No information available on whether the bank monitored progress. More info
Response
0.5
Out
of
1
Rationale for score
The bank publicly responded confirming its link to the company. It did not comment on or respond to the substance of the issues raised. Action
0
Out
of
1
Rationale for score
The bank did not outline any engagement with the company nor provide detail on whether it had taken any appropriate action itself. According to the bank, the company (Louis Dreyfus) "communicates on a very pro-active CSR policy" and the bank is "therefore comfortable with the financing we provide to the companies mentioned in the Amazon Watch report". Monitoring
0
Out
of
1
Rationale for score
No information available on whether the bank monitored progress. More info
Response
0
Out
of
1
Rationale for score
The bank responded publicly but without acknowledging the bank's link to the impact. Instead, the bank refuted the allegations and its links to the impacts raised. Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or took appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information to indicate the bank is monitoring the actions of its clients, or actions it might itself have taken in response to the impacts raised. More info
Response
0
Out
of
1
Rationale for score
The bank responded citing client confidentiality Action
0
Out
of
1
Rationale for score
The bank does not develop on the allegations because of client confidentiality. The bank only states to comply with ESG standards and that their business partners do too. Monitoring
0
Out
of
1
Rationale for score
No information available on whether the bank monitored progress.
Following the bank's response: The bank has not provided details on how it monitored the progress of specific companies or how the bank monitored the impact on rights-holders involved in raising the issue with the bank of its own action of updating the Agriculture sector policy. Therefore, the score remains unchanged.
More info
Response
0.5
Out
of
1
Rationale for score
The bank publicly responded acknowledging its link to the company. Whilst the bank references some RepRisk reports on the company resulting in it being "internally downgraded", it does not comment on or respond to the substance of the issues raised. Action
0.5
Out
of
1
Rationale for score
The bank excluded the company from its SRI (socially responsible investment) funds in response to the issues identified. However, this action does not prevent or mitigate the adverse impacts identified, as the bank still holds shares via its other ("non-socially-responsible") funds, therefore only a half point is awarded. Monitoring
0
Out
of
1
Rationale for score
No information available on whether the bank monitored progress. More info
Myanmar: Equity exposure to companies linked to the military regime (October 2021)
1
1.5
1
0.5
0
Response
1
Out
of
1
Rationale for score
The bank responded publicly to the Business and Human Rights Resouce Centre by commenting to the substance of the issues raised and acknowledging that its asset management branch, Amundi, has indirect exposure to Myanmar through investment in international companies with operations in the country. Action
0.5
Out
of
1
Rationale for score
The bank stated that Amundi has initiated engagement with certain companies mentioned in the report, notably "a French based Oil & Gas company". The bank also commented on the nature of its engagement but it did not set out further steps required from its client or taken by the bank to address the impacts raised. Monitoring
0
Out
of
1
Rationale for score
No information available about whether the bank monitored progress. More info
UN human rights complaint regarding Saudi Aramco and its financiers (July 2023)
1
0
0
0
0
Response
0
Out
of
1
Rationale for score
The bank responded publicly but it did not acknowledge a link to the impacts raised or to the company in question. Action
0
Out
of
1
Rationale for score
The bank did not provide information on whether it has engaged with its client or took appropriate action on the impacts raised. In its response, the bank outlined its approach to climate change and human rights more broadly. Monitoring
0
Out
of
1
Rationale for score
No information available on whether the bank monitored progress. More info
Response
0
Out
of
1
Rationale for score
The bank did not respond. Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or took appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information to indicate the bank is monitoring the actions of its clients, or actions it might itself have taken in response to the impacts raised. More info
Response
0.5
Out
of
1
Rationale for score
The bank responded publicly acknowledging that ArcelorMittal is a client of theirs, but without speaking to the substance of the issues raised. Action
0.5
Out
of
1
Rationale for score
The bank stated that it has engaged with ArcelorMittal on the impacts raised. However, it did not set out how it has exercised its leverage or taken any further steps to address the impacts. Monitoring
n/a
Rationale for score
The impact was not raised over a year ago and therefore is not scored on monitoring progress. More info
Response
0
Out
of
1
Rationale for score
The bank responded, stating: "regarding our relationship with PNL, for reasons of client confidentiality, we cannot provide
precise details except to say that our policy concerning this relationship will respect our commitments." Action
0
Out
of
1
Rationale for score
No information is available on whether the bank engaged with its client or took appropriate action. Monitoring
n/a
Rationale for score
The impact was not raised over a year ago and therefore is not scored on monitoring progress. More info
See the letter BankTrack sent the bank here.
Response
0
Out
of
1
Rationale for score
The bank did not respond. Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or took appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information available on there the bank monitored the impacts or the actions of its clients Response
0.5
Out
of
1
Rationale for score
The bank publicly responded, but it did not acknowledge its link to the impact. The bank did respond to the substance of the issues raised, stating that "as part of our active involvement in industry associations we engaged among others with Trafigura...and asked them to provide us with their perspective on the report" and that, "based on these interactions and further research" they ascertained further information regarding the specific issues raised in the report. Action
0.5
Out
of
1
Rationale for score
The bank stated that it had "engaged among others with Trafigura", however it did not detail any specific actions it require the company to take nor state that the bank itself had taken any appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information available on whether the bank monitored progress. More info
Banks profiting from the construction and hotel boom in Qatar (November 2022)
1
0
0
0
0
Response
0
Out
of
1
Rationale for score
The bank responded publicly but did not speak to the substance of the issues raised; rather, it referenced its relavent human rights policies and procedures. Action
0
Out
of
1
Rationale for score
The bank does not indicate whether it plans to engage or has already engaged its clients or investee companies on this issue. Monitoring
0
Out
of
1
Rationale for score
No information to indicate the bank is monitoring the actions of its clients, or actions it might itself have taken in response to the impacts raised. More info
Response
0
Out
of
1
Rationale for score
The bank publicly responded but it did not acknowledge its link to the impact nor comment on or respond to the substance of the issues raised. Action
0
Out
of
1
Rationale for score
The bank does not detail whether or how it has engaged with its clients in the sector nor detailed whether it took appropriate action itself. Monitoring
0
Out
of
1
Rationale for score
No information available on whether the bank monitored progress. More info
Response
0.5
Out
of
1
Rationale for score
The bank responded publicly by confirming it would not finance the project in question. It did not comment on or respond to the substance of the issues raised. Action
1
Out
of
1
Rationale for score
The bank took appropriate action by stating that it would not provide finance to the project. In addition, no evidence was found of substantial exposure to TotalEnergies (prior to the merger with UBS) Monitoring
0
Out
of
1
Rationale for score
No information available on whether the bank monitored measures taken by its client to address the impacts associated with the project. Finance for JBS and links to deforestation in the Brazilian Amazon (March 2023)
1
0
0
0
0
Response
0
Out
of
1
Rationale for score
The bank responded citing client confidentiality. Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or took appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information available on whether the bank monitored progress. More info
Response
0
Out
of
1
Rationale for score
The bank publicly responded but it did not acknowledge its link to the impact nor comment on or respond to the substance of the issues raised. Action
0
Out
of
1
Rationale for score
The bank stated that "shareholding positions attributed to Credit Suisse in public records we note that these are for the major part held by the bank on behalf of clients, who are the beneficial owners of such stock. Consequently, we do have virtually no leverage over the investment decisions of our clients where these are not clearly prohibited or restricted by any applicable legal regulations." This is does not consitute engagement with the banks clients or appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information available on whether the bank monitored progress. More info
Myanmar: Equity exposure to companies linked to the military regime (October 2021)
1
0
0
0
0
Response
0
Out
of
1
Rationale for score
The bank publicly responds by providing an overview of its ESG policies but does not comment on or respond to the issues raised. Action
0
Out
of
1
Rationale for score
The bank does not respond or comment on the allegations. The bank does not state appropriate action but confirms its ESG policies complying with the sanctions generally, as well as preventing its clients from purchasing securities of companies if sanctions apply, without mentioning the specific issues raised. Monitoring
0
Out
of
1
Rationale for score
No information available about whether the bank monitored progress. More info
Response
0
Out
of
1
Rationale for score
The bank did not respond. Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or took appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information to indicate the bank is monitoring the actions of its clients, or actions it might itself have taken in response to the impacts raised. More info
Response
0
Out
of
1
Rationale for score
The bank did not respond. Action
0
Out
of
1
Rationale for score
No information is available on whether the bank engaged with its client or took appropriate action. Monitoring
n/a
Rationale for score
The impact was not raised over a year ago and therefore is not scored on monitoring progress. More info
Response
0
Out
of
1
Rationale for score
The bank did not respond. Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or took appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information to indicate the bank is monitoring the actions of its clients, or actions it might itself have taken in response to the impacts raised. More info
Banks profiting from the construction and hotel boom in Qatar (November 2022)
1
0.5
0.5
0
0
Response
0.5
Out
of
1
Rationale for score
The bank responded publicly acknowledging a link to the companies and impacts mentioned (through its shareholdings); however it did not comment to the substance of the issues raised. Action
0
Out
of
1
Rationale for score
The bank's response does not indicate whether it will engage its clients or investee companies on this issue, it only references its policies and procedures. Monitoring
0
Out
of
1
Rationale for score
No information to indicate the bank is monitoring the actions of its clients, or actions it might itself have taken in response to the impacts raised. More info
Response
0
Out
of
1
Rationale for score
The bank did not acknowledge a link to the company or the adverse human rights impacts raised. Action
0
Out
of
1
Rationale for score
The bank did not state that it has engaged its client on the issues raised. Monitoring
0
Out
of
1
Rationale for score
No information available on whether the bank monitored progress. More info
Response
0
Out
of
1
Rationale for score
The bank did not respond. Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or took appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information to indicate the bank is monitoring the actions of its clients, or actions it might itself have taken in response to the impacts raised. More info
Response
0
Out
of
1
Rationale for score
The bank did not respond. Action
0
Out
of
1
Rationale for score
No information is available on whether the bank engaged with its client or took appropriate action. Monitoring
n/a
Rationale for score
The impact was not raised over a year ago and therefore is not scored on monitoring progress. More info
Response
0
Out
of
1
Rationale for score
The bank did not respond. Action
0
Out
of
1
Rationale for score
No information is available on whether the bank engaged with its client or took appropriate action. Monitoring
n/a
Rationale for score
The impact was not raised over a year ago and therefore is not scored on monitoring progress. More info
See the letter BankTrack sent the bank here.
