• Introduction
    • OVERVIEW
    • INTRODUCTION TO THE STANDARD BANK GROUP
    • OUR REPORTING SUITE
    • A LETTER FROM OUR CEO
    • STAKEHOLDER ENGAGEMENT
    • ASSURANCE STATEMENT
     
     
     
     
     
     
  • SEE impact areas
    • OVERVIEW
    • IMPACT REPORTING
    • 1.
      FINANCIAL INCLUSION
    • 2.
      JOB CREATION AND ENTERPRISE DEVELOPMENT
    • 3.
      INFRASTRUCTURE
    • 4.
      AFRICA TRADE AND INVESTMENT
    • 5.
      EDUCATION AND SKILLS DEVELOPMENT
    • 6.
      EMPLOYEE DEVELOPMENT AND TRAINING
     
     
  • ESG
    • OVERVIEW
    • ABOUT THIS REPORT
    • MANAGING E&S RISKS AND OPPORTUNITIES
    • OUR DIRECT ENVIRONMENTAL PERFORMANCE
    • VALUING OUR PEOPLE
    • INVESTING IN COMMUNITIES
    • PROMOTING SOUND GOVERNANCE AND INTEGRITY
    • ESG METRICS AND POLICIES
     
     
  • Transformation
    • OVERVIEW
    • INTRODUCTION
    • A LETTER FROM SBSA CE: LUNGISA FUZILE
    • STANDARD BANK’S BEE SCORECARD
    • WHERE TO FIND MORE INFORMATION
     
     
     
     
     
Managing E&S risks and opportunities continued
CLIMATE CHANGE RISK MANAGEMENT

CLIMATE CHANGE As a bank with operations across Africa, we are aware of Africa’s vulnerability to the negative impacts of climate change. We are committed to balancing the need to meet Africa’s energy and infrastructure demands with the challenges posed by climate change and the need for a just transition to a lowercarbon economy over time.

In support of our commitment to drive inclusive and sustainable economic growth in Africa, and in line with our E&S risk governance standard, we are:

  • Committed to facilitating access to affordable energy in African economies, while minimising the negative environmental impacts arising from our project finance activities;
  • Working with individual businesses and households to enable them to implement small-scale green energy solutions and adapt to and mitigate the impacts of climate change on their activities and livelihoods; and
  • Committed to reducing our carbon and water usage and reducing waste across our internal business operations, at office and branch level.

We are in the process of collecting and assessing data to develop a climate change strategy and embed consideration of climate related risks in our decision-making processes. This includes:

  • Working with our clients to mitigate or adapt to climate change events (such as rising sea levels, extreme weather events, changes in weather patterns or ambient temperatures);
  • Reducing/mitigating the negative impact of human development on climate change (such as greenhouse gas emissions); and
  • Encouraging positive impact opportunities, such as green energy development.

We will be analysing our data and portfolio to identify:

  • High-risk sectors where climate impacts can have a substantive change on our clients’ business operations, revenue and expenditure (with knock-on impacts for the group) such as mining, agriculture, and power industries;
  • Geographies where climate change risk management interventions are required or areas that present a significantly higher risk; and
  • Potential opportunities for new products that will aid in adaptation and mitigation.

We consider physical and transitional risk in our portfolio and lending analysis. Transition/regulatory risks can have financial, reputational and community support impacts on a client’s operations. Risks include:

  • Policy and legal risks, such as policy constraints on emissions, imposition of carbon tax and other applicable policies, water or land use restrictions or incentives;
  • Shifts in demand and supply due to technology and market changes;
  • Reputational risks reflecting changing customer or community perceptions of an organisation’s impact on the transition to a low carbon and climate-resilient economy; and
  • Physical risks can disrupt a project’s operations and supply chain and/or damage physical assets. They may include current and future location specific impacts, and resilience of the project to flooding and sea-level rise (in coastal zones or designated flood zones), drought and water stress, heatwaves and high peak temperatures, increased storm frequency and severity and bushfires.

Water risk management Water risk management
Water availability and security of supply, water and related ecosystem pollution, and potential risks related to changes in rainfall and water supply resulting from climate change pose potential risks in relation to lending and investment. We’re in the process of developing a strategy to manage our exposure to water-related risks. This will include:

  • The promotion of water-efficient technologies, and re-use and recycling of water;
  • Encouraging adaptation measures to reduce reliance and encourage efficient use of water especially for developments located in areas affected by drought, low rainfall, or where climate change is anticipated to reduce rainfall and/or increase dry periods; and
  • Ensuring development does not adversely pollute ground and surface water resources and, where this can occur, to ensure adequate engineering measures to prevent or minimise pollution of ground and surface water.

