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Issues in Social and Environmental Accounting
Vol. 1, No. 1 June 2007
Pp. 40-53




    The Equator Principles, Project Finance and the
  Challenge of Social and Environmental Responsibility
                                             Jane Andrew
                                School of Accounting and Finance,
                              The University of Wollongong, Australia

Abstract

The Equator Principles, launched in 2003 and revamped in 2006, are a set of voluntary princi-
ples designed to help private lenders make socially and environmentally responsible project
financing decisions. This paper explores the impact of these principles on the disclosures of
two signatory banks, focusing on type of information disclosures that have resulted and the
substance of these disclosures. The work considers whether it is possible to ascertain from pub-
licly available information how the practices of the banks may have changed in order to focus
on their stated social and environmental responsibilities. It is concluded that although the Equa-
tor Principles have marked the beginning of the banking sectors acknowledgement of their role
in social and environmental responsibility, at this stage insufficient information is being dis-
closed to determine the impact these principles are having on actual banking practices.

Key Words: Ethical Banking, Responsible Finance, Corporate Social Responsibility, Equator
Principles, Environmental Responsibility, Corporate Codes of Conduct.


Introduction                                                complicated and the notion of a passive
                                                            identifiable audience is insufficient
Corporations are under increasing pres-                     (Macdonell, 1986; Agger, 1992). Not
sure to represent themselves to multiple                    only is the very notion of transparency a
audiences, using complex, contested and                     matter for much public debate
often competing criteria to assess the                      (evidenced by the public discussion gen-
performance of the firm (Cooper &                           erated by the collapse of private corpora-
Sherer, 1984; Cousins & Sikka, 1993;                        tions such as Enron, WorldCom, HIH;
Gray, 1992). No longer is it presumed                       Baker and Hayes, 2004), but the identity
that corporate performance can be made                      of the potential user can not be pre-
transparent through the provision of fi-                    sumed (Young, 2006), much less the
nancial information to interested users                     purpose of the reporting process
(Andrew, 2001). The firm itself is more                     (Adams, 2004). As a result, many firms
Jane Andrew is Lecturer of Accounting at School of Accounting and Finance, the University of Wollongong, Austra-
lia, email: jandrew@uow.edu.au
J. Andrew / Issues in Social and Environmental Accounting 1 (2007) 40-53                     41


are attempting to respond to these com-                         for determining, assessing and
plex expectations, not only to satisfy the                      managing social & environmental
requirements of the audiences for which                         risk in project financing
the information is produced, but also to                        (www.equator-principles.com)
produce and constitute an audience for
the information that the firm dissemi-                   In 2003, the Equator Principles were
nates (Belkaoui & Karpick, 1989; Cova-                   developed by private lending institutions
leski & Dirsmith, 1995; Hall, 1997;                      as a way to encourage private lenders to
Husted & Allen, 2006).                                   consider social and environmental issues
                                                         before funding projectsi. These princi-
Cultural practices that respond to, pro-                 ples have focused mainly on issues that
duce and reproduce social expectations                   arise as a result of project financing in
have been considered within the field of                 developing countries and are defined as
cultural and media studies (Agger, 1992;                 “a financial industry benchmark for de-
Hall, 1997), and this work is beginning                  termining, assessing and managing so-
to inform research in emerging fields                    cial risk in project financ-
such as corporate social responsibility,                 ing” (www.equator-principles.com.
sustainable reporting, environmental                     They focus specifically on ‘project fi-
accounting and ethical finance. This pa-                 nance’ and although the definition of
per utilizes Agger’s (1992) work on me-                  this may be contested within the banking
dia, culture and representation. I assume                and finance literature, for the purposes
from the outset that information pro-                    of the Equator Principles it is defined as
duced by corporations is framed discur-
sively by the institutional and cultural                       a method of funding in which the
structures that allow its emergence; it is                     lender looks primarily to the reve-
constructed and constructing, productive                       nues generated by a single project,
and reproductive, constituted and consti-                      both as the source of repayment
tutive. Accordingly, representations of                        and as security for the exposure…
and by the firm that fall into the category                    Project finance may take the form
of corporate social responsibility are part                    of financing of the construction of
of a process and are not an end in them-                       a new capital installation, or refi-
selves as these can never be controlled
entirely by the producer or the audience.            i
                                                      Over 40 banks across the globe have adopted the Equa-
This interactive process will be consid-             tor Principles including ABN AMRO Bank, N.V., ANZ,
ered in more detail throughout the paper.            Branco Bradesco, Banco do Brasil, Banco Galicia,
It is hoped that this theoretical framing            Banco Itaύ, Bank of America, BMO Financial Group,
                                                     BTMU, Barclays plc, BBVA, BES Group, Calyon, Caja
of voluntary corporate codes of conduct,             Navarra, CIBC, CIFI, Citigroup Inc., Credit Suisse
specifically the Equator Principles, can             Group, Dexia Group, Dresdner Bank, E+Co, EKF,
                                                     FMO, Fortis, HBOS, HSBC Group, HypoVereinsbank,
help develop our understanding of the                ING Group, Intesa Sanpaolo, JPMorgan Chase, KBC la
purpose, process and possible outcomes               Caixa, Manulife, MCC, Mizuho Corporate Bank, Mil-
of these codes.                                      lennium bcp, Nordea, Nedbank Group, Rabobank
                                                     Group, Royal Bank of Canada, Scotiabank, SEB, Stan-
                                                     dard Chartered Bank, SMBC, TD Bank Financial
                                                     Group, The Royal Bank of Scotland, Unibanco, Wacho-
                                                     via, Wells Fargo, WestLB AG, Westpac Banking Cor-
The Equator Principles                               poration. Many of these have only recently associated
                                                     themselves with the principles, so it will be interesting
      A financial industry benchmark                 to see how these banks illustrate their commitment in
                                                     the future.
42                 J. Andrew / Issues in Social and Environmental Accounting 1 (2007) 40-53


       nancing of an existing installation,                  largely reversible and readily
       with or without improvements. In                      addressed through mitigation
       such transactions, the lender is                      measures;
       usually paid solely or almost ex-                     Category C: Projects with minimal
       clusively out of the money gener-                     or no social or environmental
       ated by the contracts for the facil-                  impacts.
       ity’s output, such as the electricity            2.    S oc i a l a n d E n vi r on me nt a l
       sold by a power plant                                  Assessment: This does not have to
       (www.equator-principles.com)                           be done by an independent expert
                                                              unless it is a Category A project,
Once a bank became a signatory, the                           social impacts assessed under the
lender is able to advertise that they asso-                   International Covenant of Civil and
ciated themselves with projects with                          Political Rights, the International
minimal social and environmental im-                          Covenant on Economic, Social and
pact and correspondingly, these projects                      Cultural Rights ICESCR and the
would be less likely to threaten the secu-                    UN Convention on Human Rights.
rity of the lender (Kass & McCarroll,                   3.    Applicable          Social        and
2006). The principles acknowledge the                         Environmental Standards must be
substantial social and environmental                          followed (this includes host country
impact that financiers can have as they                       laws, IFC Performance Standards)
often determine the types of projects that              4.    Action Plan and Management
will progress to development stage. It is                     System: This must address any
argued that they have the power to en-                        finding in the assessment; it will
courage “responsible environmental                            describe any actions needed to
stewardship and socially responsible                          implement mitigation measures,
development” (www.equator-                                    corrective actions and monitoring
principles.com). Signatory institutions                       measures necessary to manage the
have become known as Equator Princi-                          impacts and risks. Borrowers must
ples Financial Institutions (EPFIs) and in                    design a Social and Environmental
2003 they agreed to adhere to the fol-                        Management System that addresses
lowing principles:                                            the management of these impacts,
                                                              risks and corrective regulations.
1.    Review and Categorisation: Con-                   5.    Consultation and Disclosure:
      duct a social and environmental re-                     Consult with communities affected
      view of a proposed project and cate-                    by the project.
      gorize it in terms of its impact.                 6.    Grievance           Mechanism:
      Categorisation of Projects:                             Communities will have the right to
     Category A: Projects with potential                      have their grievances heard and
     significant adverse social or                            addressed by the borrower (this is
     environmental impacts that are                           not independent of the lender and
     diverse,         irreversible      or                    does not make provisions for an
     unprecedented;                                           independent third party to oversee
     Category B: Projects with potential                      the process).
     limite d adverse social or                         7.    Independent Review: A social or
     environmental impacts that are few                       environmental expert not directly
     in number, generally site specific,                      associated with the borrower will
J. Andrew / Issues in Social and Environmental Accounting 1 (2007) 40-53      43

