Position Statement Power generation

We remain committed to promoting sustainable practices in these sectors, while supporting economic growth and prosperity.

For more detail on our approach to climate risk and impact, please refer to our climate change position statement.

While the Group voluntarily adheres to these non-legally binding position statements, they reflect our aspiration to apply these principles consistently and to conduct our business with the highest standard of ethics and integrity. All staff are required to adhere to the position statements and endeavour to achieve these goals in line with our Group Code of Conduct and to live up to our brand promise of Here for good.

Applicable to

This position statement reflects the sector-specific criteria we assess our clients against when considering providing financial services to power generation industries. For the purpose of this position statement:

Fossil fuel power refers to the construction, operation and decommissioning of power plants and related infrastructure, that utilise coal, oil or natural gas as fuel. For activities involving the extraction, processing and transportation of coal, oil or natural gas, please refer to our extractive industries position statement.

Nuclear power refers to the construction, operation and decommissioning of nuclear power plants and related infrastructure, including the generation of power using nuclear energy, the provision of equipment, materials, and related technology to the activities listed above, and the management of radioactive waste. For activities involving the extraction, processing and transportation of uranium, please refer to our extractive industries position statement.

Renewable energy refers to power stations and related infrastructure using solar, wind, hydro, geothermal, and wave energy to generate power – including energy storage infrastructure.

For all power generation industries, criteria relating to power transmission and distribution are captured by our infrastructure and transport position statement.

Our commitment

As a key part of our mission to be Here for good, we only provide financial services to clients who manage their environmental and social impacts responsibly. The sector-specific criteria in this position statement, along with those in the cross-sector requirements set out the standards we assess our clients against. 

We regularly engage with our clients to confirm that they’re aligned with our environmental and social requirements, and consult with industry experts to ensure these stay relevant and effective.

Fossil fuel power

Where fossil fuel power generation operations have potential adverse environmental and social impacts and are located in countries which are not High Income OECD members, we use the following standards to assess the capability of our clients to manage these impacts:

  • The most recent IFC Performance Standards1
  • The IFC General Environmental, Health and Safety Guidelines2
  • The IFC Industry Sector Guidelines on Thermal Power Plants, Electric Power Transmission and Distribution

For Clients in the Fossil-Fuelled Power Sector:

  • We will not provide debt or equity to new coal fired power plants which do not achieve a long-run emissions intensity of below 830g / CO2 / kWh.
    • In certain circumstances, in particular where the size of the plant is small, it may not be technologically feasible to meet this threshold. In such cases, we will carefully balance the need for power with the environmental impacts.
    • This decision will be informed by a Best Available Technology (BAT)2 analysis, to the satisfaction of the bank, confirming that the choice of fuel type, technology and resulting emissions cannot be improved given the circumstances such as location, size and available fuel sources.
    • This BAT analysis will also assess the plant’s contribution to alleviating national or localised energy deficiencies.
  • We expect all clients to monitor and publicly report greenhouse gas emissions annually in accordance with internationally-recognised methodologies such as the GHG Protocol and where appropriate set clear targets for reducing greenhouse gas emissions.

Where applicable, we will also look to the following industry best practices, guidelines and bodies to determine effective responses to risks faced by clients:

  • The Kyoto Protocol3
  • The European Union Emissions Trading Scheme (EU ETS)4
  • The Greenhouse Gas Protocol5
  • The Climate Principles Guidance Note on Financing New Coal-Fired Power Plants6

We're aware that in some circumstances environmental and or social risks and impacts cannot be successfully mitigated. In the fossil fuel power generation sector we will therefore restrict the provision of financial services to Corporate and Institutional Banking, Commercial Banking, and Business Banking clients who:

  • Do not significantly impact upon, or have operations located within:
    • UNESCO7 World Heritage Sites
    • RAMSAR8 Wetlands, unless operations would result in ‘no net loss’ of biodiversity
  • Follow IFC Performance Standard 6 where operations impact upon Protected Areas or Critical Habitats

And to Corporate and Institutional Banking clients who:

