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Eurogroup for Animals Response to the Consultation on the European Investment Bank Group's Environmental and Social Sustainability Framework

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Eurogroup for Animals Response to the Consultation on the European Investment Bank Group's Environmental and Social Sustainability Framework Build Bank Better - Eurogroup for Animals response to the Consultation on the European Investment Bank Group's Environmental and Social Sustainability Framework 1. European Investment Bank Group as a standard setter We welcome the commitment of the European Investment Bank Group to develop their Environmental and Social Standards fit for the future and equip their staff and promoters in criteria to assess environmental, climate and social impacts and risks throughout EIB-financed projects to make economies more sustainable. Yet, we strongly believe that including animal welfare within the scope of the future EIB Group’s Environmental and Social Sustainability Framework is necessary to achieve this goal. As the biggest multilateral financial institution, the EIB is a standard setter and a guide for a number of financial institutions. As the EU’s bank, it is important for its activity and impact to reflect the current and future EU policies, as well as the global drive towards funding sustainable and forward looking projects and investments. This is of particular importance taking into account the European and worldwide scope of the EIB financial activities in question. The new EIB’s Group Environmental and Social Policy and Standards must comply not only with the Group's vision, but also with the up-to-date European Commission’s objectives and policies, which should be equally reflected in the European Investment Fund activities where the EIB and the European Commission are a majority shareholder. At the moment, the draft Policy and Standards are not ambitious enough and do not sufficiently cover the links between the sectors, taking more a mitigating and segmented than proactive and comprehensive approach. Furthermore, we strongly believe that the link between sustainability and animal welfare should be better recognised in this document, in particular in Chapters A, D-G, I, L, N (Standards 1-4, 6, 9 and 11). The reasons to include animal welfare as a dimension of the EIB’s new Environmental and Social Policy and Standards are two-fold: ● First, there is an increasing recognition of the inherent links between animal welfare, environment and sustainable development, as recognised by the EU’s Farm to Fork Strategy; ● Second, doing so would not be inconsistent with practices of other international institutions, such as the OECD, the International Finance Corporation (IFC) and the European Bank for Reconstruction and Development (EBRD). 1 2. The connection between animal welfare and sustainability Studies and reports12 confirmed the links between sustainability and animal welfare. Production systems with the potential to provide higher animal welfare conditions are more likely to have less negative impacts on the environment, the climate and livelihoods. The reason to move away from funding intensive farming projects, beyond the EU’s own commitments, is self-evident: ● Intensive farming, through highly industrialised animal production systems, has devastating effects on the welfare of the animals and the environment, as it leads to high levels of water, air and ground pollution and to deforestation due to the growing need for animal feed (Sustainable Development Goal (SDG) 6 - Clean Water and Sanitation, SDG 14 - Life below Water, SDG 15 - Life on Land). ● The livestock supply chain accounts for 14.5% of global greenhouse gas (GHG) emissions. According to the Intergovernmental Science-Policy Platform on Biodiversity and Ecosystem Services (IPBES), “approximately 25% of the globe’s GHG emissions come from land clearing, crop production and fertilization, with animal-based food contributing 75% of that. Intensive agriculture has increased food production at the cost of regulating and non-material contributions from nature”. In addition to potentially allowing for higher animal welfare standards, grass-based and mixed-farm systems, less dependent on additional feed, also have better capacities for carbon sequestration.3 ● Improving animal welfare benefits human health by helping to reduce the risk of food-borne diseases and zoonoses, as well as to lessen the use of antibiotics in animal productions (SDG 3 - Healthy Lives). In addition to being intrinsically detrimental to animal welfare, the intensification of animal agriculture has also fuelled these health-related issues: ○ The change in land-use – notably linked to the spread of animal agriculture and to the production of animal feed – and the subsequent loss of habitat have made encounters between animals (wild and farmed), humans and ecosystems closer and much more frequent. This pressure on biodiversity has been a major cause of the spread of zoonoses.4 In addition, farmed animals kept by the billions (trillions, if we consider fish in aquaculture) are reservoirs and pathways for diseases that can be dangerous or devastating to humans. 