 

Funding water infrastructure, an increasingly scarce resource

During 2016 and 2017, much of East and Southern Africa suffered from severe drought. South Africa’s Western Cape was particularly hard hit, resulting in the looming approach of Day Zero, the day the taps would run dry in the city of Cape Town, in early 2018. While strict water management, concerted efforts by residents, and longawaited rains have delayed Day Zero, however, Cape Town remains a severely water-stressed city.

The municipality of Cape Town required an alternative feedstock for the production of potable water and given the city’s proximity to the Atlantic and Indian oceans, seawater desalination technology was selected.

Standard Bank provided finance for the installation of two desalination plants in Monwabisi and Strandfontein. This included a marine intake, onshore process plant, product injection and brine return pipeline. The plant was built in a modular format to enable future expansion. Both plants are currently running at capacity and each produces about 7 million litres of potable water per day. The plants will operate as a temporary solution to the city’s urgent water requirements. PROXA and Water Solutions SA, together with the city, collaborated with the local communities to promote job creation during the project construction phase. At the time of plant decommissioning the area will be rehabilitated, and the buildings used to house the plants could be converted to community halls or other facilities which will benefit the local communities.

This provision of financing for the desalination plants with revenue collected from the supply of water into the city’s existing reticulation system, assisted the city in meeting its emergency needs.

ENGAGING WITH POLICY MAKERS

Standard Bank Group’s policy on financing new coal-fired power plants
The policy and regulatory landscape regarding the responsibilities of financial institutions in relation to environmental impacts and climate change mitigation is evolving, while pressure from investor activists and civil society organisations to disinvest in polluting industries is simultaneously increasing. Our 2018 AGM saw shareholders raise questions about our position on financing coal-fired power stations, with a focus on proposed new independent power producers in South Africa. We have identified the risks associated with new investment in coal-fired power stations, together with the importance of adaptation and mitigation of climate change, especially in relation to water in key sectors and markets, as an important issue for Standard Bank. These issues received close attention from our executives and board members during 2018. We also continue to engage with a range of external stakeholders to understand a broad range of perspectives and potential impacts.

We recognise that, while coal is a major contributor of greenhouse gas emissions, it is also a critical component of the energy mix in certain African regions, and a source of affordable energy for underserved communities.

We have adopted a policy broadly in line with the OECD Export Credit Agency Coal-Fired Power Finance Guidelines, limiting the financing of coal-fired power generation depending on a country’s energy poverty, technology and size of plant. We undertake enhanced due diligence when assessing proposals for coal-fired generation, which involves an assessment of the current energy situation in the region and future energy demand, the proposed technology, alternative options, and compliance with national environmental and social laws, relevant international conventions, standards and treaties, IFC Performance Standards and Equator Principles, and IFC Industry Guidelines on thermal power plants, electrical power transmission and distribution. Our funding parameters set limitations on new build coal power stations. While funding is not excluded, the funding requirements for new coal power stations are based on geography, technology and size of power plant. If a proposed development does not meet our criteria, we will not provide finance. We also undertake post-finance monitoring on an ongoing basis in line with Standard Bank Group’s environmental and social policy.

RESPONSIBLE FINANCE

Standard Bank works with its clients to advise on structure and arrange socially and environmentally responsible financial products. These include:

  • Investments relating to environmental goods and services that prevent or reduce environmental degradation and conserve and maintain natural resources;
  • Investments relating to positive social outcomes such as education, health care, infrastructure, housing and employment creation; and
  • Financial system components that protect the environment by using financial instruments such as green credit, green bonds, green stock indices, carbon finance, structured green funds and related products.

Investment in renewable energy
Standard Bank supports the expansion of affordable renewable energy solutions across Africa. This includes working with governments, renewable energy companies and development finance institutions to facilitate large-scale infrastructural development. Over the past several years we have significantly increased the proportion of our energy loan book committed to green energy and decreased the proportion of finance committed to fossil fuels.

