Policy commitment Sample Clauses

Policy commitment. 171. The Government supported the adhering banks in implementing par. 3.1 DBA and actively participated in their stakeholder consultations. The Ministry of Foreign Affairs sponsored the Dutch translation of the OECD Guidance on RBC that provides further guidance on policy statements. The Government also gave feedback on the human right reports of some banks.

Policy commitment. 235. FNV supported the adhering banks in implementing par. 3.1. DBA in a meaningful and practical way. It reported that it did so by supporting adhering banks in organising the Human Rights and Banking conference. However, it is not clear to the Monitoring Committee how this 2019 conference relates to the banks’ policy commitments.

Policy commitment. 257. Amnesty supported the adhering banks in implementing par. 3. 1. DBA in a meaningful and practical way. It participated in (consultation) meetings with banks regarding their human rights reports, it provided feedback to (draft or published) documents, and made recommendations related to both human rights policies and procedures. In the working groups Amnesty had obviously many conversations with banks on how to improve their policies and practices.

Policy commitment. 3.1. Most members of the NVB already have a public policy statement to respect human rights in which they have set out their responsibilities, commitments, and expectations in respecting human rights. To the extent that this is not yet fully the case, the adhering banks to this agreement will develop and publish, within one year of signing the declaration of adherence or by the end of 2017 (whichever is later), policy statements that include: a. A commitment to respect human rights, in conformity with the OECD Guidelines and the UNGPs. This commitment should be reflected in policies and procedures, including the application of the International Finance Corporation Performance Standards (hereafter referred to as “IFC PS”) or Equator Principles in the case of project finance, necessary to embed it throughout the bank; b. Information on activities that the individual bank will not finance or invest in; c. A human rights due diligence procedure; d. Sector and/or theme policies outlining human rights standards and parameters under which the bank conducts business in sectors that are deemed high-risk sectors according to the bank or assessed as such on the basis of the information in the matrix/database (see paragraph 5.1 of this agreement). 7 As defined by the Basel Committee on Banking Supervision, International Convergence of Capital Measurement and Capital Standards ("Basel II"), November 2005, pp. 48-49, ▇▇▇▇://▇▇▇.▇▇▇.▇▇▇/publ/bcbs118.pdf 8 SHIFT (2015), Exploring the concept of prioritization: An explanatory note for the Dutch ICSR process, see ▇▇▇▇://▇▇▇▇▇▇▇▇▇▇▇▇.▇▇▇/project/addressing-sector-wide-risks-through-negotiated-covenants- 3.2. Throughout the agreement period, the adhering banks are willing to discuss further improvements to their human rights related policies with the Parties and reflect on potential actions if and when improvements are identified; 3.3. The NVB will encourage the adhering banks to fulfil the abovementioned expectations within one year of signing the declaration of adherence or by the end of 2017 (whichever is later), and all the Parties are committed to supporting the adhering banks in implementing them in a meaningful and practical way; 3.4. The adhering banks will, to the extent that is not yet the case, ensure the existence of complaints and whistle blower mechanism(s) for its own staff, including in their subsidiary companies; 3.5. The adhering banks will, to the extent that is not yet the case, create a complaint procedur...

Policy commitment. 157. The NVB encouraged the adhering banks to fulfil the expectations set out in par.

Policy commitment. 313. PAX supported the adhering banks in implementing par. 3.1 DBA in a meaningful and practical way. It participated in consultation meetings with three banks on their due diligence process and in several meetings with banks on specific themes and policies, such as mining, oil and gas, remediation, human rights defenders and controversial weapons. It also provided feedback on banks’ human rights reports.

Policy commitment. Two NKD questions linked to DBA 3.1.c and relative KD, ask the Adhering Banks to provide an overview of their high-risk sector policies and of their high risk theme policies. As such, the answers to these two NKDs appear to overlap and repeat the answers to KD question 4, relating to the inclusion of a Statement on sector/theme policies outlining human rights standards and parameters under which the bank conducts business in sectors that are deemed high risk sectors (see above § 30).

Policy commitment. 218. CNV supported the adhering banks in implementing par. 3.1. DBA in a meaningful and practical way.

Policy commitment. General observations 23. DBA 3.1 refers to the policies and procedures publicly expressed that reflect the Adhering Banks’ commitments to respect human rights in conformity with the OECD Guidelines and the UNGPs. 24. In relation to the DBA reference both to the OECD Guidelines and UNGPs, the Monitoring Committee emphasises that the OECD Guidelines and UNGPs are aligned standards. Due to Ruggies close collaboration with the OECD, the Human Rights chapter of the 2011 OECD Guidelines replicates the UNGPS formulation, the « General Principles » chapter of the OECD Guidelines reiterates the UNGPS formulation of the corporate responsibility to respect Human rights, and establishes a due diligence requirement for all subjects covered by the guidelines1. Therefore, if Adhering Banks publicise or communicate internally or externally policy statements in different wording, especially if they did not refer to both the OECD Guidelines and the UNGPs, the Monitoring Committee has not considered such differences to be relevant as to the substance of the expressed commitments. 25. The OECD Guidelines and the UNGPs recommend that statements of policies be approved at the most senior level of the business enterprise, be informed by relevant internal and/or external expertise, stipulate the human rights expectations of personnel, business partners and other parties directly linked with its operations and services, be publicly available and communicated internally and externally to all personnel and relevant parties or business partners and be reflected in operational policies and procedures embedded throughout the business enterprise. 26. In Year 1, all but two Adhering Banks had a public policy statement to respect human rights (MC Report 2018, § 55 and Appendix B-1). In Year 2, all T1 Adhering Banks, as well as all T2 Banks have a public policy statement to respect human rights in line with DBA 3.1. a.. The statements are often part of the banks’ Sustainability Risk Policy. They are publicly available on line. Access to the statement is easy if the HR statement is a stand-alone statement but it can be more intricate to find if it is part of the Sustainability Risk Policy, such as in the case of one bank. As regards this bank, it should be stressed 1 ▇▇▇▇▇▇ ▇.▇., ▇▇▇▇▇▇ ▇., « Human Rights and the OECD Guidelines for Multinational Enterprises: Normative Innovations and Implementation Challenges », Corporate Social Responsibility Initiative, Working Paper n°66, Harvard Univer...