Banking and Human Rights:
A content analysis on Caixabank and BBVA sustainability
reporting
Jordi Calderer
Human Rights Bachelor Thesis 15 credits Spring semester 2021 Supervisor: Anders Melin1
Abstract
Business and human rights is a recurrent discussion and the literature shows that it is a common research topic. However, when it comes to Banking and human rights the academic works drop considerably. The purpose of this paper is first, measure the degree of detail and depth of the analyzed annual reports regarding the information relevant to human rights and second, check if the non-financial information or sustainability reporting of the selected banks have changed overtime. To try to answer those questions the paper makes use of a qualitative and quantitative content analysis that are based on a relevant theoretical framework for each of the questions. An extensive background on sustainability reporting is provided in order to have a linear narrative.
Key words: Human rights, Corporate Social Responsibility, Sustainability Reporting, UN Guiding Principles, Banking, Content Analysis
2
Table of Contents
1. Introduction ……… 3
1.1. Research problem ……… 4
1.2. Aim and purpose ………. 5
1.3. Relevance to Human Rights ……… 6
1.4. Delimitations ………... 7
2. Background and previous research ……… 8
2.1. The birth and growth of CSR ………... 8
2.2. Business communication on CSR, background of the reporting tool. 9 2.3. Literature review on sustainability reporting ………... 11
2.3.1. Reporting on the banking industry ……….. 13
2.3.1.1. Focus on Human Rights ……… 15
3. Theory ……… 17
3.1. The Stakeholder theory ………... 18
3.2. Critique on the stakeholder approach ………. 19
3.3. The Ruggie framework and the Guiding principles ……… 20
3.4. The Directive 2014/95/UE and the Real decreto-ley 18/2017 ……… 21
4. Method and material ………... 23
4.1. Content analysis ………. 23
4.2. Methodology of the research ………. 24
4.3. Firm selection and material ……… 25
5. Results and analysis ………... 27
5.1. Quality of the information reported regarding Human Rights …….. 27
5.2. Evolution of the disclosed information on non-financial reports ….. 29
6. Conclusion ……….... 33
6.1 Further research ……….. 34
3
1.
Introduction
Business and Human Rights is a well-known topic nowadays and has been an ongoing discussion for many years. In the past, it was not easy to discuss and agree if businesses have human rights obligations as this role was mainly left to the states to be fulfilled but thanks to the introduction of non-binding legal frameworks during the last two decades, the discussion has shifted to make companies more accountable towards Human Rights. As a result of this constant discussion, a new concept to make business more sustainable regarding environment and society emerged: the Corporate social responsibility (CSR). CSR had a major growth throughout the last decades of the last century and today it is globally accepted by Multinational corporations (MNCs) and big companies as a keystone to help them provide a positive impact on society in social, environmental and economic terms. To show that they comply with the required societal standards that legitimise their operations, companies often share their CSR practices and policies on the annual sustainability reports.1
Research on CSR reports is not a new trend, much has already been written about many different topics and companies but for some reasons, the financial sector and banking in particular do not have a very extensive and detailed research history. If we want to search information on how effective CSR is on this sector regarding social impact the available research materials are even lesser. It is true that for obvious reasons, other sectors such as energy producing or manufacturing corporations have bigger chances to commit human rights violations due to its global expansion and their operations taking place in countries with lower human rights protection but still, banking is a major industry in western countries and its practices need to be checked regularly to spot if the social impact of their activities is being taken into consideration.
A big part of the research done in CSR for banking or finance is focused on whether the CSR practices are adding value to the firm, in terms of social reputation or marketing purposes. Here the managerial concepts will be left aside and I will mainly focus on the non-financial information reported by the analyzed banks. I will try to cut down all of the unnecessary reported information in order to have a simpler and clearer picture of the
1 Annual reporting can come in many forms as also that field have had a major evolution, the most used
today may be found as integrated reports, sustainability reports or ESG report, depending on the chosen standard by the companies.
4
main topic of this paper, that is, the analysis of the disclosed information regarding human rights on the annual sustainability reports.
In this paper I will analyze to what extent the CSR annual reports of the selected banks show a specific interest in human rights, and how each company is promoting or creating initiatives / measures to improve human rights protection or to avoid social abuses caused by their or their clients’ everyday operations. Due to the high number of financial entities and the differences of this sector in every country, I will pick two Spanish banks, both publicly listed companies on the IBEX-35 index but with different backgrounds. In a later section I will explain the reason of my selection. The aim of the paper is not to be a case study, rather the selection means to be a simplification of the two different kinds of banks present in Spain, commercial banks and saving banks, to evaluate if that distinction is relevant when comparing their sustainability reports.
In the literature review chapter, we will see that CSR research for the banking sector is very limited in Spain and it is especially hard to find any kind of academic research based on sustainability reporting in both English or Spanish language. Therefore, hopefully this paper will be a good help for future researchers. I found that the most relevant way to understand if banking is indeed changing to a more caring sector towards its impact on society is to analyze, using content analysis, the evolution of their CSR disclosed material. The selected material will also be explained on the method and material chapter but I only take the sections related to Human Rights into account.
The analysis of the material will be based on relevant CSR theory such as the stakeholder theory, and a group of frameworks developed to help boost businesses’ accountability on human rights obligations.
1.1
Research
problem
The main research problem of this paper is to identify if the Spanish banking sector is using its CSR policies and practices in a flawless and efficient way to identify, promote and communicate possible abuses or human rights violations related to their activity. Banking operations are usually perceived by society as less intrusive and with lower impact on sustainability when compared to other economic activities such as retail manufacturing, resource extraction or energy production. This perception generates less
5
pressure on banks to enforce control of its ordinary activities in relation to human rights accountability, as the urgency to adopt or modify internal procedures to comply with the rules or guidelines is less than, for example, companies facing child labour manufacturing abuses.
In addition, taking into consideration the voluntary approach of the CSR frameworks and the lack of a standardized hard law to regulate non-financial disclosed information, one can often find shallow published sustainability reports where the aim of the company is to demonstrate that they are an environmentally and socially responsible actor of the community. One of the common critiques to those reports is based on the greenwashing behaviour and the unaudited information contained on them (Yu, Luu and Chen, 2020).
1.2
Aim and purpose
The aim of this paper, firstly, is to try to measure the degree of detail and depth of the analyzed annual reports regarding the communication detailed relevant to human rights risks and social impact. For this first part the key elements used will be based on the Ruggie framework published in 20082 that will end up with the introduction of the UNGPs. The main goal is to prove if the analyzed banks are following the proposed guidelines in a flawless manner or if they fall short on applying such principles.
