ethical consumer research report on insurance

Companies following ‘best practice’ and fully disclosing information, such as Co-operative Insurance and HBOS, get worse scores on the table than companies which fail to be transparent about their shareholdings. Our Best Buy recommendations therefore do not necessarily have the highest ethiscores (see ‘Transparent Shareholding’ opposite).The Best Buy for home and car insurance in this report is the environmental not-for-profit Environmental Transport Association (ETA) (0800 212 810). Naturesave (01803 864 390) is also a best buy for home insurance for its comprehensive take on making insurance a sustainable industry.Best of the more widely available brands for both car and home insurance are Co-operative Insurance (0845 746 46 46), esure (0845 603 7874) and MORE TH>N (www.morethan.com) for their mature take on engagement with the companies in which they hold shares. Ecclesiastical (0845 777 3322) may also interest some ethical consumers, for its history of ethical investment and its charitable status, or LV for its mutual status (0800 975 4132). For travel insurance Ethiscores, see www.ethiscore.org, and for rankings of pet insurance providers see the Money Ethiscore table on page 39.

Riskybusiness

INSURANCE

14 www.ethicalconsumer.org NOVEMBER/DECEMBER ‘07

The insurance industry estimates that the floods in the UK in spring

and summer 2007 will cost it £3

billion. Sarah Irving investigates the

insurance industry’s ethics, and whether

it’s partly to blame in creating the crises it

has to pay out on.

Extreme weather events, from hurricanes and typhoons to floods or droughts, are costing the insurance industry billions,

resulting in raised premiums for consumers and the threat of cover being withdrawn from increasing numbers of people in areas most likely to be hit.

The performance of insurance companies on the issue of climate change demonstrates the extent to which the actions of one part of a company can exacerbate the problems being faced by another. Because while some insurance companies have been facing up to the issues of climate change for years - longer than in many other industries - the investment divisions of those same companies have been helping to fund climate change activities.

Take Legal & General Group, for instance. Like many other major investors, it has holdings in big fossil fuel companies such

as Royal Dutch Shell and BP. However, it also invests heavily in a number of other oil and gas companies which are busy exploring or developing unexploited sources of fossil fuels in countries which have recently opened

up to overseas interests, such as the Central Asian states of the former Soviet Union.1

These are the smaller, riskier pioneer companies which are finding sources of climate-changing fuels to try and

prop up an unsustainable way of life in the affluent

nations, and which attract some fund managers because of the potential high returns

- whatever the environmental cost.Alongside these investors stands the Royal

Bank of Scotland, owner of the Direct Line, Churchill and Privilege insurance names, which branded itself ‘the oil and gas bank’ for the support it gives the industry. For more on Platform’s campaign against RBS, see the corporate watch article in issue 107.

As well as helping to bankroll the search for new fossil fuel sources, some major names in insurance are still helping to prop up one of greatest out-of-touch cronies of the oil industry - the US Republican Party. Zurich and AIG have both been major Republican

What’s in this report?Covered in this report are major providers of the commonest forms of insurance, namely home and car cover. Where the two products appear with different scores under the same brand, it’s because the products are underwritten by different providers, and the Ethiscores have been calculated to take account of both brand providers and underwriters.

Subscribers to the Ethiscore website will also be able to access results for travel insurance, where many of the scores are different. General insurers often use different underwriters for their travel services, which then pick up negative marks from these underwriting companies.

The products on the table can be purchased in a variety of ways - some providers have online signup, others need to be called, and a few (such as Equity and Fortis) are available only through insurance brokers.

NOVEMBER/DECEMBER ‘07 www.ethiscore.org 15

donors in recent years, at a time when the party and the Bush administration have been one of the greatest obstacles to serious global action on climate change.2

While membership of industry organisations is not always an indication of genuine action, some groups are doing significant work on climate change. These include the Institutional Investors Group on Climate Change (IIGCC) and the Carbon Disclosure Project (CDP), which encourages companies from all sectors to calculate and make public their carbon footprints. The list below shows which companies from this report are engaging with these processes:

* IIGCC : BNP Paribas (Pinnacle), HBOS (esure), Co-operative Insurance (CIS)

* CDP members (who commit to supporting the process over and above reporting their carbon footprint): Aviva (Norwich Union), Axa, Royal Bank of Scotland (Direct Line, Churchill, Privilege), BNP Paribas (Pinnacle), American International Group (AIG)

Arms Company What it produces Who invests in it or provides financial services

BAe SystemsSubmarines and military ships, military aircraft, tanks, weaponry and missiles

Axa, CIS, Legal & General, Lloyds TSB

CobhamNaval equipment, army vehicles and military aircraft

Aviva, Axa, CIS, Legal & General, Lloyds TSB

GKN Fighter planes and bombers Aviva, Axa, CIS, Legal & General

Arms investors in this report

* CDP signatories (who commit to reporting their carbon footprints): Allianz (Cornhill), Aviva, Axa, Fortis, BNP Paribas, AIG, HBOS, Legal & General, NFU Mutual, Prudential, CIS

Eco-insurance?A growing number of ‘green insurance’ products are appearing on the market, mainly offering car insurance. The main ‘environmental’ feature of most of these is that the climate change emissions caused by driving are offset by payments to companies specialising in this. The Green Insurance Company, ibuyeco and climatesure are three such providers. Ethical Consumer remains sceptical about the benefits of carbon offsetting, and therefore does not recommend these products, especially where the insurance itself comes from companies not on the Best Buys list. For more information on why Ethical Consumer does not support offsetting, see issue 106 (May/June 2007).

Funding warInsurance companies don’t just profit from and help to fund climate change industries. Many of the companies on the table have also attracted criticism for being entangled in the arms industry, deriving income from the growth of companies which profit from conflict.

Particularly controversial amongst the investments of the companies in this report are, for example, Axa’s holdings in companies which have been accused of manufacturing phosphorus weapons used by the US army in Fallujah. Phosphorus weapons are said to be designed to cause deep flesh burns.5 Fortis has also been accused of having holdings in

companies which make cluster bombs and depleted uranium weapons.6 And AIG has holdings in some of the world’s biggest arms manufacturers, like Lockheed Martin and General Electric.

Arms investments, however, are also in a small way an illustration of the power that public pressure can have on companies. French insurance giant Axa was attacked by Amnesty International in 2006 for continuing to hold shares in companies which produce cluster munitions, a type of bomb which spreads dozens or hundreds of smaller ‘bomblets’ over an area as large as two or three football pitches. According to NGO Handicap International, 98% of those injured by cluster munitions are civilians. In July 2007, Axa finally caved in to the damage being done to its image, and announced that it would be working with Handicap International and Amnesty to identify and divest itself from the estimated $5 million5 worth of cluster-bomb-linked investments in its portfolio.4

Transparent shareholdingFor some consumers, whatever the level of engagement being practised by investors, some shareholdings - whether in companies which test on animals, manufacture arms or pollute the planet - are unacceptable. This means that transparency is vital to allow people to make informed choices. As often happens in such cases, it also means that those companies following ‘best practice’ and disclosing their information, such as CIS and HBOS’ Insight Investment division, get worse scores on the table, while companies which don’t make their holdings public - like insure.co.uk’s owner Insurance Australia, have comparatively good marks which disguise their failure to be totally transparent. This also accounts for the disparities between the Best Buys advice and the table.

As with any Ethical Consumer product report, all the companies can pick up marks on the table for their own direct activities, such as infringing workers’ rights or having operations in oppressive regimes or tax havens. However, many of the companies also have criticisms derived from their investment activities, which explains why companies concerned with finance also have marks in categories such as nuclear power or armaments. Many brands also pick up boycott call marks from companies they invest in, such as Shell and Tesco. Companies in many countries are now legally obliged to reveal this information, either through the reports which the US Securities & Exchange Commission requires from investment managers, or the major shareholder lists which companies traded on the London Stock Exchange must divulge.

buyer’s guide

INSURANCE


Lloyds of LondonBest Buy companies Naturesave and ETA differ slightly from many of the other companies on the table by being entirely underwritten by Lloyds of London. One of the grand old men of the insurance industry, Lloyds was legendarily founded in an eighteenth-century London coffee shop and started out insuring the colonial trade in slaves and sugar. In 1968 a shortage of money meant that the creaking institution finally admitted women to its select population of wealthy individuals (the famous Lloyds ‘names’) who originally provided the finances to pay claims.

After a series of financial crises and scandals in the 1980s and 1990s the Lloyds system was overhauled to allow corporate groups, as well as individuals, to play a significant role in the organisation. Matthew Criddle of Naturesave admits that this has undermined much of the difference between Lloyds and conventional big insurance companies.

“There’s no such thing as an ‘ethical’ insurer at the moment,” he contends, “because every provider is dependent on unethical funds and capital structures at some point, especially the life insurance and pensions providers

but really any company with an investment element. Until the early 1990s Lloyds could be seen as a more ethical option because it was largely made up of private individuals using their funds to underwrite risk, and had no corporate capital base. But now it’s no different from most big general insurers like Royal & Sun or Zurich.”

An ethical insurance company?According to Naturesave’s Matthew Criddle, then, an ‘ethical insurance company’ is one which “encourages sustainable development, rather than those that can be identified as ethical by concentrating on their corporate structures.”

Naturesave’s approach is to offer rebates for customers who take environmental measures like fitting renewable energy sources and to give small business clients comprehensive support in ‘going green.’ Its relationship with its clients also, however, gives it clout in lobbying its Lloyds partners to become more

sustainable, because the long-term customers it attracts provide good value to underwriters.

But, says Matthew Criddle, more effort needs to come from government. “We’re lobbying for a ring-fenced insurance premium tax for flood defences, renewable technologies etc, a bit like that used in France, where a 9% premium tax is applied to all insurance to cover the costs of natural disasters.”

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Green GuideGoing green at home or driving a lower-impact car may not only be good for the environment, but save you money. ‘Eco’ insurance schemes which offer lower premiums to consumers making environmental changes include CIS’ car ‘ecoinsurance’ (www.ecoinsurance.co.uk) with discounts for more fuel-efficient cars, MORE TH>N’s rate cut for hybrid and electric cars, and Naturesave’s discounts on home insurance for houses with features such as enhanced insulation, solar panels and water butts.


Company profiles Allianz SE was criticised by Corporate Watch in June 2007 for its massive political lobbying activities, influencing the lives of millions of Europeans by its impact on EU decisions.

American International Group has been praised by some US ethical investors for being the first major American investment company to properly grasp the issue of climate change. However, it still has holdings in aviation sector companies like Boeing and airport companies.

Co-operative Insurance picks up a full boycott call mark because supermarkets in the Co-op Group are on the Boycott Israeli Goods Campaign list of shops which stock products from Israel and possibly settlements in Palestine.

The Ecclesiastical brand is owned by registered charity Allchurches Trust, to which the majority of its proceeds are donated.

Allchurches makes grants to charitable causes and to Christian organisations, but this doesn’t stop its funds investing in arms manufacturers Rolls Royce and tobacco company BAT.

Fortis is a major Belgian-Dutch financial group, which offers banking as well as insurance products across Europe. It has been criticised by environmental groups for loans to the controversial Nam Theun dam project in Laos, which is expected to result in the destruction of habitats of rare species such as the Asian elephant and the displacement of over 100,000 people.7

Liverpool Victoria and NFU Mutual are both mutual insurers, which means that their

profits remain within the business instead of being handed to shareholders as dividends. In addition to the shareholding criticisms both companies attract, NFU also loses marks on the table for its provision of insurance for bloodsports activities, and for using tax havens.

Saga Insurance is owned by private equity firm Charterhouse Capital, which also has interests in heavy engineering and European clothing retailers, thus attracting criticism for adding to climate change emissions by manufacturing aircraft parts, and for selling clothes trimmed with fur.

Zurich Financial Services picks up criticisms for paying ten members of its board

more than £1 million each in 2006, as well as for membership of international ‘free trade’ lobby groups like the World Economic Forum.

For more on Royal Bank of Scotland, see corporate watch article in issue 107.

Car & home insuranceETA e ETATrustinsure 11 h h h H h JPMorganChase,Insur.Aust’lEndsleigh 7.5 H H h h h H h H h ZurichFinancialServicesZurich 7.5 H H h h h H h H h ZurichFinancialServicesEcclesiastical 7 H h h h h h h h h h h h h h h e AllchurchesTrustLtdLV 7 H h h h h h h h h h h h h h h e LiverpoolVictoriaFriendlySoc.NFUMutual 7 H h h h h h H h h h h h h h NFUMutualIns.Soc.LtdAdmiral 6 H h h h h h h h h h h h h h h Munchener,AdmiralGroupesure 6 h h H h h H h H h h h H HBOSPlcAXA 5 H h h h h h H h h h h h H H AXACo-operativeInsurance 5 h h H h H H H h h h h H H h e Co-operativeGroupCornhillDirect 5 h h H h H H H h h h H H AllianzSE,MunchenerMORETH>N 5 H H h h h h h H h h h h h H Royal&SunAllianceNorwichUnion 5 H h H h H h h H H h h h h AXA,AvivaPlcFortis 4.5 h h H h h h H h h H h h H H FortisNVPrudential 3.5 H h H H h h h h H h h h h h h H RBSGroupPlc,PrudentialPlcChurchill 2 h h H H H h h h H H H h h h H H RoyalBankofScotlandGrpPlcDirectLine 2 h h H H H h h h H H H h h h H H RoyalBankofScotlandGrpPlcNIG 2 h h H H H h h h H H H h h h H H RoyalBankofScotlandGrpPlcCar insurance onlySaga H h H H H H h CharterhouseCapitalPartnersLLPDiamond 6 H h h h h h h h h h h h h h h Munchener,AdmiralGroupFirstAlternative 6 h h H h h H h H h h h H HBOSPlcSheila’sWheels 6 h h H h h H h H h h h H HBOSPlcLloydsTSB 2.5 h h H H h h h h H H h h h h h H H RBSGrpPlc,LloydsTSBHome insurance onlyNaturesave 14 h E NaturesavePoliciesLtdSaga 5.5 H h H h h h h H H h h h h Aviva,CharterhouseCap.PartnersLegal&General 4.5 h h h h H H h H h h h h h h H Legal&GeneralGroupplcAIG 3.5 H h H h h h h h H H h h h H H AmericanInt.Group(AIG)PlcLloydsTSB 3 h h H h h h h h h H H h h h h H H LloydsTSBGroupPlc

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KeyHbottomratinghmiddleratingtoprating(nocriticismsfound)Company ethos: efullmarkEhalfmark

Product Sustainability:companiescanreceiveamaximumoffivepositivemarksforthiscategory.ethiscore:thehigherthescore,thebetterthecompanyacrossthecriticismcategories(seewww.ethicalconsumer.org/ratings/ethicalratings.htmor“IntroductiontoEthicalConsumer”bookletformoredetails).

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buyer’s guide

INSURANCE


Engaging and divesting - how can big money be ethical?Insurance companies make their money in two main ways.

Firstly, they take a gamble that the amount that you, the policy holder, pay them in premiums will, over the course of your contract, be greater than the amount that you claim back for accidents, burglaries or whatever you’re insuring against.

Secondly, while they actually hold the money accumulated through your premiums, they invest it in massive funds which are amongst the largest shareholders operating on the world’s stock markets. This is where the sustainable investment issue becomes relevant to insurance companies, because the clout they wield by virtue of their sheer size means that they can seriously affect company behaviour, if - and this is key - they choose to.

According to Dr Rory Sullivan, head of investor responsibility at Insight Investment, engagement developed as a middle ground between selling all the shares in bad companies and turning a blind eye on corporate ethics by investors. Proponents of engagement believe that cutting off from a company entirely means that investors lose the ability to influence it, and should therefore only be done as an absolute last resort. Ethical Consumer has always taken the position that without a genuine threat of divestment, engagement is likely to be of very limited use because companies often need to be forced into making real changes for the better.

According to Rory Sullivan, fund managers

are often active in engaging on subjects where their own interests are at stake, such as company transparency, good practice on selection of directors and the amount of money paid to board members. “If it’s a corporate governance issue investors are all over it,” he says, “because it’s in the interests of shareholders to resolve it. The results haven’t been perfect but after 15-20 years of activity from investors most British businesses are in fairly good shape on this front.”

On the other hand, says Rory Sullivan, there is still “little awareness” of issues like pollution and human rights amongst general investors or the companies they hold shares in. “These become an issue for investors when consumer demand or impending regulation impacts on markets and companies because the message that this is important hasn’t got through,” he says. “But investors can sometimes work as catalysts, providing a stimulus for change and getting companies to do things like develop and implement human rights policies or environmental reporting.”

However, Sullivan still sees difficulties for investor engagement in some of the most pressing ethical issues.

“The classic case of market failure is climate change,” he says. “Until very recently, and to an extent still, the market has made making real reductions in climate change emissions uninteresting for companies in the absence of either market or consumer pressure. The costs of corporate behaviour in terms of climate change emissions have just been picked up by the state.

“Or in the case of biodiversity, companies have been effectively encouraged to squander public goods such as fish stocks and forests because there is no cost or incentive telling them not to.”

This means that investors wanting to change company behaviour have little leverage with boards intent on increasing profit, because they cannot point out probable business costs of inaction, such as increased government regulation or loss of profits.

However, Sullivan is also critical of the way

in which some campaign groups have tried to use shareholder action to force companies to change. “It’s unusual to see environmental or social shareholder resolutions in the UK,” he says. “This is often because those that have been put forward have been poorly thought through by unsophisticated campaigners. For instance, the Shell resolution in 2006 basically asked the company to do things it was already doing and did not focus on the very real problems in Sakhalin and the West of Ireland. If campaigner resolutions were better designed there might be more scope for them to be supported by institutional investors and for the groups to work together, as happens more in the USA.”

In terms of the companies in this report, Rory Sullivan singles out CIS and his own organisation, Insight, which handles investment for HBOS, as publishing wide-ranging information not only on how they vote, but on how they engage directly with companies and the results of this activity. But, he notes “most fund managers are not that transparent.”

According to Alex Van Der Velden, Executive Director of Fairpensions, a group campaigning on ethics in the pensions and insurance industries, “if the fund managers aren’t telling you what kind of action they’re taking in terms of ethical engagement, it’s probably because they’re not doing any. The ones that are active tend to make it public because it’s a selling point.”

Comparing the ethical engagement records

of different companies is not always easy; Fairpensions (www.fairpensions.org.uk) and CRG Advisory (www.crgadvisory.com) are both in the process of benchmarking UK fund managers, but no information was available as we went to press. The voting and engagement records of the companies covered in this report are given opposite.

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Company Voting records disclosed Engagement policy

Admiral Group

Company response says it does not hold shares, although its annual report does list investment income and anticipates that this will increase in volume.

Company response says that it has no environmental or social policies regarding financial activities.

Allianz Has public voting policies; only one sector of group publishes records.9

Says that divestments on ethical grounds occur ‘frequently’ but are not made public, ditto engagement contact with invested companies.9

American International Group (AIG)

Not published.

The only divestment specified was a historical one, from apartheid South Africa. A response from the company on engagement stated only that it exercised due diligence as regards potential investment targets, assumed by Ethical Consumer to refer to corporate governance rather than environmental or social issues.14

Aviva (Morley Fund Management)

Voting records not published on website. Policies are published, mainly on corporate governance but with some environmental and social issues. No response to request for information.

Voting policy includes mention of engagement but no details or mention of divestment.

AXA

No information was sent when the company was contacted; a link on www.axa.com offering “AXA IM’s voting policy and practices in 2006” did not function in August 2007.

Engages on a range of subjects to do with corporate governance and shareholder interests; one set of asset managers also claims to engage on ‘social’ issues. General meeting statistics on the company website but not individual voting results.

Co-operative Iinsurance

Yes. Searchable online database, plus reports on campaigns targeting specific companies over climate change or human rights in Burma. The first UK fund manager to back a resolution on labour rights, at First Group.