1 Linda Keeling et al. (2019) “Animal Welfare and the United Nations Sustainable Development Goals”. 2 Eurogroup for Animals, “Policy Brief: Animal Welfare, Trade And Sustainable Development Goals” (2019) & Eurogroup for Animals, “What could the European Union and China achieve for Animals” (2020). 3 Canu & Forabosco (UNEP DTU 2018), Greenhouse gas emissions of livestock raised in a harsh environment, International Journal of Global Warming, 2018 Vol.15 No.4, pp. 431-446. 4 IPBES, “Executive Summary of the IPBES Pandemics Workshop Report”(2020). 2 A study found that “since 1940, agricultural drivers were associated with >25% of all – and >50% of zoonotic — infectious diseases that emerged in humans, proportions that will likely increase as agriculture expands and intensifies”.5 ○ The overuse of antimicrobials in livestock production is the primary cause of the surge in antimicrobial resistance (AMR),6 which the World Health Organization (WHO) has described as “one of the biggest threats to global health, food security, and development today”. This phenomenon is not due to small-scale productions, but due to the spread of intensive farming systems, in which antimicrobial products are used routinely and increasingly. The EU’s One Health Action Plan against AMR already recognises the link between this issue and poor farm welfare practices, underlining the importance to address this concern.7 ● Industrialised systems typically employ fewer people than traditional ones, as many tasks become automated. Wages are low, and the seasonal nature of the work creates prolonged job insecurity. The sector also employs many migrant workers who are especially vulnerable due to their precarious legal status and who are particularly likely to experience poor working conditions, unfair wages and limited access to public services (SDG 8 - Decent Work and Economic Growth).8 ● Animal welfare tends to be connected to human rights, as animal cruelty is often linked to violence against humans. In certain countries, the agricultural industry has been connected to human rights violations against their workers. 3. EU legislation and international standards linking animal welfare with sustainability Because of the interconnections described in section 2, animal welfare has been recognised as an important element of sustainable production systems in several EU policy documents. This is the main reason why it should be reflected in the updated EIB Group Environment and Social Policy and Standards. ● In 2018, the Commission acknowledged for the first time the close connection between improved animal welfare and sustainability of food production systems, in proposals made by the Directorate-General for Trade in the context of trade negotiations with Australia and New Zealand.9 Such recognition has also been included in the trade 5 https://www.nature.com/articles/s41893-019-0293-3#Ack1 6 https://www.cddep.org/wp-content/uploads/2017/10/science.0929PolicyForum-1.pdf 7 https://ec.europa.eu/health/sites/health/files/antimicrobial_resistance/docs/amr_2017_action-plan.pdf 8 HLPE. 2016. Sustainable agricultural development for food security and nutrition: what roles for livestock? A report by the High-Level Panel of Experts on Food Security and Nutrition of the Committee on World Food Security, Rome. 9 Article X.17(1) of the FTA proposal to New Zealand quotes: “The Parties recognise that animals are sentient beings. They also recognize the connection between improved welfare of animals and sustainable food production systems”. 3 and cooperation agreement between the EU and the United Kingdom following Brexit.10 ● The EU’s Farm to Fork Strategy11 (2020) emphasized the need for a more environmentally friendly food system, which depends on resilient and sustainable agricultural supply chains. It stressed the “urgent need to improve animal welfare”, which it deemed essential to achieve a fair transition towards sustainable food systems; to help preserve biodiversity and reduce the need to use antibiotics on farms.12 ● The EU Code of Conduct for responsible businesses and marketing practices, launched in July 2021 and one of the first deliverables of the Farm to Fork strategy, recognises improved animal welfare as central in improving the sustainability of the food value chain. Improved animal welfare is one of the aspirational targets of the Code and is also featured as an indicative action both for stimulating sustainable production and for reducing the environmental footprint of food. 4. Animal welfare under international sustainable corporate governance standards Including animal welfare in the EIB’s new Environmental and Social Policy and Standards would not be a first in the
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