Secondly, in order to demonstrate if the two banks are committed to improving the relations with their stakeholders, a yearly comparison is added to check the evolution of human right indicators/policies found on the selected reports and try to demonstrate if a) there is an increase in the quantity of the reporting related to human rights issues and b) if the introduction of EU and State directives linked to the UNGPs are boosting the improvement of those reports.
2 The Protect, respect and remedy: A framework for business and human rights was the document
presented by John Ruggie after being appointed special representative of the Secretary-General on
human rights and transnational corporations and other business enterprises to work on the Corporate
6
Based on that purpose the following research questions are presented:
a) How deep is the information reported on the non-financial reports regarding Human Rights? (Qualitative content analysis to measure de degree of detail) b) Did it change overtime? Did it change due to the Directive? (Directive
2014/95/UE and Real Decreto-ley 18/2017) (Quantitative content analysis to measure change)
1.3
Relevance to Human Rights
Modern society cannot be understood without the influence that economy has on it. An essential component of the balance in any society are businesses of any type, size and range. MNCs and big companies are major actors of today’s globalization, and the way they operate have consequences not only on the financial and economic sphere but also on most parts of societies around the world. The relation between business and Human rights has been an ongoing discussion for many years. In the last decades, with the growing importance of CSR and voluntary frameworks to address the impact of business on society and the environment the discussion is bringing interesting challenges. One of the latest tools to tackle corporate abuses is the introduction of the United Nations Guiding Principles on Business and Human Rights (UNGPs).
We can consider the UNGPs framework a game changer, as their appearance
“…constitute the authoritative global framework for managing human rights risks related to business activities. They apply to all States as well as to all business enterprises regardless of their sector...” (Foley Hoag LLP and United Nations Environment
Programme Finance Initiative, 2015) This is an important point given that financial institutions might be seen less impactful on human rights than other industries.
Today, many businesses and especially MNCs and big companies, such as the analyzed public listed banks, embrace CSR strategies to encourage positive impacts towards environment and society, but that good will many times fall short to prevent human rights violations due to their own operations or its supply chain or clients’ activities.
One of the characteristics of banking that make this sector different from most other industries is its dual role: as a commercial, profit-driven bank entity that has responsibility towards its stakeholders (clients, employees, providers, investors) just as any given business, but also as a financial provider to other businesses of any kind and sector. This
7
duality makes banking more prone to be involved in human rights violations by third parties that are directly linked to them by the financial support provided. When acting as a regular business entity one of the most reported human rights issue could be the discrimination based on gender or ethnicity (Henderson, L. et al. (2015) when accessing to credit lines or financial products. When acting as financial providers the scope of the related abuses widens, from funding projects in the Amazon rainforest affecting indigenous people to underwriting government bonds in countries accused of practicing apartheid policies (Banktrack webpage).
The development of the latest CSR frameworks and initiatives to mitigate and remediate human rights abuses by businesses has not yet prevented those issues from happening and that is the main reason why the topic of the paper is relevant from a Human Rights perspective.
1.4
Delimitations
Due to the limited space of this paper and the will to elaborate on simple and clear conclusions, the thesis will analyze the reports provided by the two selected financial institutions for the most relevant and available years to the research questions. Theory, method and material have been chosen to prevent this paper from being pretentious, as the aim is to contribute to the research field with simple but honest knowledge.
The study is carried out in the Spanish banking sector; therefore, the analysis and conclusions are limited to Spain. The investigation does not take into consideration relevant areas to CSR reporting other than Human Rights.
8
2.
Background and previous research
In this chapter we will have a short introduction on the CSR history. Although the topic is not strictly focused on CSR as a whole concept, I reckon it is a necessary step to link all the parts of this paper with a shared value that will contribute to have a readable storytelling. To have a basic introduction on CSR will help us to better understand the concept, its evolution in the last decades and the connection with the research questions and the analysis. The research based on human rights in the banking sector is explained in separate parts; thus, the idea is to have a fragmented structure that will focus on each of the relevant parts to our research problem.
2.1 The birth and growth of CSR
The discussion of linking the economic or productive activity with social responsibility is not a new trend. Some academic works track this phenomenon already in the Roman law, as some associations that can be compared to modern corporations had strong ties to the society (Chaffee, E. C. 2017). However, the most accepted starting point to modern CSR is the publication of Social responsibilities of the businessman in 1953, where it can be found one of the most cited definitions of the corporate social responsibility: “the obligations of businessmen to pursue those policies, to make those decisions or to follow those lines of action which are desirable in terms of the objective and values of our society” (Bowen, 1953, p. 6). Some parts of this quote could be updated to also add the environmental part to the equation and Bowen’s definition is still up to date. CSR could be defined as a business model or self-regulating practice of business that aims to increase the accountability of business in relation to its social, environmental and financial impact on any level.
Even if the concept originated in the 50s, its importance has steadily grown and nowadays it is a general and accepted practice in most multinational corporations (MNCs) and large businesses around the world. The expansion of CSR, boosted by the growing trend of social consciousness and business ethics linked to the climate change discussion, has caused the introduction of new language and terminology. Quite often we can use similar words or concepts in an interchangeable way even if the concepts are not exactly the same. As stated in the introduction chapter, the aim of this paper is to represent a simple
9
view of the research problem and its analysis; therefore, we are dismissing the conceptual differences of sustainability referring strictly to environmental issues, and treating environmental, social and corporate governance (ESG) criteria under CSR policies and activities.
Corporate social responsibility has evolved rapidly on several concepts, one of the most relevant being the regulation of this practice, changing from a volunteer approach to a legal obligation in some countries and developing more reliable and transparent mechanisms to account for business impact. One of the reasons that this paper is based on the analysis of two Spanish companies is the incorporation of a regulated decree under the Spanish legislative pyramid, the Real Decreto-ley 18/2017, that aims to regulate the way companies generate the non-financial reporting of their operations. The foundations of this new rule together with the EU Directive 2014/95 will be explained on the theory chapter. The growing relevance of standardization helped to create some global frameworks to aid on the evaluation and comparison of CSR practices. Some of the most known frameworks or tools to measure sustainability performance are: The Global Reporting Initiative (GRI), Equator Principles, UN Guiding Principles or the AA1000. These frameworks provide guidelines and serve as indicators of the sustainability performance of the adhered companies while allowing easy traceability and comparison of the company’s activities in relation to the ESG goals between different sectors and countries.