Response
0
Out
of
1
Rationale for score
The bank did not respond. Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or took appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information available on whether the bank monitored progress. More info
Response
0
Out
of
1
Rationale for score
The bank did not respond. Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or took appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information to indicate the bank is monitoring the actions of its clients, or actions it might itself have taken in response to the impacts raised. More info
Response
0
Out
of
1
Rationale for score
The bank did not respond. Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or took appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information available on whether the bank monitored progress.
Following the bank's response: The bank has not provided details on how it monitored the progress of specific companies or how the bank monitored the impact on rights-holders involved in raising the issue with the bank of its own action of updating the Agriculture sector policy. Therefore, the score remains unchanged.
More info
Response
0.5
Out
of
1
Rationale for score
The bank publicly responded but did not acknowledge its link to the impact due to client confidentiality. The response did comment on the issues raised, stating that it had "discussed the topic that you address with your briefing with the companies". Action
0.5
Out
of
1
Rationale for score
The bank stated that it has "discussed the topic that you address with your briefing with the companies...both companies assured us of their awareness of the seriousness of that issue raised". However, the bank did not detail whether it required the companies to take specific actions nor whether the bank itself took appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information available on whether the bank monitored progress. More info
Banks profiting from the construction and hotel boom in Qatar (November 2022)
1
0
0
0
0
Response
0
Out
of
1
Rationale for score
The bank responded publicly denying the allegation and citing client confidentiality. The allegation raised is based on research showing a financial link (in loans, underwriting and/or shareholdings) between the bank and specific companies with operations in the construction and hospitality sectors in Qatar. The bank denies financing those sectors in Qatar directly, but its response does not address its indirect financial links to the impacts raised (i.e. corporate finance to the companies mentioned). Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client(s) or took appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information to indicate the bank is monitoring the actions of its clients, or actions it might itself have taken in response to the impacts raised. More info
Response
0
Out
of
1
Rationale for score
The bank publicly responded stating that it "cannot comment on any existing or potential client relationships”.
Following media reporting: In May 2022, Reuters reported that the bank ruled out financing for the project; however, the bank did not put out a public statement so it does not receive a score.
Action
0
Out
of
1
Rationale for score
The bank did not provide information on whether it engaged with its client or took appropriate action.
Following media reporting: No change in score.
Monitoring
0
Out
of
1
Rationale for score
No information available on whether the bank monitored measures taken by its client to address the impacts associated with the project. Finance for JBS and links to deforestation in the Brazilian Amazon (March 2023)
1
0
0
0
0
Response
0
Out
of
1
Rationale for score
The bank responded citing client confidentiality saying that it "cannot comment on potential, existing or former client relationships". While the bank explains it requires "clients to participate in certification schemes and expect them to publicly demonstrate their commitment to No Deforestation standards", it does not acknowledge a link to the company or impacts, but rejects the allegations. Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or took appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information available on whether the bank monitored progress. More info
Response
0.5
Out
of
1
Rationale for score
The bank publicly responded acknowledging the link to the company, however it does not comment on or respond to the substance of the issues raised. Action
0
Out
of
1
Rationale for score
The bank confirmed that it engaged with the client regarding "certain sustainability topics", but this is not enough to determine that it has engaged regarding the specific impacts raised. As such this is not sufficient for a half score. Monitoring
0
Out
of
1
Rationale for score
No information available on whether the bank monitored progress. More info
Myanmar: Equity exposure to companies linked to the military regime (October 2021)
1
0
0
0
0
Response
0
Out
of
1
Rationale for score
The bank responded publicly to the Business and Human Rights Resource Centre, but it fell short of acknowledging a link to the impacts and it did not respond to the substance of the issues raised. Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or investee companies or took appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information available about whether the bank monitored progress. More info
Response
0
Out
of
1
Rationale for score
The bank's response neither acknowledges its link to the impact, nor addresses the issues raised Action
0
Out
of
1
Rationale for score
The bank does not describe any engagement with its client or approptriate action Monitoring
0
Out
of
1
Rationale for score
No information to indicate the bank is monitoring the actions of its clients, or actions it might itself have taken in response to the impacts raised. More info
Response
0
Out
of
1
Rationale for score
The bank responded, stating that they "cannot comment on any existing or potential client relationships." Action
0
Out
of
1
Rationale for score
No information is available on whether the bank engaged with its client or took appropriate action. Monitoring
n/a
Rationale for score
The impact was not raised over a year ago and therefore is not scored on monitoring progress. More info
Response
0
Out
of
1
Rationale for score
The bank replied, stating: "we cannot comment on any existing or potential client relationships," and "State-owned enterprises in Just Energy Transition Partnership (JETP) countries will be allowed to have trajectories for the phaseout from thermal coal business that are aligned with the country’s commitments under the JETP program." Action
0
Out
of
1
Rationale for score
No information is available on whether the bank engaged with its client or took appropriate action. Monitoring
n/a
Rationale for score
The impact was not raised over a year ago and therefore is not scored on monitoring progress. More info
See the letter BankTrack sent the bank here.
Response
0
Out
of
1
Rationale for score
The bank did not respond. Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client(s) or took appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information to indicate the bank is monitoring the actions of its clients, or actions it might itself have taken in response to the impacts raised. More info
Response
0
Out
of
1
Rationale for score
The bank did not respond. Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or took appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information to indicate the bank is monitoring the actions of its clients, or actions it might itself have taken in response to the impacts raised. More info
Myanmar: Equity exposure to companies linked to the military regime (October 2021)
1
0
0
0
0
Response
0
Out
of
1
Rationale for score
The bank, in response to an inquiry from the Business and Human Rights Resource Centre, outlined its Responsible Investment, Union Investment Engagement, and Proxy Voting policies. It asserted that it actively addresses economic activities in crisis regions through engagement dialogues with companies. However, DZ Bank did not acknowledge its association with companies linked to the Myanmar junta and did not respond to the substance of the issues raised. Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or investee companies or took appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information available about whether the bank monitored progress. More info
Response
1
Out
of
1
Rationale for score
The bank responds publicly to the allegations in a way which comments on and responds to the substance of the issues raised, e.g noting the current status of the project and its expectations of Rio Tinto. Its response acknowledges its link to the impact.
