SBFN Member Since:

2016

Member Organisations

Association of Banks in Cambodia

Progress Against sub Pillars

Framework Documents

CountryPolicies/ Principles/ GuidelinesYearIssuer
Cambodia

ABC Member Banking Industry Survey on Sustainable Finance

2020Association of Banks in Cambodia
Cambodia

Sustainable Finance Principles Implementation Guidelines

2019Association of Banks in Cambodia
Cambodia

Sustainable Finance Principles – Statement of Intent

2016Association of Banks in Cambodia

Pillar 1 - ESG Integration - Strategic Alignment

National Framework

P 1.1 – Has the regulator or industry association published a national framework (“Framework”) for the banking sector that sets out expectations for integrating the consideration of environmental, social, and governance (ESG) risks and performance?

Yes

Source Reference Detail
Source Reference Document
Sustainable Finance Principles Implementation Guidelines (ABC, 2019)
Source Reference Description

P 1.2 – Has the relevant regulator or industry association published a Framework for capital markets, investment, insurance or other non-lending FIs that sets out expectations for integrating the consideration of environmental, social, and governance (ESG) risks and performance?

Yes

Source Reference Detail
Cambodia National Adaptation Plan Financing Framework and Implementation PlanGuideline for Managing Environmental and Social Risks in Projects in the Framework of the National Programme for Sub-National Democratic Development
Source Reference Document
Sustainable Finance Principles Implementation Guidelines (ABC, 2019)
Source Reference Description
Sustainable Finance Principles Implementation Guidelines (ABC, 2019)

Pillar 1 - ESG Integration - Strategic Alignment

Alignment with International Goals & Standards

P 1.3 – Does the Framework make reference to international sustainable development frameworks or goals?

Yes

Source Reference Detail
Source Reference Document
Sustainable Finance Principles Implementation Guidelines (ABC, 2019)
Source Reference Description
Page 3 – 1.2

P 1.4 – Does the Framework make reference to established international ESG risk management standards and principles for FIs??

Yes

Source Reference Detail
Source Reference Document
Sustainable Finance Principles Implementation Guidelines (ABC, 2019)
Source Reference Description
Page 3 – 1.2

Pillar 1 - ESG Integration - Strategic Alignment

Alignment with national goals & strategies

P 1.5 – Does the Framework make reference to specific national development objectives, plans, policies, goals, or targets?

Yes

Source Reference Detail
page 15: Cambodian National Strategic Plan on Green Growth 2013-2030; Cambodian National Roadmap for Green Growthpage 21: Royal Government of Cambodia, Cambodia Climate Change Strategic Plan 2014-2023;
Source Reference Document
Sustainable Finance Principles Implementation Guidelines (ABC, 2019)
Source Reference Description
Page 15, 21

P 1.6 – Does any cooperation exist between agencies or between the regulator and industry association with respect to policy design and/or implementation related to ESG integration?

Yes

Source Reference Detail
Source Reference Document
Sustainable Finance Principles Implementation Guidelines (ABC, 2019)
Source Reference Description
Page 24 – 9.1

P 1.7 – Does any inter-agency data sharing currently exist related to ESG integration by FIs?

No

Source Reference Detail
Source Reference Document
Source Reference Description

Pillar 1 - ESG Integration - Regulatory and Industry Association Actions

Overall Approach & Strategy

P 1.8 – Does the Framework provide guidance on the role of the regulator or industry association with regard to assessing and managing ESG risk and performance in the financial sector?

Yes

Source Reference Detail
1. We will assess and manage environmental risks relating to climate change, pollution and waste management and the protection of our critical natural resources.2. We will assess and manage risks that could potentially negatively impact our people, in particular local communities, workers, and indigenous/minority populations.3. We will assess and manage risks that could potentially negatively impact aspects of our cultural heritage, including our language, culture, traditions and monuments.
Source Reference Document
Sustainable Finance Principles Implementation Guidelines (ABC, 2019)
Source Reference Description
Page 1

P 1.9 – Has the regulator or industry association undertaken market assessment to identify systemic ESG risks through analysis of the portfolios of supervised entities/members and published the results?

No

Source Reference Detail
Source Reference Document
Source Reference Description

Pillar 1 - ESG Integration - Regulatory and Industry Association Actions

Technical Guidance

P 1.10 – Does the Framework provide technical guidance or tools to support implementation of ESG risk and performance management by the financial sector?

