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FREQUENTLY ASKED QUESTIONS
ON THE EQUATOR PRINCIPLES (EP III) UPDATE
OVERVIEW AND CONTEXT
1.
WHAT ARE THE EQUATOR PRINCIPLES? .................................................................................................... 3
2.
WHAT IS AN EQUATOR PRINCIPLES FINANCIAL INSTITUTION AND WHAT IS THE EQUATOR
PRINCIPLES ASSOCIATION?........................................................................................................................ 3
3.
HAS THE PROJECT FINANCE MARKET CHANGED SINCE THE LAUNCH OF EQUATOR PRINCIPLES? ........... 3
4.
WHY ARE THE EQUATOR PRINCIPLES BEING UPDATED AND WHAT DOES “EP III” MEAN? ...................... 3
5.
WHAT ARE THE KEY AIMS OF THE EP III UPDATE PROCESS? ..................................................................... 4
6.
WHAT ARE THE PROPOSED KEY CHANGES AND AREAS OF DEVELOPMENT IN THE EP III DRAFT?............ 5
7.
HOW WILL THE PROPOSED CHANGES TO THE EQUATOR PRINCIPLES AFFECT INDUSTRY SECTORS
AND CLIENTS?............................................................................................................................................. 5
8.
HOW CAN I CONTRIBUTE TO AND PARTICIPATE IN THE EP III UPDATE PROCESS? ................................... 5
PROPOSED KEY CHANGES AND AREAS OF DEVELOPMENT
9.
CAN YOU SUMMARISE THE PROPOSED KEY CHANGES AND AREAS OF DEVELOPMENT
IN THE EP III DRAFT?.................................................................................................................................7
10. WHY IS THE EQUATOR PRINCIPLES ASSOCIATION EXTENDING THE SCOPE OF THE EQUATOR
PRINCIPLES?............................................................................................................................................. 11
11. THE DEFINING CRITERIA FOR PROJECT-RELATED CORPORATE LOANS IS VERY SPECIFIC,
WILL THIS MEAN MANY PROJECTS WILL NOT BE ASSESSED UNDER THE EQUATOR PRINCIPLES
FRAMEWORK? ......................................................................................................................................... 12
12. WHY DOESN’T THE EQUATOR PRINCIPLES FRAMEWORK APPLY TO ALL AREAS OF FINANCE? .............. 12
13. HOW IS THE EQUATOR PRINCIPLES ASSOCIATION WORKING TO IMPROVE CONSISTENCY IN
EQUATOR PRINCIPLES IMPLEMENTATION? ............................................................................................ 13
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14. WHY HAS THE EQUATOR PRINCIPLES ASSOCIATION FOCUSED ON ENHANCED REPORTING AND
TRANSPARENCY? ..................................................................................................................................... 13
15. HOW DO THE ENHANCED REPORTING REQUIREMENTS IMPROVE COMPLIANCE AND
TRANSPARENCY? ..................................................................................................................................... 13
16. HOW IS THE EQUATOR PRINCIPLES ASSOCATION WORKING TO IMPROVE THE PROVISION OF
GRIEVANCE MECHANISMS AT PROJECT LEVEL? ...................................................................................... 13
17. HOW DO THE PROPOSED CHANGES TO THE EQUATOR PRINCIPLES ACKNOWLEDGE THE UN’S
“PROTECT, RESPECT AND REMEDY” FRAMEWORK AND GUIDING PRINICPLES ON BUSINESS
AND HUMAN RIGHTS? ............................................................................................................................ 14
18. HOW IS THE GAP BETWEEN THE EFFECTIVENESS DATE OF EP III AND THE UPDATED IFC
PERFORMANCE STANDARDS BEING MANAGED?.................................................................................... 14
19. WHY DOESN’T THE EP III DRAFT ADDRESS ALL THE RECOMMENDATIONS IN THE EQUATOR
PRINCIPLES STRATEGIC REVIEW REPORT? ............................................................................................. 15