Since 2012, we have financed the construction of new power projects to the value of USD2.77 billion in Africa. 86% of this funding was for renewable energy. Lending to fossil fuel power projects represented 14% of our investments (12% natural gas and 2% heavy fuel oil/thermal, 0% coal).

Cumulative green vs brown underwrite value of
energy investments from 2012 – 2018

usd-billionUSD billion0.00.050.340.380.380.380.381.081.651.681.841.901.902.382012201320142015201620172018
green-brown-energyBROWN14%1 036 MWGREEN 86%1 953 MWUSD2.77 billionTOTAL 2 989 MWof underwrite value
green-energy GREEN – Annual cumulative underwrite (USD BN) from 2012 – 2018 of project finance power generation transactions directed towards green energy. This includes clean, non-polluting and renewable energy sources that are naturally replenished over time, e.g. solar or wind.
BROWN – Annual cumulative underwrite (USD BN) from 2012 – 2018 of project finance power generation transactions directed towards brown energy, derived from conventional fossil-fuel based energy sources that release pollutants during processing and are finite/not replenished over time, e.g. coal, oil or natural gas.

 

Jobs created from renewable energy investments in South Africa

josConstruction20 523Operation1 676Total jobs22 199

 

Estimated jobs created from Standard Bank’s investments in South African renewable energy projects (2012 – 2018)

                             
    PV       CSP     Wind       Total  
Construction (direct)   6 264       2 719     4 116       13 099  
Construction (supplier)   3 530       994     2 900       7 424  
Construction total   9 794       3 713     7 016       20 523  
Operations (direct)   673       117     715       1 505  
Operations (supplier)   113       13     45       171  
Operations total   786       130     760       1 676  
Total jobs   10 580       3 842     7 776       22 199  

References
Macroeconomic assumptions from Department of Energy Integrated Energy Plan
Average capacity factors from statistics of utility-scale solar PV, wind and CSP in South Africa in 2017 by CSIR Energy Centre

Estimated households equivalent powered from Standard Bank’s investments
house-holdPhotovoltaics (PV)399 091Concentrated solar power (CSP)71 147Wind514 661Total households984 900

 

Average household electricity consumption sourced from Exon Consulting – How much electricity does my home use, August 2016

Working conditions and employee well-being

Examples of projects financed in 2018 and the SEE impacts

Scatec Solar (Industry description – Power)
PROJECT DESCRIPTION

Construction of three new photovoltaic (PV) projects (Dyason’s Klip 1, Dyason’s Klip 2, Sirius Solar PV) with an installed capacity of 75 MW each. All three projects are located adjacent to one another close to Upington in the Northern Cape province of South Africa.

SOCIAL IMPACT
  • Approximately 300 – 395 jobs will be created for each project during construction, which will be targeted at the local communities. Approximately 60% will be available to low-skilled workers and 15% to semiskilled workers. (The construction phase is expected to last 14 – 18 months.)
  • During the operations phase, it is anticipated that between 40 and 50 jobs will be created per project.
ECONOMIC IMPACT
  • At least 5% of each project will be owned by the local community.
  • Scatec has committed to 1.5% of revenue being spent on socioeconomic development and 0.6% on enterprise development.
  • The injection of income into the area in the form of wages will represent a significant opportunity for the local economy and businesses in the Upington and Keismoes area.
  • The establishment of a community trust funded by revenue generated from the sale of energy also creates an opportunity to support local development.
ENVIRONMENTAL IMPACT
  • All three projects will produce 225 MW renewable energy, thereby avoiding the release of approximately 463 185 tonnes of CO2 equivalent into the atmosphere*.

*Carbon abatement calculated using project MWs and grid emission factor of 0.94t CO2e/MWh

Wesley Wind Farm (Industry description – Power)
PROJECT DESCRIPTION

Construction of the new Wesley 33 MW wind farm in the Eastern Cape, South Africa.

SOCIAL IMPACT
  • Approximately 127 direct full-time equivalent jobs during the construction phase.
  • About eight direct fulltime equivalent jobs during the operations phase.
  • Opportunities for SMMEs in rural areas.
  • Provision of bursaries.
  • Grassroots Youth Development Socioeconomic Development Programme.
ECONOMIC IMPACT
  • The project has been developed in partnership with affected landowners and farmers in the former Ciskei homeland.
  • EDF Renewables’ business model ensures that the Uncedo Lwethu Winds of Change equity in the project was free.
  • An agreement entered into between the project and the Department of Energy ensures the use of dividends generated from equity for community upliftment projects.
ENVIRONMENTAL IMPACT
  • The project will produce 33 MW renewable energy, thereby avoiding the production of approximately 97 825 tonnes of CO2 equivalent*.
  • Use of land already degraded by overgrazing.