Yes

Source Reference Detail
Source Reference Document
Sustainable Finance Principles Implementation Guidelines (ABC, 2019)
Source Reference Description

Pillar 1 - ESG Integration - Regulatory and Industry Association Actions

Supervisory Activities & incentives

P 1.11 – Is the implementation of the Framework regularly monitored and/or information regularly collected from FIs by the regulator and/or industry association?

Yes

Source Reference Detail
Source Reference Document
Sustainable Finance Principles Implementation Guidelines (ABC, 2019)
Source Reference Description
Page 24 -9.3

P 1.12 – Does the regulator or industry association provide any financial or non-financial incentives for FIs to manage ESG performance as part of the Framework?

No

Source Reference Detail
Source Reference Document
Source Reference Description

P 1.13 – Does the regulator or industry association apply any disincentives/penalties for non-compliance by FIs in terms of expectations from the regulator and/or industry association related to ESG risk management as part of the Framework?

No

Source Reference Detail
Source Reference Document
Source Reference Description

Pillar 1 - ESG Integration - Regulatory and Industry Association Actions

Tracking & Aggregated Disclosure

P 1.14 – Has the regulator or industry association established a data collection approach and database to track or regularly publish data related to ESG integration by FIs as part of the Framework?

No

Source Reference Detail
The bank/MFI needs to define and allocate E&S roles and responsibilities(including approval authorities) to the relevant functions in the bank/MFI (e.g. senior management, Board of Directors,E&S Risk Officer/Unit , relationship managers, credit analysts, Credit Risk/Investment Committees, Internal Audit, Legal, Human Resources, Procurement, Communications departments).” Cambodian Sustainable Finance Principles Implementation Guidelines
Source Reference Document
Source Reference Description

Pillar 1 - ESG Integration - Expectations of FI Actions

Strategy & Governance

P 1.15 – Does the Framework require/ask the FI’s board of directors (or highest governing body) to approve an ESRM and/or ESG integration strategy, and to supervise its implementation?

Yes

Source Reference Detail

The bank/MFI needs to define and allocate E&S roles and responsibilities(including approval authorities) to the relevant functions in the bank/MFI (e.g. senior management, Board of Directors,E&S Risk Officer/Unit , relationship managers, credit analysts, Credit Risk/Investment Committees, Internal Audit, Legal, Human Resources, Procurement, Communications departments).” Cambodian Sustainable Finance Principles Implementation Guidelines

Source Reference Document

Sustainable Finance Principles Implementation Guidelines (ABC, 2019)
Source Reference Description
Page 27

Pillar 1 - ESG Integration - Expectations of FI Actions

Organizational Structure & Capacity Building

P 1.16 – Does the Framework require/ask FIs to allocate resources/budget commensurate with portfolio ESG risks and define roles and responsibilities for ESG integration within the organization?

Yes

Source Reference Detail
Source Reference Document
Sustainable Finance Principles Implementation Guidelines (ABC, 2019)
Source Reference Description
Page 5 – 1.5

P 1.17 – Does the Framework require/ask FIs to develop and maintain the ESG expertise and capacity of staff commensurate with portfolio ESG risks through regular training and learning?

Yes

Source Reference Detail
Source Reference Document
Sustainable Finance Principles Implementation Guidelines (ABC, 2019)
Source Reference Description
Page 7 – 2.5

P 1.18 – Does the Framework require/ask FIs to create incentives for managers to reduce the ESG risk-level of the portfolio over a specified timeframe?

No

Source Reference Detail
Source Reference Document
Source Reference Description

Pillar 1 - ESG Integration - Expectations of FI Actions

Policies & Procedures

P 1.19 – Does the Framework require/ask FIs to develop policies and procedures to identify, classify, measure, monitor, and manage ESG risks and performance throughout the financing cycle at the client level and/or the transaction/project level?

Yes

Source Reference Detail
Source Reference Document
Sustainable Finance Principles Implementation Guidelines (ABC, 2019)
Source Reference Description
Page 5 – 1.5

P 1.20 – Does the Framework require/ask FIs to undertake a regular review and monitoring of ESG risk exposure at aggregate portfolio level?

Yes

Source Reference Detail
Banks/MFIs can also conduct regular sector-based portfolio reviews, which provide insight into their aggregate exposure to E&S risks. Furthermore, banks/MFIs can seek to monitor carbon risk exposures at portfolio level.” Cambodian Sustainable Finance Principles Implementation Guidelines
Source Reference Document
Sustainable Finance Principles Implementation Guidelines (ABC, 2019)
Source Reference Description
Page 27

P 1.21 – Does the Framework require/ask FIs to establish and maintain an external inquiry/complaints/grievance mechanism for interested and affected stakeholders in relation to ESG practices?