Wide-ranging ethical engagement policy, launched with much fanfare in 2005 after a year’s consultation with stakeholders. Some engagement applied to all funds, more to ‘ethical’ funds. Has argued in the case of BAe Systems that divestment would mean no-one was exerting ethical pressure on the company, but did threaten to divest from French Connection after it refused repeated requests for changes.12

Ecclesiastical Insurance/Allchurches Trust

Publishes a list of companies in which it has shares, but not of voting records, which are disclosed only to the board.

Says it engages on a wide range of ethical topics, recently, including child slavery in the cocoa industry and the availability of medicines. Says divestment is a ‘last resort’ but that, without giving names, it has divested from companies and used to have a policy of not investing in companies owned by notorious late proprietor of Mirror Group, Robert Maxwell.10

Fortis Insurance

Fortis replied to Ethical Consumer’s questions by saying that its shareholdings are held by various different parts of the group, and there is no one policy on ethical criteria or on how engagement is handled. One subsidiary company does publish its voting records, but this is not currently the company norm. Fortis also stated that it had divested from a company in Singapore ‘some years ago’ but did not specify which company, or why.3

HBOSFull voting records published on the website of its asset management subsidiary, Insight Investment.

Detailed information on engagement activities published by Insight Investment, including benchmarking and sector-wide engagements. Does use divestment but does not disclose names or reasons when this occurs.

Legal & GeneralPolicies but not voting records published on website. No response to EC request for information.

Policies and investment management website lists topics for engagement, which have previously been focused on corporate governance; now claimed that climate change, waste etc will also be engaged on. No details or mention of divestment.

Royal & Sun Alliance

Yes, via investment management outsourced to F&C Asset Management. List of votes published on an ongoing basis, plus regular newsletters discussing the major issues being tackled.

Also via F&C Asset Management, publicised in newsletter which names companies not making changes. Subjects range from climate change to sweatshops to palm oil. According to Royal & Sun, F&C has divested from one company in the last year over armaments issues.11

ZurichVoting policy (mainly focused on corporate governance and shareholder interests), no voting record published.

Partly outsourced to asset managers, no central policy, would not comment on voting or engagement/divestment decisions.13

Companies which did not reply to requests for information on this report, and which did not have relevant information on their company websites in September 2007: Equity Insurance, Liverpool Victoria, Lloyds TSB Group, NFU Mutual, Prudential, Royal Bank of Scotland, Saga Insurance (see also Aviva for Saga home insurance).

To give weight to their engagement strategies, Ethical Consumer encourages all insurance companies to publicly divest at least one company shareholding annually on ethical grounds.

References 1 www.hemscott.com, August 2007 2 www.opensecrets.org, June 2007 3 email from Fortis Group, 22/08/2007 4 http://en.handicapinternational.be/index.php?action=article&numero=483, 4/9/2007 5 Banktrack, “preparations for a new Fallujah?”, March 2006 6 International Alert, “Conflict and Project Finance: exploring options for better management of conflict risk,” January 2006 7 Friends of the Earth International, Link magazine, January 2006 9 email from Allianz Communications Department, 31/8/2007 10 email from Ecclesiastical PR department, 23/8/2007 11 email from Royal & Sun Alliance Corporate Responsibility department, 8/8/2007 12 Guardian newspaper, 31/10/2006 13 email from Zurich media relations department, 29/8/2007 14 email from AIG media relations department, 27/8/2007

buyer’s guide

2

home and car insuranceAdmiral GroupCapital Tower, Greyfriars Road, Cardiff, CF10 3AZ, Wales

EnvironmentEnvironmental ReportingWorst ECRA rating for environmental reporting (2007)A search was made by ECRA in summer 2007 for the Admiral Group company environmental policy or report. The company’s annual report for 2006, downloaded from www.admiral.co.uk, was found to a contain a Corporate Social Responsibility section which discussed various environmental issues such as electricity use and recycling. However, it did not include any fixed or measurable future targets, did not touch on the environmental impacts of the company’s wider activities, eg the potential for promoting environmentally sustainable transport through its insurance products, and had not been independently monitored or verified. (ref: 1)Added to ethical index (2007)According to a press release from the FTSE organisation, dated 9th March 2007, Admiral Group was one of a number of companies added to the FTSE4Good sustainable investments index in March 2007. (ref: 2)

PoliticsAnti-Social FinanceInsurance subsidiary in tax haven (2006)According to the company annual report for 2006, Admiral had an insurance underwriting subsidiary in Gibraltar, a territory regarded by ECRA as a tax haven. (ref: 1)

Allchurches Trust LtdBeaufort House, Brunswick Road, Gloucester, GL1 1JZ, UK

EnvironmentEnvironmental ReportingWorst ECRA rating for environmental reporting (2007)A search was made by ECRA in 2007 on the company website www.ecclesiastical.com for a copy of the Ecclesiastical/Allchurches environmental policy or report. The website was found to contain a community page with an environment section which mentioned recycling and internal targets, but these were not set out in any detail or in a way which could be measured by general readers. There was no mention of any environmental or social decision making in the company’s wider investment and financial affairs, or of any independent monitoring or verification of environmental performance. (ref: 3)

Climate ChangeShareholdings in companies criticised by ECRA (2006)According to the 2006 annual report for the Allchurches Investment Funds, published in 2007, at 31st December 2006 the various funds had holdings in a range of companies which had been criticised by ECRA under various ethical categories. These included:- Rolls Royce (human rights, workers’ rights, armaments);- British American Tobacco (irresponsible marketing, human rights, political activities, workers’ rights, anti-social finance, pollution & toxics);

- Royal Dutch Shell (animal testing, boycott call, armaments, human rights, political activities, workers’ rights, anti-social finance, climate change, pollution & toxics, habitats & resources);- BP (climate change, pollution & toxics, habitats & resources, animal testing, human rights, workers’ rights, irresponsible marketing, boycott call, political activities;- Sinopec (human rights, climate change);- Tesco (animal testing, boycott call, factory farming, genetic engineering, other animal rights, human rights, political activities, workers’ rights, anti-social finance, climate change, pollution & toxics, habitats & resources);- GlaxoSmithkline (animal testing, boycott call, genetic engineering, irresponsible marketing, human rights, political activities, anti-social finance, pollution & toxics). (ref: 4)

Pollution & Toxics(See also ‘Shareholdings in companies criticised by ECRA’ in Climate Change above.)Habitats & Resources(See also ‘Shareholdings in companies criticised by ECRA’ in Climate Change above.)

AnimalsAnimal Testing(See also ‘Shareholdings in companies criticised by ECRA’ in Climate Change above.)Factory farming(See also ‘Shareholdings in companies criticised by ECRA’ in Climate Change above.)Other Animal Rights(See also ‘Shareholdings in companies criticised by ECRA’ in Climate Change above.)

PeopleHuman Rights(See also ‘Shareholdings in companies criticised by ECRA’ in Climate Change above.)Workers’ Rights(See also ‘Shareholdings in companies criticised by ECRA’ in Climate Change above.)Irresponsible Marketing(See also ‘Shareholdings in companies criticised by ECRA’ in Climate Change above.)Armaments(See also ‘Shareholdings in companies criticised by ECRA’ in Climate Change above.)

PoliticsGenetic Engineering(See also ‘Shareholdings in companies criticised by ECRA’ in Climate Change above.)Boycott Call(See also ‘Shareholdings in companies criticised by ECRA’ in Climate Change above.)Political Activities(See also ‘Shareholdings in companies criticised by ECRA’ in Climate Change above.)Anti-Social FinanceOperation in one tax haven (2006)According to the company’s annual report for 2006, Ecclesiastical Insurance had one insurance subsidiary in Ireland, a country regarded by ECRA as a tax haven. It had ceased its other operations in tax havens, namely agent relationships in Cyprus and Malta. (ref: 5)

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(See also ‘Shareholdings in companies criticised by ECRA’ in Climate Change above.)Company EthosNot-for-profit structure (2007)According to the company website www.ecclesiatical.com, viewed by ECRA in summer 2007, Ecclesiastical was owned by Allchurches and all of Ecclesiastical’s profits were handed on to Allchurches, which was a charitable trust (registered charity number 1043742) which gave money to church upkeep and charitable organisations. (ref: 3)

Allianz SEKoniginstrasse 28, Munich, D-80802, Germany

EnvironmentEnvironmental ReportingMiddle ECRA rating for environmental reporting (2007)A search by ECRA on the Allianz corporate website in June 2007 revealed the company’s 2006 Status Report on Sustainability in the Allianz Group and Operational Environmental Protection report for 2005/6. These were found to show a good understanding of the company’s environmental impacts and to include a range of targets for 2007. However, neither document appeared to have been independently monitored or verified. (ref: 6)

Nuclear PowerServices to controversial megaprojects (2006)According to the website of the Hermes credit agency, www.agaportal.de, viewed by ECRA in June 2006, the Hermes agency was owned and funded by the German state as an export credit guarantee agency, but the running of the organisation was done by Allianz and PricewaterhouseCoopers. Hermes was said to have been involved in funding a number of highly controversial projects with major impacts on the environment and human rights, including the Maheshwar and Ilisu dams and large nuclear projects. It was also said to have underwritten arms sales to Turkey and Indonesia. (ref: 7)

Climate ChangeShareholdings in Dana Petroleum (2007)According to the Dana Petroleum factsheet on investment information website Hemscott.com, viewed by ECRA in August 2007, Allianz had shareholdings in Dana Petroleum, an oil and gas exploration company. Fossil fuels was considered by ECRA to be a sector which made a particular contribution to climate change emissions. (ref: 8)Shareholdings in PetroLatina Energy plc (2007)According to the PetroLatina Energy plc factsheet on investment information website Hemscott.com, viewed by ECRA in August 2007, Allianz SE had shareholdings in PetroLatina Energy, an oil and gas development company. Fossil fuels were regarded by ECRA as a sector which made particular contributions to climate change emissions. (ref: 9)Insurance services to environmentally damaging sector (2006)According to the company website www.allianz.com, viewed by ECRA in June 2006, Allianz offered specialist insurance services to the aviation industry, including international and domestic flights. Aviation was considered by ECRA to be a sector with a high impact on climate change. (ref: 10)

Pollution & ToxicsInsurance services to BASF (2006)According to the Allianz AG company website www.allianz.com, viewed by ECRA in June 2006, Allianz had provided major project insurance for BASF’s construction of a major petrochemicals manufacturing facility in China, producing ethylene, propylene,

aromatics and derivatives. BASF was found to have major negative marks on ECRA’s database in the following categories: pollution & toxics, human rights, irresponsible marketing, genetic engineering and political activities. (ref: 10)

Habitats & ResourcesInvestments in criticised companies (2006)According to the Hoovers.com business information website, viewed by ECRA in June 2006, Allianz had shareholdings in a number of major German companies, including Lufthansa. Aviation was considered by ECRA to be a sector with a high climate impact. It was also said to have a stake in Deutsche Bank, a company with major negative records on the ECRA database in the following categories: Human Rights, Political Activities, Anti-Social Finance and Habitats & Resources. (ref: 11)Poor rating in banking policy report (2006)According to a Banktrack/WWF report on social and environmental policies amongst international banks, Dresdner Bank had a poor accumulated score for its policies, at just 0.54 out of a possible 5, amounting to a D- grade. The bank was said to have policies on just five out of thirteen categories, in this case labour, indigenous peoples, dams, transparency and environmental & social management. Issues such as human rights, agriculture, forests and fisheries were not covered. Like most other banks, Dresdner was also said to have few systems in place for ensuring that the policies that were in place were implemented. (ref: 12)(See also ‘Services to controversial megaprojects’ in Nuclear Power above.)

PeopleHuman RightsSubsidiaries in oppressive regimes and tax havens (2007)According to the company website www.allianz.com, viewed by ECRA in June 2007, Allianz had subsidiaries in the following countries regarded by ECRA as having oppressive regimes: Pakistan, UAE, USA, Cameroon, Cote d’Ivoire, Togo, Thailand, Russia, Lebanon, Laos, Indonesia, Egypt and China, and in the following territories regarded as tax havens: Singapore, Luxembourg, Hong Kong, Guernsey, Bermuda. (ref: 13)(See also ‘Poor rating in banking policy report’ in Habitats & Resources above.)(See also ‘Insurance services to BASF’ in Pollution & Toxics above.)Workers’ RightsBanking relationship with Gallaher Group Plc (January 2005)Hemscott www.hemscott.com was viewed by ECRA on 26 January 2004, the website listed Dresdner Kleinwort Wasserstein as the banker to Gallaher Group Plc. When Gallaher Group was rated by ECRA’s Corporate Critic database in January 2005, it received ECRA’s bottom rating in the irresponsible marketing category and it received ECRA’s middle rating in the environmental reporting, oppressive regimes, workers rights and code of conduct categories. It received a clear rating all other categories. (ref: 14)Sexual harassment and discrimination claim (16 January 2006)According to an article from the MSNBC.com news website, dated 19th May 2007, in 2007 Dresdner Kleinwort had settled a lawsuit brought by six female employees by paying out an unspecified sum of money in a no-fault settlement. The women had claimed that the bank had subjected them to a “pervasive pattern and practice” of sexual discrimination, including treating them as second-class citizens and paying men more and promoting them more often. (ref: 15)

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Irresponsible Marketing(See also ‘Insurance services to BASF’ in Pollution & Toxics above.)(See also ‘Banking relationship with Gallaher Group Plc’ in Workers’ Rights above.)Armaments(See also ‘Services to controversial megaprojects’ in Nuclear Power above.)

PoliticsGenetic Engineering(See also ‘Insurance services to BASF’ in Pollution & Toxics above.)Political ActivitiesLobbying in the EU and beyond (July 2007)According to the June/July 2007 Corporate Watch newsletter, Allianz was one of 20 companies that the organisation had criticised for having “enormous influence over the daily life of Europeans” and beyond. The report details how companies used their power to try to influence decision-making in Europe and the rest of the world. (ref: 16)(See also ‘Investments in criticised companies’ in Habitats & Resources above.)(See also ‘Insurance services to BASF’ in Pollution & Toxics above.)Anti-Social FinanceCriticised for role in Majority World privatisations (2004)According to a September 2004 report by War on Want and the Public & Commercial Services Union, Dresdner Kleinwort Wasserstein was one of a number of large international companies which had been the recipients of large sums of ‘aid’ money in their capacity as consultants on Majority World privatisations. As well as the channelling of millions of pounds of ‘aid’ money to such corporations, War on Want also criticised the doctrine of privatisation being pushed at Majority World countries, which often resulted in price increases for basic utilities and people being forced into poverty to pay for educational or healthcare bills. (ref: 17)(See also ‘Subsidiaries in oppressive regimes and tax havens’ in Human Rights above.)Excessive directors’ pay (2006)According to the company’s Annual Report for 2006, in 2006 a number of directors of AXA were paid a total of over 2 million Euros each, a sum deemed by ECRA to be excessive. (ref: 18)

American International Group (AIG) Inc70 Pine Street, New York, NY10271, USA

EnvironmentEnvironmental ReportingWorst ECRA rating for environmental reporting 2007 (2007)A search was made by ECRA in August 2007 on the company website www.aig.com for a copy of the American International Group environmental policy or report. The company’s 2007 Corporate Responsibility Report was found to contain some information on the company’s environmental impacts, including a commitment to addressing the causes of climate change and a large amount of information describing initiatives and measures in general terms, but contained no fixed and measurable commitments or targets, and there was no indication that its environmental performance was independently verified or monitored. (ref: 19)

Low score in sustainability index (2007)According to the June 2007 issue of Ethical Performance, AIG was one of the US insurers deemed unsuitable for recommendation by a new corporate sustainability ranking of the world’s 43 largest insurance companies. It said most of the top places in the oekom ranking had been occupied by European and Japanese insurance companies and that American businesses had been conspicuously absence from the upper reaches. The recommended list accounted for almost a quater of those assessed. (ref: 20)

Nuclear PowerShareholdings in Halliburton (2007)In August 2007 ECRA viewed American International Group’s SEC Filing Form 13F, filed 10th August 2007 and listing all significant holdings by the various AIG fund managers. According to this form, AIG had shares in Halliburton, a company criticised by ECRA in the following categories: nuclear power, climate change, habitats & resources, workers’ rights, irresponsible marketing, armaments and political activities. (ref: 21)Shareholdings in General Electric Co (2007)In August 2007 ECRA viewed American International Group’s SEC Filing Form 13F, filed 10th August 2007 and listing all significant holdings by the various AIG fund managers. According to this form, AIG had shares in General Electric Co, a company criticised by ECRA in the following categories: armaments, animal testing, irresponsible marketing, nuclear power, human rights, political activities, workers’ rights, anti-social finance, climate change and pollution & toxics. (ref: 21)

Climate Change(See also ‘Shareholdings in Halliburton’ in Nuclear Power above.)High climate impact sector (2007)According to the AIG Annual Report for 2006, International Lease Finance Corporation was ‘one of the world’s leading aircraft lessors’ and the world’s largest lessor of wide-body aircraft, providing 177 aircraft for 75 airlines during 2006. Aviation was considered by ECRA to be a sector which made particularly large contributions to climate change. (ref: 22)(See also ‘Shareholdings in General Electric Co’ in Nuclear Power above.)Pollution & ToxicsShareholdings in Gap (2007)In August 2007 ECRA viewed American International Group’s SEC Filing Form 13F, filed 10th August 2007 and listing all significant holdings by the various AIG fund managers. According to this form, AIG had shares in Gap, a company criticised by ECRA in the following categories: other animal rights, human rights, workers’ rights and pollution & toxics. (ref: 21)Shareholdings in Boeing (2007)In August 2007 ECRA viewed American International Group’s SEC Filing Form 13F, filed 10th August 2007 and listing all significant holdings by the various AIG fund managers. According to this form, AIG had shares in Boeing, a company criticised by ECRA in the following categories: armaments, human rights, political activities, anti-social finance, climate change and pollution & toxics. (ref: 21)(See also ‘Shareholdings in General Electric Co’ in Nuclear Power above.)Habitats & ResourcesShareholdings in Monsanto (2007)In August 2007 ECRA viewed American International Group’s SEC Filing Form 13F, filed 10th August 2007 and listing all significant holdings by the various AIG fund managers. According to this form, AIG had shares in Monsanto, a company criticised by ECRA in the following categories: factory farming, genetic engineering, irresponsible marketing, human rights, political

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activities, workers’ rights, anti-social finance, habitats & resources and pollution & toxics. (ref: 21)Shareholdings in Procter & Gamble (2007)In August 2007 ECRA viewed American International Group’s SEC Filing Form 13F, filed 10th August 2007 and listing all significant holdings by the various AIG fund managers. According to this form, AIG had shares in Procter & Gamble, a company criticised by ECRA in the following categories: pollution & toxics, habitats & resources, factory farming, other animal rights, human rights, workers’ rights, irresponsible marketing, political activities. (ref: 21)(See also ‘Shareholdings in Halliburton’ in Nuclear Power above.)

AnimalsAnimal Testing(See also ‘Shareholdings in General Electric Co’ in Nuclear Power above.)Shareholdings in Bristol-Myers Squibb (2007)In August 2007 ECRA viewed American International Group’s SEC Filing Form 13F, filed 10th August 2007 and listing all significant holdings by the various AIG fund managers. According to this form, AIG had shares in Bristol-Myers Squibb, a company criticised by ECRA in the following categories: animal testing, genetic engineering, irresponsible marketing, political activities and anti-social finance. (ref: 21)Shareholdings in 3M (2007)In August 2007 ECRA viewed American International Group’s SEC Filing Form 13F, filed 10th August 2007 and listing all significant holdings by the various AIG fund managers. According to this form, AIG had shares in 3M Corp, a company criticised by ECRA in the following categories: pollution & toxics, animal testing, human rights, workers’ rights, irresponsible marketing and political activities. (ref: 21)

Factory farming(See also ‘Shareholdings in Procter & Gamble’ in Habitats & Resources above.)(See also ‘Shareholdings in Monsanto’ in Habitats & Resources above.)Other Animal RightsShareholdings in Liz Claiborne (2007)In August 2007 ECRA viewed American International Group’s SEC Filing Form 13F, filed 10th August 2007 and listing all significant holdings by the various AIG fund managers. According to this form, AIG had shares in Liz Claiborne, a company criticised by ECRA in the following categories: other animal rights, workers’ rights. (ref: 21)(See also ‘Shareholdings in Procter & Gamble’ in Habitats & Resources above.)(See also ‘Shareholdings in Gap’ in Pollution & Toxics above.)

