Builds on the requirements for sound due diligence as explained in the Thun Group of Banks' 2013 Discussion Paper.
- Focuses on situations where banks may be directly linked to negative human rights impacts under UNGP 13b of the UNGPs (UN Guiding Principles on Business and Human Rights).
- a conceptual framework to help consider the meaning and reach of UNGP 13b for banks in a corporate and investment banking context; the paper focuses on direct linkage since in a corporate and investment banking context, a bank, is potentially directly linked to adverse human rights impacts under UNGP 13b, although, under UNGP 13a, the provision of certain financial products and services may under exceptional circumstances reach the level of contribution.
- further consideration of the due diligence envisaged by UNGP 17.
Determines that banks should, under the UNGPs:
- develop environmental and social (E&S) risk management policies and procedures to support identification, prevention and mitigation of impacts caused and/or contributed to by clients to which the bank provides financial products and services. These policies should include a due diligence as already explained in the 2013 Thun Group Discussion Paper.
Introduces the concepts of:
- Proximity to an impact (ranging from a low to high level of proximity), which may, based on operational criteria,
indicate the “degree of directness” of linkage between the impact and the product and service offered by the bank. Proximity thus describes a bank’s connection to an impact depending on the characteristics of the financial product and service provided. It is therefore an operational criterion and must not be confused with leverage. It is also not a description of a spatial or geographic relationship between a bank and potential or actual adverse impacts.
- Unit of analysis, as a means to inform the focus of a bank’s due diligence (for example, by reference to the client (company or subsidiary) to which the financial product and service is offered, or asset in the case of specific asset finance).