THE EP III UPDATE PROCESS & STAKEHOLDER ENGAGEMENT
20. WHAT IS THE PROCESS FOR UPDATING THE EQUATOR PRINCIPLES? ..................................................... 16
21. HOW IS THE EQUATOR PRINCIPLES ASSOCIATION ENSURING STAKEHOLDERS ARE CONSULTED?
HOW CAN I SUBMIT COMMENTS? .......................................................................................................... 17
22. WHERE WILL MY COMMENTS GO? AND WILL THEY BE PUBLISHED? .................................................... 18
23. WILL I GET A RESPONSE? ........................................................................................................................ 18
24. HOW WILL MY COMMENTS AFFECT THE EP III DRAFT? ......................................................................... 18
25. WHEN WILL THE NEW EQUATOR PRINCIPLES BE LAUNCHED AND IMPLEMENTED? ............................. 19
26. WHO CAN I CONTACT TO ASK A QUESTION ABOUT ANY OF THIS? ........................................................ 19
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OVERVIEW AND CONTEXT
1. WHAT ARE THE EQUATOR PRINCIPLES?
The Equator Principles (EP) is a risk framework for identifying, assessing, and managing environmental and
social risks in Project Finance transactions.
The EP framework is based on the International Finance Corporation (IFC) Performance Standards on
environmental and social sustainability and on the World Bank Group Environmental, Health, and Safety
Guidelines.
There are currently 77 adopting financial institutions (74 Equator Principles Financial Institutions and 3
Associates).
2. WHAT IS AN EQUATOR PRINCIPLES FINANCIAL INSTITUTION AND WHAT IS THE EQUATOR PRINCIPLES
ASSOCIATION?
Currently, an Equator Principles Financial Institution (EPFI) is a financial institution that adopts the EP and is
active in Project Finance or Project Finance Advisory services. EPFIs commit to not providing loans to
projects where the borrower will not, or is unable, to comply with their respective social and environmental
policies and procedures.
The EP Association is the unincorporated association of member EPFIs and Associates whose objective is
the management, administration and development of the EP framework.
3. HAS THE PROJECT FINANCE MARKET CHANGED SINCE THE LAUNCH OF EQUATOR PRINCIPLES?
There has been significant development in the Project Finance market since the launch of the EP
framework in 2003. The market has become more culturally diverse with a variety of global and local
financial institutions active in the market. In addition, there are more diverse financing structures for
example where the proceeds of a financing are used partly for Project Finance and partly for the other
general financing needs of the client, or where financing is for a project and there may be a “guarantee”
from the Parent (which some banks do not view as pure Project Finance). Furthermore, experience
managing environmental and social risk within financial institutions and awareness with clients and their
advisors has greatly improved.
4. WHY ARE THE EQUATOR PRINCIPLES BEING UPDATED AND WHAT DOES “EP III” MEAN?
As noted in the current EP text, the EP Association is committed to reviewing the EP framework from timeto-time to reflect ongoing learning and emerging good practice.
3
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Since the launch of the EP framework in June 2003 and a subsequent revision in 2006, there has been
significant growth in the number of EP adopters from the original 10 to 77 financial institutions from 32
countries across the globe. During this period there has been significant development in environmental and
social risk management practices, partly as a result of the greater challenges impacting affected
communities and the environment and partly due to the changing financial landscape, particularly the
ongoing financial crisis and changing public perception of the role of financial institutions.
In 2010, the EP Association initiated a Strategic Review which produced a series of recommendations on
key thematic areas, namely: scope, climate change, human rights, reporting and transparency, stakeholder
engagement and governance. Parallel to this, the IFC initiated a review and update of their Sustainability
Framework, and their Performance Standards, which underpin the EP, were updated and re-launched in
January 2012.
In this context it was deemed an appropriate time to reflect on the implementation experience of EP
Association members, and that of our clients, and update the EP to ensure they remain a relevant and
practical risk management tool and supportive of sustainable financing objectives.
The result of the EP Update process will, if approved by members, be the third version of the Equator
Principles – hence the term “EP III”.
5. WHAT ARE THE KEY AIMS OF THE EP III UPDATE PROCESS?
The keys aims of the EP III Update process are:
•
To ensure EP Association members continue to appropriately manage environmental and social risk
and impacts for their institutions, clients and relevant stakeholders with regard to the financing of
projects,
•
To reflect the recent update of the IFC Performance Standards, and
•
To maintain the level playing field on which international and local financial institutions operate,
with regards to sustainable financing objectives.
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6. WHAT ARE THE PROPOSED KEY CHANGES AND AREAS OF DEVELOPMENT IN THE EP III DRAFT?
In summary, key themes and areas of development proposed in the EP III draft include:
•
An extension in the scope of the EP to Project-Related Corporate Loans and Bridge Loans.