PeopleHuman RightsOperations in oppressive regimes and tax havens (2007)According to the Global Business Network section of the American International Group corporate website aig.com, viewed by ECRA in August 2007, AIG had operations in the following countries regarded by ECRA as having oppressive regimes: Zimbabwe, Kazakhstan, Russia, Uzbekistan, China, Guatemala, Egypt, Kuwait, Lebanon, Saudi Arabia, the United Arab Emirates, Pakistan, Indonesia, the Philippines, Thailand and Vietnam.It also listed operations in territories regarded by ECRA as tax havens, including the Isle of Man, Liechtenstein, Luxembourg, Aruba, the Netherlands Antilles, Uruguay, Panama, Guatemala,

Bahrain, Cyprus, Malta, Bermuda, Brunei, Hong Jong, Macau, Marshall Islands and Singapore. (ref: 23)Operations in one oppressive regime (2007)According to the AIG 2006 Annual Report, AIG Consumer Finance Group had applied for a licence to run consumer finance operations in Russia, a country regarded by ECRA in 2006 as having an oppressive regime. (ref: 22)(See also ‘Shareholdings in General Electric Co’ in Nuclear Power above.)Workers’ Rights(See also ‘Shareholdings in Liz Claiborne’ in Other Animal Rights above.)(See also ‘Shareholdings in Halliburton’ in Nuclear Power above.)(See also ‘Shareholdings in General Electric Co’ in Nuclear Power above.)Irresponsible Marketing(See also ‘Shareholdings in Halliburton’ in Nuclear Power above.)(See also ‘Shareholdings in Monsanto’ in Habitats & Resources above.)(See also ‘Shareholdings in Procter & Gamble’ in Habitats & Resources above.)ArmamentsShareholdings in Lockheed Martin (2007)In August 2007 ECRA viewed American International Group’s SEC Filing Form 13F, filed 10th August 2007 and listing all significant holdings by the various AIG fund managers. According to this form, AIG had shares in Lockheed Martin, a company criticised by ECRA in the following categories: armaments, human rights, political activities, anti-social finance. (ref: 21)Shareholdings in Motorola (2007)In August 2007 ECRA viewed American International Group’s SEC Filing Form 13F, filed 10th August 2007 and listing all significant holdings by the various AIG fund managers. According to this form, AIG had shares in Motorola, a company criticised by ECRA in the following categories: armaments, political activities, workers’ rights. (ref: 21)(See also ‘Shareholdings in Halliburton’ in Nuclear Power above.)

PoliticsGenetic Engineering(See also ‘Shareholdings in Monsanto’ in Habitats & Resources above.)(See also ‘Shareholdings in Bristol-Myers Squibb’ in Animal Testing above.)Political ActivitiesUS political donations (2006)According to the Insurance Industry Top Donors table on the Open Secrets website, www.opensecrets.org, covering the 2006 US election cycle, American International Group had donated a total of $463,769, of which 48% went to the Republican Party and 49% to the Democrats. (ref: 24)Bush donations (January 2003)According to the August 2004 report “Executive Excess,” the CEO of American International Group had raised over $100,000 for the re-election campaign of George W. Bush in 2004. (ref: 25)Member of USCIB lobby group (July 2007)The website of the US Council for International Business (www.uscib.org) in July 2007 listed American International Group Inc as a member. The USCIB described itself as “founded in 1945 to promote an open world trading system, now among the premier pro-trade, pro-market liberalization organizations ...provides unparalleled access to international policy makers and regulatory

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authorities.” ECRA noted that free trade lobby groups had been criticised by campaigners for lobbying for business interests at the expense of the environment, human rights and animal welfare. (ref: 26)

Anti-Social FinanceSettlement for financial malpractice (2006)According to the BBC News website (httP://news.bbc.co.uk) on 10th February 2006, American International Group (AIG) had agreed to pay more than $1.6bn (£920m) to settle charges of accounting abuses. Investigators claimed AIG had attempted to deceive regulators and investors. (ref: 27)Indictment for Azeri bribes (2005)According to the September 2005 issue of Multinational Monitor, in 2005 a Grand Jury Indictment was issued against a managing director of American International Group and two colleagues, who were found to have paid millions of dollars in bribes to senior government officials in Azerbaijan, in an effort to profit from the privatisation of the Azeri oil industry. The AIG consortium was said to have promised officials that they would be paid two-thirds of any profits it made. (ref: 28)Financial malpractice prosecution (October 2004)According to the Corporate Focus online newsletter of 24th January 2005, the world’s biggest insurer, American International Group, was on the Multinational Monitor list of the 10 worst corporations of 2004. It said AIG had been charged in October 2004 with aiding and abbetting a financial services company in a fraudulent transaction to transfer $750 million of troubled loans and investments off its books. It said the company had had to pay $126 million to resolve the charges but had got off lightly by entering into a “deferred prosecution agreement”. (ref: 29)

Aviva PlcSt Helen’s, 1 Undershaft, London, EC3P 3DQ

EnvironmentEnvironmental ReportingWorst ECRA rating for environmental report (2007)A search was made by ECRA in August 2007 on the company website www.aviva.com/csr for the Aviva environmental report. The company’s CSR report for 2007, in both PDF and online versions, was found to contain a range of information on the company’s efforts to reduce its environmental impact through renewable energy use, recycling and use of recycled products etc, through encouragement of more energy-efficient driving amongst car insurance customers, and a small amount of information on its SRI commitments. However, there were no fixed or measurable commitments to future progress in most areas of the report, and a substantial commitment to attain carbon neutral status did not include measurable targets on how further energy efficiency improvements might be made (eg by cutting corporate flights) and only included fixed numbers in reference to offsetting, a controversial means of addressing climate change emissions. There was also no mention of systematic monitoring or verification of Aviva’s environmental performance. (ref: 30)

Nuclear PowerShareholdings in Johnson Matthey (2007)According to the Johnson Matthey factsheet on investment information website Hemscott.com, viewed by ECRA in August 2007, Aviva had shareholdings in Johnson Matthey, a company criticised under the ECRA categories: Irresponsible Marketing, Nuclear Power, Workers’ Rights, Pollution & Toxics and Animal Testing. (ref: 31)

Climate ChangeShareholdings in Premier Oil (2007)According to the Premier Oil factsheet on investment information website Hemscott.com, viewed by ECRA in August 2007, Aviva had shareholdings in Premier Oil, a company criticised by ECRA under the categories: climate change, human rights, workers’ rights. (ref: 32)Shareholdings in AMEC (2007)According to the AMEC company factsheet on the Yahoo! Finance website http://uk.finance.yahoo.com, viewed by ECRA in August 2007, Aviva had shareholdings in AMEC, a company criticised by ECRA in the following categories: Workers’ Rights, Climate Change, Habitats & Resources. (ref: 33)Insurance provision for high climate impact sectors (2006)According to the company’s 2006 Annual Report, Aviva provided insurance cover for the Aviation industry via a part-owned subsidiary associate. Aviation was considered by ECRA to be a sector which made major contributions to climate change. (ref: 34)

Pollution & Toxics(See also ‘Shareholdings in Johnson Matthey’ in Nuclear Power above.)Investment relationship with Greggs Plc (2004)Greggs Plc Annual Report & Accounts 2003 stated that Aviva Plc owned 3.90% of Greggs Plc. When Greggs was last reviewed in Ethical Consumer Issue 92 January/February 2005, Greggs received worst ECRA ratings for criticisms in environment reporting, factory farming and code of conduct for workers rights categories and a middle ECRA rating for criticisms relating to pollution. Greggs Plc received a clear ECRA rating in all other categories. (ref: 35)

Habitats & Resources(See also ‘Shareholdings in AMEC’ in Climate Change above.)(See also ‘Shareholdings in Johnson Matthey’ in Nuclear Power above.)Support for roads expansion (2005)According to the June 2005 issue of Corporate Watch, the RAC was one of a number of businesses criticised for helping to promote the building of a large new motorway extension in Glasgow, as an expansion of the M74 road. One MSP was said to have described the plans a “five-mile, six-lane monster defacing Glasgow” and local campaigners were said to have expressed concern over the effects on communities and health in the area. (ref: 36)

AnimalsAnimal Testing(See also ‘Shareholdings in Johnson Matthey’ in Nuclear Power above.)Factory farming(See also ‘Investment relationship with Greggs Plc’ in Pollution & Toxics above.)

PeopleHuman RightsProtests at immigration centre plans (April 2007)An article dated 21st April 2007 on the Indymedia.org UK website reported that protesters had held a protest in Surrey at plans for a new immigration detention centre to be built near Gatwick Airport. The landowners, Airport Property Partnership, were said to be in the process of applying for planning permission for the site, which was intended to replace a number of other centres used to detain asylum seekers being deported or investigated by the British State. The protesters claimed that asylum seekers were returned to situations where they were in serious danger of human rights abuses, and that human rights violations also occurred in many British immigration detention centres. (ref: 37)

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(See also ‘Shareholdings in Premier Oil’ in Climate Change above.)Operations in oppressive regimes (2006)According to the company’s Annual Report for 2006, Aviva’s international operations included activities in China, the USA and Russia, countries regarded by ECRA as having oppressive regimes. (ref: 34)

Workers’ Rights(See also ‘Shareholdings in Premier Oil’ in Climate Change above.)(See also ‘Shareholdings in AMEC’ in Climate Change above.)(See also ‘Shareholdings in Johnson Matthey’ in Nuclear Power above.)Irresponsible Marketing(See also ‘Shareholdings in Johnson Matthey’ in Nuclear Power above.)ArmamentsShareholdings in GKN (2007)According to the company factsheet on investment information website Hemscott.com, viewed by ECRA in August 2007, Aviva plc had shareholdings in GKN, a company criticised by ECRA for its role in the manufacture and supply of armaments. (ref: 38)Shareholdings in Cobham (2007)According to the company factsheet on investment information website Hemscott.com, viewed by ECRA in August 2007, Aviva had shareholdings in Cobham, a company criticised by ECRA for its role in the manufacture and supply of armaments. (ref: 39)

PoliticsAnti-Social FinanceSubsidiaries in tax havens (2006)According to the company’s annual report for 2006, Aviva had subsidiaries and/or financial operations in the following territories regarded by ECRA as being tax havens: Bermuda, Ireland, Luxembourg, Hong Kong, Singapore. (ref: 34)Director’s pay 2005-6 (2006)According to the August 2006 issue of Labour Research, a director of Aviva was paid a total of £2.311 million in pay and benefits for the financial year 2005/6. (ref: 40)

AXA25 avenue Matignon, Paris, 75008, France

EnvironmentEnvironmental ReportingWorst ECRA rating for environmental reporting (2007)A search was made by ECRA in summer 2007 on the company website axa.com for a copy of the AXA environmental policy or report. The company’s 2006 report for ‘Developpement Durable’ was found to contain information on the company’s environmental activities and independent ratings and assessment of its environmental reporting by Vigeo. However, it did not include any clear or meaningful future targets for how the company planned to progress its environmental responsibility. An environmental section in the corporate responsibility subsite of ww.axa.com also gave an overview of the company’s programmes but did not include fixed and measurable targets or commitments. (ref: 41)

Nuclear PowerInvestment relationship with Citigroup (April 2004)The Transnationale website www.transnationale.org was viewed by ECRA Publishing on 2 April 2004. The website stated that AXA owned 3% of Citigroup. When Citigroup was rated on ECRA’s Corporate Critic database on 3 March 2005 it received ECRA’s worst rating in the environmental reporting, pollution, nuclear power, animal testing, oppressive regimes, workers rights, irresponsible marketing, armaments, genetic engineering, boycott call and political activity categories. In all other categories Citigroup received ECRA’s best rating. (ref: 42)Shareholdings in Johnson Matthey (2007)According to the Johnson Matthey factsheet on investment information website Hemscott.com, viewed by ECRA in August 2007, Aviva had shareholdings in Johnson Matthey, a company criticised under the ECRA categories: Irresponsible Marketing, Nuclear Power, Workers’ Rights, Pollution & Toxics and Animal Testing. (ref: 31)

Climate ChangeShareholding in Ascent Resources (2007)According to the Ascent Resources factsheet on investment information website Hemscott.com, viewed by ECRA in August 2007, AXA SA had shareholdings in Ascent Resources plc, a fossil fuels exploration company. The oil and gas sector was one regarded as making substantial contributions to climate change emissions. (ref: 43)Shareholdings in AMEC (2007)According to the AMEC company factsheet on the Yahoo! Finance website http://uk.finance.yahoo.com, viewed by ECRA in August 2007, Aviva had shareholdings in AMEC, a company criticised by ECRA in the following categories: Workers’ Rights, Climate Change, Habitats & Resources. (ref: 33)Shareholdings in Premier Oil (2007)According to the Premier Oil factsheet on investment information website Hemscott.com, viewed by ECRA in August 2007, Aviva had shareholdings in Premier Oil, a company criticised by ECRA under the categories: climate change, human rights, workers’ rights. (ref: 32)

Pollution & ToxicsInvestment in controversial weapons (March 2006)According to a press release from Banktrack, dated 16th March 2006, AXA was one of two major European financial companies to have investments in Teledyne Technologies and the Shaw Group. Both of these were described as being companies involved in the modernisation of white phosphorus weapons for the US Army for use in Iraq. White phosphorus weapons were said to have been used on civilians in Fallujah and to have caused widespread death and suffering, as they were designed to burn flesh and to be difficult to put out. White phosphorus was also said to be highly toxic to human beings and to cause death in intensive inhalation situations, including military exposure. (ref: 44)(See also ‘Investment relationship with Citigroup’ in Nuclear Power above.)(See also ‘Shareholdings in Johnson Matthey’ in Nuclear Power above.)Habitats & Resources(See also ‘Investment relationship with Citigroup’ in Nuclear Power above.)(See also ‘Shareholdings in AMEC’ in Climate Change above.)

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(See also ‘Shareholdings in Johnson Matthey’ in Nuclear Power above.)

AnimalsAnimal Testing(See also ‘Investment relationship with Citigroup’ in Nuclear Power above.)(See also ‘Shareholdings in Johnson Matthey’ in Nuclear Power above.)

PeopleHuman RightsHoldings in company in oppressive regime (2007)According to a news release on the AXA factsheet on business information website Hoovers.com, dated 2nd June 2007, AXA had acquired a significant shareholding in a company described as ‘Kazakhstan’s largest copper mining company.’ Kazakhstan was considered by ECRA in 2007 to have an oppressive regime. (ref: 45)Insurance operations in oppressive regimes (2007)According to the company website axa.com, viewed by ECRA in summer 2007, in 2007 AXA had insurance operations in the following countries regarded by ECRA as having oppressive regimes: Cameroon, Cote d’Ivoire, the USA, China, Indonesia, Thailand, the Philippines, Lebanon, Saudi Arabia and the United Arab Emirates. (ref: 46)Shareholdings in BAe Systems (2007)According to the BAe Systems factsheet on investment information website Hemscott.com, viewed by ECRA in August 2007, AXA had shareholdings in BAe Systems, a company criticised by ECRA for its role in the manufacture and supply of arms and under the following ECRA categories: Anti-Social Finance, Political Activities and Human Rights. (ref: 47)

Workers’ RightsCriticised for unethical investments (2005)According to a press release dated 14th November 2005 from the Belgian NGO Netwerk Vlaanderen, a new report by the group had revealed that several Belgian banks, including AXA, had significant investments in companies which abused human and workers’ rights. These were said to include Total, which was criticised for its close association with the human rights abuses of the Burmese junta, and Wal-Mart, which was widely criticised for the low labour standards of many of its suppliers. (ref: 48)(See also ‘Investment relationship with Citigroup’ in Nuclear Power above.)(See also ‘Shareholdings in AMEC’ in Climate Change above.)Irresponsible Marketing(See also ‘Investment relationship with Citigroup’ in Nuclear Power above.)(See also ‘Shareholdings in Johnson Matthey’ in Nuclear Power above.)ArmamentsShareholdings in GKN (2007)According to the company factsheet on investment information website Hemscott.com, viewed by ECRA in August 2007, AXA SA had shareholdings in GKN, a company criticised by ECRA for its role in the manufacture and supply of armaments. (ref: 38)(See also ‘Shareholdings in BAe Systems’ in Human Rights above.)

(See also ‘Investment in controversial weapons’ in Pollution & Toxics above.)

PoliticsGenetic Engineering(See also ‘Investment relationship with Citigroup’ in Nuclear Power above.)Boycott Call(See also ‘Investment relationship with Citigroup’ in Nuclear Power above.)Political ActivitiesMember of European Services Forum (2007)According to the Members’ Biographies section of the European Services Forum website, www.esf.be, viewed by ECRA in January 2007, AXA was a member of the organisation. The ESF was regarded by ECRA as an international corporate lobby group which exerted the power of commercial interests in a way seen as potentially detrimental to wider society and the environment. (ref: 49)(See also ‘Shareholdings in BAe Systems’ in Human Rights above.)Worst rating for information provision on lobbying (2005)The 2005 SustainAbility/WWF report ‘Influencing Power: Reviewing the conduct and content of corporate lobbying’, ranked how 100 major companies reported on lobbying and its relationship to their core business, from the provision of no information (51 companies) through to ‘basic’ (31 companies), ‘developing’ (10 companies), ‘systematic’ (8 companies) or ‘integrated’ reporting (0 companies). It said that AXA had received the lowest rating due to it making no information available. (ref: 50)

Anti-Social Finance(See also ‘Shareholdings in BAe Systems’ in Human Rights above.)Excessive directors’ pay (2006)According to AXA’s 2006 annual report, in 2006 at least two AXA directors were paid over 2 million Euros each, a sum deemed by ECRA to be excessive. (ref: 51)Subsidiaries in tax havens and oppressive regimes (2006)According to the company’s 2006 Annual Report, AXA had subsidiaries or part-subsidiaries in China (Hong Kong), the Philippines, Thailand, Indonesia and the USA, countries regarded by ECRA in 2007 as having oppressive regimes, and in Singapore, Hong Kong, Luxembourg and Ireland, countries regarded as tax havens. (ref: 51)

Charterhouse Capital Partners LLP7th Floor, Warwick Court, Paternoster Square, London, EC4M 7DX, United Kingdom

EnvironmentEnvironmental ReportingWorst ECRA rating for environmental reporting (2007)A search was made by ECRA in summer 2007 on the company website www.saga.co.uk for a copy of the Saga Group environmental policy or report. No such document, or any mention of one, could be found. No response was received from the group to a request for information from ECRA. (ref: 52)

Nuclear PowerNuclear power activities (2004)According to the World Nuclear Industry Handbook 2004, French company Cegelec provided the following services to the nuclear industry: inspection and classification; inspection, in-service; maintenance; non-destructive testing; operator training. (ref: 53)

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Climate ChangeHigh climate impact sector (2007)According to the company website www.saga.co.uk, viewed by ECRA in summer 2007, Saga offered overseas holidays by air. Aviation was considered by ECRA to be a sector which made a major contribution to climate change emissions. (ref: 52)High climate impact sector and oppressive regime operations (2007)According to the company website www.fiveslille.com, viewed by ECRA in September 2007, Fives Lille was a French engineering company with operations in China, a country regarded by ECRA as having an oppressive regime, and in the automobile parts and cement industries, both of which were regarded by ECRA as making major contributions to climate change emissions. (ref: 54)

AnimalsFactory farmingSale of meat and fish products (2007)According to the menus listed for Saga’s ocean cruise liners, on the company website www.saga.co.uk, food on the liners included meat not specified as being from free range or organic sources, and apparently wild fish and seafood. (ref: 52)

