Benchmarking credit policies of international banks
p. ii Mind the Gap
BankTrack Boothstraat 1c 3512 BT Utrecht Netherlands T: +31-30-2334343 E: [email protected] Track W: www.banktrack.org BANK
Mind the Gap p. iii
Benchmarking credit policies of international banks December 2007
p. iv Mind the Gap Content
Acknowledgements ...... vii
Summary ...... ix
1. Introduction...... 14
2. Objectives and methodology ...... 16 3. Sector Policies...... 24 4. Issue policies ...... 68 ...... 100 5. Transparency and accountability...... 105
Mind the Gap p. v 6. Dodgy deals ...... 116 7. Bank Profiles...... 138 p. vi Mind the Gap
8. Conclusion ...... 229 Annex 1 Comparison with previous benchmark study...... 234 Annex 2 References ...... 236
Mind the Gap p. vii Acknowledgements
Dodgy Deal Feedback on findings
p. viii Mind the Gap
Financial support Use and copyright About BankTrack
Mind the Gap p. ix Summary
Objectives and scope content transparency & accountability implementation. p. x Mind the Gap
Sectors and issues to be covered in credit policies
Sectors Issues
Sector and issue policies Mind the Gap
Mind the Gap p. xi Number of banks which have developed sector and issue policies
No. of Sector policies Issue policies No. of banks banks
Transparency & accountability
p. xii Mind the Gap
Implementation Dodgy Deals Dodgy Deals Dodgy Deals
Mind the Gap p. xiii Final remarks Mind the Gap Mind the Gap
All findings of the BankTrack benchmark research project, including a set of profiles with all relevant documents and policies of the 45 banks covered in the report, can be found at the BankTrack website, under section: ‘Mind the Gap’
p. 14 Mind the Gap
1. Introduction
content transparency and accountability implementation. Mind the Gap
Mind the Gap p. 15 Chapter 2 Chapter 3 Chapter 4 Chapter 5 Chapter 6 Chapter 7 Chapter 8 Annex 1 Annex 2 Summary
p. 16 Mind the Gap
2. Objectives and methodology
2.1 Objectives
content transparency accountability dodgy deals implementation Shaping the Future of Sustainable Finance’ Mind the Gap,
2.2 General description of methodology
Mind the Gap • Policies • Transparency & accountability • Implementation Mind the Gap
Mind the Gap p. 17 Dodgy Deals. Dodgy Deals Dodgy Deals
2.3 Selection of banks
p. 18 Mind the Gap
Selection of 45 banks for the benchmark Project Under Regional No. Bank Country Assets Loans finance writing leader Mind the Gap p. 19 Selection of 45 banks for the benchmark Project Under Regional No. Bank Country Assets Loans finance writing leader
2.4 Scope of the study
Mind the Gap p. 20 Mind the Gap
2.5 Benchmarking the content of credit policies
Sectors: • • • • • • • Issues: • • • • • • •
Mind the Gap p. 21
The bank has no policy on this issue/sector; The bank’s policy on this issue/sector is vaguely worded or ‘aspirational’, with no clear commitments; The bank’s policy on this issue/sector includes some important elements, but is not sufficiently consistent; The bank’s policy on this issue/sector is fairly well-defined and consistent, but falls behind best standards available on one or two elements; The bank’s policy on this issue/sector is completely consistent with best standards available. X’
p. 22 Mind the Gap
2.6 Benchmarking transparency & accountability
• • • •
2.7 Implementation cases
Dodgy Deals Dodgy Deals Dodgy Deal Deals Mind the Gap p. 23 Dodgy Deal
2.8 Bank profiles and comments by banks
Dodgy Deals Dodgy Deals
2.9 Conclusion
Mind the Gap Dodgy Deals Shaping the Future of Sustainable Finance
p. 24 Mind the Gap
3. Sector Policies
3.1 Agriculture
3.1.1 What is at stake?
wealthier • • • • • • Mind the Gap p. 25
3.1.2 Best standards available
General certification and ecolabels organic fair trade GMO- free reduced impact sustainable organic Labelling Initiatives Generic Standards Product Standards Product Standards
p. 26 Mind the Gap
Product-specific standards • Soy: • Palm Oil : Mind the Gap p. 27 • Sugarcane: • Bio-fuels: • Cocoa: • Coffee: • Cotton: • Other standards
Ecosystem conversion and land rights p. 28 Mind the Gap
• • Food entitlement and economic development Protected areas Genetically Modified Organisms Rights of indigenous peoples Labour rights Mind the Gap p. 29 Pesticides
3.1.3 Content of a bank policy
• • • • • • • • • •
3.1.4 Scoring table
p. 30 Mind the Gap
0. The bank has no policy on this sector; 1. The bank’s policy is vaguely worded or aspirational, with no clear commitments; 2. The bank’s policy sets as precondition for its financial services the best international standards for at most three of the elements listed in paragraph 3.1.3; 3. The bank’s policy sets as precondition for its financial services the best international standards for at least three of the elements listed in paragraph 3.1.3; 4. The bank’s policy is fully in line with all international standards and guidelines for all elements listed in paragraph 3.1.3;
3.1.5 Results
Mind the Gap p. 31 Scores on Agriculture policies
p. 32 Mind the Gap
3.2 Dams
3.2.1 What is at stake?
3.2.2 Best standards available
Gaining Public Acceptance Mind the Gap p. 33 Comprehensive Options Assessment Addressing Existing Dams: Sustaining Rivers and Livelihoods: Recognising Entitlements and Sharing Benefits Ensuring Compliance Sharing rivers for Peace, Development and Security:
3.2.3 Content of a bank policy
p. 34 Mind the Gap
3.2.4 Scoring table
0. The bank has no policy on this sector; 1. The bank’s policy is vaguely worded or aspirational, with no clear commitments; 2. The bank’s policy includes elements such as options assessment, steps to ensure dam safety, and consultation with neighbouring states, but does not commit to the WCD strategic priorities and supporting principles; 3. The bank’s policy commits to the WCD strategic priorities and supporting principles; 4. The bank’s policy commits to the WCD strategic priorities and supporting principles for all dams and precludes support for dam projects that are located in, or substantially impact upon, critical natural habitats.
