Employee awareness on environmental and social risk

Ongoing efforts to increase awareness of ES risk among employees and to further enhance governance have led to a noticeable rise in the number of transactions referred to the Group Sustainability team in the past five years.

Despite the fact that the number of transactions referred to Group Sustainability remains high, continuous improvement of our ES Policy Framework is gradually devolving decision-making to the operational levels, avoiding the need to refer to regional Reputational Risk Committees except in particularly complex cases.

Due to the launch of a revised Reputational Risk Framework in 2015, referral statistics cannot be directly compared to 2014. From January to May 2015, 60 transactions were referred to Divisional/Regional Reputational Risk Committees—13 of those with ES issues. After June, transactions were assessed by a Unit Reputational Risk Assessment Process (Unit RRAP) prior to possible referral to one of our four Regional Reputational Risk Committees (RRRCs). The RRRCs are subcommittees of the Group Reputational Risk Committee (GRRC) to which matters may also be referred. This is reflected in the revised table below.

In 2015, we rolled out employee training for ES risk management in the form of in-person and WebEx sessions. This training aims to provide guidance on how to apply the ES Policy Framework and is designed for the specific requirements of the various business and infrastructure units.

For instance, alongside the Global Transaction Banking (GTB) division, we developed specific escalation logic applicable to Trade Finance. Globally, around 500 GTB employees were trained in this. The training was well received and will help to ensure that all relevant Trade Finance transactions are reviewed by Group Sustainability.

Additionally, we provided training to the Credit Risk Management division in Europe and Asia, as well as initiated trainings with certain operative units involved in internal control processes.

Going forward, we will continue to work with our stakeholders see chapter Stakeholder dialog to observe societal trends and discuss their implications for the financial sector. We will continue to develop our ES Policy Framework by revising existing provisions and discussing additional ones, and we will continue the rollout of ES risk training for further business and infrastructure units globally.