Other Animal Rights(See also ‘Sale of meat and fish products’ in Factory farming above.)Clothes contained rabbit fur (2002)On 16 January 2002 garments containing a trim made from rabbit fur were seen on sale in a UK branch of Kookai. (ref: 55)Sale of slaughterhouse byproducts (2007)According to the company website www.vivarte.fr, viewed by ECRA in February 2007, several Vivarte brands sold shoes made of leather, a slaughterhouse byproduct. (ref: 56)

PeopleHuman RightsOperations in seven oppressive regimes (2007)According to the company website www.saga.co.uk, viewed by ECRA in summer 2007, Saga Holidays offered resort holidays in the following countries regarded by ECRA in 2007 as having oppressive regimes: Egypt, China, Thailand, the United Arab Emirates, Vietnam, the USA and Cuba. (ref: 52)(See also ‘High climate impact sector and oppressive regime operations’ in Climate Change above.)Products manufactured in two oppressive regimes (October 2005)A shop survey conducted by ECRA in October 2005 found products in Kookai marked as made in China and Indonesia. These countries were considered to be oppressive regimes by ECRA at the time of the survey. (ref: 57)

PoliticsAnti-Social FinanceCompany based in tax haven (2007)According to the company website www.saga.co.uk, viewed by ECRA in summer 2007, Saga Insurance was incorporated in Gibraltar, a territory regarded by ECRA as a tax haven. (ref: 52)

Co-operative Group LtdPO Box 53, New Century House, Manchester, M60 4ES, UK

EnvironmentEnvironmental ReportingBest ECRA rating for environmental report (June 2003)In response to a request by Ethical Consumer in June 2003, CIS sent a copy of their Social Accountability Report 2002 which contained targets and discussion of impacts specific to the company, the report was also independently verified. (ref: 58)

Climate ChangePoor independent rating on CSR in supermarkets (November 2006)The National Consumer Council’s 2006 report on supermarkets awarded the Co-op a poor overall rating (D) for its environmental performance. The report looked at a number of different areas including food transport, waste, nature, and sustainable farming. These were assessed as follows:C rating on food transport issues. 55% of its seasonal vegetables was UK sourced. It also had the ‘smallest’ amount of ‘long distance’ fruit from outside of Europe. It scored a D on its waste, E for its fish stocking policy (worst rating) and C for trees - as one-third of its wooden kitchenware products were FSC certified. It also scored C for sustainable farming as it had pesticide information displayed in stores. (ref: 59)

Pollution & ToxicsSale of products containing pesticide residues (2003)According to the September 2004 edition of the Ecologist, the Co-op had said it would work with suppliers to phase out some of the most worrying chemicals from its crops. Research by Friends of the Earth in 2003 on data from the Pesticide Safety Directorate showed that supermarkets had not achieved any overall reduction of pesticide residues in the last five years. (ref: 60)

Habitats & ResourcesStocked fish from unsustainable sources (March 2007)Co-op was ranked 7th (of 8 supermarkets) in the 2007 Marine Conservation Society’s Sustainable Seafood Supermarket league table. According to the table ranking, Co-op was still selling one species from the MCS fish to avoid list, although only 0.95% of its sales came from the fish to avoid species. The company received a score of 6 (out of 10) for tis wild caught fish policy and 2.5 (out of 10) for its farmed fish policy. (ref: 61)(See also ‘Poor independent rating on CSR in supermarkets’ in Climate Change above.)Stockist of four endangered fish species (1 March 2006)An article on www.guardian.co.uk on 1 March 2006 reported that the Co-op stocked four species of fish on the Marine Stewardship Council’s list of endangered fish species. The Co-op was reported to have a sustainable policy on tuna and was ranked fifth out of 10 in the Marine Conservation Society league table of leading UK supermarkets’ fish buying policies. (ref: 62)

AnimalsAnimal TestingInvestment relationship with animal testing companies (2006)According to a series of emails from a Co-operative Group Ethics Adviser, forwarded to ECRA by an Ethiscore customer, the ethical policy of the Co-op Group precluded investment or provision of banking services to companies which conducted animal testing for cosmetic or household goods purposes. However, it did not preclude such relations with companies which conducted experimentation on animals for medical purposes. However, the Co-op Bank would not divulge specific instances of companies

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which performed or commissioned such tests and to which it provided financial services. The adviser stated that there was no consensus from consultation with Co-op Bank customers which suggested that it should move to exclusion of all medical animal testing from its investments or banking provision. (ref: 63)

Factory farmingSold factory farmed chickens (2006)According to Supermarkets & Farm Animal Welfare ‘Raising the Standard’ published by the Compassion in World Farming Trust in 2006, over 90% of the chickens sold by Co-op supermarkets were intensively farmed. The report stated that the Co-op had set a maximum stocking guideline of 38kg bird per metre squared of floor space, which exceeded the government guidelines of a maximum of 34kg bird per metre squared of floor space. (ref: 64)Retail of factory farmed pigmeat (2006)According to Supermarkets & Farm Animal Welfare ‘Raising the Standard’ published by the Compassion in World Farming (CIWF) Trust in 2006, 42% of pig meat sold by the Co-op supermarkets had come from close confinement farrowing crates. CIWF had urged all supermarkets to produce pigmeat from well managed outdoor farms as it regarded this as the most welfare-friendly rearing system. (ref: 64)Long journey times to slaughter for poultry (2002)According to Supermarkets & Farm Animal Welfare ‘Raising the Standard’ published by the Compassion in World Farming (CIWF) Trust in 2002, CWS Agriculture Ltd set a maximum journey time for birds travelling from farm to slaughter of 6 hours for turkeys, 8 hours for ducks and set no maximum limit for the transport of chickens. CIWF recommended that maximum journey times should be no longer than 4 hours for birds to protect their welfare. (ref: 65)

Other Animal RightsSold products containing slaughterhouse by-products (2007)A shop survey in April 2007 found Co-op supermarkets sold products containing slaughterhouse by-products. (ref: 66)

PeopleHuman RightsDevelopments in Ethical Engagement (June 2005)According to an article in the Guardian Online, dated 27th June 2005, the Co-operative Insurance Society had announced the development of a new ‘ethical engagement policy, ‘ and claimed that it was ‘the first insurer in the world’ to do so. The policy was said to have been devised after a year of consultation with stakeholders and would inform a programme of shareholder activism and campaigning on a range of issues, including the arms trade and animal testing (ref: 67)

Workers’ RightsFined for unsafe workplace (2006)According to an article dated 31st August 2006 on the industry website workplacelaw.net, in 2006 the Co-op was fined £40,000 after a council inspection of its Heathfield store revealed “breaches of health and safety legislation.” The inspection was said to have followed an incident in which an employee’s arm was injured by a mechanical lift, and was said to have uncovered defective electrical systems, obstructed fire exits and unsafe items of lifting equipment. (ref: 68)Unions angered over workers new pay deal (19 July 2005)According to the Guardian website www.newsunlimited.co.uk on 19th July 2005, the USDAW union criticised Co-operative Insurance Services for instigating a new terms and conditions deal for its finance workers. The new scheme ended certain comission based benefits for financial advisors and the company

was alleged to have threatened to dismiss workers who did not accept the new conditions. USDAW stated that workers could be up to 20% worse off. (ref: 69)

Supply Chain PolicyMiddle ECRA rating for code of conduct (2007)The Co-op’s website was viewed in May 2007, and information about its ‘ethical sourcing’ was found. The company claimed that its membership of the ETI required its suppliers to adhere to certain standards. Although this set of standards included statements on forced and child labour, freedom of association and other areas, it merely committed companies to paying ‘legal minimumm’ or ‘industry standard’ wages, which to campaigners such as Labour Behind the Label, was not considered to be high enough wages for workers to live off. (ref: 70)Membership of ETI (August 2005)According to the ETI website www.ethicaltrade.org, visited on 17th August 2005, the Co-operative Group (CWS) was listed as a member. For companies to be accepted as members, they were required to adopt the ETI Base Code of Conduct and implement it into their supply chains. Progress reports on code implementation, and on improvements to labour practices was required. (ref: 71)

Irresponsible MarketingHarmful chemical found in soft drinks (2006)According to an article on the BBC News website (http://news.co.uk) dated 31st March 2006, the Co-op’s low-calorie bitter lemon drink with a best-before date of June 2006 contained benzene levels of 28 parts per billion (ppb). A second batch of the same drink, with an 10 august best-before date had 11 ppb. In the UK, drinking water should contain a benzene level of no more than one part per billion (ppb). The World Health Organisation’s health limit was said to be 10 ppb. The Co-op had already removed the affected batches from the shelves by the time the article was published. Benzene can cause certain cancers, and is thought to be formed when the commonly used soft-drink ingredients- the preservative sodium benzoate and ascorbic acid- interact. (ref: 72)Best independent rating on health responsibility index (November 2005)BBC News reported on 25 November 2005 that the National Consumer Council had rated the supermarkets on their approach to salt reduction, nutrition labelling, in-store promotions and customer information. The study found that supermarkets were more likely to promote unhealthy foods than fresh produce and none had met the NCC’s target of offering 33% of promotions on fruit and vegetables. The National Consumer Council produced a Health Responsibility Index of the supermarkets based on the survey, the Co-op was ranked best of the nine supermarkets. (ref: 73)Positive policy addressing marketing to children (August 2005)According to ‘Our Viewpoints’, located on the Co-operative Group’s website (www.co-op.co.uk) on the 26th August 2005, the company had formulated a policy addressing the marketing of high salt, sugar and fat foods to children. It pledged not to advertise such foods in children’s titles or next to children’s pages in newspapers, and to exclude them from any press advertising aimed directly at children. It also pledged not to give free samples, promote by demonstration in stores, or use high profile character merchandising any such food aimed directly at children.The Co-operative Group had also prohibited the display of child targeted products which were high in salt, sugar or fat at its traditional style supermarket checkouts where children may exert ‘pester power’ whilst waiting for parents to queue and pay for grocery shopping. (ref: 74)

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Armamentsxxx - Co-operative Insurance Society (CIS) Corporate

Communications:www.cis.co.uk(5September2007)(512034)

Investment relationship with arms sector (2007)According to the Socially Responsible Investment section of the company website www.cis.co.uk, viewed by ECRA in September 2007, CIS had shares in arms companies Cobham and GKN. (ref: 75)

PoliticsGenetic EngineeringSale of GM products (October 2004)As reported in the October/December 2004 issue of The Food Magazine, the Co-op was selling bacon flavour salad topping which contained GM ingredients. (ref: 76)

Boycott CallBoycott for stocking of Israeli goods (March 2007)The Big Campaign Website www.bigcampaign.org viewed by ECRA Publishing in March 2007 stated that The Co-operative Group was on the Boycott Israeli Goods boycott list, because the company stocked Carmel mangoes and own brand tinned grapefruit from Israel. (ref: 77)

Political ActivitiesDonations to the Co-operative Party (2003)The Co-operative Group’s Corporate Responsibility Report 2003 stated that the company had paid out £500,000 in political support during 2003, which included donations to the Co-operative and Labour parties. (ref: 78)Donations to the Co-operative Party (2002)According to the CIS Report & Financial Statements 2002, the company made donations to the Co-operative Party of £8,745 in 2002 and £8,745 in 2001. (ref: 79)

Anti-Social FinanceExcessive directors pay 2002 (2002)The Co-operative Bank’s Financial Statements 2003 stated that during 2002 one of its directors received a total emolument of £1,054,000. (ref: 80)

Company EthosBest ECRA rating for animal testing policy (August 2005)The BUAV website www.buav.org viewed by ECRA on 10 August 2005 listed The Co-op (Own Label) as a Humane Cosmetics Standard and Humane Household Products Standard approved company selling non-animal tested cosmetics and household cleaning products. To be approved for the Humane Cosmetics Standard and the Humane Household Products Standard, a company must no longer conduct or commission animal testing and must apply a verifiable fixed cut-off date - an unmoveable date after which none of the products or ingredients have been animal tested. The scheme required each company to be open to an independent audit throughout the supply chain to ensure that they adhered to the animal testing policy criteria. (ref: 81)Not for profit group structure (April 2005)According to the Co-operative group website, www.co-op.co.uk, viewed In April 2005, “We don’t exist to make a profit for shareholders. Like all co-operatives, our number one priority is to provide the best possible service to our members. This means: - making our businesses the best they can be - reinvesting in the communities where our members live.” At the time of writing, ECRA rated companies with a not-for-profit trading structure as potentially more sustainable in the long term. (ref: 82)

Fortis NVRue Royale 20, 1000 Brussels, Belgium

EnvironmentEnvironmental ReportingWorst ECRA rating for environmental reporting (2007)The Fortis 2006 Sustainability Report, viewed by ECRA in 2007, was found to contain a range of targets on topics such as climate change emissions reduction and waste, and discussion of various environmental impacts of the organisation’s activities, such as the sustainability of palm oil production. It was also found to have been independently verified by KPMG. (ref: 83)

Climate ChangeShareholdings in companies criticised on ethical grounds (2007)According to the company website www.fortis.nl, viewed by ECRA in September 2007, Fortis had shareholdings in a number of companies which had been criticised under ECRA’s various ethical categories. These included:- Ahold (political activities, workers’ rights, anti-social finance)- Philips Electronics (armaments, irresponsible marketing, human rights, political activities, workers’ rights, pollution & toxics)- Royal Dutch Shell (armaments, animal testing, boycott call, human rights, political activities, workers’ rights, anti-social finance, climate change, pollution & toxics, habitats & resources)- Nutreco (factory farming)- Unilever (animal testing, boycott call, factory farming, genetic engineering, irresponsible marketing, other animal rights, human rights, political activities, workers’ rights, antisocial finance, pollution & toxics, habitats & resources) (ref: 84)Financial services to climate impact sector (2006)According to the company annual report for 2006, Fortis provided financial services such as banking and loans to the fossil fuel sector, one considered by ECRA to make a major contribution to climate change emissions. (ref: 85)Criticism of investments in abusive companies (2005)According to a press release dated November 2005 by Belgian NGO Netwerk Vlaanderen, Fortis had investment in a number of companies and projects which had been criticised for environmental and social issues. In the case of Fortis, these were said to include:- shares in Total, which was the subject of a major campaign over human rights abuses on gas projects in Burma;- shares in Wal-Mart, which had been criticised by labour rights campaigners around the world for its poor standards;- involvement in funding the BTC gas pipeline, which was said to have resulted in serious repression in areas of Turkey, Azerbaijan and Georgia through which it passed, as well as environmental destruction. (ref: 86)

Pollution & ToxicsCriticism for part-financing a “catastrophic” gas exploration (June 2007)In a press release by Friends of the Earth International (FOEI) dated June 2007 (www.foei.org), the organisation criticised Fortis along with four other major international banks, for part-financing Lapindo Brantas Inc., operator of the Banjar Panji 1 gas exploration well in the Brantas Production Sharing Contract (Brantas PSC) area of Indonesia. FOEI claimed at the time of writing that a volcanic slide which began in May 2006 and had not stopped since, was linked to the exploration project. Since May 2006, FOEI reported that up to 150,000m-cubed of hot

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mud had been spilled on to the surrounding area daily. The press release also stated that “3,500 families had been forced from their homes, 11 villages submerged, approximately 350 hectares of farming land ruined, businesses and schools [had been] closed and livelihoods lost”.Fortis was named by FOEI as one of the financiers involved with the Brantas PSC which had helped to “arrange credit facilities, manage bond and/or share issuances, enter into currency swap contracts, or own shares [itself] or on behalf of customers”. FOEI demanded that any new loan from any of the banks involved in financing the exploration project “should be conditional on Lapindo Brantas paying compensation for all its damage. So far the banks [had] failed to take adequate measures to guarantee that Lapindo Brantas [was] actually repairing and compensating for the damage [it] had caused”. (ref: 87)(See also ‘Shareholdings in companies criticised on ethical grounds’ in Climate Change above.)Habitats & Resources(See also ‘Criticism for part-financing a “catastrophic” gas exploration’ in Pollution & Toxics above.)(See also ‘Shareholdings in companies criticised on ethical grounds’ in Climate Change above.)Loan to controversial dam project (2005)According to an article dated 5th May 2005 on the PlanetArk website, Fortis Bank was one of nine international commercial banks which had provided loans for the Nam Theun 2 hydroelectric dam in Laos, a country regarded at the time by ECRA as having an oppressive regime. Activists in Laos were said to have stated that the dam, which would largely produce electricity for sale outside Laos, would be a disaster for the country, forcing thousands from their homes and threatening wildlife. (ref: 88)

AnimalsAnimal Testing(See also ‘Shareholdings in companies criticised on ethical grounds’ in Climate Change above.)Factory farming(See also ‘Shareholdings in companies criticised on ethical grounds’ in Climate Change above.)Other Animal Rights(See also ‘Shareholdings in companies criticised on ethical grounds’ in Climate Change above.)

PeopleHuman Rights(See also ‘Criticism for part-financing a “catastrophic” gas exploration’ in Pollution & Toxics above.)Operations in tax havens and oppressive regimes (2007)According to the company website www.fortis.com, viewed by ECRA in September 2007, Fortis had subsidiaries in the following countries regarded by7 ECRA as having oppressive regimes: Russia, China, the USA, the UAE and Thailand, and in a number of tax havens, including Hong Kong, Ireland, the British Virgin Islands and Luxembourg. (ref: 89)(See also ‘Shareholdings in companies criticised on ethical grounds’ in Climate Change above.)Workers’ Rights(See also ‘Shareholdings in companies criticised on ethical grounds’ in Climate Change above.)Target of divestment campaign (2006)According to the March 2006 issue of Ethical Performance, Fortis was one of five Belgian banks being targeted by a campaign group which wanted them to divest from oil company Total because of its operations in Burma and Walmart because of its poor labour standards. (ref: 90)

(See also ‘Criticism of investments in abusive companies’ in Climate Change above.)Irresponsible Marketing(See also ‘Shareholdings in companies criticised on ethical grounds’ in Climate Change above.)ArmamentsFunding of weapons companies (2004)According to an International Alert January 2006 report on the role of project finance in conflicts, Fortis had been accused by human rights NGOs of having been involved in financing companies which developed or made cluster bombs, landmines, nuclear weapons and depleted uranium weaponry. (ref: 91)(See also ‘Shareholdings in companies criticised on ethical grounds’ in Climate Change above.)Allegations of military funding (2003)In spring 2002, campaign group Global Witness produced ‘All the Presidents’ Men’ which provided details of links between oil and arms in Angola. GW reported that loans made in 2000 and 2001 to Angolan state-owned oil company, Sonangol, meant Angola had breached the IMF’s borrowing agreement. A second loan, made a month after a first and for exactly the same figure of $455m, was arranged on 8/3/01, though again described as ‘working capital’, took Angola’s borrowing well beyond the IMF limit for 2001. While the first loan was detailed as having been arranged by (separate company) Standard Chartered Bank, with sixteen other banks named as co-arrangers, including Fortis Bank and another separate company, Commerzbank, which was described as the lead arranger for the second loan. A further loan of $600m, made on 16/7/01, involved several of the same banks as the first two, including Fortis Bank, which was named as one of the co-arrangers. GW cited African Energy which had suggested the loan details were a ploy to avoid immediate accusations. If true, this would imply that the loan may also aid misappropriation of state funds, hence the IMF’s objections to such loans. (ref: 92)

PoliticsGenetic Engineering(See also ‘Shareholdings in companies criticised on ethical grounds’ in Climate Change above.)Boycott Call(See also ‘Shareholdings in companies criticised on ethical grounds’ in Climate Change above.)Political ActivitiesLobbying in the EU and beyond (July 2007)According to the June/July 2007 Corporate Watch newsletter, Fortis were one of 20 companies that the organisation had criticised for having “enormous influence over the daily life of Europeans” and beyond. The report details how companies used their power to try to influence decision-making in Europe and the rest of the world. (ref: 16)(See also ‘Shareholdings in companies criticised on ethical grounds’ in Climate Change above.)Low rated information on lobbying (2005)The 2005 SustainAbility/WWF report ‘Influencing Power: Reviewing the conduct and content of corporate lobbying’, ranked how 100 major companies reported on lobbying and its relationship to their core business, from the provision of no information (51 companies) through to ‘basic’ (31 companies), ‘developing’ (10 companies), ‘systematic’ (8 companies) or ‘integrated’ reporting (0 companies). It said that Fortis’s reporting had only merited the ‘basic’ category. (ref: 50)

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Anti-Social FinanceInvolvement with rebel plunder group in Democratic Republic of Congo (2002)According to the Bloomberg News (www.bloomberg.com) website of 1st December 2005, Fortis, Belgium’s biggest financial services company was accused of being involved with rebel groups in the Democratic Republic of Congo who were stealing the country’s diamonds, gold and other natural resources.The article referenced a 2002 report by a UN panel monitoring sanctions in the country. (ref: 93)(See also ‘Operations in tax havens and oppressive regimes’ in Human Rights above.)(See also ‘Shareholdings in companies criticised on ethical grounds’ in Climate Change above.)

