Environmental, Social & Ethical (ESE) and Reputational Risk Management

We recognise that the activities of our customers can have ESE impacts – including polluting activities and the potential for human rights infringements. The ESE Risk Framework forms part of NatWest Group’s overall Reputational Risk policy and requires enhanced due diligence to be performed for certain customer relationships, transactions, activities and projects.

ESE sector risk acceptance criteria (RAC)

To manage these risks, we have developed Risk Acceptance Criteria (RAC) for nine sectors which present heightened ESE risk. These define the level of ESE risk the bank is prepared to accept. The ESE Risk Framework applies to all legal entities within NatWest Group for the onboarding of non-personal customers (including, but not limited to, for the purposes of providing lending or loan underwriting services). Customers are assessed at onboarding and during the lifecycle of their relationship. Some of the activities which we prohibit include: provision of sexual entertainment venues, the manufacture, sale, trade, servicing or stockpiling of Highly Controversial Weapons, establishing new coal relationships and customers using harmful child labour, forced labour, modern slavery or human trafficking.

We also have an ESE risk concerns process which seeks to ensure that ESE risk is identified and managed for customers and transactions in sectors which are not covered by RAC, or where there may be multiple issues or complexities. Examples might include major or sustained environmental, human rights, modern slavery issues in sectors such as agriculture and food, chemicals, tobacco, pharmaceuticals and waste management, or companies associated with controversial projects.

All customers who fall into the ‘restricted’ ESE risk category (see ESE risk framework chart below) are subject to enhanced due diligence. This includes ensuring that companies have relevant policies and procedures to manage ESE risks and the capacity to manage these risks through good governance and control. It also assesses the companies’ external ESE track record. All restricted customer relationships are approved by a business segment or legal entity accountable executive and where material, may be escalated to the Group Reputational Risk Committee. The Group Reputational Risk Committee may review the appropriateness of transaction, customer or product specific cases, or specific matters which could have bank-wide reputational risk implications.

ESE Risk Framework oversight and effectiveness is provided by the Risk Function and reported annually to the Group Reputational Risk Committee.

Our sector RAC can be found below:

For full details and definitions, please see the individual policies.

Helping to end the most harmful activity

In early 2023, we announced we will not provide reserve based lending specifically for the purpose of financing oil and gas exploration, extraction and production for new customers, and, after the 31 December 2025 we will not renew, refinance or extend existing reserve based lending used specifically for the purpose of financing oil and gas exploration, extraction and production. 

Read more in our 2023 Climate-related Disclosures Report.

Human rights risk assessment criteria

During 2023 we also developed a new standalone ESE Human Rights RAC that covers a range of sectors which have heightened risk specifically around human rights and modern slavery. This was one of our aims for 2023, as set out in our 2022 Modern Slavery and Human Trafficking Statement.

2023 Customer ESE risk assessments undertaken

In 2023, we undertook 520 customer ESE assessments (2022: 535), and 79 trade-related transactions involving defence equipment (2022: 126).

Related content

Read more about how we seek to promote and respect human rights through the continued implementation of policies and practices covering our colleagues, customers and suppliers.

Read more about the voluntary set of standards adopted by financial institutions for determining, assessing and managing environmental and social risks in project-related transactions.

Read more about how we are building a bank that is safe, simple and smart.