2.2 Business communication on CSR, background of the reporting tool
This check on previous research is the first step to mapping the research field relevant to my thesis’ topic, which is the analysis of the quality and the evolution of Caixabank and BBVA sustainability reports. As we will see, a deep analysis of multiple concepts related to CSR and sustainability reporting is lacking in the actual research (Venturelli et al. 2018; Moratis 2017; Carnevale et al. 2012; Martin-Sardesai et al. 2020); this trend is more visible in sectors that are less sensitive to environmental impact such as banking or financial services (Venturelli et al. 2018; Castelo et al. 2006). Even though the financial services sector is one of the most relevant actors globally, the reporting rates are lower than the average (KPMG 2017). During the last few years there has been a noticeable increase in the total amount of banking companies reporting sustainability information10
(from 71% in 2017 to 78% last year); however, this sector is still falling behind mining (84%), automotive (83%), oil & gas (81%), chemicals (80%) and forestry & paper (80%), hence more research is needed and hopefully my work will broaden the knowledge on the social impact of banking in Spain, where the reporting ratio, based on the N100 sample for all sectors was 98% on 2020 (KPMG 2020).
It is clear, after checking these figures, that sustainability reporting is a growing trend and it has been like that since the late 90s: companies around the world are taking the relation between business and the impact that their operations have on the planet or the people more seriously. An easy comparison will highlight this growth: in 1998 just 15% of banks & insurances analyzed on Fortune 250 sample were disclosing sustainability reports (Kolk 2003). This growth is shown with the increase in reports generated that can normally be found on the company’s websites or general databases dedicated to reporting or independent consultancy such as GRI or KPMG. The rise in reporting may be due to different factors: NGOs and stakeholder pressure, new government regulations, marketing purposes in order to improve the company’s image or for financial performance gain. For this reason, the growing interest is generating an increase in new reports focused on this multidisciplinary relation of the company that is constantly generating new trends. Some of the current areas of interest are: the importance of having an integrated reporting; the Stakeholder engagement concept; the quality of the reporting; the add-value of generating sustainability reporting or Integrated reports; the changes on the stock prices linked to the disclosure of non-financial information, etc.
The way sustainability reports are made also suffered a major change in the last decades. Back in the 70s and 80s, what we call now sustainability reports or CSR reports were introduced by companies as social reporting. The next introduction on reporting was environmental reporting during the 90s and then followed by the appearance of CSR or corporate reports in the following decades (Fifka, 2012). All in all, that evolution was more about terminology differences rather than the creation of new concepts considering all of these reports are focused on the same elements, financial, environmental and social indicators. Those are the same threefold values found in most of the CSR concepts, take the Triple Bottom Line (TBL) framework for instance, one of the most known concepts on that field (Elkington, 1998). The TBL is based on the same three elements and also named by its author as the 3Ps, planet, people and profit. Therefore, in terms of language, sustainability reporting has not changed much but the information contained in those
11
reports has. For many years the primary report elaborated by businesses were the financial statements, then other layers connected to businesses and shareholders were added (Governance and remuneration, environmental impact, management commentary, etc.) in the forms of stand-alone reports, and for the last decade the trend is to generate an integrated report where all of the information reported blends with the financial performance in a balanced mix. Organizations had been publishing extensive reports that required technical knowledge to be understood by all parts and, in addition, these reports were made by different internal departments instead of a joint document were all parts are well connected (EY 2014). We then selected the integrated reports for our sample in order to go in line with the actual trend on reporting and also to get a more suitable comparison between them.
To close our explanation on the background of corporate reporting, the following question is formulated: What was the interest or the aim of a company to publish these reports? The answer is shared between internal and external elements.
Firstly, those reports help the company to create an image to communicate with its main audience, employees and shareholders (on the first stages of CSR) / stakeholders (on a more recent CSR stage) (Lober et al. 1997; Spence 2009) about how it is dealing with financial, environmental and social challenges internally, and what next steps are to be taken on the company’s long-term sustainability strategy. And secondly, the main external aim is to communicate the efforts done (past, present and future) to improve the sustainability performance to stakeholders (Lozano, 2013).
These reports represent the relation between the organization’s day-to-day operations and the pressure by regulators on one side and stakeholders on the other, and they are the main communication method to disclose CSR information (Sweeney and Coughlan, 2008).
2.3 Literature review on sustainability reporting
Literature on sustainability reporting research is quite wide and extensive as noted in the previous point. The concept of reporting the ESG indicators of a business has always drawn attention from scholars. Furthermore, the growth of that trend in the last decades goes hand in hand with the academic research interest on the diverse new concepts that CSR or sustainability is regularly providing, such as new ways to report, the introduction
12
of new metrics to measure sustainability performance, updates on the standardization frameworks or new directives from regulators, just to name a few. This statement is easily demonstrable by the number of articles found and their publication year. Articles analyzing companies’ sustainability reports or performance could be found back in the 80-90s, matching the introduction of environmental and social disclosures as a part of the communication to stakeholders (Wiseman, 1982; Cowen et al. 1987; Zéghal and Ahmed 1990; Roberts 1991; Lober et al. 1997; Adams et al. 1998). For the following three decades, this trend has had a steady growth not only in the academic sphere but also in the professional scene. The yearly surveys of consultancy firms like KPMG or EY to check the status of CSR globally are another proof of the expansion of CSR and the sustainability reporting practice.
Despite being a quite recent research field, the characteristics of a big part of the works done are similar when it comes to the sample, theory and method used.
Some scholars researched on how works based on the CSR reporting measure the volume found in the documents to assess the value of the item analyzed according to the quantity of text disclosed relevant to that item. A big number of articles found suitable to be added to this literature review could be classified, then, in two different groups, depending on the general approach of the topic. The first group measures the volume of the sustainability report in basic units (words, sentences, numbers of pages or percentage on text) and the second group measures the reporting based on the presence or absence of predetermined topics (Unerman, 2000; Morhardt 2009).