Yes

Source Reference Detail
In order to demonstrate progress in implementing this Principle, a bank/MFI should seek to develop a policy (as a standalone policy, or as part of the general E&S/Sustainability policy) and implement the necessary systems to increase the financial awareness and literacy of the Cambodian people, and to improve customer protection. Thisincludes, without being limited to, the following:establish appropriate grievance mechanisms;
Source Reference Document
Sustainable Finance Principles Implementation Guidelines (ABC, 2019)
Source Reference Description
Page 12 Demonstrating Progress

Pillar 1 - ESG Integration - Expectations of FI Actions

Tracking, Reporting & Disclosure

P 1.22 – Does the Framework require/ask FIs to report ESG risks and performance to the regulator or industry association?

Yes

Source Reference Detail
Source Reference Document
Sustainable Finance Principles Implementation Guidelines (ABC, 2019)
Source Reference Description
Page 24 – 9.3

P 1.23 – Does the Framework require/ask FIs to report on ESG integration publicly?

Yes

Source Reference Detail
Source Reference Document
Sustainable Finance Principles Implementation Guidelines (ABC, 2019)
Source Reference Description
Page 24 – 9.3

P 1.24 – Does the Framework require/ask FIs to track credit risk (e.g. loan defaults) and/or financial returns in relation to ESG risk level?

Yes

Source Reference Detail
E&S risk can be monitored as part of the regular credit risk management cycle, and the monitoring efforts should be commensurate with the E&S risks associated with the borrower/transaction.” Cambodian Sustainable Finance Principles Implementation Guidelines pg 27
Source Reference Document
Sustainable Finance Principles Implementation Guidelines (ABC, 2019)
Source Reference Description
Page 27

Pillar 2 - Climate Risk Management - Strategic Alignment

National Framework

P 2.25 – Has the regulator or industry association published a national framework (“Framework”) for the banking sector that sets out expectations for integrating the consideration and management of climate risks and their impact in the national economy?

Yes

Source Reference Detail
Principle 1 inclusion of climate change as part of E&S risk management (Pages 3-5). In addition, Principle 1 references Annex 1 on Good Practices: Pg 27): “Specifically related to climate change, banks/MFIs should seek to develop methodologies to assess and monitor the risks and opportunities from the physical impacts as well as from the transition impacts of climate change on their loan portfolios. To this end, banks/MFIs can begin to assess climate risks in their loan portfolios for climate-sensitive sectors, using climate change scenarios and methodologies that evaluate impacts on key credit risk metrics.” and “Banks/MFIs can also conduct regular sector-based portfolio reviews, which provide insight into their aggregate exposure to E&S risks. Furthermore, banks/MFIs can seek to monitor carbon risk exposures at portfolio level. Portfolio reviews are a useful tool for banks/MFIs to monitor their sectoral exposure, risk concentration, percent of high-risk activities or climate-sensitive businesses.” For reporting (Annex, pg 28): “Reporting on E&S risk performance of Business Activities includes: “climate risk reporting (e.g. based on the work of the Task Force on Climate-related Financial Disclosures)”.
Source Reference Document
Sustainable Finance Principles Implementation Guidelines (ABC, 2019)
Source Reference Description
Principle 1

P 2.26 – Has the relevant regulator or industry association published a Framework for capital markets, investment, insurance or other non-lending FIs that sets out expectations for integrating the consideration and management of climate risks and their impact in the national economy?

No

Source Reference Detail
Source Reference Document
Source Reference Description

Pillar 2 - Climate Risk Management - Strategic Alignment

Alignment with International Goals & Standards

P 2.27 – Does the Framework make reference to international agreements or frameworks to address climate?

No

Source Reference Detail
Source Reference Document
Source Reference Description
P 2.28 – Does the Framework recognize or align with established regional or international good practice for climate risk management and disclosure by FIs?