   review the assessment, action plan                  10th principle on EPFI Reporting stating
   and consultation process.                           that
8. Covenants: covenants linked
   compliance.                                         10. Each EPFI adopting the Equator
9. Independent Monitoring and                              Principles commits to report
   Reporting:          Independent                         publicly at least annually about its
   environmental or social expert                          Equator Principles implementation
   monitor and report on compliance                        processes and experience, taking
   over the course of the loan.                            into account appropriate
                                                           confidentiality considerations
In 2003, this provided a starting point                    (www.equator-principles.com)
for the Equator project, but there were
some significant problems. Specifically,               Although this principle acknowledges
these principles did not include a review              the importance of transparency, the
body and there were no formally identi-                statement also implies that the business
fied disclosure or transparency require-               case for non-disclosure can legitimately
ments. This meant that financial institu-              outweigh the social or environmental
tions could become signatories without                 imperatives for disclosure. It doesn’t
there being any formal mechanism to                    suggest how the information should be
scrutinize the way the institutions had                presented or the level of detail that is
integrated the principles. Wright and                  appropriate. In many ways the 10th prin-
Rwabizambuga (2006, p.91) argue that                   ciple allows banks to assert they are be-
this meant “that all Equator banks gain                ing transparent, without any pressure for
some reputational benefits irrespective                substance. Some banks may choose to
of their actual practices”. In order to ad-            disclose information in a substantial
dress these concerns, a revised version                way, but this is not an essential commit-
of the Equator Principles were issued in               ment. Although corporate disclosures
2006. A number of other changes were                   are vital to an ongoing, informed dia-
incorporated in these revised principles.              logue between the community and the
Specifically, the applicability of the                 corporation about acceptable practices, it
principles expanded to include projects                is important to acknowledge that claims
more than $10 million whereas previ-                   of transparency can be problematic. As
ously the principle affected projects                  Hall (1997) has argued, everything in its
costing more than $50million; the prin-                communication is a representation. All
ciples now apply to the expansion and                  information is mediated through lan-
upgrade of existing projects that result in            guage, discourse and institutional im-
new social and environmental impacts;                  peratives it can never be wholly reveal-
EPFI’s need to report on the progress                  ing in the way that the word transpar-
and implementation of the Equator Prin-                ency implies (Andrew, 2001). If corpo-
ciples at least annually (as outlined be-              rations are allowed to claim they are be-
low); there are tighter rules regarding                ing transparent through their disclosures,
public consultation and the handling of                it may assist in the constitution of a pas-
grievances; and there are stronger cove-               sive, uncritical audience adding to the
nants to ensure compliance with the                    challenges faced by those seeking to
policies. Perhaps the most significant                 transform banking practices.
change has been the inclusions of the
44                J. Andrew / Issues in Social and Environmental Accounting 1 (2007) 40-53


It is well documented there has been a                 foundation on which to consider that
significant increase in the number of                  changes that may occur as a result of the
firms seeking to demonstrate their ethi-               revisions and this can be the focus of
cal credentials (Neimark, 1995; Kap-                   future research.
stein, 2001; Sethi, 2002). Although there
is little doubt corporations are adopting
voluntary codes as a strategy, the pur-                The Equator Principles and
pose and impact of that strategy cannot                Project Financing Disclosures:
be presumed (Husted & Allen, 2006).                    Any News?
The World Bank, the International
Monetary Fund and the International                            Cultural studies lays bare the de-
Finance Corporation all assess the social                      ception encoded in these domi-
and environmental risks of their lending                       nant cultural artifacts, It criticizes
decisions before funding projects. These                       the needs these cultural practices
assessments have been controversial, but                       purvey through the guileful repre-
there is no doubt that this approach to                        sentations of a frozen second na-
lending is fundamental to the legitimacy                       ture – reality as it “must” be – and
and identity of these multilateral institu-                    instead suggests alternative for-
tions (Saravanamuthu, 2004; Annisette,                         mations of both human needs and
2004). In some cases, private financial                        social reality (Agger, 1992,
institutions play a role in development                        p.145)
projects. They may fund projects that the
World Bank had decided not to finance,                 In order to explore the impact of the
or they may supplement the funds pro-                  Equator Principles on the practices of
vided by the World Bank. Either way,                   signatory banks, I have examined the
the lending practices of private institu-              public disclosures of HSBC and West-
tions are increasingly scrutinized by non              pac. These banks have been chosen as a
government organizations (NGO’s)                       starting point for this analysis because
(Missbach, 2004).                                      both HSBC and Westpac were actively
                                                       involved in the design of the principles
As Branco & Rodrigues (2006, p. 234)                   and have been associated with the prin-
have noted “studies focusing on social                 ciples since their inception in 2003. It
responsibility disclosure practices by                 should be acknowledged that this is an
financial institutions are scarce” and this            initial investigation and needs to be ex-
work will assist in the development of                 tended beyond these two banks in the
research in this area. It will focus on the            future.
impact of the Equator Principles before
the release of the June 2006 revisions as              This examination is understood through
banks have yet to release information                  the theoretical lens of works by Hall
using these guidelines. This work will                 (1997) and Agger (1992). In order to
consider the information that has been                 consider the impact of the Equator Prin-
available in the public domain up to the               ciples on the banks, the banks
release of the revised principles and will             ‘responsibility report’ from 2003 (the
not extend beyond this as there has not                year the Equator Principles began) until
been sufficient time for banks to respond              2006 and publicly released information
to the changes. This study will form a                 regarding the integration of the Equator
J. Andrew / Issues in Social and Environmental Accounting 1 (2007) 40-53          45

Principles into the banks practices. It                ples commitment, in general the level of
became apparent that very little informa-              substance supporting their claims was
tion of any substance was available, all               lacking. The bank used innumerable op-
banks made references to the principles                portunities to refer to the Equator Princi-
and talked about what they were doing                  ples without providing anything more
to integrate the principles but this re-               than a stated commitment. In so doing
search revealed that the information was               they position themselves as committed,
shallow and did not enable a knowledge-                without having to produce evidence of
able reader to work out just how the                   such commitment. In this context, it is
principles were impacting on the banks                 difficult to assess the way the principles
practices in any substantial way. The                  are impacting on HSBC’s practices, let
following section considers each bank in               alone the impact these may have on the
detail.                                                actual social and environmental conse-
                                                       quences of these practices.