Action
0.5
Out
of
1
Rationale for score
The bank sets out that it has engaged with the client or investee company (in general terms) and sets out its expectations of Rio Tinto regarding the project, however it does not make explicit that it has engaged with the company on the specific project, or required the company to takle specific actions. Monitoring
0
Out
of
1
Rationale for score
No information to indicate the bank is monitoring the actions of its clients, or actions it might itself have taken in response to the impacts raised. More info
Response
0
Out
of
1
Rationale for score
The bank did not respond. Action
0
Out
of
1
Rationale for score
No information is available on whether the bank engaged with its client or took appropriate action. Monitoring
n/a
Rationale for score
The impact was not raised over a year ago and therefore is not scored on monitoring progress. More info
Response
0
Out
of
1
Rationale for score
The bank responded stating that it "cannot share details of specific engagements or internal conversations". Action
0
Out
of
1
Rationale for score
There is no evidence that the bank has engaged with its client regarding the adverse human rights impact requiring them to take action or details on whether the bank itself took appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information available on whether the bank monitored measures taken by its client to address the impacts associated with the project. Myanmar: Equity exposure to companies linked to the military regime (October 2021)
1
0
0
0
0
Response
0
Out
of
1
Rationale for score
The bank responded, noting that it was in fact not exposed to one company recorded in the research, Bharat Electronics, and confirming that the data source used had been engaged and confirmed and addressed the error. However the bank did not comment on the exposure our research indentified to 16 other companies with ties to the Myanmar junta. Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or investee companies or took appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information available about whether the bank monitored progress. More info
UN human rights complaint regarding Saudi Aramco and its financiers (July 2023)
0
0
0
0
0
Response
0
Out
of
1
Rationale for score
The bank did not respond. Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or took appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information available on whether the bank monitored progress. More info
Response
0
Out
of
1
Rationale for score
The bank's confirms that the information has been shared with relevant departments, but the response neither acknowledges its link to the impact, nor ArcelorMittal. Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or took appropriate action. Monitoring
n/a
Rationale for score
The impact was not raised over a year ago and therefore is not scored on monitoring progress. More info
Response
0
Out
of
1
Rationale for score
The bank responded, stating: "Due to legal considerations and potential confidentiality obligations, we are unable to
comment on our involvement or non-involvement in specific projects." Action
0
Out
of
1
Rationale for score
No information is available on whether the bank engaged with its client or took appropriate action. Monitoring
n/a
Rationale for score
The impact was not raised over a year ago and therefore is not scored on monitoring progress. More info
Response
0
Out
of
1
Rationale for score
The bank did not respond. Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or took appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information to indicate the bank is monitoring the actions of its clients, or actions it might itself have taken in response to the impacts raised. More info
Response
0
Out
of
1
Rationale for score
The bank did not respond. Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or took appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information to indicate the bank is monitoring the actions of its clients, or actions it might itself have taken in response to the impacts raised. More info
Response
0
Out
of
1
Rationale for score
The bank did not respond. Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or took appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information to indicate the bank is monitoring the actions of its clients, or actions it might itself have taken in response to the impacts raised. More info
Response
0
Out
of
1
Rationale for score
The bank publicly responded stating that it does not comment on individual companies. Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or took appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information available on whether the bank monitored progress. More info
Response
0
Out
of
1
Rationale for score
The bank publicly responded stating that it does not comment on individual companies. Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or took appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information available on whether the bank monitored progress. More info
Response
0
Out
of
1
Rationale for score
The bank responded citing client confidentiality Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or took appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information available on whether the bank monitored progress.
Following the bank's response: The bank has not provided details on how it monitored the progress of specific companies or how the bank monitored the impact on rights-holders involved in raising the issue with the bank of its own action of updating the Agriculture sector policy. Therefore, the score remains unchanged.
More info
Response
0
Out
of
1
Rationale for score
The bank publicly responded stating that "HSBC does not and cannot discuss individual customers". Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or took appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information available on whether the bank monitored progress. More info
Response
0.5
Out
of
1
Rationale for score
The bank initially responded without commenting on the project.
Following the bank's response: As indicated in the bank's feedback, it later confirmed that it is not involved in the financing for the project. It did not comment on or respond to the substance of the issues raised, therefore it receives a half score.
Action
0.5
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or took appropriate action.
Following the bank's response: The bank confirmed that it is not involved in financing for the project; however, the bank remains exposed to TotalEnergies, the project developer, and it has not (yet) set out specific actions that it requires (or will require) the company to take to address the impacts raised.
Monitoring
0
Out
of
1
Rationale for score
No information available on whether the bank monitored measures taken by its client to address the impacts associated with the project. Response
0
Out
of
1
Rationale for score
The bank publicly responded stating that it does not comment on individual companies. Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or took appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information available on whether the bank monitored progress. More info
Response
0
Out
of
1
Rationale for score
The bank's response neither acknowledges its link to the impact, nor addresses the issues raised Action
0
Out
of
1
Rationale for score
The bank does not describe any engagement with its client or approptriate action Monitoring
0
Out
of
1
Rationale for score
No information to indicate the bank is monitoring the actions of its clients, or actions it might itself have taken in response to the impacts raised. More info
Response
0
Out
of
1
Rationale for score
The bank responded publicly but it did not acknowledge a link to the impacts raised or to the company in question. Action
0
Out
of
1
Rationale for score
The bank did not provide information on whether it has engaged with its client or took appropriate action on the impacts raised. In its response, the bank outlined its approach to climate change and human rights more broadly. Monitoring
0
Out
of
1
Rationale for score
No information available on whether the bank monitored progress. More info
Response
0
Out
of
1
Rationale for score
The bank did not respond. Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or took appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information available on whether the bank monitored progress. More info
Response
0
Out
of
1
Rationale for score
The bank's response neither acknowledges its link to the impact, nor addresses the issues raised. citing their "duty of client confidentiality prevents discussion of specific cases or clients." Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or took appropriate action. Monitoring
n/a
Rationale for score
The impact was not raised over a year ago and therefore is not scored on monitoring progress. More info
Response
0
Out
of
1
Rationale for score
The bank responded, stating: "Our policy is not to comment on speculative financing activity." Action
0
Out
of
1
Rationale for score
No information is available on whether the bank engaged with its client or took appropriate action. Monitoring
n/a
Rationale for score
The impact was not raised over a year ago and therefore is not scored on monitoring progress. More info
Response
0
Out
of
1
Rationale for score
The bank responded, stating: "Our policy is not to comment on speculative financing activity." Action
0
Out
of
1
Rationale for score
No information is available on whether the bank engaged with its client or took appropriate action. Monitoring
n/a
Rationale for score
The impact was not raised over a year ago and therefore is not scored on monitoring progress. More info
See the letter BankTrack sent the bank here.
Response
0
Out
of
1
Rationale for score
The bank did not respond. Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or took appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information available on whether the bank monitored progress. More info
Response
0
Out
of
1
Rationale for score
The bank did not respond. Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or took appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information available on whether the bank monitored measures taken by its client to address the impacts associated with the project. Response
1
Out
of
1
Rationale for score
The bank publicly responded acknowledging its link to the company and commenting on the issues raised. The bank stated that the " content and outcome of the Dirty Diesel report has been part of our regular dialogue with Trafigura and Vitol". Action
0.5
Out
of
1
Rationale for score
The bank detailed its engagement with the company, but provided no detail on any specific action sought from the company. Monitoring
0
Out
of
1
Rationale for score
No information available on whether the bank monitored progress. More info
Response
0.5
Out
of
1
Rationale for score
The bank publicly responded but did not confirm its link to the company, citing client confidentiality.
Following the bank's response: The bank stated that ""while we do not finance products directly facilitating deforestation in the Amazon, commodity traders such as the client's listed within the aforementioned report face supply chain risks"", therefore acknowledging its link to the impact. The bank did not comment on or respond to the substance of the issues raised, resulting in the bank's score being amended to 0.5.
Action
0
Out
of
1
Rationale for score
The bank stated that it "can set out an engagement plan with our clients" however it is "not able to disclose the nature of these dialogues due to client confidentiality". Therefore, the bank has not detailed whether it required the client to take specific actions nor detailed any appropriate action taken by bank itself. Monitoring
0
Out
of
1
Rationale for score
No information available on whether the bank monitored progress. More info
Response
0
Out
of
1
Rationale for score
The bank only provided a confidential response and engagaged with some of the members of the DBIO Coalition on the impacts raised in a confidential meeting. This is not eligible for a score. Action
0
Out
of
1
Rationale for score
No public information available on whether the bank engaged with its client or took appropriate action. Monitoring
0
Out
of
1
Rationale for score
No public information to indicate the bank is monitoring the actions of its clients, or actions it might itself have taken in response to the impacts raised. More info
Response
0.5
Out
of
1
Rationale for score
The bank responded confirming a link to the company (confirming it provided a loan to the company in question together with a syndicate of banks), but it did not acknowledge the human rights impacts raised. Action
0.5
Out
of
1
Rationale for score
The bank stated that it has engaged with its client on the impacts raised. However, it did not set out how it has exercised its leverage or taken any further steps to address the impacts. Monitoring
0
Out
of
1
Rationale for score
No information available on whether the bank monitored progress. More info
Response
0
Out
of
1
Rationale for score
The bank publically responded, but did not acknowledge a link to the company or impacts citing that "due to bank secrecy obligations, we cannot disclose details of our relationship with our clients." Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or took appropriate action. Monitoring
n/a
Rationale for score
The impact was not raised over a year ago and therefore is not scored on monitoring progress. More info
Response
0
Out
of
1
Rationale for score
The bank's response neither acknowledges its link to the impact, nor addresses the issues raised. Action
0
Out
of
1
Rationale for score
No information is available on whether the bank engaged with its client or took appropriate action. Monitoring
n/a
Rationale for score
The impact was not raised over a year ago and therefore is not scored on monitoring progress. More info
Response
0
Out
of
1
Rationale for score
The bank's response neither acknowledges its link to the impact, nor addresses the issues raised. Action
0
Out
of
1
Rationale for score
No information is available on whether the bank engaged with its client or took appropriate action. Monitoring
n/a
Rationale for score
The impact was not raised over a year ago and therefore is not scored on monitoring progress. More info
See the letter BankTrack sent the bank here.