Back to the similarities, a large part of the research done consists of focusing on top performing financial companies using different published company ranks. Mostly, we can find articles analyzing all the companies in those ranks or some of their sectors. The various classifications provided by the Fortune magazine (Fortune 50, 100, 250, 500 and its global versions) are one of the most used ranks when sampling (Lober et al. 1997; Kolk et al. 2001; Kolk 2003; Morhardt et al. 2002; Jose and Lee, 2007; Jeriji and Louhichi 2021), other indicators based on ESG criteria like The Dow Jones Sustainability Index are also broadly used by researchers (Albino et al, 2009; Aureli et al. 2019).
In respect of the theory used by researchers, there are significant changes depending on the topic of the paper. The majority of papers with broad research questions tend to pick the same theories, which are: stakeholder, legitimacy, agency or institutional theory
13
(Khan et al. 2020). As mentioned before, the information disclosed in the sustainability or the integrated report came from various sources, thus, the research questions proposed may interfere significantly with the approach of the researcher, which means that there are articles using other theories than the four main ones previously noted due to a better fit with the suggested questions. An example of this is the work of Martin-Sardesai and Guthrie (2020), where they focus on providing an understanding of the development process of creating social and environmental disclosure. Their work is based on a theoretical framework called The Idea Journey framework that provides a process (journey) where the development and implementation of an idea is explained in different stages.
With regard to the method used, it is clear that content analysis in both its forms, qualitative and quantitative, is the most used methodology (Khan et al. 2020). Content analysis has its pros and cons like any other social research method (we will see them in the method and material chapter) but its nature makes it undoubtably one of the best ways, if not the best, to analyze texts or any other form of communication where the aim is to focus on any part or characteristic of the message provided.
2.3.1 Reporting on the banking industry
Current literature on CSR disclosures in banking or financial entities does not match the number of available articles and papers found in other industries. A big number of the articles analyzed in this part of the review claim the lack of research when it comes to studying CSR, reporting and banking (Tarna 1999; Venturelli et al. 2018; Castelo et al. 2006; Bravo et al. 2012; Chang et al. 2019). In the previous section about the reporting background, it was stated that this might be explained by the nature of banking activity as an industry with less impact compared to others, but then, what are the aims of scholars researching CSR disclosure of banking or financial entities?
In this group, the theory and the method used are also very similar and follow the trend discussed in the last point. Content analysis is the most used method, and legitimacy and stakeholder theories are the base theoretical frameworks to build the analysis for most of the articles checked. What it is quite characteristic of articles focusing on banks are the differences in the research topics. Such diversity regarding topics and research questions might also be explained with the little research done previously, possibly
14
meaning/implying that, when a research field has had a high article production, it also means that scholars overlap each other with their studies.
The most relevant articles here for this paper research topic are the works by Chang et al. (2019). Their purpose was to test the quality of the sustainability report of 100 financial institutions by measuring the effect of the moderator variable, which is the inclusion of the Equator principles in the reports. The measurement and classification of the research is based on the GRI-G4 principles on quality reporting, which provide a guideline to test the strength of sustainability disclosures. The key and relevant element to my work, besides also using content analysis as a methodology, is the use of standardized guidelines to test the variables. In this paper, I will try to add the corporate core elements of the UNGPs as part of my research, to audit the quality of the bank reports regarding human rights due diligence and remediation.
Another interesting article to the topic of this research is the paper by Castelo and Lima (2006). They aim to test the CSR disclosed information on Portuguese bank websites and then compare it with the annual reports. Although their work is based on the Legitimacy theory, its relevance is on the sample (banks of a same country), the method (content analysis) and also the element of comparability which focuses on the social aspects of the reporting (employee information, community involvement).
Based on the analysis of websites methodology, we can also find the article by Bravo et al. (2011). Similar to Castelo and Lima (2006). Their purpose is to demonstrate the use of arbitrary CSR material to provide an artificial corporate identity that best fits the company’s interests. The key elements of this work are, again, the use of content analysis as a methodology to study 82 banks, and the single country (Spain) sample.
To sum up this part of the relevant previous research, there is the article by Rodriguez et al. (2013) that is probably the most significant work to my topic as it matches almost all of my thesis’ elements. Their purpose is to rate the quality and the transparency of CSR reports disclosed by the Spanish financial institutions. To do so they use both qualitative and quantitative content analysis and base their analysis on stakeholder and legitimacy theory. In addition, they also use a comparative element to evaluate the changes in reports from 2007 to 2010 and split the analyzed categories in four (customers, society, employees, environment) to better gasp the key elements of the stakeholder approach and the ESG values.
15
2.3.1.1
Focus on Human Rights
Relevant previous research is scarce when trying to find articles focused on sustainability reporting for the banking industry. What’s more, if we try to add human rights issues into the research topic the results found drop drastically. Finding similar academic work with a single country scope is almost mission impossible. I could not find anything related to my topic even when looking for articles written in Spanish; this scenario helps me think that I am on the good track to fill a gap in the research field with this paper.
The two relevant research works that fulfil the previous requirements besides having the special focus on human rights issues are the research and reports done by Banktrack and the 2020 Financial Services Human Rights Benchmark by the University of Sidney. Banktrack is a civil society organization (CSO) that promotes a banking sector with respect to human rights and without any negative impact on society and environment. One of their main tasks is to track the involvement of banks on harmful financial activities or projects (Banktrack website). Their main work is based on publications of annual reports, benchmarking and campaigns targeting specific issues related with harmful banking processes. The relevant part to my work is the structure, the sample and the elements tested on the human rights benchmark report as it is based on the UNGPs. More specifically, in how the Protect, Respect and Remedy framework is applied to the methodology. The benchmark is divided in four themes and each theme has some sub-questions relevant to the UNGPs, for each sub-question a score is given based on a classification of a qualitative content analysis applied to the public disclosure available of each bank. The scores can vary from 0 (No score, where no information is found linked to the sub-question), 0.5 (Half score) and 1 (Full score) (Banktrack, 2019).
The University of Sidney Human Rights benchmark is quite similar to the Banktrack one, their sample is not based on a global mix of banks as the Banktrack’s choice, instead they picked 22 financial Australian entities to analyze their financial year disclosures. Another big difference lays on the values applied to the methodology, instead of adapting the values of the UNGPs to the research they measured six human rights categories (Privacy and information; anti-discrimination; Economic security; Health and safety; voice and participation; right to remedy) and their impact on five areas related to human rights and banking activities (Retail; commercial investment; Employees; Suppliers; Society) the
16
results are scaled in red, amber and green colour scheme to show the degree of information disclosed for every category (Financial Services Human Rights Benchmark, 2020). Despite some small differences, both benchmarks propose a method, structure, analysis and conclusions very similar to my aimed goals for this work.