HSBC                                                   However, we can see that the representa-
                                                       tional performance is vital to HSBC’s
According to (Agger, 1992, p.184)                      identity as they refer to the Equator Prin-
“representation is a political practice                ciples whenever an opportunity arises.
where it encodes its content in the illu-              For instance, HSBC claim that “we do
sion of authorless stancelessness”. And                not see this as an "add-on" to our busi-
banks disclosures under the Equator                    ness, but a key part of a much wider ap-
Principles are a study in such representa-             proach to managing the sustainability of
tion. These disclosures are not apolitical,            our lending”          (http://www.hsbc.com/
they are deliberate representations of the             hsbc/csr/our-sustainable-approach-to-
firm, but are presented and represented                banking/equator-principles, Accessed:
as benign, transparent statements about                9th February, 2007). However, a detailed
position and policies. However, as Ag-                 search of the banks publicly available
ger argues they are not neutral, far from              information revealed little to substantiate
it they position the politics of the firm              this claim. HSBC also states that they
within the appearance of authorless rep-               have “established internal procedures
resentation. HSBC is the third largest                 that require all relevant project related
bank in the world by market capitaliza-                loans to be categorised in accordance
tion and they signed on to the Equator                 with the Equator Principles” (http://
Principles in 2003, taking on more high                www.hsbc.com/hsbc/csr/our-
profile roles as the chair of the Equator              s us t ai na bl e -a ppr oa c h-t o-ba n ki ng/
Principles Working Group in 2005 and                   equator-principles Accessed: 9th Febru-
as a participant in the redrafting of the              ary, 2007) but, again there is no way to
Equator Principles in 2006. As such,                   externally verify this stated commitment
they have positioned themselves as an                  and there is no legal obligation on
author, but when reporting on practices                HSBC to do so as the principles are not
relating to the principles their authorship            mandatory.
is all but invisible.
                                                       In an attempt to substantiate their com-
Having reviewed the information avail-                 mitment they claim that they report an-
able regarding HSBC’s Equator Princi-                  nually on the equator principles transac-
46                J. Andrew / Issues in Social and Environmental Accounting 1 (2007) 40-53


tions in their CSR Report, and they pro-               again, these are statements and there is
vide aggregate information but this in-                little evidence to support these claims or
formation lacks substance, it reveals                  information in order to understand how
nothing about the nature of the projects               the training is being conducted and what
they are engaging, or the internal proc-               aspects of the principles are being imple-
esses in place to assess them against the              mented, at what level and for what pur-
Equator Principles. There is little con-               pose. The intention is delimited, and the
cern about the ways the banks decisions                focus is created – irrespective of how
may have changed the social and envi-                  this can be traced to improved social and
ronmental outcomes experienced at the                  environmental performance.
project site. This kind of detail would
enable a user to understand how the                    To a large extent the Equator Principles
bank is creating a ‘better world’, rather              are self referential in that the banks can
than just internal procedures to meet the              employ “independent experts” or
principles with little external verifica-              “independent consultants” to advise
tion.                                                  them. This advice is not made public,
                                                       and the level of independence is not en-
On closer inspection of HSBC CSR Re-                   sured, they purely make the statement
ports they are disclosing some informa-                that they “retain a panel of consultants
tion in relation to the principles. In                 covering various industry sectors, envi-
HSBC’s 2003 CSR Report they are com-                   ronmental and social risk capabilities,
mitted to report summary numbers for                   and geographic locations, which our
the total value and volume of project                  Project Finance teams can draw upon.
finance deals booked. In their discussion              The selection of consultants is managed
on the implementation of the Equator                   centrally by Project Finance, with guid-
Principles they say they’ll update their               ance from the Environmental Risk Unit
procedures manual and train staff in-                  as appropriate.” (http://www.hsbc.com/
volved in the project finance and that                 hsbc/csr/our-sustainable-approach-to-
demonstration that they are adhering to                banking/equator-principles Accessed: 9th
the Equator Principles will be provided                February, 2007). There is no way of ex-
through the previously mentioned sum-                  ternally verifying the quality of this ad-
mary report. This is their commitment to               vice, or the level of bias that may ensue
public information. This is a cultural                 from the commercial arrangements
practice that can “situate the creation of             agreed to when providing the advice and
cultural artifacts in complex and eco-                 so on. However, the firm is able to rep-
nomic spaces within which creative ac-                 resent itself as legitimate, with external
tivity is conditioned, even deter-                     experts verifying their internal proce-
mined” (Agger, 1992, p.13). The asser-                 dures seamlessly creating a discourse of
tion of the corporate agenda on the proc-              legitimacy to which they can fulfil and
esses possible through the Equator Prin-               control.
ciples can be revealed in the limits, the
invisible spaces that are not represented              HSBC also reveals they are focused on
by the firm. Following on from this,                   the reputational benefits the Equator
HSBC’s CSR reports also focus consid-                  Principles provide, as opposed to the
erably on their commitment to training                 social and environmental contribution
staff on the Equator Principles, but                   that banks can make through improved
J. Andrew / Issues in Social and Environmental Accounting 1 (2007) 40-53       47


commitment to responsible lending. For                       December 2004), in so doing, they
instance, they state that they want “to                      readvertise their commitment to the
help mitigate environmental credit risk                      principles although there is no direct
and adverse impacts on our reputation”                       link between the two.
so they “have developed guidelines and                  3.   The release of HSBC’s chemical
have adopted internationally recognised                      industry sector guidelines is an op-
codes of conduct, such as the Equator                        portunity for them to note that it
Principles, to help us in our decision-                      reinforces the “the Group’s adoption
making.” (HSBC, Key CSR issues 30,                           in 2003 of the Equator Principles - a
June 2006, www.hsbc.com). The banks                          set of voluntary guidelines applied
perception that an association with the                      to project finance activi-
principles has positive reputational bene-                   ties.” (HSBC launches chemicals
fits is evident in the way they refer to the                 industry sector guideline, 03 August
Equator Principles every time they re-                       2005).
lease information about any project that                4.   They also claim that their freshwater
is associated with responsible behaviour.                    infrastructure guidelines “reinforce
Again, the self referential nature of the                    HSBC’s commitment to the Equator
Equator Principles is evident upon any                       Principles, a set of voluntary guide-
detailed consideration of the banks state-                   lines providing a common frame-
ments regarding the principles. It be-                       work for major banks to address
came apparent that everything HSBC                           environmental and social issues
did that linked to the community or the                      arising from financing pro-
environment presented an opportunity to                      jects.” (HSBC launches freshwater
promote the Equator Principles. For ex-                      infrastructure guideline, 27 May
ample:                                                       2005).
                                                        5.   The launch of a climate change part-
1.   The release of their forest sector                      nership with Newcastle University
     guidelines allows them to say “the                      and the University of East Anglia
     guideline announced today demon-                        enabled them to say that “in 2003,
     strates our commitment to the Equa-                     HSBC adopted the Equator Princi-
     tor Principles in relation to the for-                  ples” (HSBC launches climate
     est land and forest products sec-                       change partnership, 08 December
     tor” (HSBC launches forest sector                       2004) even though there is no direct
     guideline, 28 May 2004), even                           link between these two projects.
     though there is no direct relation-
     ship.                                              Obviously, HSBC is representing their
2.    When discussing their effort to be a              bank as a socially and environmentally
     ‘carbon neutral’ bank they say “this               responsible lender. The strategies out-
     complements the actions it is al-                  lined above would suggest they are us-
     ready taking to address the indirect               ing any given opportunity to use the
     impact it has on environmental and                 Equator Principles to reposition the firm
     social issues arising when financing               in this light. Unfortunately, at the stage
     projects for customers. For example,               it is impossible to tell if these are having
     in 2003, HSBC adopted the Equator                  a positive impact on the internal prac-
     Principles.” (HSBC world’s first                   tices of the bank, a situation that may
     major bank to go carbon neutral, 6                 change as the disclosure requirements of
48                J. Andrew / Issues in Social and Environmental Accounting 1 (2007) 40-53