Yes

Source Reference Detail
The 2019 Cambodian Banking Association SF Principles and Implementation Guidelines state (Annex on Good Practices: Pg 28) “Related to reporting (Annex, pg 28): “Reporting on E&S risk performance of Business Activities, such as: “climate risk reporting (e.g. based on the work of the Task Force on Climate-related Financial Disclosures)”.
Source Reference Document
Sustainable Finance Principles Implementation Guidelines (ABC, 2019)
Source Reference Description

Pillar 2 - Climate Risk Management - Strategic Alignment

Alignment with National Goals & Strategies

P 2.29 – Has the regulator or industry association aligned the Framework with national goals to address climate change in line with the country’s Nationally Determined Contributions (NDCs) to the Paris Agreement? 

No

Source Reference Detail
Source Reference Document
Source Reference Description

P 2.30 – Does any cooperation exist between agencies, or between government and industry association, with respect to policy design or implementation related to climate risk management? 

No

Source Reference Detail
Source Reference Document
Source Reference Description

P 2.31 – Does any inter-agency data sharing currently exist related to climate risk management by FIs?  

No

Source Reference Detail
Source Reference Document
Source Reference Description

Pillar 2 - Climate Risk Management - Regulatory and Industry Association Actions

Overall Approach & Strategy

P 2.32 – Has the regulator or industry association undertaken research on historical impacts to the economy and financial sector from climate change, and/or future expected impacts resulting from physical and transition climate risks? 

Yes

Source Reference Detail
While not focused on the financial sector, the Sustainble Finance Principles and Implementation Guidelines reference (Principle 1, Section 1.2, page 3) the Royal Government of Cambodia, Cambodia Climate Change Strategic Plan 2014-2023 which in turn references the Cambodia National Adaptation Plan Financing Framework and Implementation Plan (2017), and Chapter 5 on Review of Private Sector Engaging Opportunities details climate issues, GHG sources, and sinks at a sector level (e.g., Energy, Forestry, Manufacturing etc). Pages 60-71.
Source Reference Document
Sustainable Finance Principles Implementation Guidelines (ABC, 2019)
Source Reference Description
Page 60 – 71

P 2.33 -Does the Framework identify key sources of GHG emissions – such as in particular sectors – as priorities in the proactive management of climate risks by the financial sector?  

No

Source Reference Detail
Source Reference Document
Source Reference Description

P 2.34 – Does the Framework incorporate the conservation/restoration of natural carbon sinks (such as oceans, forests, mangroves, grasslands, and soils) as an important part of reducing climate change risks? (e.g., through guidelines, scenario analysis, targets, or incentives for FIs)

No

Source Reference Detail
Source Reference Document
Source Reference Description

P 2.35 – Has the regulator or industry association developed an internal strategy to address climate risk, and/or embedded climate risk management into its governance, organizational structures, and budget as part of the Framework?

No

Source Reference Detail
Source Reference Document
Source Reference Description

P 2.36 – Has the regulator or industry association undertaken any activities to expand and deepen analytical understanding of national and/or cross-border physical and transition climate risks, and to raise awareness as to how these risks may transmit to, and impact, the financial sector?  

No

Source Reference Detail

Source Reference Document
Source Reference Description

Pillar 2 - Climate Risk Management - Regulatory and Industry Association Actions

Technical Guidance

P 2.37 – Has the regulator or industry association developed risk assessment approaches, methodologies, or tools to understand and assess the financial sector’s exposure to climate risk as part of the Framework?  

No

Source Reference Detail
Source Reference Document
Source Reference Description

Pillar 2 - Climate Risk Management - Regulatory and Industry Association Actions

Supervisory Activities & Incentives

P 2.38 – As part of the Framework, has the regulator clarified supervisory expectations with regard to climate risk management by FIs, including consideration of international good practices? 

No

Source Reference Detail
Source Reference Document
Source Reference Description

P 2.39 – Has the regulator started to explicitly embed climate-related risk in supervisory activities and review processes as part of the Framework? 

No

Source Reference Detail
Source Reference Document
Source Reference Description

P 2.40 – Has the regulator started to explicitly embed climate-related risk in supervisory activities and review processes as part of the Framework? 

Yes

Source Reference Detail
Ensure periodical external reporting on progress against each of the Cambodian Sustainable FinancePrinciples, towards the public (e.g. in an annual sustainability report and on the bank/MFI’s website) and towards National Bank of Cambodia / Association of Banks in Cambodia, as the case may be (for assessing progress against the Principles at sector level)”. And For reporting (Annex, pg 28): “Reporting on E&S risk performance of Business Activities includes: “climate risk reporting (e.g. based on the work of the Task Force on Climate-related Financial Disclosures)”.
Source Reference Document
Sustainable Finance Principles Implementation Guidelines (ABC, 2019)
Source Reference Description
Section 9.3

P 2.41 – Has the regulator started to explicitly embed climate-related risk in supervisory activities and review processes as part of the Framework?  

