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The lending decision process is carried out on a case-by-case basis, following standardized
principles and guidelines. There is a clear personnel and functional separation between the
business activities and all risk management activities. In addition to classic “hard facts” and
numerous qualitative criteria, our internal rating model incorporates an evaluation of the
management, which is responsible for adequate handling of environmental and social topics within the
company. An evaluation is performed as to whether an industry is subject to special environmental or social
risks, including human rights violations or health risks, and whether a potential borrower follows the existing
rules with regard to the environment, human rights, and health. The agreed credit terms are also assessed as
standard as part of the annual analyses. Group Compliance is responsible for all issues concerning
compliance with legal requirements.
The described group-wide standards apply to all group units, but these are also supplemented with local,
sometimes more stringent, internal guidelines and policies by many of our network banks. They take into account,
to varying extents, the social and environmental risk strategies of the respective bank, define sometimes higher
minimum criteria or define the exact procedure for compliance with all of the agreed-upon principles.
The standards of the International Finance Corporation (IFC) and/or the Multilateral Investment Guarantee
Agency (MIGA) apply at seven network banks: Raiffeisen Bank Sh.A. in Albania, Raiffeisen BANK d.d. Bosna
i Hercegovina, Raiffeisen Bank Kosovo J.S.C., Raiffeisen Bank S.A. in Romania (which has also committed to
compliance with the EBRD standards), Raiffeisen banka a.d. in Serbia, Priorbank JSC in Belarus, and AO
Raiffeisenbank in Russia.
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 is responsible for proper implementation within the bank. All employees involved in
evaluating 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 adopted voluntarily and applied in the credit business at other network
banks, e.g. Raiffeisenbank (Bulgaria) EAD, Raiffeisen Bank Aval JSC in Ukraine and Priorbank JSC in Belarus.
Raiffeisen Bank International | Sustainability Report 2018