Action Plan on Human Rights 2018-2020 - BBVA
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Action Plan on Human Rights 2018-2020 /1
Action Plan
on Human Rights
2018-2020
March 2019
Action Plan on Human Rights 2018-2020 /2
BBVA and Human Rights: our journey
2018
2002 2012 Commitment to Human Rights
Joins the Thun Group of Updated
Code of
Banks
Conduct 2005 2008 Publication of the Action Plan on
published Publication of the Responsible Human Rights 2018-2020
Publication of Signed up to the United
the 1st Rules Purchasing Policy
Joined the Nations Principles for Publication of BBVA Sector
UN Global of Conduct in Responsible Investment Publication of the Social norms for environmental and
Compact Defense (UN-PRI) Housing Policy social due diligence
2004 2007 2011 2014 2017
BBVA is the 1st Publication of Diversity Updated Launch of the global human rights due
Spanish bank to BBVA's Plan of Rules of diligence process
sign up to the Commitment to launched Conduct Publication of the Code of Conduct for
Equator Human Rights in Defense Suppliers
Principles
Partnered with CSR Europe (translating and
disseminating the ‘Blueprint for Embedding
Human Rights in Key Company Functions’)
Action Plan on Human Rights 2018-2020 /3
Due Diligence Process
Context: Methodology:
In the current context and for an organization like BBVA The United Nations Guiding Principles on Business and Human
with more than 75 million customers and 125,000 Rights were used as a baseline, and according to these
employees in more than 30 countries, and with activities in guidelines, there are three fundamental steps businesses should
diverse sectors, a commitment to human rights assumes take to establish due diligence processes:
particular significance.
01 Identify the potential impact
Furthermore, this commitment runs parallel to our
of their business activities
mission: “to bring the age of opportunity to everyone.”Still,
on human rights;
the journey to fulfill this purpose is replete with challenges.
02 Design mechanisms within
One of these challenges is the identification and
the company to prevent or
assessment of the Group’s impact on human rights.
mitigate these impacts;
Specifically with the intention to strengthen this aspect, a
03 Establish channels and
global due diligence process was undertaken in 2017.
define processes that
More than 400 employees from all lines of business and ensure appropriate
the bank’s main support functions participated in the mechanisms are in place to
discussions, workshops, and surveys conducted across redress affected parties, in
the Group's holding company, as well as in Argentina, the event of a violation.
Chile, Colombia, Spain, Mexico, Paraguay, Peru, Uruguay,
the USA, and Venezuela.
Action Plan on Human Rights 2018-2020 /4
Due Diligence Process
Main Conclusions: 1. Policy and Structure
As a result of this process, the actual One of the recommendations coming out of the
and potential human rights impact process was to update our Commitment to
of BBVA’s operations were identified, Human Rights , which was then reviewed and
and mechanisms were designed within updated in 2018. The Guiding Principles on
the Group to prevent and mitigate Business and Human Rights were used as a
them. The appropriate channels and baseline, and the new version of the
procedures were put in place to ensure Commitment was framed round our principal
affected parties were provided remedy stakeholders (employees, customers, suppliers,
as necessary, in the case of a violation. and communities).
All of this provided the basis for the
Action Plan on Human Rights 2018- 2. Cultural Training and Transformation
2020.
From the due diligence process, it was also
recommended that the bank's perspective on
One of the principal conclusions of the human rights be incorporated into:
process was the identification of four the internal and external communication plan
key areas on which to focus our work:
the diversity and work life balance plan
the general and specialized employee training
plan
Action Plan on Human Rights 2018-2020 /5
Due Diligence Process
Respect for equality and diversity is 3. Process Improvement
embodied by the bank's corporate
The analysis revealed the importance of reinforcing
culture and leadership style; it is a guiding
the supplier assessment and approval process, as
principle for employment policies –
well as the scope and operation of the redress
especially policies related to employee
mechanisms.
recruitment development, and
compensation – which guarantee non- In fact, BBVA had already had a Responsible
discrimination based on gender, race, Procurement Policy and a Code of Conduct for
religion, or age and is laid out in BBVA’s Suppliers in place. In 2018, both were enhanced to
Code of Conduct. include the full scope of human rights in the supplier
assessment and approval process.