•
Changes reflecting the recent update of the International Finance Corporation (IFC) Performance
Standards.
•
New requirements related to managing impacts on climate.
•
Greater emphasis on human rights considerations in due diligence and an acknowledgment of the
UN "Protect, Respect and Remedy" Framework for Business and Human Rights and Guiding
Principles on Business and Human Rights.
•
A strengthening of reporting and transparency requirements.
The proposed changes are fully detailed in the section - KEY CHANGES AND AREAS OF DEVELOPMENT IN
THE EP III DRAFT.
7. HOW WILL THE PROPOSED CHANGES TO THE EQUATOR PRINCIPLES AFFECT INDUSTRY SECTORS AND
CLIENTS?
The proposed changes to the EP will help improve the identification, assessment and management of
environmental and social risks and impacts in projects. This will be achieved through a widening of the
scope of application to other financial products, increased transparency and access to information for
financial institutions and local communities, and the incorporation of language that reflects the updated IFC
Performance Standards. The proposed changes should also enable more consistent implementation of the
EPs, thus making it easier for clients to implement the EP on-the-ground and to manage their relationships
with EPFIs.
8. HOW CAN I CONTRIBUTE TO AND PARTICIPATE IN THE EP III UPDATE PROCESS?
The formal 60 day stakeholder consultation and public comment period will give all interested parties and
stakeholders (including EP Association members, other financial institutions, clients, industry bodies and
associations, non-governmental organisations, consultants, law firms and regulatory bodies) an opportunity
to review the EP III draft and provide comments. The EP Association is committed to openness,
transparency and responsiveness and will consider all stakeholder feedback.
You can submit your views and participate in the process in one or more of the following ways:
•
Complete the online submission form.
•
Email comments to [email protected].
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•
Participate in a webinar and/or face-to-face meeting – details are published on the EP III web
pages. Note that places are limited and by invitation only – you can register your interest in
attending by emailing [email protected].
The EP III Update process and timeline is fully detailed in the section – THE EP III UPDATE PROCESS.
6
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PROPOSED KEY CHANGES AND AREAS OF DEVELOPMENT
9. CAN YOU SUMMARISE THE PROPOSED KEY CHANGES AND AREAS OF DEVELOPMENT IN THE EP III
DRAFT?
KEY TOPIC
RELEVANT SECTION
DESCRIPTION
Structure and
Language
All
•
The document has been divided in to 3 distinct sections to
enable clear distinction between mandatory requirements
in Main Text and Annexes, and supporting information in
the Exhibits:
1. Main Text – Preamble, Scope and Statement of
Principles.
2. Annexes – This contains implementation requirements
for applying certain aspects of the EP framework. The
content of the Annexes are an integral part of the EP
and the requirements within them are mandatory.
3. Exhibits – This contains supporting information
including a new Glossary of Terms.
•
Several footnotes have been incorporated in the main text
or added to the Glossary of Terms.
•
Several Principles have been shortened and language has
been adjusted or clarified.
•
The document language has been refined to align with
new/changed language in the 2012 IFC Performance
Standards.
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KEY TOPIC
RELEVANT SECTION
DESCRIPTION
Scope
•
Scope
•
•
Principles 2, 4, 7,
and 9
•
Exhibit I
The inclusion of Project-Related Corporate Loans
(Corporate Loans related to one specific project) subject
to a US$100m threshold and a loan tenor of at least 2
years. It should be noted that general corporate purposes
loans are excluded from the scope of the EP (refer to the
Scope section of the EP III draft for the criteria).
•
The inclusion of Bridge Loans that will be refinanced by
Project Finance or a Project-Related Corporate Loan.
•
Exhibit I has been deleted and Categorisation has been
included in the main text. It should be noted that further
guidance material on Categorisation will be developed.
•
There is a new requirement for an analysis of alternatives,
including less carbon intensive fuel sources and
technologies, for projects emitting over 100.000 tonnes
CO 2 equivalent. It should be noted that the alternatives
analysis is based on the requirements stipulated in the
updated IFC Performance Standards.
•
There is a new requirement for borrowers to publicly
report on emissions for projects emitting over 100.000
tonnes CO 2 equivalent.
•
It should be noted that further guidance material on
implementation of these requirements will be developed.