3.2.5 Results
Mind the Gap p. 35 Scores on Dams policies
p. 36 Mind the Gap
3.3 Fisheries
3.3.1 What is at stake?
• • • •
3.3.2 Best standards available
Certification of sustainable fisheries FAO Code of Conduct for Mind the Gap p. 37 Responsible Fisheries Ecosystem based management of fisheries UN Straddling Stocks Agreement FAO Code of Conduct for Responsible Fisheries FAO Code of Conduct for Responsible Fisheries Precautionary principle for sustainable fisheries management precautionary principle Eliminating overfishing and restoring stocks UN Straddling Stocks Agreement Marine Protected Areas (MPAs)
Eliminating and avoiding overcapitalisation UN Straddling Stocks Agreement p. 38 Mind the Gap
Eliminating destructive fishing practices FAO Code of Conduct for Responsible Fisheries Minimising by-catch FAO Code of Conduct for Responsible Fisheries Illegal, Unregulated and Unreported fishing and flags of convenience Endangered species FAO Code of Conduct for Responsible Fisheries Sustainable aquaculture FAO Code of Conduct Mind the Gap p. 39 for Responsible Fisheries
3.3.3 Content of a bank policy
Marine Protected Areas
FAO Code of Conduct for Responsible Fisheries
p. 40 Mind the Gap
3.3.4 Scoring table
0. The bank has no policy on this sector; 1. The bank’s policy is vaguely worded or aspirational, with no clear commitments; 2. The bank’s policy includes specific elements to identify better fisheries such as minimising by-catch and a preference for certifying sustainable marine fisheries, but does not commit univocally to the goal of the sustainable management and use of fisheries; 3. The bank’s policy commits to the FAO Code of Conduct for Responsible Fisheries for financial services provided to the fisheries sector directly; 4. The bank’s policy commits to the FAO Code of Conduct for Responsible Fisheries and the International Principles for Responsible Shrimp Farming, for its financial relationships with all companies throughout the seafood chain of custody.
3.3.5 Results
Scores on Fisheries policies
Mind the Gap p. 41 3.4 Forestry
3.4.1 What is at stake?
• • • • • • •
p. 42 Mind the Gap
Unsustainable and illegal logging practices Conversion of natural forests into timber or pulp plantations Food and Agriculture Organization of the United Nations (FAO) Conversion of forests for agricultural expansion Conversion of mangrove forests for aquaculture Development of large-scale industrial and infrastructure projects
Mind the Gap p. 43
p. 44 Mind the Gap
3.4.2 Best standards available
Land rights of local and indigenous communities Illegal logging and forest governance Certification of forest management and chain of custody status quo
Mind the Gap p. 45 • • Protected areas and High Conservation Value Forests High Conservation Value Forests (HCVFs) p. 46 Mind the Gap
3.4.3 Content of a bank policy
• • • • Chain of Custody • • •
Mind the Gap p. 47 • • • •
3.4.4 Scoring table
0. The bank has no policy on this sector; 1. The bank’s policy is vaguely worded or aspirational, with no clear commitments; 2. The bank’s policy excludes companies from financing that are directly or indirectly (as traders or processors) involved in corrupt practices, illegal logging, forest conversion activities which undermine the rights of local communities or operate in specified ‘no-go zones’; 3. The bank’s policy sets FSC-certification as pre-condition for clients operating in the forestry sector; 4. The bank’s policy sets FSC-certification as pre-condition for clients operating in the forestry sector and commits explicitly to the conditions mentioned in paragraph 3.4.3. Additionally, the bank has a clear preference to finance small-scale and community-based forestry operations, offering favourable financing conditions.
3.4.5 Results
p. 48 Mind the Gap
Scores on Forestry policies
Mind the Gap p. 49 3.5 Military industry and arms trade
3.5.1 What is at stake?
p. 50 Mind the Gap
• • • •
3.5.2 Best standards available
International Humanitarian Law (IHL) • •
Mind the Gap p. 51 • • • • • Arms Trade Treaty Arms Trade Treaty Control Arms Campaign Global Principles for Arms Transfers
p. 52 Mind the Gap
3.5.3 Content of a bank policy
Mind the Gap p. 53 3.5.4 Scoring table
0. The bank has no policy on this sector; 1. The bank’s policy on this sector is vaguely worded or aspirational, with no clear commitments; 2. The bank’s policy on this sector excludes financial services to producers of specific, clearly defined types of weapon systems or to the most controversial forms of arms trade or to companies deriving more than 50% of their turnover from weapons; 3. The bank’s policy on this sector limits financial services to clients which were found to be fully compliant to the letter and spirit of all international arms control treaties (including the cluster munitions and arms trade treaties which are under development); 4. The bank’s policy on this sector excludes providing any financial services to clients in the military industry.
3.5.5 Results
p. 54 Mind the Gap
Scores for on Military industry and Arms trade policies
Mind the Gap p. 55 3.6 Mining
3.6.1 What is at stake?
resource curse International Labour Organization (ILO),
p. 56 Mind the Gap
• • • • • • • • •
3.6.2 Best standards available
Emergency response and prevention Waste management
Mind the Gap p. 57 • • • • • Closure of production facilities Financial transparency • • Host Government Agreements Intergovernmental Agreements •
p. 58 Mind the Gap
International Finance Corporation (IFC) European Bank for Reconstruction and Development (EBRD) • • Artisanal and small-scale mining
Protected areas Nature of contracts Sovereignty over resources Permanent Sovereignty over Natural Resources Mind the Gap p. 59 Good governance Rights of indigenous peoples Free, Prior and Informed Consent
Human rights Industry specific standards • • • • p. 60 Mind the Gap
3.6.3 Content of a bank policy
• • • • • • • • •
3.6.4 Scoring table
0. The bank has no policy on this sector; 1. The bank’s policy is vaguely worded or aspirational, with no clear commitments; 2. The bank’s policy sets as precondition for its financial services the best international standards for at least three of the elements listed in paragraph 3.6.3; 3. The bank’s policy sets as precondition for its financial services at least five of the elements listed in paragraph 3.6.3; 4. The bank’s policy is fully in line with all international standards and guidelines for all elements listed in paragraph 3.6.3.
