...We write to you as B4Ukraine, a coalition of Ukrainian and international civil society organizations working to curtail the financial resources enabling the Russian invasion of Ukraine...

We request an urgent dialogue regarding potential inconsistencies between BNY Mellon's stated policies on human rights and the company’s ongoing business operations and relationships in Russia that may contribute to, or be linked with, human rights harms...

While we acknowledge and welcome BNY Mellon's process of scaling back and its financial support to humanitarian efforts, that statement was made in the weeks immediately following the start of the full-scale Russian military invasion. The war is now in its tenth month. No further official updates have been made by BNY Mellon and the company maintains its current clients in Russia. These activities risk enabling and indirectly financing Russia’s violations of IHL and human rights law during the ongoing invasion and occupation of Ukraine and violating BNY Mellon's human rights commitments and responsibilities, as well as its commitment to ethical conduct.

We seek to understand the status of BNY Mellon's exposure to Russia and how the company has conducted and continues to conduct heightened human rights due diligence, per its stated policy and the UNGPs concerning due diligence in conflict-affected areas, and how the findings of such a process has resulted in these continued business activities and relationships. As noted by the UNGPs:

…the more severe the abuse, the more quickly the enterprise will need to see change before it takes a decision on whether it should end the relationship. In any case, for as long as the abuse continues and the enterprise remains in the relationship, it should be able to demonstrate its own ongoing efforts to mitigate the impact and be prepared to accept any consequences – reputational, financial or legal – of the continuing connection.

BNY Mellon's Human Rights Statement commits the company to adhering to the principles outlined in the UNGPs as well as the Universal Declaration of Human Rights.11 Therefore, in consideration of the above points and B4Ukraine’s Declaration, we request an urgent dialogue with BNY Mellon's relevant senior management and staff to discuss the company’s ongoing activities and relationships in Russia, associated risks to the people of Ukraine and the company, and potential steps to prevent/mitigate these risks...