the Equator Principles change.                         on by the Equator Principles. They state
                                                       that 13 projects were financed in the
                                                       year (all in Australia and the Pacific Is-
Westpac                                                lands), 6 new projects, 1 to buy an exist-
                                                       ing asset and six were for the refinanc-
      “A radical cultural studies inter-               ing of an existing asset. They state that 4
      venes politically where it chal-                 had capital costs below $50million, but
      lenges representation to theorize                they do not say if these underwent the
      itself, understanding how the rep-               same assessment process or not. The
      ertoire of interpretive activities in            summary information is very ambigu-
      which we habitually and thought-                 ous, giving detail but not substantial
      lessly engage is, in fact, a careful             enough to consider how the Equator
      political construction – call it ide-            Principles are working. They declined “a
      ology” (Agger, 1992, p.183)                      number of transactions” but claim this
                                                       was not because of breaches of the
Westpac is the only Australian bank to                 Equator Principles offering no insight
adopt the Equator Principles, having                   into the internal processes used for as-
become a signatory in 2003. Westpac’s                  sessment, whether any projects under-
2004 Stakeholder Impact Report, ac-                    went additional investigation based on
knowledges the banks commitment to                     the Equator Principles, whether they
the Equator Principles but provides no                 hired external advises to assist in the
material evidence of the incorporation of              assessment of the projects, or whether
these into their practices. They state the             the projects needed to undergo any
“we felt it was important to support this              changes to meet the banks standards. In
initiative so that standards such as these             essence, very little information was pro-
are adopted by all banks in the market-                vided.
place and the likelihood of competition
between banks on environmental and                     In Westpac’s 2006 Stakeholder Impact
social grounds is minimised” (SIR 2004,                Report, they congratulate themselves on
p.35). In this statement, the bank clearly             making their commitment to the
articulated a strategic interest in the de-            “Actually quite stunning” (their words
velopment of the Equator Principles, but               2006, p.7) Equator Principles and that
such an interest would leave any inter-                they had successfully marketed them-
ested party to wonder whether such this                selves as an environmentally responsible
interest was to further development, in-               bank through their 2006 advertising
novation, commitment. The emergent                     campaign. They claim this has led to
representations are political (Agger,                  request for more information and that it
1992)                                                  has been met “with an astounding re-
                                                       sponse” (2006, p.27), but they do not
In Westpac’s 2005 Stakeholder Impact                   disclose whether they are providing this
Report, they reaffirm their commitment                 additional information and in what form.
to the Equator Principles, again they use              The aggregate information proves no
this opportunity to emphasise that they                more substantial than the previous year,
are the sole Australian signatory. Like                with them claiming that they closed 14
HSBC, Westpac offers some aggregate                    deals, 6 new, 1 an expansion of an exist-
information outlining projects impacted                ing asset, and 7 refinancing of an exist-
J. Andrew / Issues in Social and Environmental Accounting 1 (2007) 40-53      49


ing asset. Equator Principles applied to                    2006, Westpac report finds risks and
all except one as it was below                              opportunities in climate change);
$10million. Again they state that “a                   2.   When discussing corporate environ-
number of transactions were declined                        mental policy and governance on
during the past year, several for reasons                   their website Westpac highlights
i nc l udi ng e nvi r on me nt a l c on-                    their commitment to the Equator
cerns” (p.31) but do not elaborate on                       Principles         stating       that
this. Interestingly, unlike HSBC, they                      “environmental considerations are
don’t tell the audience how much the                        factored into our investment and
projects are worth to them. We have no                      lending decisions and we also ad-
idea of the size of this section of West-                   here to the Equator Principles in
pac’s business and how substantially it                     managing environmental and social
will impact on the firm. We are to be-                      risk in project finance” (http://
lieve they are doing a good job as the                      www.westpac.com.au/internet/
external audit report stated that “as a                     publish.nsf/content/wicrevpg%
result of testing Equator Principles im-                    20our%20commitment);
plementation we concluded that the                     3.   Westpac promotes its receipt of the
overall approach and process is robust.                     award for the “Best Project Finance
In addition, we identified a small num-                     Bank in Australasia for 2006” by
ber of improvement opportuni-                               Global Finance magazine, with ref-
ties” (p.91).                                               erence to their commitment to the
                                                            Equator Principles’s. This reference
As outlined in the case of HSBC, West-                      has little to do with the award, but
pac also uses any mention of anything                       allows the bank to state that they are
related to corporate social or environ-                     signatories to them and that they are
mental responsibility provides them with                    committed to promoting responsible
an opportunity to mention the Equator                       project finance. (http://
Principles. These references provide lit-                   www.westpac.com.au/internet/
tle opportunity for external verification                   publish.nsf/content/wicrln%20cr%
of internal change or commitment to the                     20archived%20news%2023%
substance of the Equator Principles. In-                    20october%202006, 23 October
stead their lack of substance reinforces                    2006, Westpac wins project finance
the impression that these principles are                    award);
being exploited for their marketing po-                4.   They also received a AAA
tential. For example:                                       (outstanding) rating from RepuTex
                                                            Social Responsibility Rating,
1.   Westpac acknowledges the impor-                        wherein along with other factors,
     tance of carbon neutral business                       Westpac was noted for the only
     practices and then outlines the banks                  Australian bank to sign the Equator
     commitment to all environmental                        Principles;
     policies including its commitment                 5.   When discussing the opening of an
     “to the revised Equator Principles, a                  educational residential eco-village
     framework for assessing social and                     funded by the bank in South East
     environmental risk in project fi-                      Queensland, the state “Westpac re-
     nance - the only Australian bank to                    mains the only Australian bank to
     do so” (Westpac, 13 December                           become a signatory of the Equator
50                J. Andrew / Issues in Social and Environmental Accounting 1 (2007) 40-53