*Carbon abatement calculated using project MWs and grid emission factor of 0.94t CO2e/MWh

Copperton Wind Farm (Industry description – Power)
PROJECT DESCRIPTION

Construction of a new 102 MW wind farm in the Northern Cape, South Africa.

SOCIAL IMPACT
  • More than 83% of employees are South African, and 24.85% of these are from local communities.
  • Provision of 160 jobs during construction and 80 jobs for operations.
ECONOMIC IMPACT
  • 36% of the project company shareholding is black.
  • 5% of the project company is owned by the local community.
  • Increase in renewable energy contribution to SA’s energy mix.
ENVIRONMENTAL IMPACT
  • The project will produce 102 MW renewable energy, thereby avoiding the production of approximately 302 367 tonnes of CO2 equivalent*.

*Carbon abatement calculated using project MWs and grid emission factor of 0.94t CO2e/MWh

Alten PV solar plant (Industry description – Power)
PROJECT DESCRIPTION

Construction of a new 37 MW photovoltaic (PV) power plant in Hardap, Namibia.

SOCIAL IMPACT
  • The project fulfils the energy need of 3% of Namibia’s population, or approximately 70 000 people.
  • Provided around 400 jobs during construction and will provide an average of eight to 23 jobs (the latter at the peak months) during operations.
ECONOMIC IMPACT
  • Largest photovoltaic power plant in sub- Saharan Africa outside South Africa.
  • Reduces Namibia’s reliance on imported electricity from its neighbours.
ENVIRONMENTAL IMPACT
  • The plant avoids the production of around 33 000 tonnes of CO2 equivalent every year.
  • The site had low biodiversity and low agricultural value and was not in productive use.
  • The plant connects to an existing substation on adjacent land, avoiding lengthy transmission lines to connect to the grid.

*Carbon abatement calculated using project MWs and grid emission factor of 0.94t CO2e/MWh

Solar Capital Orange (Industry description – Power)
PROJECT DESCRIPTION

Construction of a new 75 MW PV plant located in the Northern Cape.

SOCIAL IMPACT
  • The project will create approximately 800 construction phase jobs at the peak construction period, over a period of 12 months for this first phase.
  • 80% of the employment opportunities will be available to low-skilled and semi-skilled workers with the majority available to local residents.
  • Approximately 50 jobs per month will be created during the operations phase.
  • 70% of the construction and operations employees from phase 1, will be retained in phase 2.
ECONOMIC IMPACT
  • The Solar Capital Community Trust holds 5% shareholding in the project company – dividends will be used to fund projects identified by local beneficiaries.
  • 0.65% of revenue is allocated for enterprise development to fund the Annual Solar Capital Entrepreneurial Programme. Members of the community enter the programme and are mentored over eight months in the development of sustainable enterprises.
  • 1.61% of revenue is allocated for socioeconomic development and will be used to implement social programmes that were identified during stakeholder engagement (e.g. recreation facilities and upgrading of the health care facility).
ENVIRONMENTAL IMPACT
  • The project will produce 75 MW renewable energy, thereby avoiding the release of approximately 154 395 tonnes of CO2 equivalent* into the atmosphere.

*Carbon abatement calculated using project MWs and grid emission factor of 0.94t CO2e/MWh

Indorama (Eleme Petrochemicals) (Industry description – Manufacturing)
PROJECT DESCRIPTION

The construction of phase two of a nitrogenous fertiliser plant within the existing Indorama Eleme Petrochemical complex located in Port Harcourt Nigeria. This phase entails an ammonia plant, urea plant, and supporting infrastructure and utilities.