No

Source Reference Detail
Source Reference Document
Source Reference Description

Pillar 2 - Climate Risk Management - Regulatory and Industry Association Actions

Tracking & Aggregated Disclosure

P 2.42 – Does the regulator or industry association regularly collect and/or report market-level and/or FI-level data on climate-related financial sector risks as part of the Framework?  

No

Source Reference Detail
Source Reference Document
Source Reference Description

Pillar 2 - Climate Risk Management - Expectations of FI Actions

Strategy & Governance

P 2.43 – Does the Framework require/ask FIs to establish a strategy for climate risk management with responsibility at the board of director level (or highest governing body)?  

No

Source Reference Detail
Source Reference Document
Source Reference Description

Pillar 2 - Climate Risk Management - Expectations of FI Actions

Organizational Structure & Capacity Building

P 2.44 – Does the Framework require/ask FIs to define the roles and responsibilities and related capacities of the FI’s senior management and operational staff in identifying, assessing, and managing climate-related financial risks and opportunities? 

No

Source Reference Detail
Source Reference Document
Source Reference Description

Pillar 2 - Climate Risk Management - Expectations of FI Actions

Policies & Procedures

P 2.45 – Does the Framework require/ask FIs to expand existing risk management processes to identify, measure, monitor, and manage/mitigate financial risks from climate change?

Yes

Source Reference Detail
Principle 1 inclusion of climate change as part of E&S risk management (Pages 3-5). Principle 1, Annex 1, Page 27: “Specifically related to climate change, banks/MFIs should seek to develop methodologies to assess and monitor the risks and opportunities from the physical impacts as well as from the transition impacts of climate change on their loan portfolios. To this end, banks/MFIs can begin to assess climate risks in their loan portfolios for climate-sensitive sectors, using climate change scenarios and methodologies that evaluate impacts on key credit risk metrics.” and “”Banks/MFIs can also conduct regular sector-based portfolio reviews, which provide insight into their aggregate exposure to E&S risks. Furthermore, banks/MFIs can seek to monitor carbon risk exposures at portfolio level. Portfolio reviews are a useful tool for banks/MFIs to monitor their sectoral exposure, risk concentration, percent of high-risk activities or climate-sensitive businesses.”
Source Reference Document
Sustainable Finance Principles Implementation Guidelines (ABC, 2019)
Source Reference Description
Refer to description

Pillar 2 - Climate Risk Management - Regulatory and Industry Association Actions

Tracking, reporting & disclosure

P 2.46 – Does the Framework require/ask FIs to report on their overall approaches to climate risk management in line with international good practices (e.g., TCFD), or establish a timeline by which FIs should begin to align their reporting with such practices? 

Yes

Source Reference Detail
(Annex on Good Practices: Pg 28) “Related to reporting (Annex, pg 28): “Reporting on E&S risk performance of Business Activities, such as: “climate risk reporting (e.g. based on the work of the Task Force on Climate-related Financial Disclosures)”.
Source Reference Document
Sustainable Finance Principles Implementation Guidelines (ABC, 2019)
Source Reference Description
(Annex on Good Practices: Pg 28) “Related to reporting (Annex, pg 28): “Reporting on E&S risk performance of Business Activities, such as: “climate risk reporting (e.g. based on the work of the Task Force on Climate-related Financial Disclosures)”.

P 2.47 – Does the Framework require/ask FIs to identify, measure, and report on exposure to sectors which are vulnerable to transition risk and physical risk?

Yes

Source Reference Detail
Principle #1 on risk management includes climate change, and the Annex 1 (Pg 27.) ESMS notes: Specifically related to climate change, banks/MFIs should seek to develop methodologies to assess and monitor the risks and opportunities from the physical impacts as well as from the transition impacts of climate change on their loan portfolios. To this end, banks/MFIs can begin to assess climate risks in their loan portfolios for climate-sensitive sectors, using climate change scenarios and methodologies that evaluate impacts on key credit risk metrics.
Source Reference Document
Sustainable Finance Principles Implementation Guidelines (ABC, 2019)
Source Reference Description
Refer to description

P 2.48 – Does the Framework require/ask FIs to adopt and report on performance targets to reduce portfolio greenhouse gas (GHG) emissions on a regular basis? 