     Principles.”(http://                              this voluntary code and the representa-
     www.westpac.com.au/internet/                      tional performance through which they
     publish.nsf/content/wimcmr06%                     operate, it has been revealed that banks
     20archive%20media%20release%                      are saying little of substance about their
     2024%20july%20200b, 24 July                       impact on the social and environmental
     2006, Westpac finances Australia's                practices of the bank. Instead they form
     first educational residential eco-                part of a greater dialogue about how to
     village). This reference to the Equa-             represent the bank that is not devoid of
     tor Principles has nothing to do with             real world consequences, some of which
     the project, but reinforces the image             may have positive social and environ-
     of a globally responsible lender.                 mental outcomes. However, as Agger
                                                       (1992) has pointed out the cultural logic
This research shows that Westpac is de-                of late capitalism pits the expansionist
ploying very similar strategies to that                agenda of corporate strategy against the
adopted by HSBC, using the Equator                     social and environmental responsibilities
Principles to reposition the firm as so-               of the modern corporation. Codes such
cially and environmentally responsible.                as the Equator Principles are not author-
Just as HSBC may well be undergoing                    less, stanceless offerings in a politically
internal changes that can substantiate                 neutral world. Instead, they are sophisti-
such a claim, Westpac may be engaging                  cated attempts to position the firm
in similar internal transformations re-                within the contemporary pressures of the
quired to live up to these claims – but                modern socio-political environment and
they are not making these clear to the                 they are inescapably political. They are a
public, so a reader could be forgiven for              deliberate act of representation, but they
thinking that the Equator P                            are participatory and through an audi-
rinciples lack substance. Time will tell,              ences critical readings of the disclosures
and more research will be required in                  of banks new representations will form,
order to assess the impact of the Equator              that may lead to changes that have posi-
Principles on banking practices.                       tive social and environmental conse-
                                                       quences.

Conclusions
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11.pp.0040www.iiste.org call for paper-53