In accordance with the recommendation, the Action Plan on
Human Rights deals with different working areas. BBVA’s 4. Business and Strategy Alignment
Commitment to Human Rights also comprises the use of content The due diligence analysis recommended integrating
from the International Labor Organization's principal conventions human rights criteria in the Group's strategic projects
such as those related to the elimination of forced labor; the such as due diligence related to company acquisition
abolition of child labor (minimum age and and the worst forms of (M&A and M&A Digital) or in its sustainable
child labor); and the elimination of employment and occupation development and climate change strategy.
discrimination.Action Plan on Human Rights 2018-2020 /6 Due Diligence Process In response to this recommendation and from a customer perspective, sector norms for the environmental and social due diligence were put into effect in 2018 covering (mining, energy, agribusiness, and infrastructure ). Furthermore, the role of Responsible Business was expanded to form part of the new product and business management committees in Spain, Mexico, the United States, Colombia, Peru, Turkey, and Venezuela. This Plan will be reviewed annually and will be the BBVA’s roadmap in its commitment to human rights.
Action Plan on Human Rights 2018-2020 /7
Employees
Topic Plan Leader Progress in 2018 Next steps
Promote equal Diversity and Inclusion Plan Talent The Rooney Rule for 100% of executive positions The Rooney Rule extended to management
opportunities and fight & Culture 40% of the 33 new appointments were women in positions
against employment key positions (since Sept. 2017) Sign up to the REDI initiative (Business Network for
discrimination based on Pilot coaching program for high-potential women LGBTI Diversity and Inclusion)
gender, national origin, BBVA selected for the Bloomberg Index of Gender Extend unconscious bias training across the whole
Equality Group.
language, illness,
disability, or any other The sexual harassment protocol is extended Extension of the Group's domestic violence
across the full BBVA footprint protocol for female employees to cover the Group's
breach of rights.
total footprint. (Currently covers Spain and Turkey)
Promote work-life Work-life balance plan Talent Renewal of the “Stamp of Company Equality” and Retain “Stamp of Company Equality” and the EFR
balance and work time & Culture EFR (Family-responsible company) certification in Certification
Spain
flexibility
7.5 % of the workforce at BBVA, S.A (Spain)
participating in the reduced work day and new
ways of working (flexible working, for example,
which allows employees to develop their roles
outside the work environment.)
Complaint and remedy Define an action plan that Talent Make appropriate local level whistleblowing Make the most suitable local channels available to
mechanisms. Employee assesses possible & Culture channels in the context of of the sexual harassment victims of domestic violence across the whole
improvements to protocol available across the Group’s footprint. Group.
Service Center
employee complaint and
remedy channels.
Promote training to Define training plan: Talent & Specialized training in Legal Services Launch of general training pills
increase Human Rights On a general level. Pill Culture andy Continue with the integration of human rights in
On specialized levels Responsible specialized training
awareness and literacy
Business
(Legal Services, RB)
(RB)Action Plan on Human Rights 2018-2020 /8
Real Estate Services And Security
Topic Plan Leader Progress in 2018 Next steps
Avoid abuse and excessive Develop a plan taking Real-estate Regulation of the security guard role across the Incorporation of specific human rights
and discriminatory use of into account each services and Group’s total footprint and a BBVA statement that clauses in the renewal and signing of new
security forces country's context security indicates when faced with any scenario that could contracts with security companies.
result in violence, public security forces will be
called.
Fight against Impact Communication Real estate and External communication on the bbva.com web site Strengthen external and internal
environmental pollution Plan services and in social media communication with Environment Day,
and promote efficient Internal communication on the intranet, Google+ etc. Water Day, and Energy Efficiency Day
management of resources Sustainability Week with 9 talks and 3 workshops (at
Launch of BBVA's Plastic-free Campaign
at Ciudad BBVA, Madrid.