Response
0.5
Out
of
1
Rationale for score
The bank publicly responded acknowledging it link to the impact, but did not comment on or respond to the substance of the issues raised.
Following the bank's response: The score remains unchanged.
Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or took appropriate action.
Following the bank's response: The score remains unchanged.
Monitoring
0
Out
of
1
Rationale for score
No information available on whether the bank monitored progress.
Following the bank's response: The score remains unchanged.
More info
Response
0
Out
of
1
Rationale for score
The bank did not respond. Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or took appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information to indicate the bank is monitoring the actions of its clients, or actions it might itself have taken in response to the impacts raised. More info
Response
0
Out
of
1
Rationale for score
The bank did not respond Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or took appropriate action. Monitoring
n/a
Rationale for score
The impact was not raised over a year ago and therefore is not scored on monitoring progress. More info
See the summary of bank responses here.
Response
1
Out
of
1
Rationale for score
The bank publicly responded confirming its link to the company and commenting on the issues raised. The bank states that it "recognise[s] the importance of this issue" and continues to engage with its "commodity trading clients". Action
0.5
Out
of
1
Rationale for score
The bank detailed its engagement with the company, stating that the bank "continue[s] our engagement with our commodity trading clients, including recent dialogue on this topic with both Trafigura and Vitol". The bank did not provide details on any specific actions sought from the company nor any appropriate action taken by the bank itself. Monitoring
0
Out
of
1
Rationale for score
No information available on whether the bank monitored progress. More info
Response
0
Out
of
1
Rationale for score
The bank publicly responded but did not acknowledge its link to the impact or comment on or respond to the substance of the issue raised. Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or took appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information available on whether the bank monitored progress. More info
Response
1
Out
of
1
Rationale for score
The bank publicly responded confirming its link to the company and commenting on the specific issues raised. The bank references details on the company's RSPO certification and the inclusion of "public domain allegations" in its due diligence. Action
0.5
Out
of
1
Rationale for score
The bank confirmed that its Corporate & investment Bank divison had "not had any oportunity to discuss with IOI Corporation the allegations made", but that the Asset Management division has engaged with the company. The bank's asset management divison stated "With regards to IOI Corporation, we are not aware of any formal actions that have been instituted against the company in respect of alleged breaches of regulations. We have discussed this issue with IOI Corporation management in the last week, and continue to encourage best practice". The bank did not detail any specific actions sought from the company. Monitoring
0
Out
of
1
Rationale for score
No information available on whether the bank monitored progress. More info
Finance for JBS and links to deforestation in the Brazilian Amazon (March 2023)
0
0
0
0
0
Response
0
Out
of
1
Rationale for score
The bank did not respond. Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or took appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information available on whether the bank monitored progress. More info
Myanmar: Equity exposure to companies linked to the military regime (October 2021)
0
0
0
0
0
Response
0
Out
of
1
Rationale for score
The bank did not respond. Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or investee companies or took appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information available about whether the bank monitored progress. More info
Response
0
Out
of
1
Rationale for score
The bank did not respond. Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or took appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information to indicate the bank is monitoring the actions of its clients, or actions it might itself have taken in response to the impacts raised. More info
UN human rights complaint regarding Saudi Aramco and its financiers (July 2023)
0
0
0
0
0
Response
0
Out
of
1
Rationale for score
The bank did not respond. Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or took appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information available on whether the bank monitored progress. More info
Response
0
Out
of
1
Rationale for score
The bank did not respond Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or took appropriate action. Monitoring
n/a
Rationale for score
The impact was not raised over a year ago and therefore is not scored on monitoring progress. More info
See the summary of bank responses here.
Response
0
Out
of
1
Rationale for score
The bank did not respond. Action
0
Out
of
1
Rationale for score
No information is available on whether the bank engaged with its client or took appropriate action. Monitoring
n/a
Rationale for score
The impact was not raised over a year ago and therefore is not scored on monitoring progress. More info
Response
0
Out
of
1
Rationale for score
The bank did not respond. Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or took appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information to indicate the bank is monitoring the actions of its clients, or actions it might itself have taken in response to the impacts raised. More info
Response
0
Out
of
1
Rationale for score
The bank did not respond. Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or took appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information to indicate the bank is monitoring the actions of its clients, or actions it might itself have taken in response to the impacts raised. More info
Response
0
Out
of
1
Rationale for score
The bank publicly responded citing client confidentiality. Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or took appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information available on whether the bank monitored progress. More info
Response
0
Out
of
1
Rationale for score
The bank responded citing client confidentiality Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or took appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information available on whether the bank monitored progress.
Following the bank's response: The bank has not provided details on how it monitored the progress of specific companies or how the bank monitored the impact on rights-holders involved in raising the issue with the bank of its own action of updating the Agriculture sector policy. Therefore, the score remains unchanged.
More info
Response
0
Out
of
1
Rationale for score
The bank did not respond. Action
0
Out
of
1
Rationale for score
No information is available on whether the bank engaged with its client or took appropriate action. Monitoring
n/a
Rationale for score
The impact was not raised over a year ago and therefore is not scored on monitoring progress. More info
Response
0
Out
of
1
Rationale for score
The bank did not respond. Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or took appropriate action. Monitoring
0
Out
of
1
Rationale for score
The bank did not acknowledge the grievance brought by Equity Generation Lawyers or respond to it, despite having committed to the UNGPs. More info
Response
0
Out
of
1
Rationale for score
The bank publicly responded stating that it had "no comment to make at this time". Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or took appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information available on whether the bank monitored progress. More info
Response
0.5
Out
of
1
Rationale for score
The bank responded to civil society to indicate, in a statement shared publicly, that it is not involved in financing EACOP, but it did not speak to the substance of the issues raised. Action
0.5
Out
of
1
Rationale for score
The bank took appropriate action by stating that it would not provide finance to the project; however, the bank remains exposed to TotalEnergies, the project developer, and it has not (yet) set out specific actions that it requires (or will require) the company to take to address the impacts raised. Monitoring
0
Out
of
1
Rationale for score
No information available on whether the bank monitored measures taken by its client to address the impacts associated with the project. Response
0
Out
of
1
Rationale for score
The bank publicly responded citing client confidentiality. Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or took appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information available on whether the bank monitored progress. More info
Myanmar: Equity exposure to companies linked to the military regime (October 2021)
1
0
0
0
0
Response
0
Out
of
1
Rationale for score
The bank, in response to an inquiry from the Business and Human Rights Resource Centre, referenced its Environmental and Social Policy Framework and stated that it does not provide financing for transactions which violate public order and good morals. However, MUFG did not acknowledge its association with companies linked to the Myanmar junta and did not respond to the substance of the issues raised. Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or investee companies or took appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information available about whether the bank monitored progress. More info
Response
0
Out
of
1
Rationale for score
The bank did not respond. Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or took appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information to indicate the bank is monitoring the actions of its clients, or actions it might itself have taken in response to the impacts raised. More info
Response
0
Out
of
1
Rationale for score
The bank responded but cited that they "refrain from commenting on the transactions of individual companies", but have shared the report with relevant parties. Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or took appropriate action. Monitoring
n/a
Rationale for score
The impact was not raised over a year ago and therefore is not scored on monitoring progress. More info
Response
0
Out
of
1
Rationale for score
The bank responded, stating: "due to confidentiality concerns, we would like to refrain from commenting on individual transactions." Action
0
Out
of
1
Rationale for score
The bank stated it had shared the letter with the relevant internal parties, but no information is available on whether the bank engaged with its client or took appropriate action. Monitoring
n/a
Rationale for score
The impact was not raised over a year ago and therefore is not scored on monitoring progress. More info
Response
0
Out
of
1
Rationale for score
The bank responded, stating: "Due to confidentiality concerns, we would like to refrain from commenting on individual transactions." Action
0
Out
of
1
Rationale for score
No information is available on whether the bank engaged with its client or took appropriate action. Monitoring
n/a
Rationale for score
The impact was not raised over a year ago and therefore is not scored on monitoring progress. More info
See the letter BankTrack sent the bank here.