SOCIAL IMPACT
  • At the peak of construction approximately 4 000 direct and indirect jobs will be created. This will assist in addressing the growing job demand of the young Nigerian population.
  • Indorama will invest in community development projects such as the construction of schools, community health centres, markets, teachers’ quarters, youth corpers lodges, community town halls, roads and drainage systems, water supply facilities and substations and transformers to enhance electrification and water supply facilities.
  • Skills acquisition programmes for young men and women, micro grant schemes for women and annual scholarships for students in tertiary institutions will also be implemented.
ECONOMIC IMPACT
  • The additional fertiliser production capacity will allow Nigeria to be placed on the global fertiliser map as a producer and exporter, which will allow for to a significant boost in the country’s non-oil based revenues.
  • The provision of much needed fertiliser to farmers across the country will improve crop yield.
ENVIRONMENTAL IMPACT

 

*Carbon abatement calculated using project MWs and grid emission factor of 0.94t CO2e/MWh

Working conditions and employee well-being
FINANCIAL INSTRUMENTS
FINANCIAL INSTRUMENTS TO PROMOTE POSITIVE SOCIAL AND
ENVIRONMENTAL IMPACTS

Standard Bank is working on further developing positive social and environmental instruments and products in the group, some of which include:

Green lines of credit/ investments:

Green lines of credit/ investments: Standard Bank partners with green finance investors and development finance institutions (DFIs) for lines of credit that have lending criteria linked to green/climate change requirements.

Green, social, climate bonds

Green, social, climate bonds: We’re working with clients to assist in structuring, asset approval and monitoring of green bonds.

Environmental rehabilitation

Environmental rehabilitation guarantees: African countries are increasingly formalising requirements for environmental rehabilitation at the end of mine operation (planned and unscheduled closure). This has resulted in the tightening of financial provision requirements over the life of an operation to enable rehabilitation, and ongoing monitoring thereafter.

Working with businesses and households to implement small-scale green energy solutions
Standard Bank assists our clients to adopt greener solutions for their homes and businesses, for example:

  • In South Africa, our VAF solar asset solution enables our business and commercial banking clients to apply for finance of up to R1.5 million bond free to install small-scale renewable energy solutions at their businesses. The focus has been mainly on small-scale, grid-tied solar PV solutions. By September 2018, we had invested about R48 million in smallscale embedded generation projects.
  • In Zimbabwe, we provided a forex loan of R7 million to enable our client to import solar panels, batteries and other key components, to establish a 190 kW capacity solar plant on their premises. The plant is the third largest in Zimbabwe. Solar stands have been constructed in the car park, with the panels doubling as parking shades.
Supporting our agricultural
Supporting our agricultural clients during drought – update on 2016 drought

Standard Bank works closely with our clients in the agricultural sector to help them to adapt to and mitigate the impacts of climate change. In 2016 and 2017, we reported on how we worked with agriculture clients in South Africa to reduce the financial burden created by the country’s severe drought conditions.

In 2018, we again identified distressed farmers early in the season and made pro-active plans to assist them. We needed to take a careful, tailored approach to each client, recognising that their circumstances differ widely. We spent time with each client to design solutions for their unique challenges. 72 distressed agriculture clients’ overdrafts were maintained and capital payments on term loans postponed, to service only interest due. This lowered cash-flow pressure for the farmers. We also engaged with our clients to discuss more sustainable farming practices, including rotation cropping and precision farming. We introduced multi-peril insurance, which covers a broad set of conditions, to lower the risk to farmers and the bank, which led to improved cash-flow monitoring.

HUMAN RIGHTS

Standard Bank amended our human rights statement in 2017 to ensure alignment with universal principles, including the UN Guiding Principles for Business and Human Rights. The process involved consultation with internal and external stakeholders. Human rights issues, including discrimination, child labour, forced or compulsory labour and the rights of indigenous people, are assessed as part of the screening and due diligence processes associated with financing. All employees are responsible for ensuring that Standard Bank demonstrates our commitment to human rights.

Standard Bank Group statement on human rights
In keeping with our purpose, and our obligations as a responsible financial services firm in, for and across Africa, Standard Bank Group is committed to respecting the human rights of people involved in and impacted by our business. This statement aims to achieve a consistent approach to respecting human rights across Standard Bank.

Human rights are the basic and universal rights that underpin each person’s inherent freedom, dignity and equality as outlined in the United Nations Universal Declaration of Human Rights and the International Labour Organisation Declaration on Fundamental Principles and Rights at Work. We have used these universal benchmarks as our starting point for defining human rights.

Our commitment to respecting human rights is embedded in our values and code of ethics and is fundamental to ensuring our legitimacy and reputation as a corporate citizen. While nation states have a primary responsibility to protect and promote human rights, we recognise that corporations are also obligated to respect human rights.