Categorisation
Climate
Change
•
Principle 1
•
Exhibit I in EP II
•
Principle 2 and
10
•
Annex A
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KEY TOPIC
RELEVANT SECTION
DESCRIPTION
Applicable
Environmental
and Social
Standards
•
Preamble
•
•
Principle 3
•
Various other
Principles
An overarching statement regarding the application of the
EP framework in High-Income OECD Countries has been
included in the Preamble.
•
Principle 3 now provides clarity to EPFIs and clients on the
meaning and intent of the application of standards in
different jurisdictions. Where possible, reference to
application in High-Income OECD Countries has been
deleted from individual Principles.
•
Principle 3 now states that the EPFI, at its sole discretion,
may seek to benchmark projects in these countries against
these or other internationally recognised environmental
and social assessment standards.
•
The definition and purpose of an Action Plan, and related
management plans has been clarified.
Action Plan
and
Management
systems
•
Principle 4
•
Exhibit I
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KEY TOPIC
RELEVANT SECTION
DESCRIPTION
Stakeholder
Engagement
and Human
Rights
•
Preamble
•
•
Principles 5, 6
and 10
•
Exhibit I
•
Exhibit II
New language in the Preamble and Exhibit II
acknowledges the UN "Protect, Respect and Remedy"
Framework for Business and Human Rights and Guiding
Principles on Business and Human Rights, and the
importance of human rights in the due diligence process.
•
Principles 5 and 6 include new language related to
Stakeholder Engagement (replacing the current
Consultation and Disclosure) to reflect the updated
language in the IFC Performance Standards on stakeholder
engagement hierarchy.
•
The text referencing Free, Prior and Informed Consent for
projects in non-OECD countries and OECD countries not
designated as High-Income has been inserted so that it
reflects the important changes in the IFC Performance
Standards.
•
Principle 6 has been shortened to reduce duplication of
the requirements in the IFC Performance Standards.
•
Assessment disclosure requirements have been moved to
Principle 10.
•
The requirement for covenants now explicitly refers to all
projects.
•
Requirements for Bridge Loans and Project Finance
Advisory services have been included in Principle 2 and
Principle 4.
Covenants
•
Principle 8, 2 and
4
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KEY TOPIC
RELEVANT SECTION
DESCRIPTION
Reporting and
Transparency
•
Principles 2, 5
and 10
•
•
Annex B
Principle 10 now includes all reporting and disclosure
requirements and is divided in to “Project Reporting” and
“EPFI Reporting”.
•
Annex B includes detailed requirements for EPFI reporting.
•
In addition to the client’s responsibility to disclose the
project Environmental Impact Assessment (EIA) locally,
the text now includes the requirement to disclose the EIA
and Environmental and Social Management Plan (ESMP)
(which is normally a component of the EIA), online unless
the borrower does not have a company website.
•
Annex B also includes a new requirement to provide,
subject to borrower consent, a list of projects for
publication on the EP website.
•
It should be noted that a grace period for reporting on
Project-Related Corporate Loans will be reflected in EP
Association Governance Rules.
10. WHY IS THE EQUATOR PRINCIPLES ASSOCIATION EXTENDING THE SCOPE OF THE EQUATOR
PRINCIPLES?
The EP Association is responding to trends and practices on how projects are being financed. There has
been significant development in the Project Finance market since the launch of the EP framework in 2003.
The market has become more culturally diverse with a variety of global and local financial institutions active
in the market. In addition, there are more diverse financing structures for example where the proceeds of a
financing are used partly for Project Finance and partly for the other general financing needs of the client,
or where financing is for a project and there may be a “guarantee” from the Parent (which some banks do
not view as pure Project Finance). While in many of these cases environmental and social risks and impacts
are still present, these types of financing fall outside the scope of the current EP framework. Additionally
there has been a notable maturation of additional environmental and social risk and mitigation procedures
notably with regards to climate change and human rights.
Taking all these factors into account, it is proposed that the scope is extended to a defined sub-set of
Corporate Loans (Project-Related Corporate Loans) and Bridge Loans.
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11. THE DEFINING CRITERIA FOR PROJECT-RELATED CORPORATE LOANS IS VERY SPECIFIC, WILL THIS
MEAN MANY PROJECTS WILL NOT BE ASSESSED UNDER THE EQUATOR PRINCIPLES FRAMEWORK?