Response
0
Out
of
1
Rationale for score
The bank publicly responded stating that it "cannot refer to individual transactions". Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or took appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information available on whether the bank monitored progress. More info
Response
0
Out
of
1
Rationale for score
The bank publicly responded stating that "As per our policies, we cannot refer to any specific transation". Action
0
Out
of
1
Rationale for score
The bank provided no detail on whether it engaged with its client or took approriate action. Monitoring
0
Out
of
1
Rationale for score
No information available on whether the bank monitored progress. More info
Response
0.5
Out
of
1
Rationale for score
The bank publicly responded stating that it would not finance the project "unless the on-going E&S isues will be resolved and amicable solutions will be prepared". It did not comment on or respond to the substance of the issues raised. Action
0.5
Out
of
1
Rationale for score
The bank publicly stated that it would not finance the project unless "on-going E&S issues" were resolved, which consitutes appropriate action according to rights-holders involved in raising the issue with the bank. However, the bank remains exposed to TotalEnergies, the project developer, and it has not (yet) set out specific actions that it requires (or will require) the company to take to address the impacts raised. Monitoring
0
Out
of
1
Rationale for score
No information available on whether the bank monitored measures taken by its client to address the impacts associated with the project. Response
0
Out
of
1
Rationale for score
The bank publicly responded stating that "As per our policies, we cannot refer to any specific transation". Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or took appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information available on whether the bank monitored progress. More info
Response
0
Out
of
1
Rationale for score
The bank responded citing client confidentiality and by saying it will refrain from commenting on whether the information in the report is accurate, therefore avoiding to speak to the substance of the issues raised and not acknowledging a link to the impacts. Action
0
Out
of
1
Rationale for score
The bank does not engage with the allegations and do not mention appropriate measures of action. It only reiterates its engagment with UN Guiding Principles but do not respond to any of the allegations. Monitoring
0
Out
of
1
Rationale for score
No information available about whether the bank monitored progress. More info
Response
0
Out
of
1
Rationale for score
The bank's response neither acknowledges its link to the impact, nor addresses the issues raised. The bank states "we are unable to refer to individual transactions". Action
0
Out
of
1
Rationale for score
The bank does not describe any engagement with its client or approptriate action Monitoring
0
Out
of
1
Rationale for score
No information to indicate the bank is monitoring the actions of its clients, or actions it might itself have taken in response to the impacts raised. More info
Response
0
Out
of
1
Rationale for score
The bank did not acknowledge a link to the company or the adverse human rights impacts raised. Action
0
Out
of
1
Rationale for score
The bank did not state that it has engaged its client on the issues raised. Monitoring
0
Out
of
1
Rationale for score
No information available on whether the bank monitored progress. More info
Response
0
Out
of
1
Rationale for score
The bank responded publicly but it did not acknowledge a link to the impacts raised or to the company in question. Action
0
Out
of
1
Rationale for score
The bank did not provide information on whether it has engaged with its client or took appropriate action on the impacts raised. In its response, the bank outlined its approach to climate change and human rights more broadly. Monitoring
0
Out
of
1
Rationale for score
No information available on whether the bank monitored progress. More info
Response
0
Out
of
1
Rationale for score
The bank publically responded and confirms information has been shared with relevant departments, but cites that they "cannot make responses on past, existing, and possible future
transactions with individual case due to the confidential obligation." Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or took appropriate action. Monitoring
n/a
Rationale for score
The impact was not raised over a year ago and therefore is not scored on monitoring progress. More info
Response
0
Out
of
1
Rationale for score
The bank responed, stating: "unfortunately, we cannot make responses on past, existing, and possible future
transactions with individual case due to the confidential obligation." Action
0
Out
of
1
Rationale for score
The bank stated it had shared the letter with the relevant departments, but no information is available on whether the bank engaged with its client or took appropriate action. Monitoring
n/a
Rationale for score
The impact was not raised over a year ago and therefore is not scored on monitoring progress. More info
Response
0
Out
of
1
Rationale for score
The bank responded, stating: "we cannot make responses on past, existing, and possible future transactions with individual case due to the confidential obligation." Action
0
Out
of
1
Rationale for score
No information is available on whether the bank engaged with its client or took appropriate action. Monitoring
n/a
Rationale for score
The impact was not raised over a year ago and therefore is not scored on monitoring progress. More info
See the letter BankTrack sent the bank here.
Response
0
Out
of
1
Rationale for score
The bank responded stating that it "does not comment publicly on client relationships”.
Following media reporting: In May 2022, the Financial Times reported that the bank ruled out financing for the project; however, the bank did not put out a public statement so it does not receive a score.
Action
0
Out
of
1
Rationale for score
The bank did not provide information on whether it engaged with its client or took appropriate action.
Following media reporting: No change in score.
Monitoring
0
Out
of
1
Rationale for score
No information available on whether the bank monitored measures taken by its client to address the impacts associated with the project. Finance for JBS and links to deforestation in the Brazilian Amazon (March 2023)
1
0.5
0.5
0
0
Response
0.5
Out
of
1
Rationale for score
The bank responded publicly acknowledging a link to the company and its associated impacts, but without speaking to the substance of the issues raised. Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or took appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information available on whether the bank monitored progress. More info
Response
0
Out
of
1
Rationale for score
The bank publicly responded only to say that they could not comment. Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or took appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information available on whether the bank monitored progress. More info
Myanmar: Equity exposure to companies linked to the military regime (October 2021)
0
0
0
0
0
Response
0
Out
of
1
Rationale for score
The bank did not respond. Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or investee companies or took appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information available about whether the bank monitored progress. More info
Response
0
Out
of
1
Rationale for score
The bank did not respond. Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or took appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information to indicate the bank is monitoring the actions of its clients, or actions it might itself have taken in response to the impacts raised. More info
UN human rights complaint regarding Saudi Aramco and its financiers (July 2023)
0
0
0
0
0
Response
0
Out
of
1
Rationale for score
The bank did not respond. Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or took appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information available on whether the bank monitored progress. More info
Response
0
Out
of
1
Rationale for score
The bank publicly responded stating that "we do not comment on specific clients or projects". The bank refers to its Human Rights policies, but did not comment on or respond to the substance of the issues raised. Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or took appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information available on whether the bank monitored progress. More info
Response
0
Out
of
1
Rationale for score
The bank's response neither acknowledges its link to the impact, nor addresses the issues raised Action
0
Out
of
1
Rationale for score
The bank does not describe any engagement with its client or approptriate action Monitoring
0
Out
of
1
Rationale for score
No information to indicate the bank is monitoring the actions of its clients, or actions it might itself have taken in response to the impacts raised. More info
Response
0.5
Out
of
1
Rationale for score
The bank responded confirming a link to the company (confirming it provided a loan to the company in question together with a syndicate of banks), but it did not acknowledge the human rights impacts raised. Action
0.5
Out
of
1
Rationale for score
The bank stated that it has engaged with its client on the impacts raised. However, it did not itself engage with the affected rights-holders nor did it set out how it has exercised its leverage or taken any further steps to address the impacts. Monitoring
0
Out
of
1
Rationale for score
No information available on whether the bank monitored progress. More info
Response
0
Out
of
1
Rationale for score
The bank did not respond. Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or took appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information to indicate the bank is monitoring the actions of its clients, or actions it might itself have taken in response to the impacts raised. More info
Response
0
Out
of
1
Rationale for score
The bank publicly responded stating that the bank "do not comment on individual customers". Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or took appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information available on whether the bank monitored progress. More info
Response
0
Out
of
1
Rationale for score
The bank responded publicly but did not speak to the substance of the issues raised nor did it acknowledge a link to the impacts raised; rather, it referenced its relevant human rights policies and procedures. Action
0
Out
of
1
Rationale for score
The bank does not indicate whether it plans to engage or has already engaged its clients or investee companies on this issue. Monitoring
0
Out
of
1
Rationale for score
No information to indicate the bank is monitoring the actions of its clients, or actions it might itself have taken in response to the impacts raised. More info
Response
0
Out
of
1
Rationale for score
The bank did not respond. Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or took appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information to indicate the bank is monitoring the actions of its clients, or actions it might itself have taken in response to the impacts raised. More info
Response
0
Out
of
1
Rationale for score
The bank did not respond. Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or took appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information available on whether the bank monitored progress.
Following the bank's response: The bank has not provided details on how it monitored the progress of specific companies or how the bank monitored the impact on rights-holders involved in raising the issue with the bank of its own action of updating the Agriculture sector policy. Therefore, the score remains unchanged.