A couple of other articles were examined but dismissed due to low relevance to my topic in terms of purpose and content presented, one of those being the Thun group discussion paper. The Thun group is a hub of global banks that seek to find the best fit for the financial sector of the UNGPs. They consider the framework to be generic and in need of a comprehensive approach to be applied properly, as banks have complex situations that affect all industry sectors and many geographical areas. The discussion papers provided by the Thun Group are a good attempt to broaden how the UNGPs can apply effectively to the banking industry, for instance, they developed some interesting concepts like the proximity linkage to assess risk on human rights due diligence process depending on banks’ relation to its clients (Thun Group, 2013). However, their contribution to human rights has been criticized as it falls short to comply with the recognition of the range of human rights abuses where banks can be involved; the lack of an effective remediation process and a poor engagement with affected stakeholders (de Felice, 2015).
17
3.THEORY
This chapter will serve to present the theoretical concepts used for the study. We will introduce a set of concepts that all together will hopefully help us to analyze our research work.
As noted before in the review part of this paper, the two main theories used when researching on the CSR sphere are the legitimacy and the stakeholder theory (Khan et al., 2020). Both theories belong to the political economy theory and certainly they share many values that are relevant to CSR studies.
Several scholars prefer the legitimacy approach to study sustainability disclosures as this theoretical concept provides a better fit for studying the relation between organizations and society as a whole. It is used for instance, in research questions that aim to measure the provided disclosure material with variables such as size, profits, or social visibility. The legitimacy theory is based on the idea that an organization needs to work accordingly with the values of society in order to continue existing as a business. A company cannot survive in a society without the approval of its common operations from the later, thus legitimacy theory is based on a social contract between the business and the society. Based on that, the practice of sustainability disclosure is a key factor for organizations to show that they are fulfilling that social contract (Castelo and Lima, 2006).
However, other scholars prefer to base their works on the stakeholder theory. This approach is based on the relation of the company with its stakeholders. One of the characteristics of this theory is the aim to seek accountability in business operations towards its stakeholders and not towards a broader concept of a whole society.
There is also the view that there is an overlapping between the two theories, and instead of having to pick one or the other, there is room for both approaches to be used together (Gray et al. 1995; Bonifacio Neto and Branco, 2019).
For this paper I decided to base my theoretical framework only on the stakeholder approach. I consider this theory to be more relevant to my research questions than the legitimacy theory since the questions are not measuring approval or asking why the sustainability reporting is developed in a particular way. The stakeholder approach adjusts better to my questions for two reasons, first, we discussed that banks can also be relevant
18
actors when committing human rights abuses (directly or indirectly) and we will try to test the degree of their accountability for preventing or remediating those issues by examining the quality of their communication checking the sustainability reports. And second, it will also be useful when checking the change over time in the reporting focused on human rights. Due to the introduction of new directives by regulators or voluntary frameworks, the organizations should have added or updated their affected stakeholders in their reporting practices.
3.1 The Stakeholder theory
The main focus of the Stakeholder theory is the relationship between the organization and its stakeholders. Mostly used in business ethics or the managerial moral academia realm, the theory has been highly influential in the CSR research field.
It is often portrayed as the opposite of Milton Friedman’s idea on the responsibility of businesses. His article published in 1970, A Friedman doctrine‐- The Social
Responsibility Of Business Is to Increase Its Profits provides an insight into the mission
of corporations based on the neo-liberal doctrine of profit maximization. To illustrate this distinction between a model based on shareholders and one based on stakeholders I reckon it is best to read this excerpt from his article:
“that business has a “social conscience” and takes seriously its responsibilities for providing employment, eliminating discrimination, avoiding pollution and whatever else may be the catchwords of the contemporary crop of reformers. In fact they are—or would be if they or any one else took them seriously— preaching pure and unadulterated socialism. Businessmen who talk this way are unwitting puppets of the intellectual forces that have been undermining the basis of a free society these past decades.” (Friedman,
1970).
One of the authors that contributed the most to the stakeholder theory is Robert E. Freeman. His concept of business responsibility clashes with the above definition from Friedman and he is vastly cited in CSR research papers that base or use this theory as part of their theoretical framework. An evidence of his influence on the theory is the common citation of his definition about the stakeholder concept I that appears in many papers. To Freeman, stakeholders are: “any group or individual who is affected by or can affect the
19
achievement of an organization’s objectives” (Freeman and McVea, 2001). By this
definition we can then agree that all businesses have a given group of stakeholders3 to which they have an obligation or responsibility (Sweeney and Coughlan, 2008). This part makes communication between organizations and their pertinent stakeholders a key element, given that communication provided by the company will be the tool that enables stakeholders to understand and approve or reject the reported decisions and actions. The core concept of the stakeholder approach is to build relationships with all stakeholders, as this will allow the survival of the firm, and to introduce the relevant factors into the decision-making process which will gain the support of all the stakeholders in the long run. Thus, some of the characteristics of the stakeholder theory relevant to our CSR research problem are: “…a neverending task of balancing and
integrating multiple relationships and multiple objectives.” and to “develop strategies by looking out from the firm and identifying, and investing in, all the relationships that will ensure long-term success” (Freeman and McVea, 2001). These two points suit the
introduction of the Guiding Principles by organizations, and the merge of both theories will provide us the theoretical foundation of this research project.
3.2 Critique on the stakeholder approach
Despite being generally accepted by CSR scholars, the stakeholder theory has also received some critiques. Fleming and Jones captured some of the problems of this approach in their work The end of Corporate Social Responsibility (2012). To them, this approach suffers from naivety and they state that its real role is to be an instrument of
containment (Fleming and Jones, 2012: p51). The idea should allow particularly affected
stakeholders to enter into open discussions to have their interests added into decision making processes but instead, the consultation might end up being just an official notice by the firm.
Instead of using the stakeholder approach, they propose an updated version called critical
stakeholder analysis aiming to bring power, corporate domination and class power
concepts to the centre of the discussion (Fleming and Jones, 2012: p51). The need to
3 Common groups identified as stakeholders in CSR literature are workers, environment, interest groups,
20
review the stakeholder approach is based on the fact that corporate interests always have priority over any other stakeholder discussion process. This dominant condition by corporations and the lack of power-relation discussions when analyzing the relations between firms and stakeholders on the classical approach of the theory make the ground for this critical approach.