  • 1. Issues in Social and Environmental Accounting Vol. 1, No. 1 June 2007 Pp. 40-53 The Equator Principles, Project Finance and the Challenge of Social and Environmental Responsibility Jane Andrew School of Accounting and Finance, The University of Wollongong, Australia Abstract The Equator Principles, launched in 2003 and revamped in 2006, are a set of voluntary princi- ples designed to help private lenders make socially and environmentally responsible project financing decisions. This paper explores the impact of these principles on the disclosures of two signatory banks, focusing on type of information disclosures that have resulted and the substance of these disclosures. The work considers whether it is possible to ascertain from pub- licly available information how the practices of the banks may have changed in order to focus on their stated social and environmental responsibilities. It is concluded that although the Equa- tor Principles have marked the beginning of the banking sectors acknowledgement of their role in social and environmental responsibility, at this stage insufficient information is being dis- closed to determine the impact these principles are having on actual banking practices. Key Words: Ethical Banking, Responsible Finance, Corporate Social Responsibility, Equator Principles, Environmental Responsibility, Corporate Codes of Conduct. Introduction complicated and the notion of a passive identifiable audience is insufficient Corporations are under increasing pres- (Macdonell, 1986; Agger, 1992). Not sure to represent themselves to multiple only is the very notion of transparency a audiences, using complex, contested and matter for much public debate often competing criteria to assess the (evidenced by the public discussion gen- performance of the firm (Cooper & erated by the collapse of private corpora- Sherer, 1984; Cousins & Sikka, 1993; tions such as Enron, WorldCom, HIH; Gray, 1992). No longer is it presumed Baker and Hayes, 2004), but the identity that corporate performance can be made of the potential user can not be pre- transparent through the provision of fi- sumed (Young, 2006), much less the nancial information to interested users purpose of the reporting process (Andrew, 2001). The firm itself is more (Adams, 2004). As a result, many firms Jane Andrew is Lecturer of Accounting at School of Accounting and Finance, the University of Wollongong, Austra- lia, email: jandrew@uow.edu.au
  • 2. J. Andrew / Issues in Social and Environmental Accounting 1 (2007) 40-53 41 are attempting to respond to these com- for determining, assessing and plex expectations, not only to satisfy the managing social & environmental requirements of the audiences for which risk in project financing the information is produced, but also to (www.equator-principles.com) produce and constitute an audience for the information that the firm dissemi- In 2003, the Equator Principles were nates (Belkaoui & Karpick, 1989; Cova- developed by private lending institutions leski & Dirsmith, 1995; Hall, 1997; as a way to encourage private lenders to Husted & Allen, 2006). consider social and environmental issues before funding projectsi. These princi- Cultural practices that respond to, pro- ples have focused mainly on issues that duce and reproduce social expectations arise as a result of project financing in have been considered within the field of developing countries and are defined as cultural and media studies (Agger, 1992; “a financial industry benchmark for de- Hall, 1997), and this work is beginning termining, assessing and managing so- to inform research in emerging fields cial risk in project financ- such as corporate social responsibility, ing” (www.equator-principles.com. sustainable reporting, environmental They focus specifically on ‘project fi- accounting and ethical finance. This pa- nance’ and although the definition of per utilizes Agger’s (1992) work on me- this may be contested within the banking dia, culture and representation. I assume and finance literature, for the purposes from the outset that information pro- of the Equator Principles it is defined as duced by corporations is framed discur- sively by the institutional and cultural a method of funding in which the structures that allow its emergence; it is lender looks primarily to the reve- constructed and constructing, productive nues generated by a single project, and reproductive, constituted and consti- both as the source of repayment tutive. Accordingly, representations of and as security for the exposure… and by the firm that fall into the category Project finance may take the form of corporate social responsibility are part of financing of the construction of of a process and are not an end in them- a new capital installation, or refi- selves as these can never be controlled entirely by the producer or the audience. i Over 40 banks across the globe have adopted the Equa- This interactive process will be consid- tor Principles including ABN AMRO Bank, N.V., ANZ, ered in more detail throughout the paper. Branco Bradesco, Banco do Brasil, Banco Galicia, It is hoped that this theoretical framing Banco Itaύ, Bank of America, BMO Financial Group, BTMU, Barclays plc, BBVA, BES Group, Calyon, Caja of voluntary corporate codes of conduct, Navarra, CIBC, CIFI, Citigroup Inc., Credit Suisse specifically the Equator Principles, can Group, Dexia Group, Dresdner Bank, E+Co, EKF, FMO, Fortis, HBOS, HSBC Group, HypoVereinsbank, help develop our understanding of the ING Group, Intesa Sanpaolo, JPMorgan Chase, KBC la purpose, process and possible outcomes Caixa, Manulife, MCC, Mizuho Corporate Bank, Mil- of these codes. lennium bcp, Nordea, Nedbank Group, Rabobank Group, Royal Bank of Canada, Scotiabank, SEB, Stan- dard Chartered Bank, SMBC, TD Bank Financial Group, The Royal Bank of Scotland, Unibanco, Wacho- via, Wells Fargo, WestLB AG, Westpac Banking Cor- The Equator Principles poration. Many of these have only recently associated themselves with the principles, so it will be interesting A financial industry benchmark to see how these banks illustrate their commitment in the future.
  • 3. 42 J. Andrew / Issues in Social and Environmental Accounting 1 (2007) 40-53 nancing of an existing installation, largely reversible and readily with or without improvements. In addressed through mitigation such transactions, the lender is measures; usually paid solely or almost ex- Category C: Projects with minimal clusively out of the money gener- or no social or environmental ated by the contracts for the facil- impacts. ity’s output, such as the electricity 2. S oc i a l a n d E n vi r on me nt a l sold by a power plant Assessment: This does not have to (www.equator-principles.com) be done by an independent expert unless it is a Category A project, Once a bank became a signatory, the social impacts assessed under the lender is able to advertise that they asso- International Covenant of Civil and ciated themselves with projects with Political Rights, the International minimal social and environmental im- Covenant on Economic, Social and pact and correspondingly, these projects Cultural Rights ICESCR and the would be less likely to threaten the secu- UN Convention on Human Rights. rity of the lender (Kass & McCarroll, 3. Applicable Social and 2006). The principles acknowledge the Environmental Standards must be substantial social and environmental followed (this includes host country impact that financiers can have as they laws, IFC Performance Standards) often determine the types of projects that 4. Action Plan and Management will progress to development stage. It is System: This must address any argued that they have the power to en- finding in the assessment; it will courage “responsible environmental describe any actions needed to stewardship and socially responsible implement mitigation measures, development” (www.equator- corrective actions and monitoring principles.com). Signatory institutions measures necessary to manage the have become known as Equator Princi- impacts and risks. Borrowers must ples Financial Institutions (EPFIs) and in design a Social and Environmental 2003 they agreed to adhere to the fol- Management System that addresses lowing principles: the management of these impacts, risks and corrective regulations. 1. Review and Categorisation: Con- 5. Consultation and Disclosure: duct a social and environmental re- Consult with communities affected view of a proposed project and cate- by the project. gorize it in terms of its impact. 6. Grievance Mechanism: Categorisation of Projects: Communities will have the right to Category A: Projects with potential have their grievances heard and significant adverse social or addressed by the borrower (this is environmental impacts that are not independent of the lender and diverse, irreversible or does not make provisions for an unprecedented; independent third party to oversee Category B: Projects with potential the process). limite d adverse social or 7. Independent Review: A social or environmental impacts that are few environmental expert not directly in number, generally site specific, associated with the borrower will
  • 4. J. Andrew / Issues in Social and Environmental Accounting 1 (2007) 40-53 43 review the assessment, action plan 10th principle on EPFI Reporting stating and consultation process. that 8. Covenants: covenants linked compliance. 10. Each EPFI adopting the Equator 9. Independent Monitoring and Principles commits to report Reporting: Independent publicly at least annually about its environmental or social expert Equator Principles implementation monitor and report on compliance processes and experience, taking over the course of the loan. into account appropriate confidentiality considerations In 2003, this provided a starting point (www.equator-principles.com) for the Equator project, but there were some significant problems. Specifically, Although this principle acknowledges these principles did not include a review the importance of transparency, the body and there were no formally identi- statement also implies that the business fied disclosure or transparency require- case for non-disclosure can legitimately ments. This meant that financial institu- outweigh the social or environmental tions could become signatories without imperatives for disclosure. It doesn’t there being any formal mechanism to suggest how the information should be scrutinize the way the institutions had presented or the level of detail that is integrated the principles. Wright and appropriate. In many ways the 10th prin- Rwabizambuga (2006, p.91) argue that ciple allows banks to assert they are be- this meant “that all Equator banks gain ing transparent, without any pressure for some reputational benefits irrespective substance. Some banks may choose to of their actual practices”. In order to ad- disclose information in a substantial dress these concerns, a revised version way, but this is not an essential commit- of the Equator Principles were issued in ment. Although corporate disclosures 2006. A number of other changes were are vital to an ongoing, informed dia- incorporated in these revised principles. logue between the community and the Specifically, the applicability of the corporation about acceptable practices, it principles expanded to include projects is important to acknowledge that claims more than $10 million whereas previ- of transparency can be problematic. As ously the principle affected projects Hall (1997) has argued, everything in its costing more than $50million; the prin- communication is a representation. All ciples now apply to the expansion and information is mediated through lan- upgrade of existing projects that result in guage, discourse and institutional im- new social and environmental impacts; peratives it can never be wholly reveal- EPFI’s need to report on the progress ing in the way that the word transpar- and implementation of the Equator Prin- ency implies (Andrew, 2001). If corpo- ciples at least annually (as outlined be- rations are allowed to claim they are be- low); there are tighter rules regarding ing transparent through their disclosures, public consultation and the handling of it may assist in the constitution of a pas- grievances; and there are stronger cove- sive, uncritical audience adding to the nants to ensure compliance with the challenges faced by those seeking to policies. Perhaps the most significant transform banking practices. change has been the inclusions of the