More info
Response
1
Out
of
1
Rationale for score
The bank responds publicly to the allegations in a way which comments on and responds to the substance of the issues raised, and its response acknowledges its connection to the impact. Action
1
Out
of
1
Rationale for score
The bank sets out that it has engaged with the client or investee company regarding the allegations of adverse human rights impact(s) linked to its finance and it discusses its exposure and leverage. Monitoring
0
Out
of
1
Rationale for score
No information to indicate the bank is monitoring the actions of its clients, or actions it might itself have taken in response to the impacts raised. More info
Response
0
Out
of
1
Rationale for score
The bank publicly responded citing client confidentiality. The response did not comment on or respond to the issues raised. Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or took appropriate action.
Following the bank's response: The bank stated that engagements with clients are publicly reported in an anonymised format in its annual reports. This reporting does not provide details on whether or how the bank has engaged with the company in this specific instance nor does it state whether the bank has required the company to take specific actions or taken appropriate action itself. Therefore, the score remains unchanged.
Monitoring
0
Out
of
1
Rationale for score
No information available on whether the bank monitored progress. More info
Response
0.5
Out
of
1
Rationale for score
The bank responded publicly acknowldeging that it has clients that are linked to the impact, that the issue raised is relevant, and engagement is appropriate. Action
0
Out
of
1
Rationale for score
The bank indicates that it has "encouraged engagement" with clients within the relevant departments. However, it is not clear engagement with clients on this issue has or will take place. Monitoring
0
Out
of
1
Rationale for score
No information available on whether the bank monitored progress. More info
Banks assisting with war mobilisation in Russia (October 2022)
1
0.5
0.5
0
0
Response
0.5
Out
of
1
Rationale for score
The bank publicly responded acknowledging the substance of the issues raised, commenting on how it has responded to partial mobilization of its employees in Russia. However, the it did not entirely address the questions, for example it did not indicate how it plans to mitigate the impacts raised. Action
0
Out
of
1
Rationale for score
The bank provides no information on whether it has set up a plan to take action. Monitoring
0
Out
of
1
Rationale for score
No information to indicate the bank is monitoring the actions of its clients, or actions it might itself have taken in response to the impacts raised. More info
Response
0.5
Out
of
1
Rationale for score
The bank publicly responded confirming that it is “not involved in the project”. It did not comment on or respond to the substance of the issues raised. Action
0.5
Out
of
1
Rationale for score
The bank took appropriate action by publicly stating that it would not provide finance to the project; however, the bank remains exposed to TotalEnergies, the project developer, and it has not (yet) set out specific actions that it requires (or will require) the company to take to address the impact raised. Monitoring
0
Out
of
1
Rationale for score
No information available on whether the bank monitored measures taken by its client to address the impacts associated with the project. Myanmar: Equity exposure to companies linked to the military regime (October 2021)
1
0
0
0
0
Response
0
Out
of
1
Rationale for score
The bank responded citing client confidentiality and its relevant ESG policies, but failed to acknowledge a link to the allegations and did not respond to the substance of the issues raised. Action
0
Out
of
1
Rationale for score
The bank does not engage with the allegations and do not mention appropriate measures of action. It only reiterates its engagment with ESG polciies but do not respond to any of the allegations. Monitoring
0
Out
of
1
Rationale for score
No information available about whether the bank monitored progress. More info
Response
1
Out
of
1
Rationale for score
The bank responded confirming a link to the company (confirming it provided a loan to the company in question together with a syndicate of banks), and it acknowledged the human rights impacts raised. Action
0.5
Out
of
1
Rationale for score
The bank stated that it has engaged with its client on the impacts raised. However, it did not set out how it has exercised its leverage or taken any further steps to address the impacts. Monitoring
0
Out
of
1
Rationale for score
No information available on whether the bank monitored progress. More info
Response
0
Out
of
1
Rationale for score
The bank confirmed reciept but did not otherwise respond. Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or took appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information to indicate the bank is monitoring the actions of its clients, or actions it might itself have taken in response to the impacts raised. More info
Response
0
Out
of
1
Rationale for score
The bank publically responded, but cites that they "do not comment on client-specific matters." Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or took appropriate action. Monitoring
n/a
Rationale for score
The impact was not raised over a year ago and therefore is not scored on monitoring progress. More info
Response
0
Out
of
1
Rationale for score
The bank did not respond. Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or took appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information available on whether the bank monitored progress. More info
Response
0
Out
of
1
Rationale for score
The bank did not respond. Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or took appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information available on whether the bank monitored progress.
Following the bank's response: The bank has not provided details on how it monitored the progress of specific companies or how the bank monitored the impact on rights-holders involved in raising the issue with the bank of its own action of updating the Agriculture sector policy. Therefore, the score remains unchanged.
More info
Response
0
Out
of
1
Rationale for score
The bank did not respond. Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or took appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information to indicate the bank is monitoring the actions of its clients, or actions it might itself have taken in response to the impacts raised. More info
Response
0
Out
of
1
Rationale for score
The bank responded publicly but without acknowledging the bank's link to the impact and citing client confidentiality. Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or took appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information available on whether the bank monitored progress. More info
Response
0
Out
of
1
Rationale for score
The bank responded, stating that "its rule of conduct is not to provide information about specific companies or operations, whether or not it accompanies them." Action
0
Out
of
1
Rationale for score
No information is available on whether the bank engaged with its client or took appropriate action. Monitoring
n/a
Rationale for score
The impact was not raised over a year ago and therefore is not scored on monitoring progress. More info
Response
0
Out
of
1
Rationale for score
The bank did not respond. Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or took appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information to indicate the bank is monitoring the actions of its clients, or actions it might itself have taken in response to the impacts raised. More info
Banks profiting from the construction and hotel boom in Qatar (November 2022)
0
0
0
0
0
Response
0
Out
of
1
Rationale for score
The bank did not respond. Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client(s) or took appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information to indicate the bank is monitoring the actions of its clients, or actions it might itself have taken in response to the impacts raised. More info
Response
0
Out
of
1
Rationale for score
The bank did not respond. Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or took appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information available on there the bank monitored the impacts or the actions of its clients Response
0
Out
of
1
Rationale for score
The bank has stated that it responded to the International Federation for Human Rights (FIDH), a member of the Don’t Buy Into Occupation coalition. However, the response was not public, and thus, does not receive a score. Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or took appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information to indicate the bank is monitoring the actions of its clients, or actions it might itself have taken in response to the impacts raised. More info
Response
0
Out
of
1
Rationale for score
Although news sources reported that the bank would not finance the project, the bank has not responded to stakeholders or confirmed its position publicly. Action
0
Out
of
1
Rationale for score
Although media reports suggest the bank has taken appropriate action by refusing to provide finance to the project, the bank has not set this position out publicly. Monitoring
0
Out
of
1
Rationale for score
No information available on whether the bank monitored measures taken by its client to address the impacts associated with the project. Response
1
Out
of
1
Rationale for score
The bank publicly responded confirming its link to the company and addressing the issues raised. The bank states that "Information of the last few months regarding the quality of car fuels in African countries and debates around the role of the different actors of the value chain have been factored in our reviews" of the companies involved. Action
0.5
Out
of
1
Rationale for score
The bank detailed its engagement with the company, but provided no detail on any appropriate action being taken. Monitoring
0
Out
of
1
Rationale for score
No information available on whether the bank monitored progress. More info
Response
1
Out
of
1
Rationale for score
The bank publicly responded confirming its link to the client and addressing the issues raised. The bank stated that it "carefully considered the elements brought to its attention" by the letter from PUBB. Action
0
Out
of
1
Rationale for score
The bank stated that it performed an additional internal investigation to determine the use of net proceeds from The Ministry of Finance's bond. However, the bank did not detail whether it engaged with its client or outlined specific actions sought from its client. Monitoring
0
Out
of
1
Rationale for score
No information available on there the bank monitored the impacts or the actions of its clients More info
Response
0.5
Out
of
1
Rationale for score
The bank acknowledged its link with the company and also discussed its responsibilities under the UNGPs with regard to the management of minority shareholdings. The bank did not comment on the specific issues raised. Action
0
Out
of
1
Rationale for score
The bank did not provided any details on whether it had engaged with its client or taken appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information available on whether the bank monitored progress. More info
Myanmar: Equity exposure to companies linked to the military regime (October 2021)
1
0.5
0.5
0
0
Response
0.5
Out
of
1
Rationale for score
The bank responded publicly, acknowledging that Lyxor Asset Management, a wholly owned subsidiary of Société Générale, has exposure to companies with direct involvement in Myanmar. However, the response does not comment on the substance of the issue raised nor set out any actions taken to address the impact. Action
0
Out
of
1
Rationale for score
The bank did not address the substance of the allegations and did not set out any appropriate measures of action. Monitoring
0
Out
of
1
Rationale for score
No information available about whether the bank monitored progress. More info
Response
1
Out
of
1
Rationale for score
The bank publicly responded acknowledging its link to the impact and responding to the issues raised. The bank states that it is "aware of some recent challenges encountered by the project". Action
0.5
Out
of
1
Rationale for score
The bank has stated that "actions have been taken and we believe that these issues are being satisfactorily addressed by the lenders pool". The bank also referred to a letter from its client which addresses the issues raised by communities. The bank did not outline any specific actions sought from the company. Monitoring
0
Out
of
1
Rationale for score
No information available on whether the bank monitored the issue or steps taken by the client. Response
0.5
Out
of
1
Rationale for score
The bank responds publicly to the allegations and its response acknowledges its link to the impact via its finance for Rio Tinto, but without detailing specific actions taken. Although the bank states that it engages with the company, it does not make clear that it engaged on the specific issues related to this mining project.
