In general, it is a well-balanced report, but we question some of the results and the conclusion. The results based analysis is based on exceptions, rather than the norm. From this, conclusions are then drawn around implementation. This demonstrates a lack of understanding of the scope of Equator Principles (EP) and indeed the banks’ leverage over clients to implement certain ESG practices...For example: on the two transactions Standard Bank is involved in: KCM (water issue): This is a legacy issue which KCM/Vedanta inherited as part of existing operations. KCM is working with the lenders on a clear plan of action to reduce the environmental impact...Lonmin (housing issue): Lonmin has implemented a number of measures as part of its ongoing housing plan having completed the conversion of all hostels into 1908 single and 776 family units.