  • 5. 44 J. Andrew / Issues in Social and Environmental Accounting 1 (2007) 40-53 It is well documented there has been a foundation on which to consider that significant increase in the number of changes that may occur as a result of the firms seeking to demonstrate their ethi- revisions and this can be the focus of cal credentials (Neimark, 1995; Kap- future research. stein, 2001; Sethi, 2002). Although there is little doubt corporations are adopting voluntary codes as a strategy, the pur- The Equator Principles and pose and impact of that strategy cannot Project Financing Disclosures: be presumed (Husted & Allen, 2006). Any News? The World Bank, the International Monetary Fund and the International Cultural studies lays bare the de- Finance Corporation all assess the social ception encoded in these domi- and environmental risks of their lending nant cultural artifacts, It criticizes decisions before funding projects. These the needs these cultural practices assessments have been controversial, but purvey through the guileful repre- there is no doubt that this approach to sentations of a frozen second na- lending is fundamental to the legitimacy ture – reality as it “must” be – and and identity of these multilateral institu- instead suggests alternative for- tions (Saravanamuthu, 2004; Annisette, mations of both human needs and 2004). In some cases, private financial social reality (Agger, 1992, institutions play a role in development p.145) projects. They may fund projects that the World Bank had decided not to finance, In order to explore the impact of the or they may supplement the funds pro- Equator Principles on the practices of vided by the World Bank. Either way, signatory banks, I have examined the the lending practices of private institu- public disclosures of HSBC and West- tions are increasingly scrutinized by non pac. These banks have been chosen as a government organizations (NGO’s) starting point for this analysis because (Missbach, 2004). both HSBC and Westpac were actively involved in the design of the principles As Branco & Rodrigues (2006, p. 234) and have been associated with the prin- have noted “studies focusing on social ciples since their inception in 2003. It responsibility disclosure practices by should be acknowledged that this is an financial institutions are scarce” and this initial investigation and needs to be ex- work will assist in the development of tended beyond these two banks in the research in this area. It will focus on the future. impact of the Equator Principles before the release of the June 2006 revisions as This examination is understood through banks have yet to release information the theoretical lens of works by Hall using these guidelines. This work will (1997) and Agger (1992). In order to consider the information that has been consider the impact of the Equator Prin- available in the public domain up to the ciples on the banks, the banks release of the revised principles and will ‘responsibility report’ from 2003 (the not extend beyond this as there has not year the Equator Principles began) until been sufficient time for banks to respond 2006 and publicly released information to the changes. This study will form a regarding the integration of the Equator
  • 6. J. Andrew / Issues in Social and Environmental Accounting 1 (2007) 40-53 45 Principles into the banks practices. It ples commitment, in general the level of became apparent that very little informa- substance supporting their claims was tion of any substance was available, all lacking. The bank used innumerable op- banks made references to the principles portunities to refer to the Equator Princi- and talked about what they were doing ples without providing anything more to integrate the principles but this re- than a stated commitment. In so doing search revealed that the information was they position themselves as committed, shallow and did not enable a knowledge- without having to produce evidence of able reader to work out just how the such commitment. In this context, it is principles were impacting on the banks difficult to assess the way the principles practices in any substantial way. The are impacting on HSBC’s practices, let following section considers each bank in alone the impact these may have on the detail. actual social and environmental conse- quences of these practices. HSBC However, we can see that the representa- tional performance is vital to HSBC’s According to (Agger, 1992, p.184) identity as they refer to the Equator Prin- “representation is a political practice ciples whenever an opportunity arises. where it encodes its content in the illu- For instance, HSBC claim that “we do sion of authorless stancelessness”. And not see this as an "add-on" to our busi- banks disclosures under the Equator ness, but a key part of a much wider ap- Principles are a study in such representa- proach to managing the sustainability of tion. These disclosures are not apolitical, our lending” (http://www.hsbc.com/ they are deliberate representations of the hsbc/csr/our-sustainable-approach-to- firm, but are presented and represented banking/equator-principles, Accessed: as benign, transparent statements about 9th February, 2007). However, a detailed position and policies. However, as Ag- search of the banks publicly available ger argues they are not neutral, far from information revealed little to substantiate it they position the politics of the firm this claim. HSBC also states that they within the appearance of authorless rep- have “established internal procedures resentation. HSBC is the third largest that require all relevant project related bank in the world by market capitaliza- loans to be categorised in accordance tion and they signed on to the Equator with the Equator Principles” (http:// Principles in 2003, taking on more high www.hsbc.com/hsbc/csr/our- profile roles as the chair of the Equator s us t ai na bl e -a ppr oa c h-t o-ba n ki ng/ Principles Working Group in 2005 and equator-principles Accessed: 9th Febru- as a participant in the redrafting of the ary, 2007) but, again there is no way to Equator Principles in 2006. As such, externally verify this stated commitment they have positioned themselves as an and there is no legal obligation on author, but when reporting on practices HSBC to do so as the principles are not relating to the principles their authorship mandatory. is all but invisible. In an attempt to substantiate their com- Having reviewed the information avail- mitment they claim that they report an- able regarding HSBC’s Equator Princi- nually on the equator principles transac-
  • 7. 46 J. Andrew / Issues in Social and Environmental Accounting 1 (2007) 40-53 tions in their CSR Report, and they pro- again, these are statements and there is vide aggregate information but this in- little evidence to support these claims or formation lacks substance, it reveals information in order to understand how nothing about the nature of the projects the training is being conducted and what they are engaging, or the internal proc- aspects of the principles are being imple- esses in place to assess them against the mented, at what level and for what pur- Equator Principles. There is little con- pose. The intention is delimited, and the cern about the ways the banks decisions focus is created – irrespective of how may have changed the social and envi- this can be traced to improved social and ronmental outcomes experienced at the environmental performance. project site. This kind of detail would enable a user to understand how the To a large extent the Equator Principles bank is creating a ‘better world’, rather are self referential in that the banks can than just internal procedures to meet the employ “independent experts” or principles with little external verifica- “independent consultants” to advise tion. them. This advice is not made public, and the level of independence is not en- On closer inspection of HSBC CSR Re- sured, they purely make the statement ports they are disclosing some informa- that they “retain a panel of consultants tion in relation to the principles. In covering various industry sectors, envi- HSBC’s 2003 CSR Report they are com- ronmental and social risk capabilities, mitted to report summary numbers for and geographic locations, which our the total value and volume of project Project Finance teams can draw upon. finance deals booked. In their discussion The selection of consultants is managed on the implementation of the Equator centrally by Project Finance, with guid- Principles they say they’ll update their ance from the Environmental Risk Unit procedures manual and train staff in- as appropriate.” (http://www.hsbc.com/ volved in the project finance and that hsbc/csr/our-sustainable-approach-to- demonstration that they are adhering to banking/equator-principles Accessed: 9th the Equator Principles will be provided February, 2007). There is no way of ex- through the previously mentioned sum- ternally verifying the quality of this ad- mary report. This is their commitment to vice, or the level of bias that may ensue public information. This is a cultural from the commercial arrangements practice that can “situate the creation of agreed to when providing the advice and cultural artifacts in complex and eco- so on. However, the firm is able to rep- nomic spaces within which creative ac- resent itself as legitimate, with external tivity is conditioned, even deter- experts verifying their internal proce- mined” (Agger, 1992, p.13). The asser- dures seamlessly creating a discourse of tion of the corporate agenda on the proc- legitimacy to which they can fulfil and esses possible through the Equator Prin- control. ciples can be revealed in the limits, the invisible spaces that are not represented HSBC also reveals they are focused on by the firm. Following on from this, the reputational benefits the Equator HSBC’s CSR reports also focus consid- Principles provide, as opposed to the erably on their commitment to training social and environmental contribution staff on the Equator Principles, but that banks can make through improved
