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2011 Corporate Responsibility Report - JPMorgan Chase

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PUBLIC RESPONSIBILTY COMMITTEE OF THE BOARD<br />

HEAD OF<br />

CORPORATE<br />

RESPONSIBILITY<br />

OFFICE OF<br />

ENVIRONMENTAL<br />

AFFFAIRS<br />

CEO AND CHAIRMAN<br />

CHIEF RISK<br />

OFFICER<br />

GLOBAL<br />

REPUTATION<br />

RISK OFFICE<br />

GESRM (6 FTEs)<br />

Figure 2. Environmental and Social Risk Function<br />

Organization Chart<br />

potential level of environmental and social<br />

risk, and the appropriate level of due diligence.<br />

The team then conducts a corporate-level<br />

assessment looking at a client’s:<br />

− Commitment (typically defined by<br />

Environmental Health and Safety (EHS)<br />

policies)<br />

− Management capacity / approach<br />

(EHS management systems, community<br />

engagement)<br />

− EHS track record (accidents, spills, fines,<br />

negative press)<br />

The corporate assessment is based on<br />

publicly available information, such as a<br />

company’s website as well as annual and/<br />

or sustainability reports. Where capital is<br />

being raised for a specific asset, GESRM<br />

will conduct asset-specific due diligence,<br />

which entails reviewing relevant project<br />

documentation, such as Environmental<br />

and Social Impact Assessments (ESIA),<br />

Environmental and Social Management<br />

Plans (ESMP), specific Action Plans (e.g.,<br />

resettlement, biodiversity) or audit reports.<br />

Higher-risk transactions will often require a<br />

site visit either by GESRM or a consultant to<br />

better understand how the identified risks<br />

are being managed at the project site.<br />

If GESRM’s review identifies material<br />

risks, a transaction believed to be<br />

highly sensitive may be escalated to the<br />

Reputation Risk Committee and/or the<br />

OEA. Where improvement in a client’s<br />

performance is required (whether at a<br />

corporate or asset level), conditions or<br />

covenants will typically be defined by<br />

GESRM and included in the final decision.<br />

Where we require the client to implement<br />

specific recommendations, the GESRM<br />

team will monitor the client’s progress<br />

regularly and as new transactions arise.<br />

Asset-Specific Reviews<br />

The GESRM team’s risk review process<br />

is built on the structure of the Equator<br />

Principles, but is tailored to our individual<br />

business in capital markets. This is due to<br />

the belief that the Principles are a useful<br />

risk management framework that can, in<br />

certain circumstances, be applied beyond<br />

their project finance focus.<br />

The GESRM team assesses all transactions<br />

subject to our Environmental and Social Risk<br />

Policy to determine their environmental and<br />

social impact, categorize them appropriately<br />

and apply the correct level of due diligence.<br />

In <strong>2011</strong>, GESRM completed 268 assessments:<br />

SECTOR TOTAL<br />

Agriculture 28<br />

Chemicals 12<br />

Forestry, pulp and paper 11<br />

Infrastructure 8<br />

Manufacturing 32<br />

Mining and metals 76<br />

Oil and gas 67<br />

Power 24<br />

Shipping and Storage 5<br />

Other 5<br />

TOTAL 268<br />

REGION TOTAL<br />

Asia Pacific 97<br />

EMEA 82<br />

Latin America 36<br />

North America 53<br />

TOTAL 268<br />

CATEGORY ASIA<br />

PACIFIC<br />

EMEA LATIN<br />

AMERICA<br />

NORTH<br />

AMERICA<br />

A 1 15 15 5 12 47<br />

B 2 64 51 21 32 168<br />

C 3 18 16 10 9 53<br />

TOTAL<br />

TOTAL 97 82 36 53 268<br />

<strong>2011</strong> CORPORATE RESPONSIBILITY REPORT 59

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