Implementation, monitoring, and reporting
Financial institutions can ensure that policies are compliant with their policies, by putting in place processes to identify, monitor, and report progress against their policy. Financial institutions should consider including:
Timeline for updating policy
Financial institutions should regularly review and update their policy to reflect changing risks associated with companies in soft commodity supply chains.
Company subsidiary disclosure
Many risks associated with financing companies in soft commodity supply chains originate from assets held by subsidiary companies. It is therefore essential that financial institutions are aware of subsidiary and associated companies involved in the production or procurement of soft commodities so that risks can be effectively mitigated.
Process for identifying non-compliance
Various options are available to financial institutions to identify company policy non-compliance, including pre- and post- financing screening as well as ongoing engagement with companies. What is important is that financial institutions continually monitor companies and utilise best available data as it changes over time.
By reporting progress towards policy implementation, the financial institution can send a strong message to portfolio companies that their activities are being monitored on an ongoing basis.