We will proactively and responsibly consult, engage and partner with relevant stakeholders to achieve society’s goals.
PLEASE NOTE: The Implementation Guidance is being updated following the completion of the Consultative Process, the below is the original draft version.
Implementation guidance for Principle 4: Stakeholders
Key words and intent: proactive; consult, engage and partner; increasing impact; scale of change
Banks are a crucial part of our economic and social system. However, on their own, they cannot deliver the scale of change necessary to meet the objectives of the SDGs, the Paris Climate Agreement and other relevant national, regional or international frameworks, nor can they address all relevant global and local issues. By partnering with relevant stakeholders (notably their peers, investors, suppliers, clients, regulators, employees, policy-makers, scientists, academia, civil society, trade unions and communities), banks are able to significantly increase the impact of their actions and support action at the scale of change that is required.
Proactively consulting stakeholders ensures your bank benefits from their knowledge and subject-matter expertise and enables correct/legitimate definition of society’s goals; it drives legitimacy and capacity to identify positive and negative impacts. Proactively engaging stakeholders early on ensures that all relevant interests are taken into account and a bank will not encounter challenges down the line.
+ How your bank can achieve this
- View your banks as part of a social system, in which it has to identify its key stakeholders and understand their roles, capabilities and needs, with the help of stakeholder mapping methodologies.
- Engage, listen and consult with these stakeholders to gather their views and advice on the material issues in your strategy and business practices and their ideas on the solutions that may be adopted. Consult notably on:
- Stakeholder needs and expectations,
- Focus areas/material impacts,
- Translation of society’s goals into bank objectives,
- Target setting.
- Partner with relevant stakeholders which can help your bank to reduce negative impacts and achieve or scale up positive impacts. Create partnerships or relationships that enable your bank to leverage intellectual and social capital and deliver more than it could by working on its own.
- Work with your peers to accelerate change in the banking sector and help the implementation of these Principles.
- Ensure that your engagement with regulators and policymakers is aligned with the goals and objectives of the Principles for Responsible Banking. Proactively advocate for sustainable regulations and frameworks.
- Identify and map key external stakeholders such as regulators, investors, governments, suppliers, academia, civil society institutions and non-profit organizations. Pay special attention to “affected” stakeholders, i.e. those that are affected by the banks’ indirect impacts, such as communities or wildlife (represented by NGOs). It can be useful to differentiate stakeholders that you have a contractual relationship with such as investors, employees, customers and suppliers, from other stakeholders such as trade unions, civil society organizations, and governments.
- Identify those issues or areas where collaboration could help accomplish results beyond what the bank could deliver on its own.
- Consult and engage relevant stakeholders to allow them to express their expectations regarding your bank’s impacts, strategy, targets and in general the role your bank can play in driving sustainability. Make use of stakeholders’ expertise and knowledge.
- Engage all your stakeholders, notably investors and shareholders, on your efforts to implement these Principles.
- Be transparent on public policy engagement and actions and ensure they are in line with the bank’s commitments under these Principles. Proactively advocate for policies and regulations conducive to sustainable development and responsible banking in particular.
Ensuring continuous improvement…
- Establish partnerships with stakeholders in order to develop and implement solutions that make substantial contributions to the goals of the SDGs, the Paris Climate Agreement and other relevant national, regional or international frameworks.
- Establish multi-disciplinary consultation channels and ensure frequent interaction concerning your strategy with regard to the SDGs or Paris Climate Agreement, with focus on high impact issues (consistent with your materiality assessment).
- Use digital and connected technologies to facilitate continuous and fruitful engagement with stakeholders.
- Work with other banks and financial institutions to ensure concrete and at-scale change in the sector, taking into account the applicable competition law restrictions that may exist in your jurisdictions.
- Regularly review your stakeholder engagement strategy and raise ambition and action towards comprehensiveness and efficiency. Ensure adaptability and flexibility to embed new relevant stakeholders when needed.
+ Key Resources and Examples
Some key resources
- The IFC has issued a comprehensive guide to help companies with stakeholder mapping. The guide provides corporations and banks with concrete proposals to enable them to identify their key stakeholders and to establish fruitful relationships with them.