Mind the Gap p. 61 3.6.5 Results
Scores on Mining policies
p. 62 Mind the Gap
3.7 Oil and Gas
3.7.1 What is at stake?
resource curse
Mind the Gap p. 63 3.7.2 Best standards available
Emergency response and prevention Exxon Valdez Waste management • Convention for the Protection of the Marine Environment of the North-East Atlantic • venting flaring Closure of production facilities Transparency •
p. 64 Mind the Gap
• Host Government Agreements Intergovernmental Agreements • International Finance Corporation (IFC) European Bank for Reconstruction and Development (EBRD) • • Marine animals Protected areas Unconventional oil reserves Mind the Gap p. 65 Nature of contracts Sovereignty over resources Permanent Sovereignty over Natural Resources Good governance Rights of indigenous peoples Human rights
p. 66 Mind the Gap
3.7.3 Content of a bank policy
• • • • • • • • •
3.7.4 Scoring table
0. The bank has no policy on this sector; 1. The bank’s policy is vaguely worded or aspirational, with no clear commitments; 2. The bank’s policy sets as precondition for its financial services the best international standards for at least three of the elements listed in paragraph 3.7.2 3. The bank’s policy sets as precondition for its financial services the best international standards for at least five of the elements listed in paragraph 3.7.2 4. The bank’s policy is fully in line with all international standards and guidelines for all elements listed in paragraph 3.7.2 Mind the Gap p. 67
3.7.5 Results
Scores for Oil and Gas policies
p. 68 Mind the Gap
4. Issue policies
4.1 Biodiversity
4.1.1 What is at stake?
4.1.2 Best standards available
Mind the Gap p. 69 Ecosystem and habitat protection Convention on Biological Diversity Protected Area Management Categories Species protection Convention on Biological Diversity p. 70 Mind the Gap
UN Convention on the Law of the Sea Convention on Biological Diversity Genetic materials protection Convention on Biological Diversity
4.1.3 Content of a bank policy
Mind the Gap p. 71 General • • Ecosystem and habitat protection • • • Species protection • • • • Genetic materials protection • •
4.1.4 Scoring table
0. The bank has no policy on this issue; 1. The bank’s policy makes a general commitment to the protection of biodiversity in its financing activities, but does not commit to clear steps; 2. The bank’s policy makes a clear commitment - in line with the recommendations above - to one of the main elements of biodiversity protection (ecosystem and habitat protection; species protection and genetic materials protection);
p. 72 Mind the Gap
3. The bank’s policy makes a clear commitment - in line with the recommendations above - to at least two of the three main elements of biodiversity protection (ecosystem and habitat protection; species protection and genetic materials protection); 4. The bank’s policy is fully in line with the recommendations above for the three main elements of biodiversity protection (ecosystem and habitat protection; species protection and genetic materials protection).
4.1.5 Results
Scores on Biodiversity policies
Mind the Gap p. 73
4.2 Climate change
4.2.1 What is at stake?
• • • Stern Review • •
p. 74 Mind the Gap
• • • •
4.2.2 Best standards available
Mind the Gap p. 75
Assessing and reporting on climate emissions
Reducing climate emissions Shifting towards climate-friendly technology
4.2.3 Content of a bank policy
p. 76 Mind the Gap
Assessing and reporting the bank’s climate impact operational emissions financed emissions GHG Protocol Setting measurable reduction targets Shifting financing from fossil fuels to renewable energy
Mind the Gap p. 77 Financing the transition to a carbon-extensive economy p. 78 Mind the Gap
Exclude ‘false solutions’ Carbon offsets carbon sequestration
4.2.4 Scoring table
0. The bank has no policy on this issue or has a policy that deals only with operational emissions; 1. The bank’s policy acknowledges the bank has a responsibility for its financed emissions, but does not commit to clear steps; 2. The bank’s policy aims to measure and reduce the bank’s financed emissions OR takes concrete steps to shift its financing to renewable energy and a carbon- extensive economy (excluding unacceptable alternatives); 3. The bank’s policy aims to measure and reduce the bank’s financed emissions AND takes concrete steps to shift its financing to renewable energy and a carbon- extensive economy (excluding unacceptable alternatives);
Mind the Gap p. 79 4. The bank’s policy sets ambitious (about 90%) portfolio-level reduction targets and is actively shifting its portfolio towards renewable energy and a carbon-extensive economy (excluding unacceptable alternatives).
4.2.5 Results
operational emissions financed emissions Scores on Climate Change policies
p. 80 Mind the Gap
4.3 Human Rights
4.3.1 What is at stake?
4.3.2 Best standards available
UN Human Rights Norms for Business Mind the Gap p. 81 UN Human Rights Norms for Business UN Human Rights Norms for Business • • • • • • • • • • UN Human Rights Norms for Business UN Sub-commission on the Promotion and Protection of Human Rights UN Human Rights Commission Special Representative of the UN Secretary General on business and human rights UN Human Rights Council UN Human Rights Norms for Business
p. 82 Mind the Gap
4.3.3 Content of a bank policy
• Direct complicity • Indirect complicity • silent complicity • • • UN Human Rights Norms for Business UN Human Rights Norms for Business UN Human Rights Norms for Business UN Human Rights Norms for Business
Mind the Gap p. 83 UN Human Rights Norms for Business UN Human Rights Norms for Business
4.3.4 Scoring table
0. The bank has no policy on this issue; 1. The bank’s policy is vaguely worded or aspirational, for instance by endorsing the Global Compact or the Universal Declaration of Human Rights, with no clear commitments; 2. The bank’s policy defines a clear bottom-line on human rights-related activities and practices which will not be financed OR requires a meaningful Human Rights Impact Assessment for relevant transactions, sectors and countries; 3. The bank’s policy defines a clear bottom-line on human rights-related activities and practices which will not be financed AND requires a meaningful Human Rights Impact Assessment for relevant transactions, sectors and countries; 4. The bank’s policy is fully in line with the UN Human Rights Norms for Business.
4.3.5 Results
p. 84 Mind the Gap
UN Human Rights Norms for Business OECD Guidelines for Multinational Enterprises ILO fundamental principles and rights at work Scores on Human Rights policies
Mind the Gap p. 85 4.4 Indigenous Peoples
4.4.1 What is at stake?
4.4.2 Best standards available
Right to self-identification and self-determination p. 86 Mind the Gap
Recognition and protection of, and compensation for land and territorial rights • • • • Right to participation Right to Free, Prior Informed Consent (FPIC) Free, Prior Informed Consent (FPIC) Mind the Gap p. 87 Prohibition of involuntary resettlement , No-Go zones for uncontacted people
4.4.3 Content of a bank policy
• Direct complicity • Indirect complicity • Silent complicity FPIC
p. 88 Mind the Gap
4.4.4 Scoring table
0. The bank has no policy on this issue; 1. The bank’s policy endorses the UN Declaration on the Rights of Indigenous Peoples or a similar statement but is not precise on what this means in practice; 2. The bank’s policy defines a bottom-line on human rights-related activities and practices which will not be financed OR requires an impact assessment with respect to the rights of indigenous peoples for relevant transactions, sectors and countries; 3. The bank’s policy defines a bottom-line on human rights-related activities and practices which will not be financed AND requires an impact assessment with respect to the rights of indigenous peoples for relevant transactions, sectors and countries; 4. The bank’s policy is fully in line with the UN Declaration on the Rights of Indigenous Peoples and requires an impact assessment with respect to its elements for all relevant transactions. The policy puts a ban on the bank’s direct, indirect and silent complicity with the violation of the rights of indigenous peoples.