We take any adverse human rights impacts seriously. We seek to avoid human rights infringements and being complicit in the human rights infringements of other parties. Our commitment to respecting human rights is included in many of our policies and standards. In this way, we seek to integrate respect for human rights into our day-to-day operations and in the way we do business.

We acknowledge that this is a journey, one that may differ across our regions and countries based on the institutional and regulatory setting of each country where we operate. Where local legislation may conflict with Standard Bank’s statement on human rights, we will comply with the law while seeking, within our spheres of influence, to raise awareness of human rights and provide an example of good practice through our own conduct, while being mindful of the local context.

We are committed to:
commitedThis statement is available on the Standard Bank website Contributing to the combating of financial crime and corruption in all its forms, including extortion, bribery, and money launderingAdhering to the Equator Principles in project financingProviding a work environment for our people that respects their human rights and this commitment will be reflected in our people policies and practicesRegularly reviewing our progress in meeting these commitments under the oversight of the group social and ethics committeeCommunicating about and reporting on our activities in the human rights arena through our report to society, and engaging with our stakeholders regarding the responsibilities of business in respecting and upholding human rightsRequiring our people to report any alleged or suspected human rights violations to the group’s chief ethics officer or to make use of the group’s whistleblowing hotline
Due diligence and human rights

Due diligence and human rights
The Standard Bank Group exercises due diligence in deciding who we do business with. This includes understanding the potential human rights impacts of our business relationships, purchasing, lending and investing.

  • We assess the social, economic and environmental impacts, including human rights, associated with our business decisions, including entering customer relationships and issuing of loans in line with Standard Bank Group E&S risk standard and policy, and exceptions list.
  • We comply with regulations and standards in respect of anti-money laundering, sanctions, and anti-bribery and corruption in all our countries of operation, and actively work to support the combating of financial crime and corruption in all its forms, including extortion, bribery, and money laundering.
  • We respect the privacy of our clients and abide by data privacy and protection laws.
  • We commit to ensuring that new financial products and services are assessed in terms of potential social, economic and environmental impacts, including human rights considerations, and that any risks should be evaluated and mitigated.

Our policies require that, if any human rights risk is identified as a result of a client relationship, project, product or other client interaction, the issue should be referred to GESRF, or the group’s chief ethics officer, or reported via the whistleblowing hotline (depending on the nature of the issue). We are committed to taking appropriate steps where we discover, or are made aware, that we have caused or contributed to actual or perceived human rights abuses. This may include disciplinary action, exiting a particular business relationship, or constructive engagement with others to promote better practice.

Human rights in relation to our employees
Our employees have the right to enjoy fair and just conditions of work. Our commitment to respecting this right is reflected in our human capital policies and practices, which are underpinned by our values and code of ethics. While these policies do not necessarily mention ‘human rights’ specifically, they nonetheless promote human rights directly or indirectly and are consistent with our human rights statement. Relevant policies include:

environmental-climate
Statement of intent on diversity and inclusion
Anti-harassment policy
Disability policy
Remuneration policy
Whistle-blowing policy

Human rights in relation to procurement
Standard Bank’s procurement policy commits us to ethical procurement. It specifies that:

  • All procurement transactions must be objective, transparent and fair, in line with sound corporate governance principles, and the highest procurement and ethical standards must be applied to all such transactions.
  • All suppliers should respect basic human rights and establish a clean and safe working environment. This includes not allowing forced labour, child labour or discrimination, and paying appropriate wages, regulating working hours and respecting everyone’s freedom of association.
  • The bank strives to procure goods and services that have a lesser or reduced impact on the environment and on the health and safety of workers and communities
  • All contractors, suppliers and consultants must comply with the bank’s internal requirements and with the South African Occupational Health and Safety Act and regulations at a minimum, and with environmental and social legislation in the relevant country.
  • Procurement should be aimed at supporting local suppliers while at the same time ensuring alignment to Standard Bank standards for quality, sustainability and commerciality.

Grievance mechanisms and reporting
We currently do not have a formal grievance mechanism for transaction related E&S concerns/issues. However, we actively engage with our stakeholders, including human rights and environmental organisations, and the relevant ombudsman. We have an anonymous whistle-blowing hotline in place for employees, and employees are actively encouraged, through regular communications, to report any behaviours or activities that may conflict with Standard Bank’s values and ethics.