Another critical view of this approach is the lack of transparency found in the way firms communicate their actions (by means of disclosing sustainability documents for instance) and the different value given to various stakeholder groups, the external ones being less included in the negotiating process. Arguably that communication is aimed to fulfil organizational own interest rather to effectively communicate the real performance (Boiral and Henri, 2017).
3.3 The Ruggie framework and the Guiding Principles
The United Nations Guiding Principles (UNGPs) were established by the United Nations Human Rights Council (HRC) in 2011. It was the first time that a global standard framework linking the business role and implications towards human rights was approved by governments, and this fact is a good indicator of the quality and robustness of the balance that the framework proposes (Addo, 2014).
That achievement was possible thanks to the previous work by John G. Ruggie, while he was serving as UN Secretary-General’s Special Representative for Business and Human Rights. During the previous six years of research and consultation, Ruggie had to work with many different actors to establish and present the primary source that UNGPs are based on, the Protect, Respect, Remedy framework.
The UN Guiding Principles rest on the three pillars found on Ruggie’s framework:
“…state duty to protect against human rights abuses by third parties, including business; the corporate responsibility to respect human rights; and the need for more effective access to remedies” (Ruggie, 2008)
A set of 31 different principles are explained in the document, the most relevant to businesses and to this paper being the ones from the second pilar, which are principles 11 (Business should respect human rights) to 24 (Address actual and potential adverse
21
human rights impacts), as they cover and make reference to how private firms should act to fulfil the frameworks’ directives.
The UNGPs and the three core pillars require companies, of any kind of activity, therefore, including banks, to: a) Express their commitment to respect human rights in a statement of policy; b) Adopt a human rights policy that will lead to the incorporation of a human rights due diligence process to identify, prevent, mitigate, and account for impacts on human rights; c) Provide access to enable the remedy of impacts caused by the firm or to which they contribute (Foley, 2015)
Also in 2011, the European Commission published a communication linking Corporate Social Responsibility to the UNGP and requiring European governments to adopt a National Action Plan for the implementation of the new framework. (Addo, 2014, EU Commission 2011)
The point 4.8.2 of that communication (Implementing the UN Guiding Principles on Business and Human Rights) expects: “all European enterprises to meet the corporate
responsibility to respect human rights, as defined in the UN Guiding Principles.” and “Invites EU Member States to develop by the end of 2012 national plans for the implementation of the UN Guiding Principles.” (EU Commission, 2011)
These last two points bring us to the last theoretical concept of this chapter, the introduction of the European Directive 2014/95/UE and the influence it has had on the Spanish domestic law.
3.4 The Directive 2014/95/UE and the Real Decreto-ley 18/2017
The Directive 2014/95/UE brought an updated view on the CSR annual reporting. Besides the regulated financial statements, this directive requires certain large companies to additionally attach a non-financial performance report. The report must comply some requirements and display information about how the company deals with environmental
issues, social conditions, employees, respect for human rights and counteracting corruption.
The article 4 of Directive 2014/95/UE requires Member States to adopt laws or regulations to comply with the its requirements by December 2016. The Real
Decreto-22
ley 18/2017 is the regulation that brought the requirements from the EU Directive into Spanish domestic law.
The Real Decreto-ley 18/2017 is a simple transliteration of the Directive 2014/95/UE which at the same time is based on the Directive 2013/34/EU, thus the companies that must comply are the ones under these criteria:
- Companies with more than 500 employees - Balance sheet total: EUR 20.000.000 - Net turnover: EUR 40.000.000
- Average number of employees during the financial year: 250
This is relevant to us because both of the analyzed firms must comply with the domestic regulation, and as part of the second research questions, we will try to determine if the incorporation of such requirements by the Directive 2014/95/UE and the Real Decreto-ley 18/2017 brought an improvement on how information regarding human rights is reported.
23
4.
Method and material
In this chapter I will discuss the method applied on this research. A brief explanation on picking content analysis, its strengths and weaknesses and alternatives that could also have worked on the study. The methodology of the research will also be explained, showing in detail the frameworks used to test the material, as well as the operationalization of the theory and an explanation on the firm selection.
4.1 Content Analysis
Content analysis is the predominant method applied when it comes to textual analysis of annual reporting. As we could state in the literature review chapter, is it by far, the most used method for the selected articles. Researchers rely on content analysis for several reasons: is considered “… an objective, reproducible method that allows for comparison,
in terms of both time and space” (Venturelli et al. 2018), is a frequent method when
analyzing corporate disclosures (Moratis, 2017) because it allows comparison, with other variables and when studying an overtime evolution (Oliveira et al. 2019).
The method itself developed with the emergence of mass-media communication, and the need to analyze public opinion and enemy propaganda during the first and second World Wars. Since then, it has been widely used to analyze questions related to any form of communication with special importance given to texts and images (Rosenthal, 2018: 193).
The common use of this method within the CSR field answers to the need of the researchers to analyze large amounts of text (mainly primary sources). It is especially useful here due to the fact that the main material analyzed is often the different reports provided by the corporations itself, and that reports are done under a standardized framework (GRI400, ISO26000, etc) hence the method allows an easy comparison not only with other companies or sectors but also with other ways of reporting. Boréus defend this strength of content analysis when analyzing patterns over time with these words:
“…quantitative content analysis provides a kind of general information that other analytical approaches… are rarely capable of” (Boréus, K et al. 2017: 26)
24
If properly coded, it is also very useful to analyze the evolution or the change of a certain set of variables on a time series.
In Kolk (2003; 2010) this comparison overtime serves to demonstrate the trends on the total percentage of reporters disclosed by countries and also by sectors to measure the developments done from one period to the other. Also, Martin-Sardesai, A (2020) makes use of SR from 2007 to 2012 to analyze the structural changes in the social report over time of the Italian bank. And Ortiz (2014) uses two consecutive years to analyze, in a quantitative way, the degree of adherence of the various Spanish listed companies to different reporting standards and the changes from one year to another.
The use of content analysis for this research was always my first pick, after going through the literature review it was clear that the method fits our topic perfectly. Certainly, there are some negative singularities attached to this method, the most obvious ones are: the limitations linked to its quantification nature, and the avoidance of context analysis. Not all ideas or concepts can be quantified or broke down to small units without losing a relevant part of the intention of the analysis. The context limitation does also imply that we can only analyze what it is written (in the case of texts), hence, the lack of certain ideas or concepts not present in the texts are left out of the study even if the omission could be relevant to the research (Boréus, K et al. 2017: 45).