4.4.5 Results
Mind the Gap p. 89 Scores on Indigenous Peoples policies
p. 90 Mind the Gap
4.5 Labour
4.5.1 What is at stake?
4.5.2 Best standards available
International Labour Organization (ILO) Conventions Recommendations Mind the Gap p. 91 • • • • Tripartite Declaration • • • • • • • • Tripartite Declaration • • • Tripartite Declaration
p. 92 Mind the Gap
• Tripartite Declaration •
4.5.3 Content of a bank policy
Tripartite Declaration employer , Tripartite Declaration bank’s clients Tripartite Declaration supply chain issues Tripartite Declaration
Mind the Gap p. 93 4.5.4 Scoring table
0. The bank has no policy on this issue; 1. The bank’s policy stimulates its clients to adhere to the four ILO fundamental principles and rights at work and/or the Tripartite Declaration, but does not make clear how this affects the bank’s financial services; 2. The bank’s policy defines a bottom-line on labour-related activities and practices which will not be financed OR requires an assessment of the client’s adherence to the four ILO fundamental principles and rights at work and/or the Tripartite Declaration for relevant transactions, sectors and countries; 3. The bank’s policy defines a bottom-line on labour-related activities and practices which will not be financed AND requires an assessment of the client’s adherence to the four ILO fundamental principles and rights at work and/or the Tripartite Declaration for relevant transactions, sectors and countries; 4. The bank’s policy ensures respect for local, national and international law and adherence to the four ILO fundamental principles and rights at work and the Tripartite Declaration in all its spheres of influence.
4.5.5 Results
p. 94 Mind the Gap
Scores on Labour policies
Mind the Gap p. 95 4.6 Taxation
4.6.1 What is at stake?
shell mailbox
4.6.2 Best standards available
p. 96 Mind the Gap
Government tax measures Tax planning DRAFT Code of Conduct for Taxation DRAFT Code of Conduct for Taxation • • • Mind the Gap p. 97 Transparency and country-by-country tax reporting • • • • • •
p. 98 Mind the Gap
4.6.3 Content of a bank policy
Special Purpose Entities trust banking offshore banking services offshore • • • •
4.6.4 Scoring table
0. The bank has no policy on tax compliance; 1. The bank’s tax policy is vaguely worded or aspirational, with no clear commitments other than that the bank ensures legal compliance (no tax evasion); 2. The bank ensures its financial services are compliant with the letter and the spirit of tax laws (no tax avoidance);
Mind the Gap p. 99 3. The bank ensures its financial services are compliant with the letter and the spirit of tax laws. The bank also refrains from products or transactions which main or only goal is to secure tax advantages OR from the use of tax havens. 4. The bank ensures its financial services are compliant with the letter and the spirit of tax laws. The bank also refrains from products or transactions which main or only goal is to secure tax advantages AND from the use of tax havens.
4.6.5 Results
Scores on Taxation policies
p. 100 Mind the Gap
4.7 Toxics
4.7.1 What is at stake?
• Endocrine Disrupting Chemicals (EDCs) • Very Persistent and Very Bioaccumulative chemicals (VPVBs)
Mind the Gap p. 101 4.7.2 Best standards available
Regulation of production and consumption of dangerous toxics • • • • Impact assessment of new and existing toxics • United Nations Conference for Environment and Development (UNCED) World Summit for Sustainable Development
p. 102 Mind the Gap
• • Management of chemical by-products and waste • World Summit on Sustainable Development • • • Specific sector standards • • Mind the Gap p. 103 •
4.7.3 Content of a bank policy
4.7.4 Scoring table
0. The bank has no policy on this issue; 1. The bank’s policy is vaguely worded or aspirational, with no clear commitments; 2. The bank’s policy on toxics contains several standards included in either REACH or SAICM; 3. The bank’s policy requires all clients in sectors producing and consuming toxics to comply fully to REACH or to SAICM; 4. The bank’s policy requires all clients in sectors producing and consuming toxics to comply to the precautionary principle, which means that toxics can only be used in production processed when their safety is proven scientifically.
p. 104 Mind the Gap
4.7.5 Results
Scores on Toxics policies
Mind the Gap p. 105 5. Transparency and accountability
5.1 Why transparency and accountability are important
trust me show me
p. 106 Mind the Gap
5.2 Application to the banking sector
• • • •
Mind the Gap p. 107 5.3 Institutional transparency
5.3.1 Best practices
GRI Reporting Framework Sustainability Reporting Guidelines Protocols Sector Supplements , GRI Sustainability Reporting Guidelines Financial Services Sector Supplements
5.3.2 Scoring table
p. 108 Mind the Gap
0. The bank does not publish an annual sustainability report or does not include sustainability information in its annual report; 1. The bank publishes an annual sustainability report, which does not meet GRI Sustainability Reporting Guidelines in terms of reviewing its performance on social and environmental issues; 2. The bank publishes an externally verified annual sustainability report, which meets the basic requirements of the GRI Sustainability Reporting Guidelines and its Financial Services Sector Supplements; 3. The bank publishes an externally verified annual sustainability report, which meets the basic requirements of the GRI Sustainability Reporting Guidelines and its Financial Services Sector Supplements. Additionally, the bank publishes in their entirety all of its sector and issue financing policies; 4. The bank publishes an externally verified annual sustainability report, which meets the basic requirements of the GRI Sustainability Reporting Guidelines and its Financial Services Sector Supplements. Additionally, the bank publishes in their entirety all of its sector and issue financing policies and reports on cases of non- compliance with its policies.
