This discussion paper: 

Provides 

• a conceptual framework to help consider the meaning and reach of Principle 13 of the UNGPs…for banks in a corporate and investment banking context
• further consideration of the due diligence envisaged by Principle 17.

Determines that banks should, under the UNGPs:

• develop environmental and social (E&S) risk management policies and procedures to support identification, prevention and mitigation of impacts caused and/or contributed to by clients to which the bank provides financial products and services. These policies should include a requirement to perform due diligence on higher risk transactions and/or clients…

Introduces the concepts of:

• Proximity to an impact, which may indicate the “degree of directness” of linkage between the impact and the product and service offered by the bank, and
• Unit of analysis, as a means to inform the focus of a bank’s due diligence…

Illustrates, through case studies, under which circumstances direct linkage may apply depending on the unit of analysis.”…