Other methods were also tested on the initial stages of the thesis planning. A potential candidate was to elaborate a case study and base the whole research on the singularity of CSR and human rights approach in the company, however, the idea was dismissed as the aim of this paper is to further investigate human rights on banking sector (limited to Spain) rather than focus on human rights issues of a single company.
4.2 Methodology of the research
The research methodology will be divided in two parts, both will have a deductive approach. We will try to mix the theory of the previous chapter with a framework to allow us an observation of the material selected and then reach a confirmation of the hypotheses that is linked to the research questions introduced in the first part of this paper.
Firstly, we will elaborate a framework based on a qualitative content analysis of the material. The framework will be structured in a set of topics that will be used to test the
25
information reported in depth, allowing us to verify and classify (by the use of a simple scale system) the results in order to have picture of the quality and deepness of the disclosed material. The topics will be based on the UNGPs, particularly the ones of the second pillar in the Protect, Respect and Remedy framework, thus, enabling us to test the bank’s accountability regarding the relevant human rights principles found in the theory. Each of the question of the framework is divided into key topics that reflect the kind of information that a firm can disclose with regard the UNGPs concepts.
The next step is to compare the information reported on the material with the topics selected and provide a score that reflects the quality of the information shared. This methodology excludes any other information reported by the bank that is not present on the analyzed report. Hence, other materials available in the bank’s website in the form of specific policies, stand-alone reports or CSR related documents are left out the study even if they are suitable with human rights field. I’m aware that the exclusion of such materials is limiting our study scope but we consider, based on previous literature, the annual report as the primary source of communication with firms’ stakeholders and we designed the research on this foundation.
Secondly, to be able to answer our second research question, we will try to elaborate a simple coding scheme that will permit us test if the disclosed information regarding human rights of the two banks has improved over time. Hopefully that will also show if the introduction of relevant legislative documents by regulators has been significant to that change. Consequently, we will make use of a quantitative content analysis based on the Directive 2014/95/UE and the Real Decreto-ley 18/2017 to analyze the presence of the core elements of these regulations.
4.3 Firm selection and material
Our research is based on two of the biggest banks in Spain, Caixabank and BBVA. The sample could look small, but for the last decades, the Spanish banking sector has been suffering from an intense merging activity of its financial institutions and nowadays the
26
sector is represented by only 5 companies on the IBEX-354 (Caixabank, BBVA, Banc Sabadell, Banco Santander and Bankinter).
The selection of these two banks is also based on the type of financial activity of each one, representing the two different banking entities present in the market. Caixabank is based on the model of saving bank and its core business sector is retail banking while BBVA represents the commercial bank model with bigger presence in corporate banking. This nuance can help explain some of the differences between the two firms in the next chapter, as the purpose or function of a saving bank has a strong social component, not so, a regular commercial bank where the main purpose is profit generation.
The material used in the research will be Integrated Reports of both firms. My first idea when selecting the material was to search for the reports on the GRI database to have a more standardized approach. In addition, many documents available in the GRI database have a technical description of the disclosure, and a checklist to verify if the document comply with international standards and also if it has been produced following GRI guidelines. Sadly, I had to reconsider my first intention as some availability issues appeared. One of them was the lack of the reports uploaded in English. Only three English reports are available for BBVA in the database and they are of mixed nature (Financial report for 2010, Integrated report for the whole group in 2016 and corporate responsibility report for 2007). Other issues for using the GRI database to get the material are the absence of some years uploaded and the change of name in 2011 suffered by Caixabank5. Due to that situations, the material is taken from bank’s websites.
The selected years for the analysis are based on relevant events which can modify the type of information reported. Two time periods are taken into consideration, 2010 and 2018. An exception is made for Caixabank 2018 report as it is not available in the form of the rest of the material (Integrated reports) instead is renamed to ‘Group management
report of Caixabank group 2018’ not knowing if this new name will modify the previous
layout, I decided to pick it to maintain the same time period for both entities. The selected years should reflect changes between the periods, not only due to the time gap but also
4 The IBEX-35 is the main stock market index in Spain, portraying the biggest 35 Spanish companies by
market capitalization.
5 Formerly known as La Caixa, it was restructured and renamed to Caixabank due to new regulations in
27
due to the introduction of new guidelines or regulations (2011 UNGPs; 2014 Directive 2014/95/UE; 2017/2018 Real Decreto-ley 18/2017).
5.Results and analysis
In this chapter we will share the results of the applied methodology to the selected material. The two research questions formulated in the introduction chapter will be answered by the explanation of the results in combination with the relevant theory proposed.
5.1 Quality of the information reported regarding Human Rights
This first part of the analysis chapter is targeting our first research question. How deep is
the information reported on the non-financial reports regarding Human Rights? To try
to answer it we have developed a qualitative content analysis where we measure the deepness of the information disclosed for our topics. The information relevant to each topic is classified in three different grades: ‘No information found’ with a given score of 0 when the selected topic is not found on the reporting; ‘Basic information’ with a given score of 1 when the topic is described but no further argumentation or deep explanation is provided; and ‘Complete information’ with a given score of 2 to the topics where description is present in the document along with a clear and detailed explanation of the theme.
The framework is based on the Operational Principles found in the UNGPs. Three main areas are covered: Policy Commitment, Human Rights Due Diligence and Remediation. For every of these areas a set of questions is asked based on the proper principle from the framework.
The first area, policy commitment is analyzed by these two questions:
1. Does the bank have a statement of policy available expressing the commitment to respect human rights? (Based on the Guiding Principle (GP) 16)
2. Does the bank include other stakeholders rather than employees on the scope of the policy commitment? (Based on GP 16c)
28
1. Does the bank have in place or is working on the implementation of human rights due diligence? (Based on GP17)
2. Is the due diligence analyzing adverse impacts caused by its regular operations or any of its clients? (Based on GP-17a)
3. Does the bank seek external consultation on human rights experts? (Based on GP18a)
4. Does the bank provide analysis on the prevention or mitigation of adverse human rights impacts? (Based on GP19)
5. Does the bank report and communicate human rights impacts? (GP21) The last area of analysis, remediation, is based on the following question:
1. Does the bank have a grievance-mechanism to provide remediation to possible human rights impacts? (Based on GP22)
With this set of questions, we will cover the whole scope of the second pillar of the UNGPs. Hopefully at the end of the analysis we will be able to have a realistic picture of how the two selected banks perform in relation to the disclosed information.
