| Inclusion of the requirement that SFN entities establish and implement an action plan, encouraging them to undertake socio-environmental actions. |
CONTRAF-CUT/DIEESE and GVces. |
This requirement indicates the BCB’s intention not only that the document be prepared, but also that it be put into practice. |
Inclusion of the requirement for periodic reassessment of the
Socio-environmental Responsibility Policy (SERP). |
ABDE. |
For this reassessment to take place, the BCB would have to participate in the preparation and reassessment of the SERP of SFN organizations, at least in the initial cycles. |
Establishment of the principles of relevance (the degree of exposure of the institution’s activities to
socio-environmental risk) and proportionality (the compatibility of the SERP with the nature of the institution and complexity of its activities). |
FEBRABAN,
CONTRAF-CUT/DIEESE, ABDE, and ABBC. |
The BCB appears to have incorporated these principles based on stakeholders’ contributions, possibly refining the definition through complementary research. |
| Emphasis on the need to identify, classify, assess, monitor, mitigate, and control socio-environmental risk. |
ABBI, OCB, and CONTRAF-CUT/DIEESE. |
This implies additional investments in governance structures by SFN organizations. |
Recognition that entities may be exposed to several types of risk, with socio-environmental, image, and reputational risks being only some
of them. |
ABDE, ABBI, OCB, ABBC, FEBRABAN, and CONTRAF-CUT/DIEESE. |
The prevailing definition of socio-environmental risk emphasizes the losses that SFN organizations may suffer, but not those they may cause. |
| Removal of the requirements for evaluating clients’ operations “based on consistent and verifiable criteria”. |
FEBRABAN,
CONTRAF-CUT/DIEESE, and ABBC. |
Such requirements could have led financial institutions, for example, to evaluate socio-environmental risk mitigation instruments and the guarantees offered - among other aspects - in order to create barriers to projects unconcerned with socio-environmental risks. However, the view prevailed that the number of credit concessions would decrease and that financing would become more costly as a result of this measure. |
Encouragement of stakeholder participation in the process of preparing the SERP, rather than in
its execution. |
ABDE, OCB, FEBRABAN, CONTRAF-CUT/DIEESE, and IBRACON. |
The view prevailed that stakeholder participation in the execution process would hinder implementation. |
| Removal of the term “socially just”. |
ABBC and
CONTRAF-CUT/DIEESE. |
Entities could benefit from activities carried out in favor of the “promotion of the common good”, increasing recognition, positive public image,
and reputation. |
| Removal of explicit references to ethical and transparent relationships among entities or between entities and stakeholders. |
ABBC, ABDE, CONTRAF-CUT/DIEESE; FEBRABAN, and IBRACON. |
Strengthening relationships would also mean removing stakeholders from their comfortable position as critics and sharing with them the attribute and responsibility of defining the Socio-environmental Responsibility Report (SERR). |
Complete removal, in the final text,
of the requirement to prepare and disclose the SERR. |
ABBC, GVces, CONTRAF-CUT/DIEESE, and FEBRABAN. |
With this removal, the requirements
for clarity of information, ease of access to information, and better conditions for clients to decide whether to contract and use the entity’s products and services based on its SERR were also removed. |
| Removal of most references to the socio-environmental impacts of activities, services, or products. |
FEBRABAN, OCB,
and CONTRAF-CUT/DIEESE. |
The emphasis remained on the prevention or mitigation of potential risks. The identification and correction of socio-environmental damages already incurred did not appear in the regulation. |
| Removal, in the final text, of the requirement for financial conglomerates to inform which entities compose them. |
ABBI, OCB, and CONTRAF-CUT/DIEESE. |
Financial conglomerates may include organizations with very different areas of operation. Mandatory disclosure of their composition would reveal the need for specific reports and policies for each area, which would increase technical and operational complexity but would also provide a wealth of data capable of improving the public policy in question. |
| Removal, in the final text, of the indication that entities should be concerned with generating services and products more suitable to the needs of clients and users. |
FEBRABAN and CONTRAF-CUT/DIEESE. |
The BCB possibly considered this topic too broad for the scope of the Resolution, believing it should be addressed in another context. |
Stakeholders e mudança institucional: Normatização da responsabilidade socioambiental no sistema financeiro brasileiro