Ciudad BBVA, Madrid)Action Plan on Human Rights 2018-2020 /9
Providers
Topic Plan Leader Progress in 2018 Next steps
Work with suppliers to prevent Define the information plan building on Procurement Publication on the web: Completed
a negative impact on human BBVA's human rights commitment department https://suppliers.bbva.com/compras-
rights resulting from their responsables/
Publication of information related to
activity and assess the start or BBVA's commitment to human
ongoing viability of commercial rights on the Supplier website
relations with them based on
their human rights Procurement Completed
Publication of the Code of Conduct for
performance. department
Suppliers
Prevent and mitigate the Internal and external audits Prioritize Reputational Assessment of including a human rights Analysis of the high-risk sector
potential negative human rights high-risk sectors and outsourcing Risk review checklist in supplier audits and the preparation of human
impact resulting from rights checklist
subcontractor activity linked to
the supply chain Supplier reputation assessment in the Procurement On-going integration of the Rep risk 50% volume of awards resulting
certification process department assessments in the approval process from suppliers evaluated on
(Scope : Spain, Mexico and South their reputation (Scope: Spain,
America) Mexico and South America)
33% of suppliers approved evalucated
according to reputation (Scope: Spain,
Mexico and South America)
Remedy mechanisms. Review Develop plan based on the results of the Procurement Analysis of the different channels for Implementation of evaluated
access to queries and reports remedy mechanisms report department incident submission on the channels
filed by supplier employees Suppliers.bbva web siteAction Plan on Human Rights 2018-2020 / 10
Customers
Topic Plan Leader Progress in 2018 Next steps
Development of Social Development of Social and CIB and RB Publication of sector norms for Stakeholder engagement during the annual
and Environmental Environmental Framework environmental and social due diligence review of sector norms
Frameworkhuman rights in 4 critical sectors: mining, energy,
Sector Policies infrastructure,and agribusiness.
impact resulting from
business customer activity Inclusion of RB in the new product
and business committee Enhanced ESG (environmental, social, Extension of the ESG due diligence pilot to the
and assess start or corporate governance) due diligence entire customer base representing the priority
ongoing viability of Integration of CIB customer due pilot for CIB customers (onboarding & sectors (mining, energy, infrastructure, and
commercial relations with diligence in risk-prone sectors repapering) agribusiness).
them. (onboarding & repapering)
Extension of the scope of Free, Prior, Update of the Rules of Conduct in Defense:
Protocol in connection with and Informed Consent (FPIC) to all
controversial issues / projects regardless of geographic • Extension of the concept of controversial
engagement location and proposed amendment to weapons ( inclusion of depleted uranium
the Equator Principles. and white phosphorus)
The launch of a controversial issues / • New ban on manufacturers of assault
engagement Protocolt weapons for civil use
On-going alignment of the lending portfolio to the
commitments agreed in the Paris Agreement on
Climate ChangeAction Plan on Human Rights 2018-2020 / 11
Customers
Topic Plan Leader Progress in 2018 Next steps
Remedy mechanisms. Review Define plan to establish corporate CIB and RB Analysis work, pre-assessment Implementation of the mechanisms
access to queries and reports finance query mechanisms and preparation
on corporate finance topics
Prevent and mitigate potential Inclusion of RB in the new product RB Incorporation of the committees Incorporation of Responsible Business
negative human rights impacts and business committee for new products and businesses in the new product and businesses
coming out of the development in Spain, Mexico, United States, committees in Argentina, Paraguay and
Colombia, Peru, Venezuela and Uruguay
of products and businesses.
Turkey
Protect and ensure the Draw up a manifesto on the RB and Data Research work and preparation
responsible use of our responsible use of data Drafting of the principles of responsible
customers' personal data use models for the whole group
and their right to privacy, as
well as to guarantee that the
algorithms we use are
documented, auditable, and
strict.Action Plan on Human Rights 2018-2020 / 12
Own Capital Businesses
Topic Plan Leader Progress in 2018 Next steps
Ascertain the absence of Include human rights-related M&A and Participation in the evaluation of M&A transactions Improvement of screening in the risk
human rights issues when criteria in company acquisition Digital M&A from the perspective of reputational risk: identification process.
investing in or acquiring a processes. Human rights checklist 1/ Screening Based on the Rep Risk analysis ( which Enhancement of the due diligence
covers human rights) and analysis of the company
company. in due diligence processes process
and its founding partners 2/ Analysis of CSR
Include human rights-related standards with partner companies 3/ If risk is
criteria in company acquisition identified, a due diligence and engagement process
processes will be undertaken with the M&A executor.
Others
Topic Plan Leader Progress in 2018 Next steps
Ensure the adequate Training plan to include human RB and Legal Integration of human rights in training developed Continue integrating human rights into
Services by Legal Services, with special attention given to training (especially in the legal services
interpretation of domestic rights in the interpretation of the
laws and regulations that standard the protection of personal data. department)
may not take human rights
into consideration
Fight against tax fraud, Definition of a new plan against tax Tax Continuation of the Reduction of Offshore Introduction of new measures for the
avoidance, and evasion fraud, avoidance and evasion Financial Centers Plan. prevention of tax evasion schemes, such
Closure of the BBVA branch in the Cayman as the DAC 6, an EU directive that obliges
Islands disclosure about specific transactions -
both the banks and customers - to tax
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