Based on our first research question, our hypothesis should be that both banks would have better scores on the 2018 reports than in the 2010 ones. The later adoption of the UNGPs and the Directive 2013/34/EU not affecting the 2010 disclosure should show us a more primitive status of the business and human rights concept on both banks when compared to the more recent ones.
Policy Commitment Caixabank 2010 Caixabank 2018 BBVA 2010 BBVA 2018
Question 1 1 2 2 2 Question 2 0 2 2 2
0,5 2 2 2
Human Rights Due Diligence Caixabank 2010 Caixabank 2018 BBVA 2010 BBVA 2018
Question 1 0 1 0 2 Question 2 0 1 0 2 Question 3 0 0 0 1 Question 4 0 1 0 2 Question 5 1 1 0 1 0,2 0,8 0 1,6
Remediation Caixabank 2010 Caixabank 2018 BBVA 2010 BBVA 2018
Question 1 0 0 0 0
0 0 0 0
29
After checking the provided results, we can confirm that our hypothesis was correct. Both of the selected banks improve the quality of the information reported regarding human rights over the years. The analysis provides us a quick view of the weak and strong points of both companies when it comes to applying the UNGPs into the non-financial disclosed information. The only good indicator in the 2010 reports is the policy commitment area for BBVA as it provides a clear and extensive description of the bank commitment to respect human rights. The weak spots are sadly all of the other indicators, the concept of human rights due diligence was completely absent in the case of BBVA and almost totally missing for Caixabank. With regards the remediation area, we can assure that it is clearly the weakest point of the two banks for both years. They add a point on working towards providing such mechanism so hopefully future reports will have grievance-mechanism in place. It is interesting to note that even if Caixabank’s 2010 result looks disturbing, there are many individual policies in place and with a basic level of detail, for instance policies to tackle sexual harassment and workplace mobbing, but they are not labelled under the human rights or social sustainability scope.
With these results, we can see that sustainability reporting on human rights is on the rise, at least when it comes to quality of the content. Businesses are embracing the idea of the stakeholder approach, increasing their accountability to their relevant groups and therefore adding mechanism, indicators and communication channels to be part of a sustainable community when it comes to relation of ESG impacts.
Based on the results, the commitment to both stakeholders and human rights are clearly on the rise and the UNGPs are the mainstream tool to engage with its values. This is an evident sign when checking BBVA 2018 report as the UNGPs is the used framework to elaborate on sustainable disclosure, almost all of the GPs are present and well elaborated.
5.2 Evolution of the disclosed information on non-financial reports
In this second part of the analysis our purpose is to answer our second research question,
did the information reported on non-financial reports change overtime? Did it change due to the Directive? In this case we decided to take a different research approach and
instead of using a qualitative analysis we applied a quantitative approach. Similar to the previous point, we made use of the theory related to the introduction of the Directive 2014/95/UE and Real Decreto-ley 18/2017 and applied a grid of topics of that part of the
30
theoretical framework to the same reports of the previous section. We will then measure the frequency that the chosen topics are found on the texts and set a comparison for the different selected years.
The selected topics go in line with the key points found on Directive 2014/95/UE and the amendments done to Directive 2013/34/EU. Thus, the aim of this modification is to require the elaboration of a non-financial statement with the necessary information:
“…for an understanding of the undertaking's development, performance, position and impact of its activity, relating to, as a minimum, environmental, social and employee matters, respect for human rights, anti-corruption and bribery matters…” (EU, 2014).
The Directive also breaks down this explanation into smaller units, to make it easier to understand the requirements of the amendments. It requires to include a brief description
of the business model, to asses this point I add two topics that could generate a valid
picture of the business matching the purpose of this paper: ‘Identification of stakeholders’ and ‘Description of relevant sustainability impacts. Knowing who is affected by the company daily operations (directly or indirectly) and the type or amount of sustainability impacts that the company is reporting as relevant information will provide us with a good track of its business model.
The second requirement is to include a description of the policies linked to that matters, to track that point I made use of the topic ‘Description of policies/initiatives in relation to human rights respect’, also as a reminder that this paper is focusing only on the human rights issues of the sustainability or non-financial disclosures.
The third requirement asks to include information on the outcome of the policies from the previous point, to match that with a proper topic I used ‘Description of rules or targets of the policies’ as for this category I expect to find detailed information in relation to how these policies are structured or what is the target of enforcing such policies.
The fourth requirement from the amendments asks to include information of the main
risks related to those matters, that are likely to cause adverse impacts. Based on that
specification I think that a basic, but suitable topic would be ‘Description of human rights risks’ to first check if this information is found on the reports, and also an additional one ‘Analysis of internal or external impacts in relation to human rights’ to try to test if those risks are being analyzed or not.
31
The fifth demand is to include relevant non-financial key performance indicators. In order to check that point I decided to first add a basic topic to include indicators that could fit all of the required matters, that is ‘Performance indicators’. And to measure how relevant is the human rights matter in relation to the rest of the matters, I add the ‘Human Rights indicators’ topic, any kind of KPI linked to human rights will fit under this topic, ie. total number of employees with disability or gender parity indicators that if found in the reports, will then show us an interest on gender equality or discrimination issues by the bank.
The last relevant modification of the Directive is the demand to provide a description of
the diversity policy applied in relation to gender, age, educational background, etc. To
test that part, I make use of a basic topic to find matching content, ‘Description of a
diversity policy and data’. For this field any match on diversity information, especially
regarding gender ratio or disability issues is considered a hit even if it overlaps with performance indicator and human rights indicators, for instance this single reference,
“Employees of ”la Caixa”: distribution by gender”(Caixabank, 2010) will be counted in
both, performance and human rights indicators and also in the diversity policy and data topic.
After this explanation, and before checking the results of the study, lets recap on the purpose of this chapter. The second research question is: did the information reported on
non-financial reports change overtime? Did it change due to the Directive? Our
hypothesis is that the introduction of the Directive and the enforcement of the Real Decreto-ley will provide better results for the 2018 reports in both banks, as more information related to our analyzed topics should be provided by the companies.
On behalf of the methodology and the results it is important to note that:
1. The analysis counted the number of times the topics were present by checking every single page of the reports.
2. If present more than one time in the same page the topic is counted only once. 3. For Caixabank 2018 also the appendix is counted.
4. For BBVA 2018 an external stand-alone report about the commitment to human
