CAIXA Econômica Federal (2021)

In 2021, the Central Bank of Brazil – BACEN, in line with the best practices and market trends in the international context, consolidated the social, environmental and climate risks for financial institutions, publishing new regulatory standards, including the one that provides for the risk management structure, the capital management structure and the information disclosure policy, in addition to establishing a list of obligations for managing such risks. Due to advances in the Brazilian regulatory agenda, CAIXA expanded its mandate from socio-environmental risk to social, environmental and climate risk. The change did not just reflect the inclusion of climate risk on the agenda, but the strengthening of social and environmental risks.

Another relevant regulation for the Brazilian banking sector was the establishment of procedures for reporting and transparency focused on social, environmental and climate risks. Such reports provide the disclosure of data regarding the governance of risk management, including the attributions and responsibilities of the institution’s bodies involved with the management of social risk, environmental risk and climate risk, such as the board of directors, when existing, and the institution’s board of directors; real and potential impacts, when considered relevant, of the risks in the strategies adopted by the institution in the businesses and in the risk and capital management in the short, medium and long term horizons, considering different scenarios, according to documented criteria; and risk management processes.

Thus, in 2021 the context was one of expansion of regulation on the subject and in 2022 CAIXA should make efforts to implement the new regulatory guidelines. The socio-environmental risk processes in the year underwent a review/change to improve risk management, of which the monitoring of the second line of defense of social, environmental and climate risk stands out.

For 2021, social, environmental and climate risk aimed to work with projects on the following topics: capacity building/training; socio-environmental risk culture, Agribusiness Defense Line and implementation of recommendations from the Task Force on Climate Related Financial Disclosures – TCFD.

Due to the increase in demands and processes, the team responsible for socio-environmental risk analysis had an increase in its workforce to meet the demands. The bank also started to adopt a standardized socio-environmental risk assessment model, issuing a socio-environmental rating for companies with activities that use natural resources or those subject to potentially cause socio-environmental damage (customers subject to environmental licensing) from a certain amount and type of operation.

CAIXA’s socio-environmental and climate risk management is managed by the Vice-Presidency of Risks, the area responsible for the topic also has a mandate for the bank’s credit risk. It is in this unit that models, guidelines and other socio-environmental requirements applicable to the entire bank are developed, in addition to being responsible for the Equator Principles, to which CAIXA has been a signatory since 2009.

Regarding the analysis of projects that fall under the Equator Principles, the bank follows the international standardization of the International Finance Corporation – IFC, adopting the environmental criteria referenced by the IFC Performance Standards on Social and Environmental Sustainability and the World Bank Group’s Environment, Health, and Safety Guidelines. CAIXA requires, in the analysis of projects, a socio-environmental compliance assessment carried out by an independent socio-environmental consultancy, if high risk is identified (Category A) and, when necessary, in medium risk projects (Category B). This assessment addresses the legal requirements applicable to environmental management, health and safety management and occupational medicine, the conditions of environmental licenses and the implementation of the Basic Environmental Plan for compensation and mitigation of socio-environmental impacts, as well as other criteria established in the Equator Principles. For projects with high-magnitude socio-environmental impacts, socio-environmental monitoring reports are also required periodically, covering the implementation and operation of the project during the term of the financing. Currently, socio-environmental consultants work in the risk monitoring of projects under the scope of the Equator Principles, whose review of the analysis of critical compliance and monitoring is carried out in pairs for greater evaluation. After validated by the team, all technical levels go through two higher levels until they are finally approved. In addition, the team periodically reviews the internal rules that deal with the Equator Principles, always seeking to improve the management of socio-environmental and ensure that projects are properly evaluated and monitored by the bank. The businesses areas are responsible for framing the operations, forwarding them to the area of ​​social, environmental and climate risks, in addition to carrying out all the necessary negotiations for Due Diligence, hiring consultants and negotiations with the entrepreneur. It is also up to them to check the contractual obligations to comply with Principle 8. In addition, they are responsible for monitoring the contract throughout the life of the contract, as well as for dealing with socio-environmental monitoring.

Annually, the socio-environmental risk area reports to higher levels on the Equator Principles, both to the Bank’s Risk Superintendence to which it is linked, and to the General Secretariat responsible for institutional relations with external entities. He is also responsible for the annual report on the Equator Principles with the EP Secretariat and for the Bank’s Integrated Report.

CAIXA has specific rules and guidelines for granting of responsible credit, using environmental and social criteria for the approval of clients and projects, to ensure that they comply with CAIXA’s Institutional Policy. This concern also extends to the bank’s portfolio, with socio-environmental requirements in other areas, such as rural credit, sanitation, infrastructure and housing. The company has specific rules to regulate its Institutional Policy, which delimits the implementation of socio-environmental responsibility guidelines. Among them, it is worth mentioning the management of socio-environmental risk, the management of assets (own and third parties), in corporate operations and in the risk analysis of clients and projects, demonstrating the Bank’s commitment to the Equator Principles.

More information on CAIXA’s socio-environmental responsibility, on its management of socio-environmental and climate risks, and on the projects included in the Equator Principles in 2021 can be found in its Integrated Report (pages 271 to 285: https://www.caixa.gov.br/Downloads/caixa-governanca/relatorio-integrado-2021.pdf (available in Portuguese).