  • 8. J. Andrew / Issues in Social and Environmental Accounting 1 (2007) 40-53 47 commitment to responsible lending. For December 2004), in so doing, they instance, they state that they want “to readvertise their commitment to the help mitigate environmental credit risk principles although there is no direct and adverse impacts on our reputation” link between the two. so they “have developed guidelines and 3. The release of HSBC’s chemical have adopted internationally recognised industry sector guidelines is an op- codes of conduct, such as the Equator portunity for them to note that it Principles, to help us in our decision- reinforces the “the Group’s adoption making.” (HSBC, Key CSR issues 30, in 2003 of the Equator Principles - a June 2006, www.hsbc.com). The banks set of voluntary guidelines applied perception that an association with the to project finance activi- principles has positive reputational bene- ties.” (HSBC launches chemicals fits is evident in the way they refer to the industry sector guideline, 03 August Equator Principles every time they re- 2005). lease information about any project that 4. They also claim that their freshwater is associated with responsible behaviour. infrastructure guidelines “reinforce Again, the self referential nature of the HSBC’s commitment to the Equator Equator Principles is evident upon any Principles, a set of voluntary guide- detailed consideration of the banks state- lines providing a common frame- ments regarding the principles. It be- work for major banks to address came apparent that everything HSBC environmental and social issues did that linked to the community or the arising from financing pro- environment presented an opportunity to jects.” (HSBC launches freshwater promote the Equator Principles. For ex- infrastructure guideline, 27 May ample: 2005). 5. The launch of a climate change part- 1. The release of their forest sector nership with Newcastle University guidelines allows them to say “the and the University of East Anglia guideline announced today demon- enabled them to say that “in 2003, strates our commitment to the Equa- HSBC adopted the Equator Princi- tor Principles in relation to the for- ples” (HSBC launches climate est land and forest products sec- change partnership, 08 December tor” (HSBC launches forest sector 2004) even though there is no direct guideline, 28 May 2004), even link between these two projects. though there is no direct relation- ship. Obviously, HSBC is representing their 2. When discussing their effort to be a bank as a socially and environmentally ‘carbon neutral’ bank they say “this responsible lender. The strategies out- complements the actions it is al- lined above would suggest they are us- ready taking to address the indirect ing any given opportunity to use the impact it has on environmental and Equator Principles to reposition the firm social issues arising when financing in this light. Unfortunately, at the stage projects for customers. For example, it is impossible to tell if these are having in 2003, HSBC adopted the Equator a positive impact on the internal prac- Principles.” (HSBC world’s first tices of the bank, a situation that may major bank to go carbon neutral, 6 change as the disclosure requirements of
  • 9. 48 J. Andrew / Issues in Social and Environmental Accounting 1 (2007) 40-53 the Equator Principles change. on by the Equator Principles. They state that 13 projects were financed in the year (all in Australia and the Pacific Is- Westpac lands), 6 new projects, 1 to buy an exist- ing asset and six were for the refinanc- “A radical cultural studies inter- ing of an existing asset. They state that 4 venes politically where it chal- had capital costs below $50million, but lenges representation to theorize they do not say if these underwent the itself, understanding how the rep- same assessment process or not. The ertoire of interpretive activities in summary information is very ambigu- which we habitually and thought- ous, giving detail but not substantial lessly engage is, in fact, a careful enough to consider how the Equator political construction – call it ide- Principles are working. They declined “a ology” (Agger, 1992, p.183) number of transactions” but claim this was not because of breaches of the Westpac is the only Australian bank to Equator Principles offering no insight adopt the Equator Principles, having into the internal processes used for as- become a signatory in 2003. Westpac’s sessment, whether any projects under- 2004 Stakeholder Impact Report, ac- went additional investigation based on knowledges the banks commitment to the Equator Principles, whether they the Equator Principles but provides no hired external advises to assist in the material evidence of the incorporation of assessment of the projects, or whether these into their practices. They state the the projects needed to undergo any “we felt it was important to support this changes to meet the banks standards. In initiative so that standards such as these essence, very little information was pro- are adopted by all banks in the market- vided. place and the likelihood of competition between banks on environmental and In Westpac’s 2006 Stakeholder Impact social grounds is minimised” (SIR 2004, Report, they congratulate themselves on p.35). In this statement, the bank clearly making their commitment to the articulated a strategic interest in the de- “Actually quite stunning” (their words velopment of the Equator Principles, but 2006, p.7) Equator Principles and that such an interest would leave any inter- they had successfully marketed them- ested party to wonder whether such this selves as an environmentally responsible interest was to further development, in- bank through their 2006 advertising novation, commitment. The emergent campaign. They claim this has led to representations are political (Agger, request for more information and that it 1992) has been met “with an astounding re- sponse” (2006, p.27), but they do not In Westpac’s 2005 Stakeholder Impact disclose whether they are providing this Report, they reaffirm their commitment additional information and in what form. to the Equator Principles, again they use The aggregate information proves no this opportunity to emphasise that they more substantial than the previous year, are the sole Australian signatory. Like with them claiming that they closed 14 HSBC, Westpac offers some aggregate deals, 6 new, 1 an expansion of an exist- information outlining projects impacted ing asset, and 7 refinancing of an exist-
  • 10. J. Andrew / Issues in Social and Environmental Accounting 1 (2007) 40-53 49 ing asset. Equator Principles applied to 2006, Westpac report finds risks and all except one as it was below opportunities in climate change); $10million. Again they state that “a 2. When discussing corporate environ- number of transactions were declined mental policy and governance on during the past year, several for reasons their website Westpac highlights i nc l udi ng e nvi r on me nt a l c on- their commitment to the Equator cerns” (p.31) but do not elaborate on Principles stating that this. Interestingly, unlike HSBC, they “environmental considerations are don’t tell the audience how much the factored into our investment and projects are worth to them. We have no lending decisions and we also ad- idea of the size of this section of West- here to the Equator Principles in pac’s business and how substantially it managing environmental and social will impact on the firm. We are to be- risk in project finance” (http:// lieve they are doing a good job as the www.westpac.com.au/internet/ external audit report stated that “as a publish.nsf/content/wicrevpg% result of testing Equator Principles im- 20our%20commitment); plementation we concluded that the 3. Westpac promotes its receipt of the overall approach and process is robust. award for the “Best Project Finance In addition, we identified a small num- Bank in Australasia for 2006” by ber of improvement opportuni- Global Finance magazine, with ref- ties” (p.91). erence to their commitment to the Equator Principles’s. This reference As outlined in the case of HSBC, West- has little to do with the award, but pac also uses any mention of anything allows the bank to state that they are related to corporate social or environ- signatories to them and that they are mental responsibility provides them with committed to promoting responsible an opportunity to mention the Equator project finance. (http:// Principles. These references provide lit- www.westpac.com.au/internet/ tle opportunity for external verification publish.nsf/content/wicrln%20cr% of internal change or commitment to the 20archived%20news%2023% substance of the Equator Principles. In- 20october%202006, 23 October stead their lack of substance reinforces 2006, Westpac wins project finance the impression that these principles are award); being exploited for their marketing po- 4. They also received a AAA tential. For example: (outstanding) rating from RepuTex Social Responsibility Rating, 1. Westpac acknowledges the impor- wherein along with other factors, tance of carbon neutral business Westpac was noted for the only practices and then outlines the banks Australian bank to sign the Equator commitment to all environmental Principles; policies including its commitment 5. When discussing the opening of an “to the revised Equator Principles, a educational residential eco-village framework for assessing social and funded by the bank in South East environmental risk in project fi- Queensland, the state “Westpac re- nance - the only Australian bank to mains the only Australian bank to do so” (Westpac, 13 December become a signatory of the Equator
  • 11. 50 J. Andrew / Issues in Social and Environmental Accounting 1 (2007) 40-53 Principles.”(http:// this voluntary code and the representa- www.westpac.com.au/internet/ tional performance through which they publish.nsf/content/wimcmr06% operate, it has been revealed that banks 20archive%20media%20release% are saying little of substance about their 2024%20july%20200b, 24 July impact on the social and environmental 2006, Westpac finances Australia's practices of the bank. Instead they form first educational residential eco- part of a greater dialogue about how to village). This reference to the Equa- represent the bank that is not devoid of tor Principles has nothing to do with real world consequences, some of which the project, but reinforces the image may have positive social and environ- of a globally responsible lender. mental outcomes. However, as Agger (1992) has pointed out the cultural logic This research shows that Westpac is de- of late capitalism pits the expansionist ploying very similar strategies to that agenda of corporate strategy against the adopted by HSBC, using the Equator social and environmental responsibilities Principles to reposition the firm as so- of the modern corporation. Codes such cially and environmentally responsible. as the Equator Principles are not author- Just as HSBC may well be undergoing less, stanceless offerings in a politically internal changes that can substantiate neutral world. Instead, they are sophisti- such a claim, Westpac may be engaging cated attempts to position the firm in similar internal transformations re- within the contemporary pressures of the quired to live up to these claims – but modern socio-political environment and they are not making these clear to the they are inescapably political. They are a public, so a reader could be forgiven for deliberate act of representation, but they thinking that the Equator P are participatory and through an audi- rinciples lack substance. Time will tell, ences critical readings of the disclosures and more research will be required in of banks new representations will form, order to assess the impact of the Equator that may lead to changes that have posi- Principles on banking practices. tive social and environmental conse- quences. Conclusions References We can phrase the political agenda of this cultural studies Adams, C. (2004) "The ethical, social negatively: it wants to help people and environmental reporting- avoid domination – self defeating, performance portrayal gap", Ac- self-reproducing practices that counting, Auditing and Account- violate their own best interests ability Journal, Vol. 17, No 5, (Agger, 1992, p.196) pp. 731-757. Agger, B. (1992) Cultural Studies as The Equator Principles mark the begin- Critical Theory. London: The- ning of the financial industries recogni- Falmer Press. tion of their social and environmental Andrew, J. (2001) “Environmental Ac- impact. When the disclosure practices of counting and Accountability: two banks were considered in light of Can The Opaque Become Trans-
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