5.3.3 Results
Mind the Gap p. 109 Scores on Institutional Transparency
5.4 Deal transparency
5.4.1 Best practices
World Bank Asian Development Bank p. 110 Mind the Gap
Summaries of Project Information (SPIs) Environmental Assessments (EAs) Environmental Action Plans (EAPs) Environmental Review Summaries (ERSs)
5.4.2 Score Table
0. The bank is not transparent about deals at all; 1. The bank provides sectoral and regional breakdowns of the deals it was involved in (in the reporting period), by financial product or service; 2. The bank provides sectoral and regional breakdowns of the deals it was involved in and a list with the basic details of the deals it was involved in (in the reporting period); 3. The bank provides sectoral and regional breakdowns of the deals it was involved in and a list with the basic details of the deals it was involved in (in the reporting period). It also requires clients (in some or all cases) to disclose environmental and social assessment reports, reviews and management plans to affected people;
Mind the Gap p. 111 4. The bank provides sectoral and regional breakdowns of the deals it was involved in and a list with the basic details of the deals it was involved in (in the reporting period). It also requires clients (in some or all cases) to disclose environmental and social assessment reports, reviews and management plans to affected people. The bank also discloses information on pending deals and on deals rejected because they do not meet the criteria in the bank’s issue and sector policies.
5.4.3 Results
Scores on Deal Transparency
5.5 Institutional accountability
5.5.1 Best practices
p. 112 Mind the Gap
internal Environmental and Social Risk Management System external Environmental and Social Risk Management System. Environmental and Social Risk Management System AA1000 Series 1999 Framework Assurance Standard Stakeholder Engagement Standards
5.5.2 Score table
0. The bank has no institutional accountability mechanism at all; 1. The bank conducts internal audits of its sector and issue financing policies; 2. The bank hires external auditors to audit its sector and issue financing policies; 3. The bank publicly publishes the results of the audits of its sector and issue financing policies; 4. The bank publicly publishes the results of the audits of its sector and issue financing policies and conducts stakeholder engagement processes on its sector and issue policies that comply with the AA1000 Series of Standards or similar standards.
Mind the Gap p. 113 5.5.3 Results
Scores on Institutional Accountability
5.6 Deal accountability
5.6.1 Best practices
p. 114 Mind the Gap
Bank Policy Complaint Mechanism Bank Policy Complaint Mechanism Bank Policy Complaint Mechanism Bank Policy Complaint Mechanism Bank Policy Complaint Mechanism Equator Principles
5.6.2 Score table
0. The bank has no Bank Policy Complaint Mechanism at all; 1. The bank has an informal Bank Policy Complaint Mechanism in place which is not independent or has no authority within the bank; 2. The bank has set up an independent Bank Policy Complaint Mechanism for a specific field of financing activity (e.g. project finance); 3. The bank has set up an independent Bank Policy Complaint Mechanism for all deals in which the bank is involved; 4. The bank has set up an independent Bank Policy Complaint Mechanism for all deals in which the bank is involved and reports publicly on the complaints filed, the responses and the steps taken to address problems.
5.6.3 Results
Mind the Gap p. 115 Scores on Deal Accountability
p. 116 Mind the Gap
6. Dodgy deals
6.1 Introduction
Additional and regularly updated information on all deals can be found on the ‘Dodgy Deals’ section of the BankTrack website .
6.2 Aracruz
Bank involvement: •
Mind the Gap p. 117 •
6.3 Asia Pulp & Paper
Bank involvement: • • •
6.4 Baku-Tbilisi-Ceyhan pipeline
p. 118 Mind the Gap
Bank involvement: • 253
6.5 Belene
• • • • • Bank involvement: •
6.6 Botnia
Mind the Gap p. 119 Bank involvement: •
6.7 Camisea natural gas project
Bank involvement: • • •
6.8 China Datang
p. 120 Mind the Gap
Bank involvement: • •
6.9 Cluster munitions producers
submunitions Bank involvement: • • • •
Mind the Gap p. 121 • • •
6.10 CNPC in Sudan
Bank involvement: • • • •
p. 122 Mind the Gap
6.11 Dynegy
Bank involvement; • • • • •
6.12 Freeport McMoran
Mind the Gap p. 123 Bank involvement: • • •
6.13 Gunns
Bank involvement: • p. 124 Mind the Gap
6.14 Ilisu dam
Bank involvement: •
6.15 Kashagan
Mind the Gap p. 125 Bank involvement: • •
6.16 Kayelekera
Bank involvement: • • •
6.17 Lafayette Mining
p. 126 Mind the Gap
Bank involvement • • •
6.18 Mountain top removal mining
Bank involvement: • • Mind the Gap p. 127 • • • • • • • • • • • •
6.19 Mud volcano in Sidoarjo
p. 128 Mind the Gap
Bank involvement: • • • • • • • • • •
6.20 Nam Theun 2
Mind the Gap p. 129 Bank involvement: •
6.21 National Hydroelectric Power Corporation- NHPC
p. 130 Mind the Gap
Bank involvement: • •
6.22 Rio Madeira dams
Bank involvement: • • • •
6.23 Rosia Montana
Mind the Gap p. 131 Bank involvement: • •
6.24 Sakhalin 2
p. 132 Mind the Gap
Bank involvement: • •
6.25 Samling
Bank involvement • •
6.26 Sinopec in Burma
Mind the Gap p. 133 Bank involvement • •
6.27 Turkmen Central Bank accounts
Bank involvement •
6.28 Uranium weapon producers
p. 134 Mind the Gap
Bank involvement • • • • • ` • •
6.29 Vedanta Resources
Mind the Gap p. 135 Bank involvement: • • • • • • • • •
6.30 Wal-Mart Stores
p. 136 Mind the Gap
Bank involvement: • • • • • • • •
6.31 Wilmar International
Mind the Gap p. 137 Bank involvement: • • • • •
p. 138 Mind the Gap
7. Bank Profiles
7.1 Introduction
Dodgy Deals
7.1.1 Collective Standards
Mind the Gap p. 139 Scoring of collective standards
Sector policies Equator UN Global Carbon UNEP FI UN PRI EITI Principles Compact Disclosure
Issue policies
Equator Principles p. 140 Mind the Gap
UNEP Finance Initiative UN Principles for Responsible Investment UN Global Compact Extractive Industries Transparency Initiative (EITI) Carbon Disclosure Project
Mind the Gap p. 141
7.2 ABN AMRO
ABN AMRO: scoring of policies and transparency & accountability
Sector policies Score Comments
Issue policies Score Comments
Transparency and Accountability Score Comments