Yes

Source Reference Detail
Source Reference Document
Source Reference Description

P 2.49 – Does the Framework require/ask FIs to adopt and report on performance targets to reduce exposure to climate change risks at the portfolio level on a regular basis?

No

Source Reference Detail
Source Reference Document
Source Reference Description

Pillar 3 - Financing Sustainability - Strategic Alignment

National Framework

P 3.50 – Has the regulator or industry association published a national framework (“Framework”) for the banking sector that sets out expectations for integrating the consideration of instruments, goals, and standards for financing sustainability, including requirements for ensuring credibility and managing and measuring resulting impacts in the national economy?

Yes

Source Reference Detail
Source Reference Document
Sustainable Finance Principles Implementation Guidelines (ABC, 2019)
Source Reference Description
Page 16 – 17 – 6.5

P 3.51 – Has the relevant regulator or industry association published a Framework for capital markets, investment, insurance or other non-lending FIs that sets out expectations for integrating the consideration of instruments, goals, and standards for financing sustainability, including requirements for ensuring credibility and managing and measuring resulting impacts in the national economy

No

Source Reference Detail
Source Reference Document
Source Reference Description

Pillar 3 - Financing Sustainability - Strategic Alignment

Alignment with International Goals & Standards

P 3.52 – Has the regulator or industry association developed a strategy, regulations, or set of frameworks for stimulating the allocation of capital to sustainable assets, projects, and related sectors in line with global goals, such as the Sustainable Development Goals (SDGs)?

Yes

Source Reference Detail
Source Reference Document
Sustainable Finance Principles Implementation Guidelines (ABC, 2019)
Source Reference Description
Page 24 – 9.4

P 3.53 – Does the Framework recognize and/or align with existing standards, voluntary principles, or market good practices related to sustainable finance instruments?

No

Source Reference Detail
Source Reference Document
Source Reference Description

Pillar 3 - Financing Sustainability - Regulatory and Industry Association Actions

Alignment with national goals & strategies

P 3.54 – Does the Framework enable the achievement of stated national objectives by guiding capital to sectors, assets, and projects that have environmental and social benefits in line with national sustainable development priorities, strategies, targets, and the size of sustainable investment needs, and taking into account the local barriers to scaling-up sustainable finance? 

Yes

Source Reference Detail

Source Reference Document
Sustainable Finance Principles Implementation Guidelines (ABC, 2019)
Source Reference Description

Page 15 – 6.2

P 3.55 – Does the Framework enable the achievement of stated national objectives by guiding capital to sectors, assets, and projects that have environmental and social benefits in line with national sustainable development priorities, strategies, targets, and the size of sustainable investment needs, and taking into account the local barriers to scaling-up sustainable finance?

No

Source Reference Detail
Source Reference Document
Source Reference Description

P 3.56 – Does any inter-agency data sharing currently exist related to stimulating and monitoring sustainable finance flows?

No

Source Reference Detail
Source Reference Document
Source Reference Description

Pillar 3 - Financing Sustainability - Strategic Alignment

Overall Approach & Strategy

P 3.57 – Does the Framework require/ask the regulator or industry association to establish mechanisms to identify and encourage the allocation of capital to sustainable sectors, assets, and projects?

No

Source Reference Detail
Source Reference Document
Source Reference Description

Pillar 3 - Financing Sustainability - Regulatory and Industry Association Actions

Technical Guidance

P 3.58 – Does the Framework require/ask the regulator or industry association to establish mechanisms to identify and encourage the allocation of capital to sustainable sectors, assets, and projects? 

Yes

Source Reference Detail
Source Reference Document
Sustainable Finance Principles Implementation Guidelines (ABC, 2019)
Source Reference Description
Page 13 – 5.3 and Page 15 – 6.3

P 3.59 – Does the Framework provide guidelines for extending green, social or sustainability-focused loans (excluding bonds)?

No

Source Reference Detail
Source Reference Document
Source Reference Description

P 3.60 – Does the Framework provide guidelines for issuance of green, social or sustainability bonds?

No

Source Reference Detail
Source Reference Document
Source Reference Description

P 3.61 – Does the Framework require/ask for external party verification to ensure the credibility of sustainability instruments?