HBOS PlcThe Mound, Edinburgh, EH1 1YZ, UK

EnvironmentEnvironmental ReportingBest ECRA rating for environmental reporting (2007)The HBOS 2005 Corporate Responsibility report, viewed by ECRA in 2007, was found to contain a range of targets on company impacts such as energy use, waste, transport methods and recycling, and to include information on the impacts of the company’s investments and engagement by the HBOS subsidiary Insight Investments. The report had been independently verified by WSP. The company’s website, www.hbosplc.com, was also found to include updates on the 2005 report, including commitments to source all UK electricity from renewable sources and to implement a scheme incentivising staff to find means of working which did not include travel, particularly flights. (ref: 94)

Climate ChangeHigh climate impact sector (2006)According to the company annual report for 2006, HBOS was a major provider of banking and financial services to the oil and gas industry, particularly in the North Sea. Fossil fuels were considered by ECRA to be a sector which made a major contribution to climate change emissions. (ref: 95)Investment relationship with oil sector company (December 2003)HBOS Plc’s Annual Report & Accounts 2004 stated that in December 2003 Energy North Sea “acquired Shells’ non-operated minority interests in the MONARB and West of Britain oil fields in the North Sea”. According to the report, “Bank of Scotland Corporate provided Energy North Sea with £145m integrated debt and equity funding package for the acquisition. BoS took a 35% share as part of the transaction and subsequent disposal after just 10 months resulted in a significant profit”. ECRA regarding the oil sector to be a sector with climate change impact. (ref: 96)

Pollution & ToxicsShareholdings in Balfour Beatty (2007)According to the Balfour Beatty company factsheet on the Yahoo! Finance website http://uk.finance.yahoo.com, viewed by ECRA in August 2007, HBOS had shareholdings in Balfour Beatty, a company criticised by ECRA in the following categories: Workers’ Rights, Habitats & Resources, Pollution & Toxics, Anti-Social Finance. (ref: 97)

Habitats & Resources(See also ‘Shareholdings in Balfour Beatty’ in Pollution & Toxics above.)Poor rating in bank policy survey (2006)According to a Banktrack/WWF report on social and environmental policies amongst international banks, HBOS had a

poor accumulated score for its policies, at just 0.08 out of a possible 5, amounting to an E grade. The bank was said to have policies on just four out of thirteen categories, in this case human rights. Issues such as indigenous peoples, agriculture, labour, forests and fisheries were not covered. Like most other banks, HBOS was also said to have few systems in place for ensuring that the policies that were in place were implemented. (ref: 12)Banking relationship with Associated British Foods (January 2005)Hemscott www.hemscott.com was viewed by ECRA on 26 January 2005, the website listed HBOS Plc as one of the bankers to Associated British Foods Plc. When Associated British Foods was rated on ECRA’s Corporate Critic database in January 2005, it received ECRA’s bottom rating in the environmental reporting, animal testing, factory farming, other animal rights and genetic engineering. Associated British Foods received ECRA’s middle rating for oppressive regimes, boycott call and political activity categories. It received ECRA’s top rating in the remaining categories. (ref: 98)

AnimalsAnimal Testing(See also ‘Banking relationship with Associated British Foods’ in Habitats & Resources above.)Factory farming(See also ‘Banking relationship with Associated British Foods’ in Habitats & Resources above.)Other Animal Rights(See also ‘Banking relationship with Associated British Foods’ in Habitats & Resources above.)Investment in Austin Reed Group (2003)Austin Reed Group Plc Report & Accounts 2003/2004 stated that HBOS Plc owned 7.96% of the share capital of Austin Reed Group Plc. When Austin Reed was rated on ECRA’s Corporate Critic database on 3 March 2005, Austin Reed received ECRA’s worst rating in the environmental reporting, other animal rights and code of conduct categories. It received ECRA’s best rating in all other categories. (ref: 99)Criticism for use of animals in advertising (May 2005)According to the May 2005 issue of ARCNews, Halifax had received a number of complaints from the public over its use of a white tiger cub in an advert. The company was said to have stated that it would not be using wild animals in any future advertising campaigns, although it refused to withdraw the existing advert. (ref: 100)

PeopleHuman RightsBanking relationship with Remnant Media (December 2004)The Edinburgh Evening News reported in an article dated 14 December 2004 that HBOS had arranged a £4.5million loan to publishers Remnant Media in order for the group to buy pornographic magazines Asian Babes, Readers Wives’, Mothers-in-Law, Barely Legal and 60 Plus. (ref: 101)Banking relationship with Remnant Media (March 2004)The BBC News website www.bbc.co.uk reported in an article dated 22 March 2004 that Bank of Scotland had arranged a £5million loan to publishers Remnant Media in order for the group to buy 45 magazines including adult publications “Asian Babes”, “60 Plus”, “Best of Real Wives”, “Fantasy Channel Magazine” and “Big Ones International”. The Bank of Scotland admitted it regretted its decision and the offence it had caused to some of its customers and stated that it would “review our lending policies and processes as a matter of urgency”. However the Bank of

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Scotland stated that it remained committed to the loan as “one of our key principles is to stand by our customers”. Another bank which had agreed to provide finance for the deal pulled out after pressure from offended customers. (ref: 102)Subsidiaries in a tax haven and an oppressive regime (2006)According to the company annual report for 2006, HBOS had subsidiaries in Ireland and the USA, countries regarded by ECRA as a tax haven and having an oppressive regime, respectively. (ref: 95)

Workers’ Rights(See also ‘Shareholdings in Balfour Beatty’ in Pollution & Toxics above.)(See also ‘Poor rating in bank policy survey’ in Habitats & Resources above.)Banking relationship with Scottish & Newcastle Plc (January 2005)Hemscott www.hemscott.com was viewed by ECRA on 26 January 2005, the website listed HBOS Plc as the banker to Scottish & Newcastle Plc. When Scottish & Newcastle was rated on ECRA’s Corporate Critic database in January 2005, it received ECRA’s bottom rating in the environmental reporting category and it received ECRA’s middle rating in the oppressive regimes and workers rights categories. It received ECRA’s top rating in the remaining categories. (ref: 103)

PoliticsGenetic Engineering(See also ‘Banking relationship with Associated British Foods’ in Habitats & Resources above.)Boycott Call(See also ‘Banking relationship with Associated British Foods’ in Habitats & Resources above.)Political ActivitiesBanking relationship with Reuters Group Plc (January 2005)Hemscott www.hemscott.com was viewed by ECRA on 26 January 2005, the website listed HBOS Plc as the bankers to Reuters Group Plc. When Reuters Group was rated on ECRA’s Corporate Critic database in January 2005, it received ECRA’s bottom rating in the environmental reporting, oppressive regimes and alert categories. Reuters Group received ECRA’s middle rating in the workers rights, code of conduct and political activity categories. It received ECRA’s top rating in the remaining categories. (ref: 104)(See also ‘Banking relationship with Associated British Foods’ in Habitats & Resources above.)Anti-Social FinanceBreaches of FSA rules (2004)HBOS Plc’s Taking Care of Tomorrow; The HBOS Corporate Responsibility Report 2004 reported that in February 2003 Bank of Scotland was fined £750,000 and disciplined by the Financial Services Authority for breaches of the FSA principles and IMRO rules in the administration of its Pep and ISA business. In January 2004 the Bank of Scotland was fined a further £1,250,000 for breaches of the record-keeping aspects of the FSA’s Money Laundering Rules. (ref: 105)(See also ‘Shareholdings in Balfour Beatty’ in Pollution & Toxics above.)(See also ‘Subsidiaries in a tax haven and an oppressive regime’ in Human Rights above.)

Insurance Australia GroupLevel 62, 388 George Street, Sydney NSW 2000, Australia

EnvironmentEnvironmental ReportingMiddle ECRA rating for environmental reporting (2007)The IAG Sustainability Report for 2006, downloaded from www.iag.com.au and supplemented with environmental performance information from the website, was found to contain several targets for environmental improvements, including cuts in greenhouse gas emissions, and it had been independently verified by KPMG. However, its discussion of environmental impacts was largely confined to the company’s direct impacts, and did not consider indirect effects such as the results of investment decisions. (ref: 106)

PeopleHuman RightsOperations in two oppressive regimes (2007)According to the company website www.iag.com.au, viewed by ECRA in September 2007, Insurance Australia Group had subsidiaries in China and Thailand, countries regarded by ECRA as having oppressive regimes. (ref: 107)

PoliticsPolitical ActivitiesMember of one international lobby group (2007)According to the organisation’s website www.wbcsd.org, viewed by ECRA in January 2007, in 2007 Insurance Australia Group was a member of the World Business Council for Sustainable Development. This was regarded by ECRA as an international corporate lobby group which exerted undue corporate influence on policy-makers in favour of market solutions that were potentially detrimental to the environment and human rights. (ref: 108)

Anti-Social FinanceSubsidiaries in tax havens (2006)According to the company’s 2006 Annual Report, in 2006 Insurance Australia Group had subsidiaries in a number of tax havens, including Singapore, Labuan (Malaysia, Ireland and Mauritius. (ref: 109)Excessive director’s pay (2006)According to the company’s 2006 Annual Report, in 2006 one director of Insurance Australia Group was paid over Aus$3 million, a sum deemed by ECRA to be excessive. (ref: 109)Large golden handshakes (2003)The November 2004 issue of Labour Research listed the largest golden handshakes paid to company directors in 2003. One director of Cox Insurance was said to have received £391,000 on leaving the company, and another got £302,000. (ref: 110)

JP Morgan Chase & Company270 Park Avenue, New York, NY 10017

PeopleHuman RightsShareholdings in Roxi Petroleum (2007)According to the Roxi Petroleum factsheet on investment information website Hemscott.com, viewed by ECRA in August 2007, JP Morgan Chase had shareholdings in Roxi Petroleum, an oil and gas development company working in Kazakhstan. Fossil fuels were regarded by ECRA as a sector which made particular contributions to climate change emissions, and Kazakhstan was regarded in 2007 as having an oppressive regime. (ref: 111)

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Investments with climate change and human rights impacts (2007)According to the Spring 2007 edition of Earth Island Journal, JP Morgan was being targetted by the Movement for the Emancipation of the Niger Delta (MEND) because of its investments in the regions oil and gas industry. The group wanted the companies to put pressure on the Nigerian government. MEND was using armed force as a last resort after three decades of peaceful entreaty had met with cynical indifference, and was involved in kidnapping oil workers in the region. The report said that oil and gas companies in the region had backed military attacks on local communities to protect the oil fields. However, as attacks on its fields resulted in the killing of company workers and shutting down 140,000 barrels of daily oil production, the companies were said to be rethinking policies. (ref: 112)

Workers’ RightsAllegations of racism in contractors and lending (2006)According to a press release from the Chasemonitor.org monitoring group, sourced on the Yahoo! Finance website in December 2006, campaigners against JP Morgan Chase were staging demonstrations over allegations of racism and poor working practices.The first set of allegations were said to relate to alleged practices by a JP Morgan Chase subcontractor, MACC, at its major facilities in Columbus, Ohio. Workers were said to “face poor and physically demanding working conditions including near-poverty wages with no health benefits or wage increases.” Somali were also said to have complained of racism and religious discrimination, including not being allowed to wash for prayers, being told they looked like “an animal” and forced to bring presents for supervisors. One pregnant woman was said to have been threatened with unsafe work assignments if she did not bring gifts for her boss. MACC was said to have responded to complaints about its practices by other companies by firing staff.JP Morgan Chase was also said to be accused of discriminatory lending practices to communities of colour, with African-American applicants said to be 80% more likely to be refused loans than whites, and Latino applicants more than twice as likely to be offered high-interest loans. (ref: 113)Investment services for Vedanta (2005)According to an August 2005 issue of CSR Asia Weekly (week 32), a new report by the India Resource Centre had revealed a range of human rights and environmental misdemeanours by Vedanta Resources, a company in the share issue of which JP Morgan was said to have played a significant role. The company was said to have opencast mined aluminium, removing the tops of a number of scenic hills and at one point operating a mine adjacent to a tiger reserve. Mines were in some cases said to have been established on land to which the company did not have title, and local people to have been forced off it. Labourers were also said to have been forced to work without helmets and to live in hut accommodation without amenities such as running water and light. The company was also accused of a lack of financial transparency in relation to some of its dealings. (ref: 114)Investment relationship with National Australia Bank (2003)National Australia Bank’s Annual Report 2003 stated that JP Morgan Nominees Australia Limited owned 11.86% of the company as at 17 October 2003. When scored on ECRA’s Corporate Critic database on 3 March 2005, National Australia Bank received ECRA’s middle rating in the environmental reporting, pollution, animal testing, other animal rights, oppressive regimes, workers’ rights and genetic engineering categories. In all other categories the company received ECRA’s best rating. (ref: 115)

PoliticsPolitical ActivitiesMembership of NFTC lobby group (25 May 2007)According to the website of the National Foreign Trade Council (NFTC), www.nftc.org, visited on 8th June 2007, JP Morgan Chase & Co was listed as a director. The NFTC’s motto was ‘Advancing Global Commerce’ and it also claimed to be “the only business association dedicated solely to trade policy, export finance, international tax, and human resource issues on behalf of its members”. It also stated the organization advocated open world markets and fought against protectionist legislation and policies. It also offered rapid and effective response to fast-moving legislative and policy developments by a team with a reputation for tackling tough issues and getting results, and participation in NFTC-led business coalitions on major international trade and tax issues. These were listed as benefits of membership of the organisation. (ref: 117)

Legal & General Group plcTemple Court, 11 Queen Victoria Street, London, EC4N 4TP, UK

EnvironmentEnvironmental ReportingMiddle ECRA rating for Environmental Report (2007)A search was made by ECRA in June 2007 on the company website www.legalandgeneral.com for the Legal & General Group environmental policy or report. The company’s online CSR report was found to include environmental information, including progress on 2006 targets and new targets set for 2007. It also discussed issues beyond the company’s direct impacts, including brief mention of the effects of the company’s investments. However, the report did not appear to be independently monitored or verified. (ref: 118)Top of oekom sustainability index (2007)According to the June 2007 issue of Ethical Performance, Legal & General, along with another UK-Based firm, jointly headed a new corporate sustainability ranking of the world’s 43 largest insurance companies.It said it had done well primarily because it offered staff a good working environment and equality of opportunity. It also stood out as an example of best practice in the area of eco-efficiency. (ref: 20)

Nuclear PowerShareholdings in Johnson Matthey (2007)According to the Johnson Matthey factsheet on investment information website Hemscott.com, viewed by ECRA in August 2007, Legal & General Investment Management had shareholdings in Johnson Matthey, a company criticised under the ECRA categories: Irresponsible Marketing, Nuclear Power, Workers’ Rights, Pollution & Toxics and Animal Testing. (ref: 31)

Climate ChangeShareholding in Royal Dutch Shell (2007)According to the Royal Dutch Shell factsheet on investment information website Hemscott.com, viewed by ECRA in August 2007, Legal & General Group had shareholdings in Royal Dutch Shell, a company criticised by ECRA under the categories: climate change, human rights, habitats & resource and political activities. (ref: 119)Shareholdings in Cairn Energy (2007)According to the Cairn Energy factsheet on investment information website Hemscott.com, viewed by ECRA in August 2007, Legal & General Asset Management had shareholdings in Cairn Energy, a company criticised by ECRA under the categories: climate change, human rights. (ref: 120)

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Shareholdings in Premier Oil (2007)According to the Premier Oil factsheet on investment information website Hemscott.com, viewed by ECRA in August 2007, Legal & General Group had shareholdings in Premier Oil, a company criticised by ECRA under the categories: climate change, human rights, workers’ rights. (ref: 32)

Pollution & Toxics(See also ‘Shareholdings in Johnson Matthey’ in Nuclear Power above.)Shareholdings in Hanson plc (2007)According to the Hanson plc 2006/7 Annual Report, in 2007 Legal & General Investment Management had shareholdings in Hanson, a company criticised by ECRA in the categories Workers’ Rights and Pollution & Toxics. (ref: 121)Shareholding in Tesco (2007)According to the Tesco factsheet on investment information website Hemscott.com, viewed by ECRA in August 2007, Legal & General Group had shareholdings in Tesco, a company criticised by ECRA under the categories: habitats & resources, workers’ rights, climate change, factory farming and pollution & toxics. (ref: 122)

Habitats & Resources(See also ‘Shareholdings in Johnson Matthey’ in Nuclear Power above.)Shareholdings in AMEC (2007)According to the AMEC company factsheet on the Yahoo! Finance website http://uk.finance.yahoo.com, viewed by ECRA in August 2007, Legal & General Investment Management had shareholdings in AMEC, a company criticised by ECRA in the following categories: Workers’ Rights, Climate Change, Habitats & Resources. (ref: 33)Shareholdings in Balfour Beatty (2007)According to the Balfour Beatty factsheet on investment information website Hemscott.com, viewed by ECRA in August 2007, Legal & General Investment Management had shareholdings in Balfour Beatty, a company criticised under the ECRA categories: pollution & toxics, habitats & resources, workers’ rights, anti-social finance. (ref: 123)

AnimalsAnimal TestingSale of animal tested products (July 2005)According to the website Op-info (www.opinfo.net), which provided information on the full range of Kingfield Heath products and which was viewed by ECRA on the 16th July 2005, the company retailed household cleaning products. Some of these brands were known by ECRA to have been tested on animals. (ref: 124)(See also ‘Shareholdings in Johnson Matthey’ in Nuclear Power above.)Factory farming(See also ‘Shareholding in Tesco’ in Pollution & Toxics above.)Other Animal RightsLeather goods (2005)According to the online office supplies retailer Office Giant, www.officegiant.co.uk, Kingfield Heath’s house brand Q Connect range included executive chairs made of leather. (ref: 125)Investment relationship with Alexon Group (July 2004)Hemscott Premium was viewed by ECRA Publishing on 16 July 2004. The website stated that Legal & General owned 3.42% of Alexon Group Plc. When Alexon Group was rated on ECRA’s Corporate Critic database at that time it received ECRA’s worst rating for environmental reporting, environment other, other animal rights, oppressive regimes and code of conduct. It received

ECRA’s middle rating in the workers rights and alert categories. In all other categories Alexon Group received ECRA’s best rating. (ref: 126)