Comments: • Annual Report 2006 Environmental, Social and Ethical (ESE) Risk Management policies
p. 142 Mind the Gap
• • • • • •
Collective standards • • • • • • •
Dodgy deals (for details see chapter 6) • • • • • • • • Mind the Gap p. 143 Comment provided by ABN AMRO:
p. 144 Mind the Gap
7.3 ANZ
ANZ: scoring of policies and transparency & accountability
Sector policies Score Comments
Issue policies Score Comments
Transparency and Accountability Score Comments
Comments: • • Forests and Biodiversity policy
Mind the Gap p. 145 • • ANZ and Human Rights Collective standards: • • • Dodgy deals (for details see chapter 6) • • • • • • • • Comment provided by ANZ:
p. 146 Mind the Gap
7.4 Banco Bradesco
Banco Bradesco: scoring of policies and transparency & accountability
Sector policies Score Comments
Issue policies Score Comments
Transparency and Accountability Score Comments
Collective standards: • • •
Dodgy deals (for details see chapter 6) •
Mind the Gap p. 147 Comment provided by Banco Bradesco
p. 148 Mind the Gap
7.5 Banco do Brasil
Banco do Brasil: scoring of policies and transparency & accountability
Sector policies Score Comments
Issue policies Score Comments
Transparency and Accountability Score Comments
Comments: • Annual Report General Policies Letter of SER Principles
Mind the Gap p. 149 • Protocolo Verde Agenda 21 • • Combat Slave Labour Initiative
Collective standards • • • Dodgy deals (for details see chapter 6) •
p. 150 Mind the Gap
7.6 Banco Itaú
Banco Itaú: scoring of policies and transparency & accountability
Sector policies Score Comments
Issue policies Score Comments
Transparency and Accountability Score Comments
Comments: • Social-Environmental Credit Policy • Corporate Policy for the Prevention and Fight Against Illegal Activities
Mind the Gap p. 151 • Exclusion List
Collective standards • • • • Dodgy deals (for details see chapter 6) • • Comment provided by Banco Itaú:
p. 152 Mind the Gap
7.7 Bank Mandiri
Bank Mandiri: scoring of policies and transparency & accountability
Sector policies Score Comments
Issue policies Score Comments
Transparency and Accountability Score Comments
Collective standards •
Dodgy deals (for details see chapter 6) • •
Mind the Gap p. 153
7.8 Bank of America
Bank of America: scoring of policies and transparency & accountability
Sector policies Score Comments
Issue policies Score Comments
Transparency and Accountability Score Comments
Comments: • Climate Change position paper • Environmental matters Developing countries lending criteria
p. 154 Mind the Gap
Collective standards • • •
Dodgy deals (for details see chapter 6) • • • • • • •
Mind the Gap p. 155 7.9 Bank of China
Bank of China: scoring of policies and transparency & accountability
Sector policies Score Comments
Issue policies Score Comments
Transparency and Accountability Score Comments
Collective standards • Dodgy deals (for details see chapter 6) • • • •
p. 156 Mind the Gap
7.10 Barclays
Barclays: scoring of policies and transparency & accountability
Sector policies Score Comments
Issue policies Score Comments
Transparency and Accountability Score Comments
Mind the Gap p. 157 Comments: • Internal Guidance for lending managers • Environmental and Social Impact Assessment Policy • Environmental and Social Risk Assessment in Lending • • • • • • • • • • • • Annual Report Corporate Social Responsibility Report
p. 158 Mind the Gap
Collective standards: • • • • Dodgy deals (for details see chapter 6) • • • • •
Mind the Gap p. 159
7.11 BBVA
BBVA: scoring of policies and transparency & accountability
Sector policies Score Comments
Issue policies Score Comments
Transparency and Accountability Score Comments
Comments: • Code of Conduct • •
p. 160 Mind the Gap
Collective standards • • • • Dodgy deals (for details see chapter 6) • • •
Comment provided by BBVA:
Mind the Gap p. 161
7.12 BNP Paribas
BNP Paribas: scoring of policies and transparency & accountability
Sector policies Score Comments
Issue policies Score Comments
Transparency and Accountability Score Comments
Comments: • Environmental and Social Report 2006
p. 162 Mind the Gap
Collective standards • • • •
Dodgy deals (for details see chapter 6) • • • • • • • • •
Mind the Gap p. 163
7.13 China Construction Bank
China Construction Bank: scoring of policies and transparency & accountability
Sector policies Score Comments
Issue policies Score Comments
Transparency and Accountability Score Comments
Collective standards • Dodgy deals (for details see chapter 6) • • •
p. 164 Mind the Gap
7.14 Citi
Citi: scoring of policies and transparency & accountability
Sector policies Score Comments
Issue policies Score Comments
Transparency and Accountability Score Comments
Comments: • Environmental and Social Risk Management (ESRM) Policy
Mind the Gap p. 165 • ´ Statement on Climate Change • Tax Standard for Tax Sensitive Financial Products and Strategies •
Collective standards • • • •
Dodgy deals (for details see chapter 6) • • • • • • • • • • •
p. 166 Mind the Gap
7.15 Crédit Agricole / Calyon
Crédit Agricole: scoring of policies and transparency & accountability
Sector policies Score Comments
Issue policies Score Comments
Transparency and Accountability Score Comments
Comments •
Collective standards • • • • •
Mind the Gap p. 167 Dodgy deals (for details see chapter 6) • • • • • • • • • •
p. 168 Mind the Gap
7.16 Credit Suisse
Credit Suisse: scoring of policies and transparency & accountability
Sector policies Score Comments
Issue policies Score Comments
Transparency and Accountability Score Comments
Comments: • ´ Climate Change Statement
Collective standards • • • • •
Mind the Gap p. 169 Dodgy deals (for details see chapter 6) • • • • • • • • Comment provided by Credit Suisse:
p. 170 Mind the Gap
7.17 Deutsche Bank
Deutsche Bank: scoring of policies and transparency & accountability
Sector policies Score Comments
Issue policies Score Comments
Transparency and Accountability Score Comments
Comments: • Sustainability Flyer 2006 Sustainability Report
•
Mind the Gap p. 171 Collective standards • • • •
Dodgy deals (for details see chapter 6) • • • • • • • • • • Comment provided by Deutsche Bank:
p. 172 Mind the Gap
7.18 Dexia
Dexia: scoring of policies and transparency & accountability
Sector policies Score Comments
Issue policies Score Comments
Transparency and Accountability Score Comments
