2020 Universal registration document and annual financial report - BNP PARIBAS 591
7
7
A COMMITTED BANK: INFORMATION CONCERNING THE ECONOMIC, SOCIAL, CIVIC AND ENVIRONMENTAL RESPONSIBILITY OF BNP PARIBAS
Our civic responsibility: being a positive agent for change
Management of salient risks(1) as part of the distribution of the Group s products and services
BNP Paribas has identified two main risks in the distribution of its products and services:
■ non-discrimination in access to financial services;
■ right to privacy (protection of clients personal data).
Non-discrimination in access to financial services The Group considers that sustainable economic development promotes wider access to fundamental rights. For that reason, it strives to boost access to financial services in the communities in which it operates (see Products and services that are widely accessible, Commitment 7).
Right to privacy Privacy protection remains an ethical priority issue in the Code of conduct. The Group continues to strengthen data protection for both its employees and its customers. In 2020, BNP Paribas continued to develop its network of data protection specialists, integrated into all of the Group s territories and businesses. Thus, more than 100 contacts around the world are tasked with ensuring compliance with the principles of data confidentiality and increasing personal data protection knowledge in the Group.
A new department has been set up within the Group the Group Data Protection Office whose mission is to support, advise and supervise activities related to Data Protection. It carried out a study across all businesses and territories in order to assess their degree of knowledge in terms of Data Protection in strategic sectors. This exercise also aims to help local teams develop action plans to remedy any shortcomings. Completed in 2020, this study will be repeated as part of a continuous improvement process.
The Group continued its efforts to improve the performance and use of tools specifically developed to comply with our Data Protection obligations. These tools have been set up in accordance with the General Data Protection Regulation (GDPR) and have been deployed in all regions to provide Group-level visibility of key data protection practices and also any vulnerabilities.
The key tools/themes available for all employees relate to:
■ data protection risk assessment to identify and address data processing risks;
■ reporting personal data breaches. Each employee can report any suspicious personal data breach for analysis;
■ the processing register maps the flow of personal data between the Group and its entities.
Together, they provide a single view on how the Group manages and assesses personal data risks.
Monitoring of salient risks in the Group s financing and investment activities
The activities of the Group corporate clients may pose a risk to human rights, particularly in the area of workers rights, and have an impact on local communities.
The Group uses its influence to encourage its clients to manage their own activities with respect to human rights. It also seeks to identify, evaluate (due diligence process), monitor and foster the improvement of the current and future performance of clients operating in sensitive sectors (defence, agriculture, palm oil, etc.) through the application of its investment and financing policies (see Systematic integration and management of Environmental, Social and Governance risks, Commitment 3).
To ensure that the existing system meets the requirements of the French Duty of Care, BNP Paribas set up a risk mapping of its clients taking into account both their business sectors and the countries they operate in. This tool covers human rights issues through the analysis of several criteria, such as child labour, forced labour, human trafficking and failure to respect the rights of local communities. The criteria are both sector- weighted and geographically weighted. The risk mapping thus allows the concerned business lines and functions to better deploy and monitor the most adapted due diligence measures. Concerned to implement the most appropriate and thorough Duty of Care measures (see Duty of Care and Modern Slavery and Human Trafficking statement in section 7.6).
Workers rights The human rights criteria in the financing and investment policies of sensitive sectors deal with matters such as workers rights, in particular child and forced labour, health & safety and freedom of association. These issues are also tackled in the analysis of projects covered by the Equator Principles (see Systematic integration and management of Environmental, Social and Governance risks, Commitment 3).
Rights of local communities Identified as another salient issue, these rights are at the heart of most controversies related to large industrial projects.
Therefore, for its project finance activities, BNP Paribas encourages its clients to obtain the Free, Prior and Informed Consent (FPIC) of the local communities impacted by their projects.
In accordance with the Equator Principles (see Systematic integration and management of Environmental, Social and Governance risks, Commitment 3), the Group ensures that the negative impacts are avoided and, if necessary, remedied. Moreover, in 2019, BNP Paribas actively participated in the update of the Equator Principles (EP4) standards. EP 4 focused on a number of key subjects, Social Impact & Human Rights being one of them. As part of the update process, BNP Paribas was able to give its opinion at the different stages of discussion including on specific human rights issues like the FPIC of indigenous peoples, or the implementation of grievance mechanisms by clients, in particular through its participation to the Social Risk Working Group. Discussions resulted in a greater acknowledgement of the UN Guiding Principles by the Equator Principles, and a broader use of Equator Principle-defined standards including mandatory FPIC in Designated Countries , where they were previously considered as optional.
(1) Salient is the term used by the drafters of the United Nations Guiding Principles Reporting Framework.