No

Source Reference Detail
Source Reference Document
Source Reference Description

Pillar 3 - Financing Sustainability - Regulatory and Industry Association Actions -

Supervisory activities & incentives

P 3.62 – Does the regulator or industry association monitor information reported by FIs related to green/social/sustainability investment, lending, and other instruments to prevent greenwashing and social-washing?

No

Source Reference Detail
Source Reference Document
Source Reference Description

P 3.63 – Are there any financial or non-financial incentives for FIs to develop and grow green, social, or sustainability finance instruments?

No

Source Reference Detail
Source Reference Document
Source Reference Description

Pillar 3 - Financing Sustainability - Regulatory and Industry Association Actions -

Tracking & Aggregated Disclosure

P 3.64 – Does the regulator or industry association collect and/or publish data from FIs or other sources about allocation of capital to green/social/sustainability assets, projects, or sectors?

No

Source Reference Detail
Source Reference Document
Source Reference Description

Pillar 3 - Financing Sustainability - Expectations of FI Actions

Strategy & Governance

P 3.65 – Does the Framework require/ask FIs to establish a strategy, governance, or high-level targets, including at the Board of Directors level, for capital allocation to sustainable assets, projects, or sectors?

No

Source Reference Detail
Source Reference Document
Source Reference Description

Pillar 3 - Financing Sustainability - Expectations of FI Actions

Organizational Structure & Capacity Building

P 3.66 – Does the Framework require/ask FIs to define internal staff roles and responsibilities to encourage finance flows to green, social, and/or sustainability-focused investments?

No

Source Reference Detail
Source Reference Document
Source Reference Description

P 3.67 – Does the Framework require/ask FIs to develop and maintain internal staff capacity on green, social, or sustainability products through regular training and learning?

Yes

Source Reference Detail
Provide training to staff and clients to create awareness about green products and services”
Source Reference Document
Sustainable Finance Principles Implementation Guidelines (ABC, 2019)
Source Reference Description
Page 17

Pillar 3 - Financing Sustainability - Expectations of FI Actions

Policies & Procedures

P 3.68 – Does the Framework require/ask FIs to put in place policies and procedures for defining, issuing, managing proceeds, tracking performance, and reporting on green, social or sustainability-focused products?

Yes

Source Reference Detail
Source Reference Document
Sustainable Finance Principles Implementation Guidelines (ABC, 2019)
Source Reference Description
Page 16 – 17 – 6.5

P 3.69 – Does the Framework require/ask FIs to appoint an independent external reviewer to confirm that the FI’s internal framework meets the requirements of the recognized national framework and regulations, or aligns to international standards?

Yes

Source Reference Detail
Source Reference Document
Sustainable Finance Principles Implementation Guidelines (ABC, 2019)
Source Reference Description
Page 24 – 9.3

P 3.70 – Does the Framework require/ask that FIs create incentives for managers to increase sustainable loans or investments in the portfolio?

No

Source Reference Detail
Source Reference Document
Source Reference Description

Pillar 3 - Financing Sustainability - Expectations of FI Actions

Tracking, reporting & disclosure

P 3.71 – Does the Framework require/ask FIs to publish annual updates on the performance and impacts of the sustainability instruments in compliance with relevant national and/or international standards?

No

Source Reference Detail
Source Reference Document
Source Reference Description

P 3.72 – Does the Framework require/ask FIs to obtain and disclose independent review of metrics reported annually in relation to the social and environmental outcomes and impacts achieved through the sustainability instruments?

No

Source Reference Detail
Source Reference Document
Source Reference Description

P 3.73 – Does the Framework require/ask FIs to obtain and disclose independent review of metrics reported annually in relation to the social and environmental outcomes and impacts achieved through the sustainability instruments?

Yes

Source Reference Detail
Source Reference Document
Sustainable Finance Principles Implementation Guidelines (ABC, 2019)
Source Reference Description
Principle 9

P 3.74 – Does the Framework require/ask FIs to report to the regulator(s) or industry association(s) on green, social, and/or sustainability bonds or other positive impact investments?

Yes

Source Reference Detail
Source Reference Document
Sustainable Finance Principles Implementation Guidelines (ABC, 2019)
Source Reference Description
Principle 9

P 3.75 – Does the Framework require/ask FIs to report publicly on their green, social and sustainability-focused finance activities and positive outcomes or impacts (i.e. not only to the regulator or shareholders)?

Yes

Source Reference Detail
Source Reference Document
Sustainable Finance Principles Implementation Guidelines (ABC, 2019)
Source Reference Description
Page 17