PeopleHuman Rights(See also ‘Shareholdings in Premier Oil’ in Climate Change above.)Subsidiaries in oppressive regime and tax havens (2007)According to the company factsheet on business website Hoovers.com, viewed by ECRA in June 2007, Legal & General had subsidiaries in a tax haven (Luxembourg) and a country regarded by ECRA as having an oppressive regime (the USA). (ref: 127)(See also ‘Shareholding in Royal Dutch Shell’ in Climate Change above.)Workers’ Rights(See also ‘Shareholdings in Johnson Matthey’ in Nuclear Power above.)(See also ‘Shareholdings in AMEC’ in Habitats & Resources above.)(See also ‘Shareholdings in Hanson plc’ in Pollution & Toxics above.)Irresponsible Marketing(See also ‘Shareholdings in Johnson Matthey’ in Nuclear Power above.)Shareholdings in Imperial Tobacco (2007)According to the Imperial Tobacco factsheet on investment information website Hemscott.com, viewed by ECRA in August 2007, Legal & General Investment Management had shareholdings in Imperial Tobacco Group plc, a company which had been criticised for its sale of tobacco products. (ref: 128)Prizes for sales of boycotted goods (2005)According to a recent news item on the Kingfield Heath website, www.kingfieldheath.com, viewed by ECRA in July 2005, the company was awarded a prize for the re-seller company with the highest sales volume of Nestle products. Nestle was controversial as the subject of a 20-year, worldwide boycott due to its repeated infringement of the International Code on the Marketing of Breastmilk Substitutes and resulting ill-health amongst children in the Third World. The manager of the team winning Kingfield Heath’s prize was quoted as saying: “we would like to thank Kingfield Heath for their support, and let’s keep drinking the [Nescafe] coffee!” (ref: 129)

ArmamentsShareholdings in BAe Systems (2007)According to the BAe Systems factsheet on investment information website Hemscott.com, viewed by ECRA in August 2007, Legal & General Investment Management had shareholdings in BAe Systems, a company criticised by ECRA for its role in the manufacture and supply of arms. (ref: 47)Shareholdings in GKN (2007)According to the company factsheet on investment information website Hemscott.com, viewed by ECRA in August 2007, Legal & General Investment Management had shareholdings in GKN, a company criticised by ECRA for its role in the manufacture and supply of armaments. (ref: 38)Shareholdings in Cobham (2007)According to the company factsheet on investment information website Hemscott.com, viewed by ECRA in August 2007, Legal & General Investment Management had shareholdings in Cobham, a company criticised by ECRA for its role in the manufacture and supply of armaments. (ref: 39)

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PoliticsBoycott Call(See also ‘Prizes for sales of boycotted goods’ in Irresponsible Marketing above.)Political Activities(See also ‘Shareholding in Royal Dutch Shell’ in Climate Change above.)(See also ‘Shareholdings in BAe Systems’ in Armaments above.)Anti-Social Finance(See also ‘Shareholdings in Balfour Beatty’ in Habitats & Resources above.)(See also ‘Subsidiaries in oppressive regime and tax havens’ in Human Rights above.)Shareholdings in British Airways (2007)According to the BA factsheet on investment information website Hemscott.com, viewed by ECRA in August 2007, Legal & General Group had shareholdings in British Airways, a company criticised by ECRA under the categories: Climate Change; Anti-Social Finance; Workers’ Rights. (ref: 130)

Liverpool Victoria Friendly SocietyCounty Gates, Bournemouth, Dorset, BH1 2NF

EnvironmentEnvironmental ReportingWorst ECRA rating for environmental reporting (2007)A search was made by ECRA in August 2007 on the Liverpool Victoria website for a copy of the company’s environmental policy or report. No such document could be found, and a request sent to the company for environmental information was not replied to. The company’s 2006 annual report stated that it had an environmental policy but included no information on its contents. The company website also contained a Community section but this dealt solely with corporate philanthropy. (ref: 131)

Nuclear PowerShareholdings in companies criticised by ECRA (2006)According to the Liverpool Victoria Portfolio Managers factsheet on the investments information website Trustnet.com, viewed by ECRA in August 2007, at the end of December 2006 Liverpool Victoria Asset Managers funds included holdings in a number of companies criticised under a variety of ECRA’s environmental, social and animal categories. These included:- Total SA (Climate change, pollution & toxics, habitats & resources, human rights, irresponsible marketing, boycott call, political activities, anti-social finance);- Roche Holdings AG (animal testing, other animal rights, human rights, irresponsible marketing, political activities);- Siemens AG (nuclear power, climate change, human rights, workers rights, armaments, political activities, anti-social finance);- Nestle SA (pollution & toxics, habitats & resources, animal testing, factory farming, other animal rights, human rights, workers’ rights, irresponsible marketing, genetic engineering, boycott call, political activities, anti-social finance);- Novartis AG (pollution & toxics, animal testing, factory farming, human rights, workers’ rights, irresponsible marketing, genetic engineering, political activities, anti-social finance);along with other companies criticised in these categories such as BP, GlaxoSmithkline and Royal Dutch Shell. (ref: 132)

Climate Change(See also ‘Shareholdings in companies criticised by ECRA’ in Nuclear Power above.)Pollution & Toxics(See also ‘Shareholdings in companies criticised by ECRA’ in Nuclear Power above.)Habitats & Resources(See also ‘Shareholdings in companies criticised by ECRA’ in Nuclear Power above.)

AnimalsAnimal Testing(See also ‘Shareholdings in companies criticised by ECRA’ in Nuclear Power above.)Factory farming(See also ‘Shareholdings in companies criticised by ECRA’ in Nuclear Power above.)Other Animal Rights(See also ‘Shareholdings in companies criticised by ECRA’ in Nuclear Power above.)

PeopleHuman Rights(See also ‘Shareholdings in companies criticised by ECRA’ in Nuclear Power above.)Workers’ Rights(See also ‘Shareholdings in companies criticised by ECRA’ in Nuclear Power above.)Irresponsible Marketing(See also ‘Shareholdings in companies criticised by ECRA’ in Nuclear Power above.)Armaments(See also ‘Shareholdings in companies criticised by ECRA’ in Nuclear Power above.)

PoliticsGenetic Engineering(See also ‘Shareholdings in companies criticised by ECRA’ in Nuclear Power above.)Boycott Call(See also ‘Shareholdings in companies criticised by ECRA’ in Nuclear Power above.)Political Activities(See also ‘Shareholdings in companies criticised by ECRA’ in Nuclear Power above.)Anti-Social Finance(See also ‘Shareholdings in companies criticised by ECRA’ in Nuclear Power above.)Company EthosMutual organisation (2007)According to the company website www.lv.com, viewed by ECRA in August 2007, Liverpool Victoria was a Friendly Society, a mutual financial organisation run for the benefit of its members instead of shareholders. (ref: 133)

Lloyds TSB Group plc25 Gresham Street, London, EC2V 7HN, UK

EnvironmentEnvironmental ReportingMiddle ECRA rating for environmental reporting (2007)The Lloyds TSB Group Corporate Responsibility Report for 2006, downloaded from www.lloydstsb.com and viewed by

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ECRA in September 2007, was found to contain several targets for reduction of CO2 emissions, increases in recycling and reduction of water use. The report was also found to have been verified by the Centre for Sustainability & Excellence and to have an additional verification statement for the environment section from RPS Group. However, the scope of the report was limited to the direct environmental impacts of the group and did not properly address its impacts via lending, investment and other activities. (ref: 134)

Nuclear PowerShareholdings in Johnson Matthey (2007)According to the Johnson Matthey factsheet on investment information website Hemscott.com, viewed by ECRA in August 2007, Scottish Widows Insurance Partnership had shareholdings in Johnson Matthey, a company criticised under the ECRA categories: Irresponsible Marketing, Nuclear Power, Workers’ Rights, Pollution & Toxics and Animal Testing. (ref: 31)Banking relationship with Smiths Group Plc (January 2005)Hemscott www.hemscott.com was viewed by ECRA on 26 January 2005, the website listed Lloyds TSB Bank Plc as the bankers to Smiths Group Plc. When Smiths Group Plc was rated on ECRA’s Corporate Critic database in January 2005, it received ECRA’s bottom rating in the environment other and armaments categories and ECRA’s middle rating in the environmental reporting, nuclear power, oppressive regimes and alert categories. It received ECRA’s top rating in the remaining categories. (ref: 135)Banking relationship with Johnson Matthey Plc (January 2005)Hemscott www.hemscott.com was viewed by ECRA on 26 January 2005, the website listed Lloyds TSB Bank Plc as one of the bankers to Johnson Matthey Plc. When Johnson Matthey was rated by ECRA’s Corporate Critic database in January 2005, it received ECRA’s bottom rating in the environmental reporting, nuclear power and animal testing categories. It received a middle rating in the oppressive regimes, code of conduct and political activity categories. It received a clear rating all other categories. (ref: 136)

Climate ChangeLinked with oil and arms in Angola (2002)In Spring 2002, campaign group Global Witness produced a publication ‘All the Presidents’ Men’ which provided details of links between oil and arms in Angola. Cabinda Trust featured and was described as “an oil trust” and “effectively a set of offshore accounts that have rights over a significant proportion of the oil generated from the Angolan Government’s share of production”. Global Witness reported that the Trust owned Block 0, that it was being run by Lloyds Bank and that repayments took priority over any other Angolan Government obligations arising from the Block. (ref: 92)Promoting high climate impact sector (2007)According to the company website www. lloydstsb.com, viewed by ECRA in September 2007, Lloyds TSB offered credit card accounts which allowed customers to accumulate air miles, which could then be exchanged for free flights. Aviation was considered by ECRA to be a sector which made major contributions to climate change emissions. (ref: 137)High climate impact sector loans (2007)According to the company profile on business information website Hoovers.com, viewed by ECRA in September 2007, Lloyds TSB group maintained an aircraft lending portfolio. Aviation was regarded by ECRA as a sector which made major contributions to climate change emissions. (ref: 138)

Pollution & Toxics(See also ‘Shareholdings in Johnson Matthey’ in Nuclear Power above.)Shareholdings in Balfour Beatty (2007)According to the Balfour Beatty factsheet on investment information website Hemscott.com, viewed by ECRA in August 2007, Lloyds TSB Group had shareholdings in Balfour Beatty, a company criticised under the ECRA categories: pollution & toxics, habitats & resources, workers’ rights. (ref: 123)Banking relationship with Cadbury Schweppes (February 2005)The Juniper business information database was viewed by ECRA on 9 February 2005, the website listed Lloyds TSB as the bankers to Cadbury Schweppes Plc. When Cadbury Schweppes was rated on ECRA’s Corporate Critic database in February 2005, it received ECRA’s bottom rating in the environmental reporting, animal testing, oppressive regimes and irresponsible marketing categories. It received ECRA’s middle rating in the pollution, other animal rights, workers rights, code of conduct and genetic engineering categories. It received ECRA’s top rating in all other categories. (ref: 139)

Habitats & Resources(See also ‘Shareholdings in Balfour Beatty’ in Pollution & Toxics above.)(See also ‘Banking relationship with Cadbury Schweppes’ in Pollution & Toxics above.)Banking relationship with Smith & Nephew Plc (January 2005)Hemscott www.hemscott.com was viewed by ECRA on 26 January 2005, the website listed Lloyds TSB Bank Plc as on of the bankers to Smith & Nephew Plc. When Smith & Nephew was rated on ECRA’s Corporate Critic database in January 2005, it received ECRA’s bottom rating in the code of conduct category and ECRA’s middle rating in the environmental reporting, environment other, animal testing, animal testing policy, oppressive regimes and alert categories. It received ECRA’s top rating in the remaining categories. (ref: 140)

AnimalsAnimal Testing(See also ‘Shareholdings in Johnson Matthey’ in Nuclear Power above.)(See also ‘Banking relationship with Cadbury Schweppes’ in Pollution & Toxics above.)Banking relationship with Shell Transport and Trading Co Plc (January 2005)Hemscott www.hemscott.com was viewed by ECRA on 26 January 2005, the website listed Lloyds TSB Bank Plc as the bankers to Shell Transport & Trading Plc. When Shell Transport & Trading was rated on ECRA’s Corporate Critic database in January 2005, it received ECRA’s bottom rating in the pollution, animal testing, oppressive regimes, workers rights, armaments, genetic engineering and political activity categories. It received ECRA’s middle rating in the environmental reporting category and received ECRA’s top rating in the remaining categories. (ref: 141)

Factory farmingBanking relationship with Associated British Foods (January 2005)Hemscott www.hemscott.com was viewed by ECRA on 26 January 2005, the website listed Lloyds TSB Bank Plc as one of the bankers to Associated British Foods Plc. When Associated British Foods was rated on ECRA’s Corporate Critic database in January 2005, it received ECRA’s bottom rating in the environmental reporting, animal testing, factory farming, other animal rights and genetic engineering. Associated British Foods received ECRA’s middle rating for oppressive regimes, boycott call and political activity categories. It received ECRA’s top rating in the remaining categories. (ref: 98)

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Other Animal Rights(See also ‘Banking relationship with Cadbury Schweppes’ in Pollution & Toxics above.)Banking relationship with Tate & Lyle Plc (January 2005)Hemscott www.hemscott.com was viewed by ECRA on 26 January 2005, the website listed Lloyds TSB Bank Plc as the bankers to Tate & Lyle Plc. When Tate & Lyle was rated on ECRA’s Corporate Critic database in January 2005, it received ECRA’s bottom rating in the animal testing category and ECRA’s middle rating in the environmental reporting, animal testing policy, other animal rights, oppressive regimes, workers rights, code of conduct and genetic engineering categories. It received ECRA’s top rating in the remaining categories. (ref: 142)(See also ‘Banking relationship with Associated British Foods’ in Factory farming above.)

PeopleHuman RightsOperations in two oppressive regimes (2007)According to the company factsheet on business website Hoovers.com, viewed by ECRA in September 2007, Lloyds TSB Group had operations in China and the USA, countries considered by ECRA in 2007 to have oppressive regimes. (ref: 138)(See also ‘Banking relationship with Cadbury Schweppes’ in Pollution & Toxics above.)(See also ‘Banking relationship with Smiths Group Plc’ in Nuclear Power above.)Workers’ Rights(See also ‘Shareholdings in Johnson Matthey’ in Nuclear Power above.)(See also ‘Shareholdings in Balfour Beatty’ in Pollution & Toxics above.)(See also ‘Banking relationship with Cadbury Schweppes’ in Pollution & Toxics above.)Supply Chain PolicyWorst ECRA rating for supply chain policy (2007)ECRA located Lloyds TSB’s Human Rights Policy on the company’s website (www.investorrelations.lloydstsb.com) on 16th March 2007. Although mention of suppliers was made as was reference to the International Labor Organization’s Fundamental Conventions, including freedom of association, the abolition of forced labour, equality and the elimination ofchild labour, ECRA did not consider this to amount to a formal supply chain policy, so gave Lloyds TSB a worst rating. (ref: 143)

Irresponsible Marketing(See also ‘Shareholdings in Johnson Matthey’ in Nuclear Power above.)Shareholdings in Imperial Tobacco plc (2007)According to the Imperial Tobacco factsheet on investment information website Hemscott.com, viewed by ECRA in August 2007, Lloyds TSB Group plc had shareholdings in Imperial Tobacco Group plc, a company which had been criticised for its sale of tobacco products. (ref: 128)(See also ‘Banking relationship with Cadbury Schweppes’ in Pollution & Toxics above.)ArmamentsShareholdings in Cobham (2007)According to the company factsheet on investment information website Hemscott.com, viewed by ECRA in August 2007, Lloyds TSB Group plc had shareholdings in Cobham, a company criticised by ECRA for its role in the manufacture and supply of armaments. (ref: 39)

Financing of companies involved in the production of cluster munitions (2007)According to the Bank Track website, viewed 26 June 2007, a report produced by Netwerk Vlaanderen - “Explosive Investments” (Feb 2007) - stated that Lloyds TSB was one of sixty-nine financial institutions involved in the financing of at least six companies involved in the production of cluster munitions during the period 2004-2007. Worldwide 98% of the victims of cluster munitions are civilians. (ref: 144)(See also ‘Banking relationship with Smiths Group Plc’ in Nuclear Power above.)

PoliticsGenetic Engineering(See also ‘Banking relationship with Cadbury Schweppes’ in Pollution & Toxics above.)(See also ‘Banking relationship with Shell Transport and Trading Co Plc’ in Animal Testing above.)(See also ‘Banking relationship with Tate & Lyle Plc’ in Other Animal Rights above.)Boycott Call(See also ‘Banking relationship with Associated British Foods’ in Factory farming above.)Political ActivitiesWTO lobbying (2006)According to the March 2006 edition of the Ecologist, British Telecom was a member of the European Services Forum (ESF). The report said ESF had privileged access to senior policy makers and the ‘133 Committee.’ This was said to be “a powerful but secretive body made up of European Commission (EC) officials and trade experts, which formulate[d] important EU polices for World Trade Organisation (WTO) negotiations.” The article discussed the access that multinational companies had to policymakers at the World Trade Organisation (WTO), claiming that the 742 external advisors to the US trade department had access to confidential WTO negotiating documents, and attended meetings with US trade negotiators. 93% of these were said to represent business lobby groups and corporations. The article alleged that the 17,000 lobbyists in Washington DC outnumbered lawmakers in US Congress and federal officials by 30 to one. It also said that corporations and lobby groups spent nearly $13 billion influencing Congress and federal officials from 1998-2004. The article claimed that tariff cuts brought about by trade liberalisation, had reduced Majority World countries’ income from import taxes by up to $60 billion per year. This was because cheap imports flooded Majority World countries markets, leaving farmers unable to sell their products and forcing local factories to shut down. (ref: 145)(See also ‘Banking relationship with Cadbury Schweppes’ in Pollution & Toxics above.)(See also ‘Banking relationship with Shell Transport and Trading Co Plc’ in Animal Testing above.)Anti-Social Finance(See also ‘WTO lobbying’ in Political Activities above.)Criticised by the Advertising Standards Agency (25 October 2006)According to the BBC’s Business News website viewed by ECRA on October 25 2006, the UK’s Advertising Standards Authority (ASA) ruled that Lloyds TSB bank’s promotional leaflet made to look like a hand-written note redirected by a neighbour to recommend the bank’s services, included a “ficticious recommendation (that) could mislead readers into believing it was from people known to them” (ASA). (ref: 146)Criticised for loans to customer suffering psychiatric disorder (August 2005)According to an article dated 1th August 2005 on the Guardian

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Unlimited website www.guardian.co.uk, Lloyds TSB bank had come in for criticism from consumer groups after it was said to have loaned a total of £70,000 to a man suffering from a psychiatric disorder who gave the money away to homeless people in the belief that he was a wealthy philanthropist. Consumer groups were quoted as saying that he had later been sectioned under the Mental Health Act, and although he had previously been earning a ‘decent’ wage he had not been a home owner and did not have collateral for the borrowings. (ref: 147)

Munchener Ruckversicherungs-Gesellschaft AktiongesellschaftKoniginstrasse 107, D-80802 Munich, Germany

EnvironmentEnvironmental ReportingBest ECRA rating for environmental reporting (2007)A search was made by ECRA in June 2007 on the company website www.munichre.com for a copy of the Munich Re environmental policy or report. The company was found to have published a number of environmental reports under the name ‘Perspectives,’ in an annual magazine format. The most recent of these was dated early 2006, and covered environmental progress at the company for the year 2005. This included a range of targets in areas including company office operations, development of Kyoto-compliant products and development of company policies. Progress against these targets was also given, as well as a range of information putting the company’s environmental progress into global context. The report was also verified by an environmental verifier from Agimus AG. (ref: 148)

Nuclear PowerShareholdings in companies criticised on ethical grounds (June 2007)According to the 30th June 2007 Securities & Exchange Commission 13f filing for MEAG New York Corp, the company held shares in a range of companies for which ECRA had found criticisms on ethical grounds, including the following:Anheuser-Busch: boycott call, irresponsible marketing, other animal rights, human rights, political activities, workers’ rights, pollution & toxics;Boeing: climate change, pollution & toxics, human rights, armaments, political activities, anti-social finance;Chevron: animal testing, boycott call, irresponsible marketing, human rights, political activities, workers’ rights, anti-social finance, climate change, pollution & toxics, habitats & resources;Exxon Mobil: armaments, boycott call, factory farming, other animal rights, human rights, political activities, workers’ rights, anti-social finance, climate change, pollution & toxics, habitats & resources;General Electric: armaments, animal testing, irresponsible marketing, nuclear power, human rights, workers’ rights, political activities, anti-social finance, climate change, pollution & toxics;Johnson & Johnson: animal testing, boycott call, irresponsible marketing, human rights, political activities, pollution & toxics;Pepsico: boycott call, factory farming, genetic engineering, irresponsible marketing, human rights, political activities, antisocial finance, pollution & toxics, habitats & resources. (ref: 149)

Climate Change(See also ‘Shareholdings in companies criticised on ethical grounds’ in Nuclear Power above.)Reinsurance services to sectors of concern (2007)According to the company website www.munichre.com, viewed by ECRA in June 2007, the company provided reinsurance services against risks including those associated with oil rigs and genetic engineering. Oil rigs were regarded by ECRA as being associated with the production of fossil fuels and therefore climate change, and both sectors were regarded by ECRA as being of concern due to their impacts on the environment and human health. (ref: 150)

Pollution & Toxics(See also ‘Shareholdings in companies criticised on ethical grounds’ in Nuclear Power above.)Habitats & Resources(See also ‘Shareholdings in companies criticised on ethical grounds’ in Nuclear Power above.)