Comments: • Dexia position towards armaments industry
Mind the Gap p. 173
• Sustainability Report • • Human Rights Policy • Policy on Labour Rights Principles of Social Development •
Collective standards: • • • • • • Dodgy deals (for details see chapter 6) • •
p. 174 Mind the Gap
7.19 Fortis
Fortis: scoring of policies and transparency & accountability
Sector policies Score Comments
Issue policies Score Comments
Transparency and Accountability Score Comments
Comments: • Agri Core Values Supplement on Palm Oil Agri Core Values • Fortis Policy on the Defence Industry
Mind the Gap p. 175 • Fortis Policy on the Defense Industry • Carbon Neutrality Programme Collective standards: • • • • •
Dodgy deals (for details see chapter 6) • • • • • •
p. 176 Mind the Gap
7.20 Goldman Sachs
Goldman Sachs: scoring of policies and transparency & accountability
Sector policies Score Comments
Issue policies Score Comments
Transparency and Accountability Score Comments
Comments: • Goldman Sachs’ Environmental Policy Framework Environmental Policy Framework •
Mind the Gap p. 177 Collective standards • •
Dodgy deals (for details see chapter 6) • • • • • •
p. 178 Mind the Gap
7.21 HSBC
HSBC: scoring of policies and transparency & accountability
Sector policies Score Comments
Issue policies Score Comments
Transparency and Accountability Score Comments
Comments •
Mind the Gap p. 179 Collective standards: • • • • • • •
Dodgy deals (for details see chapter 6) • • • • • • Comment provided by HSBC:
p. 180 Mind the Gap
7.22 Industrial and Commercial Bank of China
ICBC: scoring of policies and transparency & accountability
Sector policies Score Comments
Issue policies Score Comments
Transparency and Accountability Score Comments
Comments: • Collective standards •
Dodgy deals (for details see chapter 6) • • • •
Mind the Gap p. 181
7.23 ING
ING: scoring of policies and transparency & accountability
Sector policies Score Comments
Issue policies Score Comments
Transparency and Accountability Score Comments
p. 182 Mind the Gap
Comments: • Annual Corporate Social Responsibility Report General Environmental and Social Risk Policy
• Manufacturing & Agriculture Policy • Forestry & Plantations Policy • Defence Policy • • Natural Resources & Chemical Sector Policy • Environmental Statement • Human Rights Statement • Corporate Responsibility policies •
Mind the Gap p. 183 Collective standards • • • • • •
Dodgy deals (for details see chapter 6) • • • • • • • • •
p. 184 Mind the Gap
7.24 Intesa Sanpaolo
Intesa Sanpaolo: scoring of policies and transparency & accountability
Sector policies Score Comments
Issue policies Score Comments
Transparency and Accountability Score Comments
Comments: •
Mind the Gap p. 185 • Environmental Management System •
Collective standards • • • •
Dodgy deals (for details see chapter 6) • • •
p. 186 Mind the Gap
7.25 JPMorgan Chase
JPMorgan Chase: scoring of policies and transparency & accountability
Sector policies Score Comments
Issue policies Score Comments
Transparency and Accountability Score Comments
Comments: • Environmental Risk Management Policy
Mind the Gap p. 187 Collective standards • • • • • Dodgy deals (for details see chapter 6) • • • • • • • •
p. 188 Mind the Gap
7.26 KBC
KBC: scoring of policies and transparency & accountability
Sector policies Score Comments
Issue policies Score Comments
Transparency and Accountability Score Comments
Comments: • FSC covenant • Statement on Controversial Weapons
Mind the Gap p. 189 • Statement on Human Rights • Responsible Tax Strategy Collective standards • • • Dodgy deals (for details see chapter 6) • • Comment provided by KBC:
p. 190 Mind the Gap
7.27 Merrill Lynch
Merrill Lynch: scoring of policies and transparency & accountability
Sector policies Score Comments
Issue policies Score Comments
Transparency and Accountability Score Comments
Comments: • • Environmental Sustainability Framework
Mind the Gap p. 191 • Environmental Sustainability Framework ´ ´ • Human and Labour Rights Responsible Citizenship Core Principles Responsible Citizenship • • Public Policy & Responsibility Committee Collective standards • •
Dodgy deals (for details see chapter 6) • • • • • • • •
p. 192 Mind the Gap
7.28 Mitsubishi UFJ
Mitsubishi UFJ: scoring of policies and transparency & accountability
Sector policies Score Comments
Issue policies Score Comments
Transparency and Accountability Score Comments
Comments: • • Environmental Statement and Policy
Mind the Gap p. 193 Collective standards • • • • Dodgy deals (for details see chapter 6) • • • • • • • •
p. 194 Mind the Gap
7.29 Mizuho
Mizuho: scoring of policies and transparency & accountability
Sector policies Score Comments
Issue policies Score Comments
Transparency and Accountability Score Comments
Comments: • •
Mind the Gap p. 195 • Human Rights policy • CSR Report 2006 Collective standards • • • • •
Dodgy deals (for details see chapter 6) • • • • • • • • • •
p. 196 Mind the Gap
7.30 Morgan Stanley
Morgan Stanley: scoring of policies and transparency & accountability
Sector policies Score Comments
Issue policies Score Comments
Transparency and Accountability Score Comments
Comments: • “Commitment on the environment”
Collective standards •
Mind the Gap p. 197 Dodgy deals (for details see chapter 6) • • • • • • • •
p. 198 Mind the Gap
7.31 Nedbank
Nedbank: scoring of policies and transparency & accountability
Sector policies Score Comments
Issue policies Score Comments
Transparency and Accountability Score Comments
Comments: • Nedbank Environmental Policy
Mind the Gap p. 199 Collective standards • • • • Comment provided by Nedbank:
p. 200 Mind the Gap
7.32 Rabobank
Rabobank: scoring of policies and transparency & accountability
Sector policies Score Comments
´
Issue policies Score Comments
Transparency and Accountability Score Comments
Mind the Gap p. 201 Comments: • Basic CSR policies in the credit process • Climate Policy Policy on Soy • Wood Supply Chain Policy • CSR issue list Chemical Industry • Statement on the Weapon’s Industry •
Collective standards • • • • • • Dodgy deals (for details see chapter 6) •
p. 202 Mind the Gap
7.33 Royal Bank of Canada
Royal Bank of Canada: scoring of policies and transparency & accountability
Sector policies Score Comments
Issue policies Score Comments
Transparency and Accountability Score Comments