The proposed extension of scope to Project-Related Corporate Loans is a significant step forward and
should capture more transactions for assessment under the EP framework. The definition of ProjectRelated Corporate Loans has been subject to extensive debate within the EP Association and the proposed
criteria have been deemed the most appropriate for a number of reasons, including:
•
ensuring the consistent implementation of the EP framework,
•
providing a starting point for capacity building for new adopters, and
•
ensuring that adopters have sufficient leverage to implement the EP framework when nonadopters are present in the syndicate or leading the syndication.
Furthermore it should be noted that financing a project through a Project-Related Corporate Loan is
different to Project Finance in two important respects.
In general, financial institutions have a lesser degree of influence/leverage over a project financed through
a Corporate Loan. There is also a higher degree of competition with financial institutions in certain
geographies including those that are not EP adopters. Furthermore loans are often arranged in a shorter
timescale meaning that parts of the EP framework would require a different approach.
The proposal to extend the scope to Project-Related Corporate Loans has taken these factors in to account
to ensure that the EP framework can be implemented by financial institutions. It should be noted that the
proposals also aim to ensure there are more stringent requirements for the highest risk Corporate Loan
projects.
12. WHY DOESN’T THE EQUATOR PRINCIPLES FRAMEWORK APPLY TO ALL AREAS OF FINANCE?
The EP framework was originally created for environmental and social risk management in Project Finance
transactions. While the proposal is to extend the scope of the EP to Project-Related Corporate Loans and
Bridge Loans, the focus will still be on Project Finance and Project Finance Advisory services as it easily
follows a project’s financing, development and operational cycle.
The EP framework does not lend itself readily to other areas of finance. For example, capital markets deals
(such as bonds and IPOs) are often general corporate purposes in nature, and in these transactions financial
institutions do not have long-term “hooks” such as Covenants or monitoring requirements.
Additionally, the level of due diligence required to apply the EP framework can be significant in terms of
timing and resources and many financing products are structured in a way which makes the consistent
application of EP impractical or unfeasible. Therefore the scope has been limited to projects in order to
ensure that the EP framework can be applied consistently.
12
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The EP Association does acknowledge however that many members use the “EP” concept and the IFC
Performance Standards within their own internal policy frameworks for other finance activities.
13. HOW IS THE EQUATOR PRINCIPLES ASSOCIATION WORKING TO IMPROVE CONSISTENCY IN EQUATOR
PRINCIPLES IMPLEMENTATION?
The EP III Update process has facilitated extensive discussion within the EP Association on the challenges
and possible solutions for better consistency and these discussions will be ongoing. The EP III draft also
proposes language on how EPFIs might be able to exchange non-confidential information and communicate
with each other during the due diligence phase of a project. Furthermore, the EP Association will be
providing more opportunities for members to discuss this topic and it will be discussed at the next EP
Association Annual Meeting which takes place during Phase III of the EP III Update process.
14. WHY HAS THE EQUATOR PRINCIPLES ASSOCIATION FOCUSED ON ENHANCED REPORTING AND
TRANSPARENCY?
It is recognised that transparency is an important part of environmental and social risk management and it
contributes to overall accountability. As the EP Association has grown and developed this topic has become
an important consideration for members and stakeholders alike. The proposals in EP III draft take
important steps to enhance reporting and transparency and the implementation of the proposals will be
challenging. It is acknowledged that it will take both time and experience to create a level playing field on
this topic.
15. HOW DO THE ENHANCED REPORTING REQUIREMENTS IMPROVE COMPLIANCE AND TRANSPARENCY?
The new reporting requirements proposed in the EP III draft allow for greater transparency by:
•
increasing the amount of information disclosed about the projects financed,
•
requesting clients to publicly disclose project related assessment documentation,
•
requesting client consent to publicly disclose project names and,
•
creating structured ways for information sharing between EPFIs.
16. HOW IS THE EQUATOR PRINCIPLES ASSOCATION WORKING TO IMPROVE THE PROVISION OF
GRIEVANCE MECHANISMS AT PROJECT LEVEL?
The provision of grievance mechanisms is a very important component of the EP framework and the
requirements enable Project Sponsors to proactively address grievances and concerns at project level. The
proposals in the EP III draft aim to reflect the IFC’s current thinking on the subject (as detailed in the
updated Performance Standards and Guidance Notes).
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17. HOW DO THE PROPOSED CHANGES TO THE EQUATOR PRINCIPLES ACKNOWLEDGE THE UN’S
“PROTECT, RESPECT AND REMEDY” FRAMEWORK AND GUIDING PRINICPLES ON BUSINESS AND
HUMAN RIGHTS?