Action
0
Out
of
1
Rationale for score
The bank does not describe any engagement with its client on the topics raised in the letter or appropriate action, only a general engagement process that applies to all clients in the sector. Monitoring
0
Out
of
1
Rationale for score
No information to indicate the bank is monitoring the actions of its clients, or actions it might itself have taken in response to the impacts raised. More info
UN human rights complaint regarding Saudi Aramco and its financiers (July 2023)
1
0
0
0
0
Response
0
Out
of
1
Rationale for score
The bank responded publicly but it did not speak to the subject matter nor did it acknowledge a link to the impacts raised and the company in question. The bank instead listed its relevant social and environmental policies. Action
0
Out
of
1
Rationale for score
The bank does not indicate that it will take action on the allegations raised, or that it will engage its client. The bank reiteraites its commitment to respecting human rights and the enviroment without outlining a plan for action. Monitoring
0
Out
of
1
Rationale for score
No information available on whether the bank monitored progress. More info
Response
0
Out
of
1
Rationale for score
The bank's response neither acknowledges its link to the impact, nor addresses the issues raised citing that "we are not able to comment on any existing or potential client relationships." Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or took appropriate action. Monitoring
n/a
Rationale for score
The impact was not raised over a year ago and therefore is not scored on monitoring progress. More info
Response
0
Out
of
1
Rationale for score
The bank responded, stating: "Societe Generale group (the “Group”) has a policy, due in particular to legal and/or contractual confidentiality obligations, of not providing information regarding specific companies or operations. For this reason, we will not be able to comment on the elements listed in your open letter." Action
0
Out
of
1
Rationale for score
No information is available on whether the bank engaged with its client or took appropriate action. Monitoring
n/a
Rationale for score
The impact was not raised over a year ago and therefore is not scored on monitoring progress. More info
See the letter BankTrack sent the bank here.
Response
n/a
Rationale for score
The bank did not respond.
Following publication: The bank responded stating that it is not involved in financing of the project, therefore it has not been included in the scoring.
Action
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or took appropriate action.
Following publication: The bank responded stating that it is not involved in financing of the project, therefore it has not been included in the scoring.
Monitoring
n/a
Rationale for score
No information available on there the bank monitored the impacts or the actions of its clients Response
0.5
Out
of
1
Rationale for score
The bank responded publicly acknowledging its link to the impacts, but did not address the issues raised. The bank stated that the information provided in the open letter is "given attention and due consideration during...screening processes".
Following the bank's response: The score remains unchanged.
Action
0.5
Out
of
1
Rationale for score
The bank stated that the project will be reviewed by an independent consultant in line with the Equator Principles and the IFC Performance Standards. The bank did not detail any specific actions sought from the company to address human rights violations.
Following the bank's response: The score remains unchanged.
Monitoring
0
Out
of
1
Rationale for score
No information available on whether the bank monitored measures taken by its client to address the impacts associated with the project. Response
0
Out
of
1
Rationale for score
The bank did not respond. Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or took appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information to indicate the bank is monitoring the actions of its clients, or actions it might itself have taken in response to the impacts raised. More info
Response
0
Out
of
1
Rationale for score
The bank publicly responded citing client confidentiality. Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or took appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information available on whether the bank monitored progress. More info
Response
0
Out
of
1
Rationale for score
The bank responded citing client confidentiality Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or took appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information to indicate the bank is monitoring the actions of its clients, or actions it might itself have taken in response to the impacts raised. More info
Response
0
Out
of
1
Rationale for score
The bank responds publicly but without acknowledging the bank's link to the impact. Action
0
Out
of
1
Rationale for score
The bank provides evidence of having reviewed its management systems to prevent such impacts from occurring in the future, but without this being considered an appropriate and sufficient remedy by rights-holders involved in raising the issue with the bank. Monitoring
0
Out
of
1
Rationale for score
No information available on whether the bank monitored progress.
Following the bank's response: The bank has not provided details on how it monitored the progress of specific companies or how the bank monitored the impact on rights-holders involved in raising the issue with the bank of its own action of updating the Agriculture sector policy. Therefore, the score remains unchanged.
More info
Response
0.5
Out
of
1
Rationale for score
The bank initially responded publicly stating that it was undertaking due diligence on the project. At a later time, the bank responded publicly by confirming it would not finance the project in question. It did not comment on or respond to the substance of the issues raised. Action
0.5
Out
of
1
Rationale for score
The bank publicly announced it will not finance the project in question. The bank remains exposed to TotalEnergies, the project developer, and has stated that it engaged with Total as part of its due diligence. However it has not (yet) set out specific actions that it requires (or will require) the company to take to address the impacts raised. Monitoring
0
Out
of
1
Rationale for score
No information available on whether the bank monitored measures taken by its client to address the impacts associated with the project. Response
0.5
Out
of
1
Rationale for score
The bank publicly responded confirming that it has "acted for IOI on a number of transactions" but stated that "client confidentiality, a legal obligation, does nonetheless prevent us from discussing specifics of a possible relationship with any particular company." The bank acknowledged its responsibility to respect human rights, and provided general details about its policies and process, but did not comment on or respond to the substance of the issues raised. Action
0
Out
of
1
Rationale for score
The bank did not provide any details on whether it had engaged with its client or taken appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information available on whether the bank monitored progress. More info
Response
1
Out
of
1
Rationale for score
The bank publicly responded acknowledging its link to the impact and responding in its comments to the issues raised. The bank stated that it is "aware of the communities’ concerns and have been using our leverage, in collaboration with other lenders to the project, to ensure that they continue to be prioritised and systematically resolved". Action
0.5
Out
of
1
Rationale for score
The bank has stated that, together with the other financial lenders, it is using its leverage to ensure the concerns of the communities are prioritised by the company. The bank also attached a copy of a letter from its client which addresses the issues raised by communities. The bank did not outline details of specific actions sought from the company. Monitoring
0
Out
of
1
Rationale for score
No information available on whether the bank monitored the issue or steps taken by the client. Response
0
Out
of
1
Rationale for score
The bank responded, stating: "Due to client confidentiality, we do not comment on details of specific relationships." Action
0
Out
of
1
Rationale for score
No information is available on whether the bank engaged with its client or took appropriate action. Monitoring
n/a
Rationale for score
The impact was not raised over a year ago and therefore is not scored on monitoring progress. More info
Response
0
Out
of
1
Rationale for score
The bank responded, stating: "due to client confidentiality, Standard Chartered (‘we’, ‘us’ or
‘our’) does not comment on details of specific relationships." Action
0
Out
of
1
Rationale for score
No information is available on whether the bank engaged with its client or took appropriate action. Monitoring
n/a
Rationale for score
The impact was not raised over a year ago and therefore is not scored on monitoring progress. More info
See the letter BankTrack sent the bank here.