Mind the Gap p. 203 Comments: • • Position on Forestry, Biodiversity and Indigenous Peoples • Environmental Blueprint Position on Climate Change • • Human Rights Policy • Labour Rights Policy Collective standards • • •
Dodgy deals (for details see chapter 6) • • •
p. 204 Mind the Gap
RBS: scoring of policies and transparency & accountability
Sector policies Score Comments
Issue policies Score Comments
Transparency and Accountability Score Comments
Comments: • Environmental Policy Collective standards • • • •
Mind the Gap p. 205 Dodgy deals (for details see chapter 6) • • • • • • • •
p. 206 Mind the Gap
7.35 Santander
Santander: scoring of policies and transparency & accountability
Sector policies Score Comments
Issue policies Score Comments
Transparency and Accountability Score Comments
Comments •
Mind the Gap p. 207 Collective standards • • • •
Dodgy deals (for details see chapter 6) • • •
p. 208 Mind the Gap
7.36 Saudi-American Bank
Saudi-American Bank : scoring of policies and transparency & accountability
Sector policies Score Comments
Issue policies Score Comments
Transparency and Accountability Score Comments
Collective standards •
Mind the Gap p. 209
7.37 Scotiabank
Scotiabank: scoring of policies and transparency & accountability
Sector policies Score Comments
Issue policies Score Comments
Transparency and Accountability Score Comments
Comments: • Mining Review Sustainability Report 2006
p. 210 Mind the Gap
• Environmental policy Environmental policy • Guidelines for business conduct
Collective standards • • •
Dodgy deals (for details see chapter 6) • • • •
Mind the Gap p. 211
7.38 Société Générale
Société Générale: scoring of policies and transparency & accountability
Sector policies Score Comments
Issue policies Score Comments
Transparency and Accountability Score Comments
Comments: • Nathetic • CSR Report 2007
p. 212 Mind the Gap
• Environmental Policy • Human Rights Policies • • Collective standards • • • • • • Dodgy deals (for details see chapter 6) • • • • • • • • • • • Comment provided by Société Générale:
Mind the Gap p. 213
7.39 Standard Bank
Standard Bank: scoring of policies and transparency & accountability
Sector policies Score Comments
Issue policies Score Comments
Transparency and Accountability Score Comments
Collective standards • Dodgy Deals (for details see chapter 6) •
p. 214 Mind the Gap
7.40 Standard Chartered
Standard Chartered: scoring of policies and transparency & accountability
Sector policies Score Comments
Issue policies Score Comments
Transparency and Accountability Score Comments
Co mments: • • Statement on Defence Equipment and Armament
Mind the Gap p. 215 • Group Environmental and Social Risk Policy • Human Rights policy Statement on Oppressive Regimes • HIV/AIDS policy Health & Safety Guidelines • •
Collective standards • • • • •
Dodgy deals (for details see chapter 6) • • • • • • • •
p. 216 Mind the Gap
Comment provided by Standard chartered
Mind the Gap p. 217
7.41 State Bank of India
State Bank of India: scoring of policies and transparency & accountability
Sector policies Score Comments
Issue policies Score Comments
Transparency and Accountability Score Comments
Collective standards •
Dodgy deals (for details see chapter 6) • •
p. 218 Mind the Gap
7.42 Sumitomo Mitsui
Sumitomo Mitsui: scoring of policies and transparency & accountability
Sector policies Score Comments
Issue policies Score Comments
Transparency and Accountability Score Comments
Comments: • Environmental Policy
Mind the Gap p. 219 Collective standards • • •
Dodgy deals (for details see chapter 6) • • • • • •
p. 220 Mind the Gap
7.43 UBS
UBS: scoring of policies and transparency & accountability
Sector policies Score Comments
Issue policies Score Comments
Transparency and Accountability Score Comments
Comments: • Climate Change Strategy
Mind the Gap p. 221 • UBS Statement on Human Rights Collective standards • • • • • Dodgy deals (for details see chapter 6) • • • • • • •
p. 222 Mind the Gap
7.44 UniCredit / HVB
UniCredit: scoring of policies and transparency & accountability
Sector policies Score Comments
Issue policies Score Comments
Transparency and Accountability Score Comments
Comments: • • General Group Credit Policy • Weapons Policy Mining Policy
Mind the Gap p. 223 • Human Rights • Sustainability Report Collective standards • • • •
Dodgy deals (for details see chapter 6) • • • • Comment provided by UniCredit
p. 224 Mind the Gap
7.45 WestLB
WestLB: scoring of policies and transparency & accountability
Sector policies Score Comments
Issue policies Score Comments
Transparency and Accountability Score Comments
Comments: •
Mind the Gap p. 225 Collective standards • • • •
Dodgy deals (for details see chapter 6) • • • • • •
p. 226 Mind the Gap
7.46 Westpac
Westpac: scoring of policies and transparency & accountability
Sector policies Score Comments
Issue policies Score Comments
Transparency and Accountability Score Comments
Comments: • Environmental Lending Policy •
Mind the Gap p. 227 • Human Rights’ policy Business Principles Principles on Governance and Ethical Practice Business Principles • Business Principles • Business Principles • • Collective standards • • • • • p. 228 Mind the Gap
Comment provided by Westpac:
Mind the Gap p. 229 8. Conclusion
8.1 Content of policies
p. 230 Mind the Gap
Number of banks which have developed sector and issue policies
No. of No. of Sector policies Issue policies banks banks
8.2 Transparency & accountability
Mind the Gap p. 231
8.3 Summary scores
p. 232 Mind the Gap
Summary of highest score per sector and issue
Policies and issues Highest Bank that received highest score score
8.4 Implementation
Mind the Gap p. 233 Dodgy Deals Dodgy deals Dodgy Deals
8.5 Final remarks
Mind the Gap Dodgy Deal
p. 234 Mind the Gap
Annex 1 Comparison with previous benchmark study
Shaping the Future of Sustainable Finance Mind the Gap, Banks covered in present and previous benchmark studies Previous Present Previous Present Bank Bank report report report report
Mind the Gap p. 235 Banks covered in present and previous benchmark studies Previous Present Previous Present Bank Bank report report report report • • • • • • • • •
p. 236 Mind the Gap
Annex 2 References
Mind the Gap p. 237
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