The EP Association has discussed the UN "Protect, Respect and Remedy" Framework for Business and
Human Rights and Guiding Principles on Business and Human Rights as part the EP III Update process and it
was agreed that the updated EP should acknowledge the framework.
The second pillar of the "Protect, Respect and Remedy" framework sets out the corporate responsibility to
respect human rights as follows:
“business enterprises should act with due diligence to avoid infringing on the rights of others and to
address adverse impacts with which they are involved”.
The EP provides financial institutions the required “due diligence” framework to identify, assess and
manage project impacts by defining the processes and standards for stakeholder engagement with affected
communities (including for Indigenous Peoples), labour rights, and occupational and community health and
safety. The important requirement for project-level grievance mechanisms also allows affected
communities to address grievances proactively with Project Sponsors which is an important component in
driving greater accountability at project level.
It should also be noted that the EP III draft introduces the term “human rights” in the EP framework for the
first time.
18. HOW IS THE GAP BETWEEN THE EFFECTIVENESS DATE OF EP III AND THE UPDATED IFC
PERFORMANCE STANDARDS BEING MANAGED?
Consistent with the current EP framework, the EP Association Steering Committee agreed that the revised
IFC Performance Standards would take effect for EP Association Members on 1 January 2012 (the official
implementation date for the IFC). Accordingly Exhibit III of the current EP, which previously referred to the
2006 IFC Performance Standards, was updated on 1 January 2012.
The EP Association Steering Committee also made a recommendation to members, clients and
stakeholders on how to transition smoothly and consistently to the updated IFC Performance Standards
and provided the following guidance. As such EP Association members will already be applying the
updated IFC Performance Standards when EP III is officially adopted and launched.
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19. WHY DOESN’T THE EP III DRAFT ADDRESS ALL THE RECOMMENDATIONS IN THE EQUATOR
PRINCIPLES STRATEGIC REVIEW REPORT?
The Strategic Review was intended to be the first step in a longer term process to determine the future of
the EP framework. It was also intended to support the EP Association in developing a road map for
improved implementation, action and engagement, and communication with members and stakeholders
alike. As such, the EP III Update process has focused on many of the short and medium term priorities
identified in the Strategic Review. Additionally, it should be notes that the Strategic Review
recommendations that were not deemed as immediate priorities will be considered following the EP III
Update process.
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THE EP III UPATE PROCESS & STAKEHOLDER ENGAGEMENT
20. WHAT IS THE PROCESS FOR UPDATING THE EQUATOR PRINCIPLES?
Phase I
Internal Consultation and
Initial Drafting of EP III
July 2011 – August 2012
Phase II
Stakeholder Consultation
and Public Comment Process
August 2012 - October 2012
Phase III
Finalisation and
Launch of EP III
October 2012 – January 2013
PHASE I: Internal Consultation and Initial Drafting of EP III (July 2011 - August 2012)
Existing Working Groups and new Task Forces initiated discussions and detailed analysis for each topic area
and shared proposals with the EP Association Steering Committee on how the EP framework might be
updated to reflect changes to the IFC Performance Standards and current best practice. All members were
invited to join the discussion groups to ensure full participation.
The Working Groups and Task Force proposals were discussed more widely with EP Association members at
their Annual Meeting in October 2011 and the Working Groups and Task Forces were subsequently
commissioned to provide final proposals and updated/new language for incorporation in to the EP.
The final proposals and updated/new language were examined and discussed at length by the EP
Association Steering Committee and members and the first draft of EP III was approved for public release
for the formal Stakeholder Consultation and Public Comment period.
PHASE II: Formal 60 day Stakeholder Consultation and Public Comment Period (August - October 2012)
The EP Association is committed to carrying out a robust and consultative process. The formal 60 day
stakeholder consultation and public comment period will give all interested parties and stakeholders
(including EP Association members, other financial institutions, clients, industry bodies and associations,
non-governmental organisations, consultants, law firms and regulatory bodies) an opportunity to
review the EP III draft and provide comments. The EP Association is committed to openness,
transparency and responsiveness and will consider all stakeholder feedback.
The EP Association Working Groups are working with specific stakeholder groups (e.g. Industry/clients,
NGOs) however the EP Association welcomes feedback and comments from any interested party on
both process and substance.
You can submit your views and participate in the process in one or more of the following ways:
•
Complete the online submission form.
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•
Email comments to [email protected].