AnimalsAnimal Testing(See also ‘Shareholdings in companies criticised on ethical grounds’ in Nuclear Power above.)Factory farming(See also ‘Shareholdings in companies criticised on ethical grounds’ in Nuclear Power above.)Other Animal Rights(See also ‘Shareholdings in companies criticised on ethical grounds’ in Nuclear Power above.)

PeopleHuman Rights(See also ‘Shareholdings in companies criticised on ethical grounds’ in Nuclear Power above.)Operations in one oppressive regime (2007)According to the Munich Re factsheet on business information website Hoovers.com, viewed by ECRA in June 2007, it had a subsidiary, American Re, in the USA. This was considered by ECRA in 2007 to have an oppressive regime. (ref: 151)Operations in four oppressive regimes (2006)According to the company’s annual report for 2006, in 2006 Munchener Ruckversicherungs- Gesellschaft had operations in the following countries regarded by ECRA as having oppressive regimes: China, Russia, the United Arab Emirates and the USA. (ref: 152)

Workers’ Rights(See also ‘Shareholdings in companies criticised on ethical grounds’ in Nuclear Power above.)Irresponsible Marketing(See also ‘Shareholdings in companies criticised on ethical grounds’ in Nuclear Power above.)Armaments(See also ‘Shareholdings in companies criticised on ethical grounds’ in Nuclear Power above.)

PoliticsGenetic Engineering(See also ‘Shareholdings in companies criticised on ethical grounds’ in Nuclear Power above.)(See also ‘Reinsurance services to sectors of concern’ in Climate Change above.)Boycott Call(See also ‘Shareholdings in companies criticised on ethical grounds’ in Nuclear Power above.)

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Anti-Social Finance(See also ‘Shareholdings in companies criticised on ethical grounds’ in Nuclear Power above.)Subsidiaries and operations in tax havens (2006)According to the company’s annual report for 2006, in 2006 Munchener Ruckversicherungs- Gesellschaft had a subsidiary in Luxembourg and branches in Hong Kong, Dubai and Singapore, all territories regarded by ECRA as tax havens. (ref: 152)

National Farmers Union Mutual Insurance Society LimitedTiddington Road, Stratford-Upon-Avon, Warwickshire, CV37 7BJ, UK

EnvironmentEnvironmental ReportingWorst ECRA rating for environmental reporting (2007)The National Farmers Union Mutual Insurance Society website www.nfumutual.co.uk was accessed on 4th September 2007, the website did not display an environmental policy or report. NFU Mutual’s Annual Report 2006, also displayed on the website contained a statement on corporate social responsibility. However this statement did not include quantified future targets for environmental impact reduction and neither did it amount to a reasonable discussion of the company’s impact on the environment. A written request for CSR information made by ECRA to NFU Mutual was not replied to. (ref: 153)

Climate ChangeShareholdings in companies criticised on ethical grounds (2007)According to the factsheet on NFU Mutual’s funds on investment information website Trustnet.com, as of 30th April 2007 NFU MUtual held shareholdings in a number of companies criticised under various ECRA categories. These included:- Royal Dutch Shell (armaments, animal testing, boycott call, human rights, political activities, workers’ rights, anti-social finance, climate change, pollution & toxics, habitats & resources)- Nestle (animal testing, boycott call, factory farming, genetic engineering, irresponsible marketing, other animal rights, human rights, political activities, workers’ rights, anti=social finance, pollution & toxics, habitats & resources-Sun Microsystems: armaments, human rights- GlaxoSmithkline: animal testing, boycott call, genetic engineering, irresponsible marketing, human rights, political activities, anti-social finance, pollution & toxics- Astrazeneca: pollution & toxics, animal testing, human rights, workers rights, irresponsible marketing, genetic engineering, political activities, anti-social finance- Tesco: animal testing, boycott call, factory farming, genetic engineering, other animal rights, human rights, political activities, workers’ rights, anti-social finance, climate change, pollution & toxics, habitats & resources (ref: 154)

Pollution & Toxics(See also ‘Shareholdings in companies criticised on ethical grounds’ in Climate Change above.)Habitats & Resources(See also ‘Shareholdings in companies criticised on ethical grounds’ in Climate Change above.)

AnimalsAnimal Testing(See also ‘Shareholdings in companies criticised on ethical grounds’ in Climate Change above.)Factory farming(See also ‘Shareholdings in companies criticised on ethical grounds’ in Climate Change above.)Other Animal Rights(See also ‘Shareholdings in companies criticised on ethical grounds’ in Climate Change above.)Support for bloodsports (2007)According to the NFU Mutual website www.nfumutual.co.uk, viewed by ECRA in September 2007, NFU MUtual offered specialist insurance provision covering bloodsports events such as shooting and fishing. (ref: 153)

PeopleHuman Rights(See also ‘Shareholdings in companies criticised on ethical grounds’ in Climate Change above.)Workers’ Rights(See also ‘Shareholdings in companies criticised on ethical grounds’ in Climate Change above.)Irresponsible Marketing(See also ‘Shareholdings in companies criticised on ethical grounds’ in Climate Change above.)Armaments(See also ‘Shareholdings in companies criticised on ethical grounds’ in Climate Change above.)

PoliticsGenetic Engineering(See also ‘Shareholdings in companies criticised on ethical grounds’ in Climate Change above.)Boycott Call(See also ‘Shareholdings in companies criticised on ethical grounds’ in Climate Change above.)Political Activities(See also ‘Shareholdings in companies criticised on ethical grounds’ in Climate Change above.)Anti-Social Finance(See also ‘Shareholdings in companies criticised on ethical grounds’ in Climate Change above.)Subsidiaries in tax havens (2004)The National Farmers Union Mutual Insurance Company Annual Report 2004 listed wholly-owned subsidiaries in Jersey and Guernsey, countries considered to be tax havens by ECRA at the time of the report. (ref: 155)

Company EthosMutual company status (2007)According to the company website www.nfumutual.co.uk, viewed by ECRA in September 2007, NFU Mutual was a mutual insurance society. (ref: 153)

Naturesave Policies Ltd58 Fore Street, Totnes, Devon, TQ9 5RU, UK

EnvironmentEnvironmental ReportingMiddle ECRA rating for environmental reporting (2007)A search was made by ECRA in June 2007 on the Naturesave company website www.naturesave.co.uk for the company’s environmental policy or report. The website was found to contain

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a range of environmental information, including the statement that the company’s office used recycled materials, sourced its energy from ‘green’ and ethical suppliers and used sustainable transport ‘wherever possible.’ It offered business customers a free Environmental Performance Review of their premises and operations in order to assess and improve their impacts in terms of energy, waste and resource use. It also offered discounts to domestic customers for environmental features such as renewable energy generation, water butts and energy efficiency measures. A percentage of company profits were also put into a fund which was used to support environmental programmes and enterprises. (ref: 156)

PoliticsCompany EthosEnvironmental insurance company (2007)According to the company’s website, www.naturesave.co.uk, viewed by ECRA in June 2007, Naturesave was “an ethical insurance intermediary offering personal and commercial insurance policies.” It stated that it aimed “to encourage the adoption of more environmentally aware trading practices in the business community, by using the insurance industry as a vehicle for sustainable development.” It offered business customers a free Environmental Performance Review of their premises and operations in order to assess and improve their impacts in terms of energy, waste and resource use. It also offered discounts to domestic customers for environmental features such as renewable energy generation, water butts and energy efficiency measures. A percentage of company profits were also put into a fund which was used to support environmental programmes and enterprises. (ref: 156)

Prudential plc5 Laurence Pountney Hill, London, EC4R 0HH

EnvironmentEnvironmental ReportingWorst ECRA rating for environment report (2007)A search was made by ECRA in August 2007 on the company websites www.prudential.co.uk and www.pru.co.uk for a copy of the Prudential environmental policy or report. The company’s 2006/7 Corporate Responsibility Report was found to contain environmental data, but this was not found to include any meaningful fixed or measurable targets for future environmental improvements, and did not appear to have been independently monitored or verified. Although the report showed understanding of the direct environmental impacts of the company, such as energy usage for company offices, it showed no acknowledgement of the impact of the company’s financial activities aside from those specifically within sustainable investment or sustainable property funds. (ref: 157)

Nuclear PowerShareholdings in Johnson Matthey (2007)According to the Johnson Matthey factsheet on investment information website Hemscott.com, viewed by ECRA in August 2007, Johnson Matthey had shareholdings in Johnson Matthey, a company criticised under the ECRA categories: Irresponsible Marketing, Nuclear Power, Workers’ Rights, Pollution & Toxics and Animal Testing. (ref: 31)

Climate ChangeShareholdings in Tullow Oil plc (2007)According to the Tullow Oil factsheet on investment information website Hemscott.com, viewed by ECRA in August 2007, Prudential plc had shareholdings in Tullow Oil plc, a fossil fuels exploration company. The oil and gas sector was one regarded

as making substantial contributions to climate change emissions. (ref: 158)Poor rating in climate change survey (2006)According to an article from the Independent newspaper, dated 18th September 2006, Prudential was one of a number of large companies which had been criticised by the Carbon Disclosure Project for scoring ‘below average’ marks in terms of their commitments and plans to tackle climate change. (ref: 159)

Pollution & ToxicsShareholdings in Hanson plc (2007)According to the Hanson plc 2006/7 Annual Report, in 2007 Prudential plc had shareholdings in Hanson, a company criticised by ECRA in the categories Workers’ Rights and Pollution & Toxics. (ref: 121)(See also ‘Shareholdings in Johnson Matthey’ in Nuclear Power above.)Shareholdings in Balfour Beatty (2007)According to the Balfour Beatty factsheet on investment information website Hemscott.com, viewed by ECRA in August 2007, Prudential Group had shareholdings in Balfour Beatty, a company criticised under the ECRA categories: pollution & toxics, habitats & resources, workers’ rights, anti-social finance. (ref: 123)

Habitats & Resources(See also ‘Shareholdings in Johnson Matthey’ in Nuclear Power above.)(See also ‘Shareholdings in Balfour Beatty’ in Pollution & Toxics above.)

AnimalsAnimal Testing(See also ‘Shareholdings in Johnson Matthey’ in Nuclear Power above.)Factory farmingInvestment relationship with Greggs Plc (2004)Greggs Plc Annual Report & Accounts 2003 stated that Prudential Plc owned 4.23% of Greggs Plc. When Greggs was last reviewed in Ethical Consumer Issue 92 January/February 2005, Greggs received worst ECRA ratings for criticisms in environment reporting, factory farming and code of conduct for workers rights categories and a middle ECRA rating for criticisms relating to pollution. Greggs Plc received a clear ECRA rating in all other categories. (ref: 35)

PeopleHuman RightsSubsidiaries in tax havens and an oppressive regime (2007)According to the company website www.prudential.co.uk, viewed by ECRA in August 2007, in 2007 Prudential had affiliate or subsidiary companies in Hong Kong and Singapore, territories regarded by ECRA as tax havens, and Vietnam, a country regarded at the time as having an oppressive regime. (ref: 160)Subsidiaries in oppressive regimes (2007)According to the company factsheet on business website Hoovers.com, viewed by ECRA in August 2007, Prudential had annuity and life insurance operations in the USA and a major expansion plan in China, both countries regarded by ECRA as having oppressive regimes. (ref: 161)

Workers’ Rights(See also ‘Shareholdings in Hanson plc’ in Pollution & Toxics above.)(See also ‘Shareholdings in Johnson Matthey’ in Nuclear Power above.)(See also ‘Shareholdings in Balfour Beatty’ in Pollution & Toxics above.)

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Irresponsible Marketing(See also ‘Shareholdings in Johnson Matthey’ in Nuclear Power above.)

PoliticsPolitical ActivitiesMember of European Services Forum (2007)According to the Members’ Biographies section of the European Services Forum website, www.esf.be, viewed by ECRA in January 2007, Prudential was a member of the organisation. The ESF was regarded by ECRA as an international corporate lobby group which exerted the power of commercial interests in a way seen as potentially detrimental to wider society and the environment. (ref: 49)

Anti-Social Finance(See also ‘Subsidiaries in tax havens and an oppressive regime’ in Human Rights above.)Offering financial services in a tax haven (2007)According to the company’s factsheet on business website Hoovers.com, viewed by ECRA in August 2007, Prudential had an asset management and pension joint venture in Hong Kong, a territory regarded by ECRA as a tax haven. (ref: 161)(See also ‘Shareholdings in Balfour Beatty’ in Pollution & Toxics above.)

Royal & Sun Alliance Insurance Group PlcOne Plantation Place, 30 Fenchurch St, London, EC3M 3BD, UK

EnvironmentEnvironmental ReportingBest rating for environmental reporting (2007)A search was made by ECRA in summer 2007 for a copy of the Royal & Sun Alliance environmental policy or report, on company websites. The company’s 2006 Corporate Responsibility Report was found to contain environmental information, including a range of measurable targets for the following year in areas such as recycling, energy use and waste production, set against comparative data for previous years. The report also acknowledged the company’s impacts via its investments, and included an assurance statement from The SMART Company. (ref: 162)

Nuclear PowerInvestments in companies criticised on ethical grounds (June 2007)In response to a request for information from ECRA in summer 2007, Royal & Sun stated that it did not hold shares directly but outsourced its asset management to F&C Asset Management. F&C’s major funds included shareholdings in a range of companies criticised in various EC categories, including at June 30th 2007:- Total SA (Climate change, pollution & toxics, habitats & resources, human rights, irresponsible marketing, boycott call, political activities, anti-social finance);- Roche Holdings AG (animal testing, other animal rights, human rights, irresponsible marketing, political activities);- Siemens AG (nuclear power, climate change, human rights, workers rights, armaments, political activities, anti-social finance); (ref: 163)Provision of services to sectors of concern (2007)According to the company information page on business website Hemscott.com, viewed by ECRA in August 2007, Royal & Sun Alliance Insurance Group participated in insurance pools which

offered services to the nuclear industry and to the aviation and oil and gas industries, which were considered by ECRA to have high climate change emissions impacts. (ref: 164)

Climate Change(See also ‘Investments in companies criticised on ethical grounds’ in Nuclear Power above.)(See also ‘Provision of services to sectors of concern’ in Nuclear Power above.)Pollution & Toxics(See also ‘Investments in companies criticised on ethical grounds’ in Nuclear Power above.)Habitats & Resources(See also ‘Investments in companies criticised on ethical grounds’ in Nuclear Power above.)

AnimalsAnimal Testing(See also ‘Investments in companies criticised on ethical grounds’ in Nuclear Power above.)Factory farmingService provision to the factory farming industry (2007)According to the company business services website www.royalsunconnect.co.uk, viewed by ECRA in August 2007, Royal & Sun provided insurance services specifically tailored to the fish farming industry. (ref: 165)

Other Animal Rights(See also ‘Investments in companies criticised on ethical grounds’ in Nuclear Power above.)

PeopleHuman Rights(See also ‘Investments in companies criticised on ethical grounds’ in Nuclear Power above.)Operations in oppressive regimes (2007)According to the company website www.royalsunalliance.com, viewed by ECRA in June 2007, in 2007 Royal & Sun Alliance had operations in the following countries regarded by ECRA as having oppressive regimes: the United Arab Emirates, China, Egypt. (ref: 166)Operations in oppressive regimes and tax havens (2007)According to the company factsheet on business website Hoovers.com, viewed by ECRA in August 2007, Royal & Sun Alliance had subsidiaries in Vietnam, China, Saudi Arabia, the USA and Thailand, countries regarded by ECRA in 2007 as having oppressive regimes. It also had subsidiaries in the Channel Islands, the Netherlands Antilles, Hong Kong, Uruguay and Singapore, all territories regarded by ECRA as tax havens. (ref: 167)

Workers’ Rights(See also ‘Investments in companies criticised on ethical grounds’ in Nuclear Power above.)Irresponsible Marketing(See also ‘Investments in companies criticised on ethical grounds’ in Nuclear Power above.)Armaments(See also ‘Investments in companies criticised on ethical grounds’ in Nuclear Power above.)

PoliticsBoycott Call(See also ‘Investments in companies criticised on ethical grounds’ in Nuclear Power above.)Political Activities(See also ‘Investments in companies criticised on ethical grounds’ in Nuclear Power above.)