Response
0
Out
of
1
Rationale for score
The bank did not respond. Action
0
Out
of
1
Rationale for score
No information is available on whether the bank engaged with its client or took appropriate action. Monitoring
n/a
Rationale for score
The impact was not raised over a year ago and therefore is not scored on monitoring progress. More info
Response
0
Out
of
1
Rationale for score
The bank did not respond. Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or took appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information to indicate the bank is monitoring the actions of its clients, or actions it might itself have taken in response to the impacts raised. More info
Myanmar: Equity exposure to companies linked to the military regime (October 2021)
1
0
0
0
0
Response
0
Out
of
1
Rationale for score
The bank, in response to an inquiry from the Business and Human Rights Resource Centre, referred to its sustainability policy, human rights policy, and Human Rights Due Diligence Liaison Committee, which is responsible for investigating the human rights responses across the entire banking Group. Sumitomo Mitsui Trust Holdings further highlighted its engagement with investee companies, noting that in certain cases, it may exercise voting rights at shareholder meetings or consider divestment. However, the bank did not acknowledge its association with companies linked to the Myanmar junta and did not respond to the substance of the issues raised. Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or investee companies or took appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information available about whether the bank monitored progress. More info
Response
0
Out
of
1
Rationale for score
The bank's response neither acknowledges its link to the impact, nor addresses the issues raised. Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or took appropriate action. Monitoring
n/a
Rationale for score
The impact was not raised over a year ago and therefore is not scored on monitoring progress. More info
Response
0
Out
of
1
Rationale for score
The bank responded, but chose to "refrain from commenting on the individual project." Action
0
Out
of
1
Rationale for score
The bank stated it had shared the letter with the relevant departments, but no information is available on whether the bank engaged with its client or took appropriate action. Monitoring
n/a
Rationale for score
The impact was not raised over a year ago and therefore is not scored on monitoring progress. More info
Response
0
Out
of
1
Rationale for score
The bank did not respond. Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or took appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information available on whether the bank monitored progress. More info
Complicity in Destruction IV: Mining and Indigenous Rights in the Amazon (March 2022)
0
0
0
0
0
Response
0
Out
of
1
Rationale for score
The bank did not respond. Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or took appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information available on whether the bank monitored progress. More info
Response
0.5
Out
of
1
Rationale for score
The bank publicly said it is not "currently involved" in financing EACOP, but it did not speak to the substance of the issues raised. Action
0.5
Out
of
1
Rationale for score
The bank took appropriate action by stating that it would not provide finance to the project; however, the bank remains exposed to TotalEnergies, the project developer, and it has not (yet) set out specific actions that it requires (or will require) the company to take to address the impacts raised. Monitoring
0
Out
of
1
Rationale for score
No information available on whether the bank monitored measures taken by its client to address the impacts associated with the project. Response
0
Out
of
1
Rationale for score
The bank publicly responded only to say that they could not comment. Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or took appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information available on whether the bank monitored progress. More info
UN human rights complaint regarding Saudi Aramco and its financiers (July 2023)
1
0
0
0
0
Response
0
Out
of
1
Rationale for score
The bank responded publicly but it did not acknowledge a link to the impacts raised or to the company in question. Action
0
Out
of
1
Rationale for score
The bank did not provide information on whether it has engaged with its client or took appropriate action on the impacts raised. In its response, the bank outlined its approach to climate change and human rights more broadly. Monitoring
0
Out
of
1
Rationale for score
No information available on whether the bank monitored progress. More info
Response
0
Out
of
1
Rationale for score
The bank did not respond. Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or took appropriate action. Monitoring
0
Out
of
1
Rationale for score
SMBC did not acknowledge the grievance brought by Equity Generation Lawyers or respond to it, despite having committed to the UNGPs. More info
Response
0
Out
of
1
Rationale for score
The bank's confirms that the information has been shared with relevant departments, but the response neither acknowledges its link to the impact, nor ArcelorMittal. Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or took appropriate action. Monitoring
n/a
Rationale for score
The impact was not raised over a year ago and therefore is not scored on monitoring progress. More info
Impacts of Indonesia’s state electricity company PLN (March 2025)
1
0
0
0
n/a
Response
0
Out
of
1
Rationale for score
The bank's response neither acknowledges its link to the impact, nor addresses the issues raised. Action
0
Out
of
1
Rationale for score
No information is available on whether the bank engaged with its client or took appropriate action. Monitoring
n/a
Rationale for score
The impact was not raised over a year ago and therefore is not scored on monitoring progress. More info
See the letter BankTrack sent the bank here.
Response
0
Out
of
1
Rationale for score
The bank did not respond. Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or took appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information to indicate the bank is monitoring the actions of its clients, or actions it might itself have taken in response to the impacts raised. More info
Myanmar: Equity exposure to companies linked to the military regime (October 2021)
1
0
0
0
0
Response
0
Out
of
1
Rationale for score
The bank responds publicly but without acknowledging the bank's link to the allegations. Action
0
Out
of
1
Rationale for score
The bank does not engage with the allegations and do not mention appropriate measures of action. It only states general ESG policies. Monitoring
0
Out
of
1
Rationale for score
No information available about whether the bank monitored progress. More info
Response
0
Out
of
1
Rationale for score
The bank did not respond. Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or took appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information to indicate the bank is monitoring the actions of its clients, or actions it might itself have taken in response to the impacts raised. More info
Response
0
Out
of
1
Rationale for score
The bank publicly responded but did not acknowledge its link to the impact or comment on or respond to the substance of the issues raised. Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or took appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information available on whether the bank monitored progress. More info
Response
0
Out
of
1
Rationale for score
The bank publicly responded stating, due to the bank having "reportable positions in a large number of companies worldwide, usually held on behalf of clients / asset owners. Strictly speaking, it is therefore incorrect to conclude in such situations that UBS "is involved in financing" a particular company". Action
0
Out
of
1
Rationale for score
The bank did not provided any details on whether it had engaged with its client or taken appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information available on whether the bank monitored progress. More info
Response
0
Out
of
1
Rationale for score
The bank responds publicly but without acknowledging the bank's link to the allegations. Action
0
Out
of
1
Rationale for score
The bank does not engage with the allegations and do not mention appropriate measures of action. It only states general ESG policies. Monitoring
0
Out
of
1
Rationale for score
No information available about whether the bank monitored progress. More info
Response
0
Out
of
1
Rationale for score
The bank responded, stating that "due to banking confidentiality we cannot and do not comment on any potential clients or transactions." Action
0
Out
of
1
Rationale for score
No information is available on whether the bank engaged with its client or took appropriate action. Monitoring
n/a
Rationale for score
The impact was not raised over a year ago and therefore is not scored on monitoring progress. More info
Response
0
Out
of
1
Rationale for score
A civil society group has confirmed that the bank will not be financing the project, however the bank has not confirmed its position publicly. Action
0
Out
of
1
Rationale for score
Although civil society has confirmed the bank has taken appropriate action by refusing to provide finance to the project, the bank has not set this position out publicly. Monitoring
0
Out
of
1
Rationale for score
No information available on whether the bank monitored measures taken by its client to address the impacts associated with the project. Response
0.5
Out
of
1
Rationale for score
The bank publicly responded but did not acknowledge its link to the impact or comment on the specific issues raised.
Following the bank's response: The bank acknowledges its link to the impact, but still does not comment on or respond to the substance of the issues raised. Therefore, the score has been amended to 0.5.
Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or took appropriate action.
Following the bank's response: The bank confirmed that it ""engaged with the customer and gathered statements and positions on the allegation"". The bank did not provide details of this engagement nor did the bank state whether it had required the company to take specific actions or that the bank had taken appropriate action itself. Therefore, the score remains unchanged.
Monitoring
0
Out
of
1
Rationale for score
No information available on whether the bank monitored progress. More info
Response
0
Out
of
1
Rationale for score
The bank publically responded, but cites that they, "do not provide information about relations with individual customers." Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or took appropriate action. Monitoring
n/a
Rationale for score
The impact was not raised over a year ago and therefore is not scored on monitoring progress. More info
Response
0
Out
of
1
Rationale for score
The bank did not respond. Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or took appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information to indicate the bank is monitoring the actions of its clients, or actions it might itself have taken in response to the impacts raised. More info
Myanmar: Equity exposure to companies linked to the military regime (October 2021)
0
0
0
0
0
Response
0
Out
of
1
Rationale for score
The bank did not respond. Action
0
Out
of
1
Rationale for score
No information available on whether the bank engaged with its client or investee companies or took appropriate action. Monitoring
0
Out
of
1
Rationale for score
No information available about whether the bank monitored progress. More info
Response
0
Out
of
1
Rationale for score
The bank publicly responded stating that "as a general rule, Wells Fargo does not disclose details regarding specific relationships".
Following the bank's response: The score remains unchanged.
Action
0
Out
of
1
Rationale for score
The bank provided no detail on whether it engaged with its client or took approriate action.
Following the bank's response: The score remains unchanged.
Monitoring
0
Out
of
1
Rationale for score
No information available on whether the bank monitored progress.
Following the bank's response: The score remains unchanged.
More info
Response
0
Out
of
1
Rationale for score
The bank's response neither acknowledges its link to the impact, nor addresses the issues raised. The bank agreed to a meeting on the subject, but no additional information was shared. Action
0
Out
of
1
Rationale for score
The bank does not describe any engagement with its client or approptriate action Monitoring
0
Out
of
1
Rationale for score
No information to indicate the bank is monitoring the actions of its clients, or actions it might itself have taken in response to the impacts raised. More info
Response
0.5
Out
of
1
Rationale for score
The bank responded confirming a link to the company (confirming it provided a loan to the company in question together with a syndicate of banks), but it did not acknowledge the human rights impacts raised. Action
0.5
Out
of
1
Rationale for score
The bank stated that it has engaged with its client on the impacts raised. However, it did not itself engage with the affected rights-holders nor did it set out how it has exercised its leverage or taken any further steps to address the impacts. Monitoring
0
Out
of
1
Rationale for score
No information available on whether the bank monitored progress. More info
Average
64%
0.19
0.12
0.07
0