•
Participate in a webinar and/or face-to-face meeting – details are published on the EP III web
pages. Note that places are limited and by invitation only – you can register your interest in
attending by emailing [email protected].
PHASE III - Finalisation and Launch of EP III (October 2012 – January 2013)
The EP Association will review comments received from members and stakeholders during this period
and will consult with members on amending the EP III draft.
The EP Association will not publish every comment received on the EP website however it will publish a
summary (unattributed) of the key topics/issues raised during the Stakeholder Consultation and Public
Comment period. The summary will include statements on how and why issues/comments have or have
not been incorporated in to the EP III draft.
The EP Association will also agree a plan for the formal adoption and launch of EP III (including setting an
official launch date and implementation transition period, training and communications) and will finalise all
the relevant guidance notes during this period. It should be noted that the EP Association will carry out a
final voting process with members, in line with the EP Association Governance Rules, to approve and readopt EP III.
Note that the timeline for the EP III Update process, described above, is tentative and may be extended by
the EP Association as appropriate. The EP website is updated on a regular basis to ensure members and
stakeholders are fully aware of all the relevant details and you can keep up to date with activities at
http://www.equator-principles.com/index.php/ep3
21. HOW IS THE EQUATOR PRINCIPLES ASSOCIATION ENSURING STAKEHOLDERS ARE CONSULTED? HOW
CAN I SUBMIT COMMENTS?
The EP Association is committed to carrying out a robust and consultative process. The formal 60 day
stakeholder consultation and public comment period will give all interested parties and stakeholders
(including EP Association members, other financial institutions, clients, industry bodies and associations,
non-governmental organisations, consultants, law firms and regulatory bodies) an opportunity to
review the EP III draft and provide comments. The EP Association is committed to openness,
transparency and responsiveness and will consider all stakeholder feedback.
The EP Association Working Groups are working with specific stakeholder groups (e.g. Industry/clients,
NGOs) however the EP Association welcomes feedback and comments from any interested party on
both process and substance.
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You can submit your views and participate in the process in one or more of the following ways:
•
Complete the online submission form.
•
Email comments to [email protected].
•
Participate in a webinar and/or face-to-face meeting – details are published on the EP III web
pages. Note that places are limited and by invitation only – you can register your interest in
attending by emailing [email protected].
The EP Association will review comments received from members and stakeholders during this period
and will consult with members on amending the EP III draft.
The EP Association will not publish every comment received on the EP website however it will publish a
summary (unattributed) of the key topics/issues raised during the Stakeholder Consultation and Public
Comment period. The summary will include statements on how and why issues/comments have or have
not been incorporated in to the EP III draft.
22. WHERE WILL MY COMMENTS GO? AND WILL THEY BE PUBLISHED?
Comments from stakeholders are an integral part of the EP III Update process and the EP Association
will be considering them during Phase III (Finalisation and Launch of EP III, October 2012 – January
2013) of the EP III Update process.
On submission comments go to the EP Secretariat for collation and distribution internally and the
submitter will receive an automated message to confirm receipt.
The EP Association will not publish every comment received on the EP website however it will publish a
summary (unattributed) of the key topics/issues raised during the Stakeholder Consultation and Public
Comment process. The summary will include statements on how and why issues/comments have or
have not been incorporated in to the EP III draft.
23. WILL I GET A RESPONSE?
You will receive an e-mail thanking you for your comments and, where a question has been submitted, we
will endeavour to respond within 5 working days.
24. HOW WILL MY COMMENTS AFFECT THE EP III DRAFT?
The EP Association is committed to considering all comments received however no guarantee can be given
that your comment will have direct impact on the EP III draft. Furthermore, it should be noted that the EP
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Association is required to carry out a final voting process with members, in line with the EP Association
Governance Rules, to approve any changes to the content of the EP.
25. WHEN WILL THE NEW EQUATOR PRINCIPLES BE LAUNCHED AND IMPLEMENTED?
After full consideration of stakeholder feedback by members and an internal revision process, the EP
Association will agree a plan for the formal adoption and launch of EP III including setting an official launch
date and implementation transition period, training and communications. It should be noted that the EP
Association will carry out a final voting process with members, in line with the EP Association Governance
Rules, to approve and re-adopt EP III.
26. WHO CAN I CONTACT TO ASK A QUESTION ABOUT ANY OF THIS?
All questions and comments can be sent directly to the EP Association Secretariat at
[email protected].
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