- The AA1000 AccountAbility Stakeholder Engagement Standard is a stakeholder engagement standard, issued by the private consulting agency AccountAbility. It is designed to support organizations in designing, implementing and communicating an integrated approach to stakeholder engagement.
- BSR (Business for Social Responsibility) has published a simple guide to conducting stakeholder-mapping exercises.
- Numerous peer initiatives have proven to be helpful in scaling up change. For example, the Dutch Banking Sector Agreement, and the Thun Group of Banks engaged in exploring the practical implications of the UN Guiding Principles on Business and Human Rights for banks; the Banking Environment Initiative whose mission is to lead the banking industry in collectively directing capital towards environmentally and socially sustainable economic development; the Soft Commodities Compact that the BEI has issued jointly with the Consumer Goods Forum is a client-led initiative that aims to mobilize the banking industry as a whole to contribute to transforming soft commodity supply chains and help clients achieve zero net deforestation by 2020.
- The National Association of Corporate Directors has published guidelines on board – shareholder engagement that banks’ boards might find quite helpful in strategically engaging the banks’ shareholders on the implementation of these Principles.
a. Stakeholder engagement: the vision of the International Integrated Reporting Council (IIRC)
Integrated Reporting (<IR>) aims to improve the quality of information available to providers of financial capital by communicating the full range of factors, including environmental and social drivers, that materially affect the ability of an organization to create value over time. An integrated report should provide insight into the nature and quality of the organization’s relationships with its key stakeholders, including how and to what extent the organization understands, takes into account and responds to their legitimate needs and interests. IIRC’s view is that value is not created by or within an organization alone, but is created through relationships with others, and that stakeholders provide useful insights about matters that affect the ability of the organization to create value. IIRC’s framework provides organizations with a useful and concrete canvas to manage stakeholder relationships.
b. Working responsibly for policy change
Banks occasionally come up against policies, laws, regulations and soft law, which unintentionally prevent innovation that is needed to achieve the rapid transformation of the global economy (or even their local economy). Some years ago, for example, UNEP FI members commissioned academic research in order to provide input to the Basel Committee to address the problem of banking rules that penalized long-term debt and in so doing inadvertently increased the difficulty in financing some forms of renewable energy generation, which had longer pay back periods.
In these instances, where banks do engage stakeholders with a view to changing policies, it should be with full transparency so the engagement cannot be mistaken for acting in narrow self-interest. “Rules of Responsible Engagement”, based on the OECD Principles for Transparency and Integrity in Lobbying, which notably include following points, should be considered when undertaking the engagement:
- Do the bank’s rules and guidelines respect the socio-political and administrative context?
- Are the rules and guidelines consistent with the wider policy and regulatory frameworks?
- Is sufficient information on bank interventions publicly available?
- Can stakeholders scrutinize the positions and approaches?
- Are those undertaking the work on behalf of business meeting standards of professionalism and transparency?
- Are the rules of engagement and compliance with them periodically reviewed?
c. Partnering to scale up
Social risks can be very significant in some regions where banks operate. When assessing materiality and when deciding on priorities for action, banks should not exclude issues such as large-scale migration resulting from climate change, water shortages or gender issues, simply because, on its own, the bank may not be able to have a significant influence on the issue in question. Banks should consider whether, in partnerships with others, they could make a significant contribution to social or environmental issues that are of particular concern to the locations where they operate.
As an example, in 2017 UN Environment and a major European bank have signed an agreement to establish a collaborative partnership aimed at raising capital to drive sustainable economic growth in emerging countries. Both partners will collaborate to identify suitable commercial projects with measurable environmental and social impact, with a target of capital funding amounting to US$ 10 billion by 2025 in developing countries. The aim is to support smallholder projects in emerging countries related to renewable energy access, agroforestry, water access and responsible agriculture among other sustainable activities.
Another fruitful area for partnering is mobile banking in low-income countries. In Africa, where there is an average of five branches per 100 000 adults (vs 32 in North America, source: McKinsey 2015), unbanked communities in rural areas are reached through mobile technologies based on partnerships between banks and local telco operators. Many other brilliant examples in Kenya can be found here: https://www.equitel.com/.