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These network banks all have an Environmental and Social Management System (ESMS) and a corresponding
Environmental and Social Policy (E&S Policy). This policy describes the principles of the ecological and social
risk management in the bank and defines important roles and responsibilities for managing E&S risks as
well as key elements of the E&S risk management process. An E&S Officer is nominated by the Management
Board for each bank and are responsible for proper implementation within that bank. All of the employees
who are involved in the evaluation of E&S risks receive appropriate training.
The credit process ensures that all credit applications in the corporate customer area are reviewed in three
steps, in addition to the usual credit and risk criteria.
1. Evaluating whether the company is engaged in activities on the IFC Exclusion List.
2. Categorizing the environmental and social (E&S) risk level depending on the type, location, noticeability
and size of the project as well as the nature and scope of its possible environmental and social impact (low,
medium or high).
3. Social and environmental impact assessment (E&S due diligence) for all transactions of high and medium
risk: Determining the environmental and social impacts and risks of a project as well as determining whether
it meets the laws of the respective country and other policies of the World Bank and IFC.
Also included are performance standards regarding work and labor conditions, resource efficiency and the
avoidance of environmental pollution, public health and safety, land acquisition and forced relocations,
retention of biodiversity and sustainable management of natural resources as well as indigenous peoples and
cultural heritage (see the IFC website at www.ifc.org). The IFC and MIGA standards also include extensive
reporting and monitoring requirements, which are carried out within the scope of “E&S Supervisory Visits”.
More extensive standards are also applied in the credit business at other network banks. For instance, social
and environmental criteria for the credit assessment and limit applications apply at Raiffeisenbank (Bulgaria)
EAD. Target industries have also been defined for financing. These include health care, agricultural products,
the food retail trade as well as human resources and employment.
At Raiffeisen Bank Aval JSC in Ukraine, the analysis of social and environmental risks is also part of the decisionmaking
procedure for the credit analysis in the non-retail segment. In this process, the industry environmental
risk is classified as high, medium or low according to its impact and then categorized into one of three
segments. This is done on the basis of historical data and general developments in Ukraine. A management
quality assessment of environmental and social risks as well as a general evaluation of the quality of the assets
is also carried out, which enters into the corporate rating database within the scope of the qualitative assessment.
For the retail segment, the policy also contains criteria for lending in the area of environmental protection, and
a number of sensitive business areas are excluded from lending activities. This information is included in the
SMB rating database as part of the qualitative assessment.
Raiffeisen Bank International | Sustainability Report 2017