  • Monitor and report greenhouse gas emissions annually in accordance with internationally recognised methodologies such as the GHG Protocol and where appropriate, set clear targets for reducing greenhouse gas emissions
  • Have implemented, or are in the process of implementing, an environmental and social management system which controls their specific risk exposure
  • Support the application of the Equator Principles9

Nuclear power

Where nuclear power operations have potential adverse environmental and social impacts and are located in countries which are not High Income OECD members, we use the following standards to assess the capability of our clients to manage these impacts:

  • The International Atomic Energy Agency (IAEA) Safety Standards
  • The IAEA Security Series
  • The most recent IFC Performance Standards1
  • The IFC General Environmental, Health and Safety Guidelines2
  • The IFC Industry Sector Guidelines for Thermal Power Plants (as relevant for nuclear power plants)

Where applicable, we will also look to the following industry best practices, guidelines and bodies to determine effective responses to risks faced by clients:

  • The World Association of Nuclear Operators (WANO)10
  • The World Institute for Nuclear Safety (WINS)11
  • The Nuclear Power Plant Exporters’ Principles of Conduct12
  • The World Nuclear Transport Institute (WNTI)13
  • The Treaty for Non Proliferation of Nuclear Weapons14
  • The IAEA Safeguard Agreements15
  • The Nuclear Supplier Group Guidelines16
  • The IAEA Guide ‘Milestones in the Development of a National Infrastructure for Nuclear Power’17

We're aware that in some circumstances environmental and or social risks and impacts cannot be successfully mitigated. In the nuclear power sector we will therefore restrict the provision of financial services to Corporate and Institutional Banking, Commercial Banking, and Business Banking clients who:

  • Demonstrate that their operations do not contribute to the manufacture or distribution of nuclear weapons, and that they have a long term commitment to the use of nuclear technology and equipment for a peaceful purpose
  • Have nuclear operations only in locations where the host country is a signatory to the Treaty for Non Proliferation of Nuclear Weapons, or has in place appropriate IAEA Safeguard Agreements and where the country of origin of the materials, equipment and technology is a member of the Nuclear Supplier Group Guidelines
  • Demonstrate compliance with applicable IAEA Safety Standards and Nuclear Safety Series
  • Use the IAEA Site and External Events Design (SEED) review service for siting
  • Do not significantly impact upon, or have operations located within:
    • UNESCO7 World Heritage Sites
    • RAMSAR8 Wetlands, unless operations would result in ‘no net loss’ of biodiversity
  • Follow IFC Performance Standard 6 where operations impact upon Protected Areas or Critical Habitats

And to Corporate and Institutional Banking clients who:

  • Have implemented, or are in the process of implementing, an environmental and social management system which controls their specific risk exposure
  • Support the application of the Equator Principles9

Renewable energy

Where dams and hydropower operations have potential adverse environmental and social impacts and are located in countries which are not High Income OECD members, we use the following standards to assess the capability of our clients to manage these impacts:

  • The most recent IFC Performance Standards1
  • The IFC General Environmental, Health and Safety Guidelines2
  • The IFC Industry Sector Guidelines on Wind Energy, Geothermal Power Generation and Electric Power Transmission and Distribution

We're aware that in some circumstances environmental and or social risks and impacts cannot be successfully mitigated. In the renewable energy sector we will therefore restrict the provision of financial services to Corporate and Institutional Banking, Commercial Banking, and Business Banking clients who:

  • Do not significantly impact upon, or have operations located within:
    • UNESCO7 World Heritage Sites
    • RAMSAR8 Wetlands, unless operations would result in ‘no net loss’ of biodiversity
  • Follow IFC Performance Standard 6 where operations impact upon Protected Areas or Critical Habitats

And to Corporate and Institutional Banking clients who:

  • Have implemented, or are in the process of implementing, an environmental and social management system which controls their specific risk exposure
  • Support the application of the Equator Principles9

How we work with clients in sensitive sectors

View our other sector specific position statements, which we use to assess whether to provide financial services

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