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Anti-Social Finance(See also ‘Investments in companies criticised on ethical grounds’ in Nuclear Power above.)(See also ‘Operations in oppressive regimes and tax havens’ in Human Rights above.)Excessive director’s pay (2006)According to the company’s annual report for 2006, in the year ending 31st December 2006 one director of Royal & Sun Alliance was paid a sum of over £1 million, an amount deemed by ECRA to be excessive. (ref: 168)

Royal Bank of Scotland Group plc42 St Andrews Square, Edinburgh, EH2 2YE

EnvironmentEnvironmental ReportingBest ECRA rating for environmental reporting (2007)A search was made by ECRA in August 2007 on the company website www.rbs.com for a copy of the Royal Bank of Scotland environmental policy or report. The company’s 2006 Corporate Responsibility report was found to include environmental data, including future targets for reduction of energy use and waste and implementation of the Equator Principles. However, the report made little mention of the impact of the company’s investments and financial activities, for which it had been extensively criticised by environmental campaign groups focusing on its investments in and provision of services to oil and gas activities. The report was found to be independently verified by Deloitte. (ref: 169)Poor pension fund transparency (2006)According to the December 2006 issue of ENDS Report, Royal Bank of Scotland was one of the worst performers in a survey by Fairpensions of major UK pension funds on their environmental and social transparency and disclosure of policies. (ref: 170)

Nuclear PowerBanking relationship with Old Mutual Plc (January 2005)Hemscott www.hemscott.com was viewed by ECRA on 26 January 2005, the website listed National Westminster Bank Plc as one of the bankers to Old Mutual Plc. When Old Mutual was rated by ECRA’s Corporate Critic database in January 2005, it received ECRA’s bottom rating for environmental reporting and it received ECRA’s middle rating in the pollution, nuclear power, animal testing, factory farming, oppressive regimes, workers rights, irresponsible marketing, armaments, genetic engineering, boycott call and political activity categories. It received a clear rating all other categories. (ref: 171)Banking relationship with United Utilities plc (January 2005)Hemscott www.hemscott.com was viewed by ECRA on 26 January 2005, the website listed National Westminster Bank Plc as the bankers to United Utilities Plc. When United Utilities was rated on ECRA’s Corporate Critic database in January 2005, it received ECRA’s bottom rating in the pollution category and ECRA’s middle rating in the nuclear power, oppressive regimes and workers rights categories. It received ECRA’s top rating in the remaining categories. (ref: 172)Banking relationship with Johnson Matthey Plc (January 2005)Hemscott www.hemscott.com was viewed by ECRA on 26 January 2005, the website listed National Westminster Bank Plc as one of the bankers to Johnson Matthey Plc. When Johnson Matthey was rated by ECRA’s Corporate Critic database in January 2005, it received ECRA’s bottom rating in the environmental reporting, nuclear power and animal testing categories. It received a middle rating in the oppressive regimes, code of conduct and political activity categories. It received a clear rating all other categories. (ref: 136)

Climate ChangeHigh climate impact sector (2004)The 3i Group website www.3i.com viewed by ECRA Publishing on 2 March 2004 stated that the company operated in the oil and gas sector, a high climate impact sector. (ref: 173)High climate impact sector (2007)According to the UKI Partnerships website www.ukipartnerships.com, viewed by ECRA in August 2007, UKI Partnerships claimed to be a leading provider of motor insurance, car fleet insurance and motor assistance products. Cars and motoring were considered by ECRA to be a sector which caused major contributions to climate change emissions. (ref: 174)Poor rating in climate change survey (2007)According to an article from the Independent newspaper, dated 18th September 2006, Royal Bank of Scotland Group was one of a number of large companies which had been criticised by the Carbon Disclosure Project for scoring ‘below average’ marks in terms of their commitments and plans to tackle climate change. (ref: 159)

Pollution & ToxicsBanking relationship with Unilever Plc (February 2005)The Juniper business information database was viewed by ECRA on 9 February 2005, the website listed NatWest Bank Plc as the bankers to Unilever Plc. When Unilever was rated on ECRA’s Corporate Critic database in February 2005, it received ECRA’s bottom rating in the pollution, environment other, animal testing, factory farming, oppressive regimes, workers rights, irresponsible marketing, genetic engineering and political activity categories. It received ECRA’s middle rating in the environmental reporting, animal testing policy, other animal rights, code of conduct, boycott call and alert categories. It received ECRA’s top rating in all other categories. (ref: 139)Banking relationship with Imperial Chemical Industries Plc (February 2005)The Juniper business information database was viewed by ECRA on 9 February 2005, the website listed NatWest Bank as the bankers to Imperial Chemical Industries Plc. When Imperial Chemical Industries was rated on ECRA’s Corporate Critic database in February 2005, it received ECRA’s bottom rating in the pollution, environment other, oppressive regimes and genetic engineering categories. It received ECRA’s middle rating in the environmental reporting, animal testing, armaments, political activity and alert categories. It received ECRA’s top rating in all other categories. (ref: 139)Banking relationship with Carnival Plc (February 2005)The Juniper business information database was viewed by ECRA on 9 February 2005, the website listed Royal Bank of Scotland as the bankers to Carnival Plc. When Carnival was rated on ECRA’s Corporate Critic database in February 2005, it received ECRA’s bottom rating in the environmental reporting and workers rights categories and middle rating in the pollution, environment other, oppressive regimes and alert categories. It received ECRA’s top rating in all other categories. (ref: 175)

Habitats & ResourcesPoor rating in survey of banking policies (2006)According to a Banktrack/WWF report on social and environmental policies amongst international banks, the Royal Bank of Scotland had a poor accumulated score for its policies, at just 0.54 out of a possible 5, amounting to a D- grade. The bank was said to have policies on just five out of thirteen categories, in this case labour, indigenous peoples, dams, transparency and environmental & social management. Issues such as human rights, agriculture, forests and fisheries were not covered. Like most other banks, RBS was also said to have few systems in place for ensuring that the policies that were in place were implemented. (ref: 12)

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(See also ‘Banking relationship with Imperial Chemical Industries Plc’ in Pollution & Toxics above.)(See also ‘Banking relationship with Unilever Plc’ in Pollution & Toxics above.)Banking relationship with Compass Group Plc (February 2005)The Juniper business information database was viewed by ECRA on 9 February 2005, the website listed NatWest Bank as the bankers to Compass Group Plc. When Compass Group was rated on ECRA’s Corporate Critic database in February 2005, it received ECRA’s bottom rating in the environmental reporting, factory farming, oppressive regimes and code of conduct categories. It received ECRA’s middle rating in the workers rights category. It received ECRA’s top rating in all other categories. (ref: 175)

AnimalsAnimal Testing(See also ‘Banking relationship with Unilever Plc’ in Pollution & Toxics above.)(See also ‘Banking relationship with Imperial Chemical Industries Plc’ in Pollution & Toxics above.)Banking relationship with Alliance UniChem Plc (February 2005)The Juniper business information database was viewed by ECRA on 9 February 2005, the website listed Nat West Bank as the bankers to Alliance UniChem Plc. When Alliance UniChem was rated on ECRA’s Corporate Critic database in February 2005, it received ECRA’s bottom rating in the environmental reporting category and middle rating in the animal testing and oppressive regimes categories. It received ECRA’s top rating in all other categories. (ref: 139)

Factory farming(See also ‘Banking relationship with Unilever Plc’ in Pollution & Toxics above.)(See also ‘Banking relationship with Compass Group Plc’ in Habitats & Resources above.)Banking relationship with Boots Group Plc (January 2005)Hemscott www.hemscott.com was viewed by ECRA on 26 January 2005, the website listed National Westminster Bank Plc as the bankers to Boots Group Plc. When Boots Group was rated on ECRA’s Corporate Critic database in January 2005 it received ECRA’s bottom rating for animal testing, other animal rights and irresponsible marketing. It received ECRA’s middle rating for environmental reporting, animal testing, factory farming, oppressive regimes and genetic engineering categories. It received ECRA’s top rating in the remaining categories. (ref: 176)Banking relationship with Aviva Plc (January 2005)Hemscott www.hemscott.com was viewed by ECRA on 26 January 2005, the website listed National Westminster Bank Plc as the banker to Aviva Plc. When Aviva was rated on ECRA’s Corporate Critic database in January 2005, it received ECRA’s bottom rating in the oppressive regime category and ECRA’s middle rating in the environmental reporting, pollution, factory farming and genetic engineering categories. It received ECRA’s top rating in the remaining categories. (ref: 177)

Other Animal Rights(See also ‘Banking relationship with Unilever Plc’ in Pollution & Toxics above.)Banking relationship with Next Plc (January 2005)Hemscott www.hemscott.com was viewed by ECRA on 26 January 2005, the website listed National Westminster Bank Plc as one of the bankers to Next Plc. When Next was rated by ECRA’s Corporate Critic database in January 2005, it received ECRA’s bottom rating for environmental reporting and other animal rights. It received ECRA’s middle rating in the oppressive regimes and code of conduct categories. It received a clear rating all other categories. (ref: 178)

(See also ‘Banking relationship with Boots Group Plc’ in Factory farming above.)

PeopleHuman RightsLegal action over support of apartheid in South Africa (2003)The December 2005 report from the Corporate Responsibility Coalition, A Big Deal? Corporate Social Responsibility and the Finance Sector in Europe stated that in 2003 NatWest was one of a number of banks that faced a claim in the US, under the Alien Tort Claims Act (ATCA), for $100billion in damages for its “role in supporting apartheid in South Africa”. (ref: 179)New venture in oppressive regime (2007)According to a story on the BBC news website news.bbc.co.uk, dated 20th March 2007, in March 2007 RBS had announced that it was engaging in a joint venture with the Bank of China, aimed at promoting premium private banking at “the growing ranks of China’s super-rich.” China was regarded by ECRA at the time as having an oppressive regime. (ref: 180)(See also ‘Poor rating in survey of banking policies’ in Habitats & Resources above.)Workers’ Rights(See also ‘Banking relationship with Unilever Plc’ in Pollution & Toxics above.)(See also ‘Banking relationship with Compass Group Plc’ in Habitats & Resources above.)(See also ‘Banking relationship with Carnival Plc’ in Pollution & Toxics above.)Irresponsible Marketing(See also ‘Banking relationship with Unilever Plc’ in Pollution & Toxics above.)Banking relationship with Imperial Tobacco Group Plc (February 2005)The Juniper business information database was viewed by ECRA on 9 February 2005, the website listed NatWest Bank as the bankers to Imperial Tobacco Group Plc. When Imperial Tobacco was rated on ECRA’s Corporate Critic database in February 2005, it received ECRA’s bottom rating in the irresponsible marketing category and middle rating in the environmental reporting, oppressive regimes, code of conduct and alert categories. It received ECRA’s top rating in all other categories. (ref: 139)Banking relationship with Diageo (January 2005)Hemscott www.hemscott.com was viewed by ECRA on 26 January 2005, the website listed National Westminster Bank Plc as one of the bankers to Diageo Plc. When Diageo was rated by ECRA’s Corporate Critic database in January 2005, it received ECRA’s middle rating in the environmental reporting, pollution, animal testing, oppressive regimes, irresponsible marketing, genetic engineering and political activity categories. It received a clear rating all other categories. (ref: 181)

ArmamentsFinancing of companies involved in the production of cluster munitions (2007)According to the Bank Track website, viewed 26 June 2007, a report produced by Netwerk Vlaanderen - “Explosive Investments” (Feb 2007) - stated that RBS was one of sixty-nine financial institutions involved in the financing of at least six companies involved in the production of cluster munitions during the period 2004-2007. Worldwide, 98% of the victims of cluster munitions are civilians. (ref: 144)(See also ‘Banking relationship with Imperial Chemical Industries Plc’ in Pollution & Toxics above.)Banking relationship with BP (January 2005)Hemscott www.hemscott.com was viewed by ECRA on 26 January

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2005. The website listed National Westminster Bank Plc as one of the bankers to BP Plc. When BP was rated on ECRA’s Corporate Critic database in January 2005, it received ECRA’s bottom rating in the pollution, animal testing, oppressive regimes, workers rights and political activity categories. It received ECRA’s middle rating in the environmental reporting, irresponsible marketing, armaments and boycott call categories. It received ECRA’s top rating in all other categories. (ref: 182)

PoliticsGenetic Engineering(See also ‘Banking relationship with Unilever Plc’ in Pollution & Toxics above.)(See also ‘Banking relationship with Imperial Chemical Industries Plc’ in Pollution & Toxics above.)(See also ‘Banking relationship with Diageo’ in Irresponsible Marketing above.)Boycott Call(See also ‘Banking relationship with Unilever Plc’ in Pollution & Toxics above.)Banking relationship with GlaxoSmithKline Plc (January 2005)Hemscott www.hemscott.com was viewed by ECRA on 26 January 2005, the website listed National Westminster Bank Plc as one of the bankers to GlaxoSmithKline Plc. When GlaxoSmithKline was rated by ECRA’s Corporate Critic database in January 2005, it received ECRA’s bottom rating in the animal testing, oppressive regimes, irresponsible marketing, genetic engineering, boycott call and political activity categories. It received ECRA’s middle rating in the environmental reporting, pollution, environment other, code of conduct and alert categories. It received a clear rating all other categories. (ref: 183)(See also ‘Banking relationship with Old Mutual Plc’ in Nuclear Power above.)Political ActivitiesMembership of ICC lobby group (2007)The website of the International Chamber of Commerce (www.iccwbo.org), viewed on 16th May 2007, listed National Westminster Bank as a member. According to the ICC, it had “direct access to national governments all over the world through its national committees”; “speaks for world business when governments take up such issues as intellectual property rights, transport policy, trade law or the environment”; “At UN summits on sustainable development, financing for development and the information society, ICC spearheads the business contribution.” ECRA noted that the activity of lobby groups such as the ICC often meant that business interests were protected at the expense of the environmental and human rights. (ref: 184)Member of European Services Forum (2007)According to the Members’ Biographies section of the European Services Forum website, www.esf.be, viewed by ECRA in January 2007, Royal Bank of Scotland was a member of the organisation. The ESF was regarded by ECRA as an international corporate lobby group which exerted the power of commercial interests in a way seen as potentially detrimental to wider society and the environment. (ref: 49)Membership of Financial Leaders Group (FLG) (2006)According to a 2006 report by the Seattle to Brussels Network, called ‘Corporate Power Over EU Trade Policy: Good for business, bad for the world’, the Financial Leaders Group (FLG), was a “very high-level lobby group”, with the world’s largest banks and insurance companies as its members, including Royal Bank of Scotland. Examples of its lobbying for the liberalisation of financial services were its two major World Trade Organisation ‘seminars’ in 2001 and 2005, with representatives from its member groups as speakers and the GATS negotiators from several developing countries as audience. (ref: 185)

Anti-Social FinanceSettlement in Enron case over fraud allegations (17 August 2005)According to the article “JP Morgan pays $1bn to settle Enron claim”, published in the Guardian on 17 August 2005, the Royal Bank of Scotland had agreed to pay $41.8m to settle claims brought against it by Enron, accusing the bank of helping the energy company’s former management to commit fraud. Royal Bank of Scotland was one of ten banks that Enron had filed suit against. (ref: 186)Financing Indian power projects (2002)According to a 2002 report on financing in the Indian power industry, Natwest was one of a number of international banks to have been involved in lending to India’s power sector. Many Indian power projects were said to have been criticised for their environmental impacts, for forced displacement of people living in their areas, and for incidents of bribery and corruption. (ref: 187)Subsidiaries in seven tax havens (January 2006)According to the Coutts Group website www.coutts.com viewed on 16 January 2006, the company had subsidiary operations in Cayman, Dubai, Hong Kong, Isle of Man, Jersey, Monaco and Singapore. These countries were considered to be tax havens by ECRA at the time of writing. (ref: 188)

Zurich Financial ServicesMythenquai 2, 8022 Zurich, Switzerland

EnvironmentEnvironmental Reportingworst ECRA rating for environmental reporting (2007)A search was made by ECRA in June 2007 on the company website www.zurich.com for a copy of the Zurich Financial Services environmental policy or report. No separate report was found. The company’s annual report for 2006 contained a few pages of CSR information, mainly talking about corporate philanthropy, and covering some reductions in CO2 emissions and resource use by the company and specific examples such as the switch of 24% of Zurich Australia’s power to biomass energy. There was no apparent appreciation of the company’s wider impacts, caused by its broader operations and investments rather than the fairly small direct impacts of a financial services company. There were also no future measurable targets for improvements in environmental performance. Information about environmental performance on the company website was also minimal. There was no indication that the company’s environmental reporting or management was independently monitored or verified. (ref: 189)2002 environmental report (2002)Zurich’s website was accessed in November 2002. It contained details about its Environmental Policy. Targets included annual 1% energy reductions up to 2010 at 41 sites and a 20% CO2 reduction from gas and electricity from 1999 to 2004. However, it did not appear to be independently verified. (ref: 190)

Nuclear PowerNuclear industry services (2007)According to the 2007 edition of the World Nuclear Industry Handbook, Zurich Risk Services provided the following services to the nuclear industry: analysis, stress inspection and audit, insurance, steam generator inspection. (ref: 191)

Climate ChangeShareholdings in AMEC (2007)According to the AMEC company factsheet on the Yahoo! Finance website http://uk.finance.yahoo.com, viewed by ECRA in August 2007, Zurich Financial Services had shareholdings in AMEC, a company criticised by ECRA in the following categories: Workers’ Rights, Climate Change, Habitats & Resources. (ref: 33)

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Pollution & ToxicsShareholdings in Hanson (2007)According to the Hanson plc 2006/7 Annual Report, in 2007 Zurich Financial Services had shareholdings in Hanson, a company criticised by ECRA in the categories Workers’ Rights and Pollution & Toxics. (ref: 121)

Habitats & Resources(See also ‘Shareholdings in AMEC’ in Climate Change above.)

PeopleHuman RightsOperations in tax havens and oppressive regimes (2007)According to the factsheet for Zurich Financial Services on the business information website Hoovers.com, viewed by ECRA in June 2007, Zurich Financial Services had several subsidiaries each in Bermuda and Jersey and one in Hong Kong, territories regarded by ECRA as being tax havens, and expanding operations in China and the USA, countries regarded by ECRA as having an oppressive regime. (ref: 192)Operations in oppressive regimes and tax havens (2006)According to the company’s Annual Report and Financial Review for 2006, viewed by ECRA in June 2007, Zurich Financial had operations in China, Russia and the USA, all regarded by ECRA as having oppressive regimes. It also had operations and/or subsidiaries in Bermuda, Ireland and the Isle of Man, territories regarded as tax havens. (ref: 189)operations in seven oppressive regimes (November 2004)According to Zurich Financial’s corporate website in November 2004, the company had operations in the following countries regarded by ECRA as oppressive regimes: Brazil, China, Indonesia, Lebanon, Mexico, Russia and Thailand. (ref: 193)

Workers’ Rights(See also ‘Shareholdings in Hanson’ in Pollution & Toxics above.)(See also ‘Shareholdings in AMEC’ in Climate Change above.)

PoliticsPolitical ActivitiesUS political donations (2006)According to the Insurance Industry Top Donors table on the Open Secrets website, www.opensecrets.org, covering the 2006 US election cycle, Zurich Financial Services had donated a total of $489,085, of which 81% went to the Republican Party and 18% to the Democrats. (ref: 24)Member of World Economic Forum (2007)According to the organisation’s website www.weforum.org, viewed by ECRA in January 2007, Zurich Financial Services was a member of the World Economic Forum. This was considered by ECRA to be a high level corporate lobby group which exerted undue corporate influence, to the potential detriment of the environment and human and animal rights. (ref: 194)Member of one international lobby group (2002)Zurich Financial Services Group was listed as a member of the free trade lobby group World Business Council for Sustainable Development on the WBCSD website (http://www.wbcsd.org/aboutus/members.htm), viewed by ECRA on 17th September 2002. (ref: 195)

Anti-Social Finance(See also ‘Operations in tax havens and oppressive regimes’ in Human Rights above.)(See also ‘Operations in oppressive regimes and tax havens’ in Human Rights above.)High directors’ pay (2006)

According to the company annual review for 2006, for the financial year 2006 Zurich Financial Services paid 10 members of its board totals of more than US$1,600,000, of whom four were paid over US$3,000,000. These were judged by ECRA to be excessive sums. (ref: 189)

References1-AdmiralGroupCorporateCommunications:2006Annual

Report(3September2007)(511273)2 - FTSE4Good Index Series Company Engagement

ProgrammeReport:March2007FTSE4Goodcompaniesreview(9March2007)(504262)

3 - Allchurches Trust Ltd Corporate Communications:www.ecclesiastical.com(3September2007)(511442)

4 - Allchurches Trust Ltd Corporate Communications:AllchurchesInvestmentFundsannualreport2006(2007)(511432)

5 - Allchurches Trust Ltd Corporate Communications:Annual Report2006(2007)(511423)

6-AllianzSECorporateCommunications:StatusReport2006:SustainabilityintheAllianzGroup(July2006)(510669)

7-HermesCorporateCommunications:www.agaportal.de(6June2006)(292204)

� - Hemscott (www.hemscott.com):Dana Petroleum factsheet (August2007)(509357)

9 - Hemscott (www.hemscott.com):PetroLatina Energy plc (August2007)(509214)

10-AllianzSECorporateCommunications:www.allianz.com(6June2006)(292160)

11-HooversOnlinewww.hoovers.com:AllianzAGfactsheet(6June2006)(292016)

12 - Shaping the Future of Sustainable Finance:Shaping the FutureofSustainableFinance(January2006)(283167)

13-AllianzSECorporateCommunications:www.allianz.com(June2007)(510653)

14 - Hemscott (www.hemscott.com):Gallaher Group Plc Advisers(26January2005)(247169)

15 - MSNBC.com:US case settled by Dresdner Kleinwort (19 May2007)(503472)

16-CorporateWatchnewsletter:Issue35(June2007)(507658)17-ProfitingfromPoverty:privatisationconsultants,DFID

andpublicservices:ProfitingfromPoverty:Privatisationconsultants,DFID&publicservices(September2004)(283055)

18-AllianzSECorporateCommunications:AnnualReport2006(2007)(511246)

19 - American International Group (AIG) Inc Corporate Communications:CorporateResponsibilityReport2007(April2007)(509498)

20-EthicalPerformance:Volume9Issue2(June2007)(508081)

21 - American International Group (AIG) Inc Corporate Communications:SECFilingForm13F(10August2007)(509381)

22 - American International Group (AIG) Inc Corporate Communications:AnnualReport2006(2007)(509429)

23 - American International Group (AIG) Inc Corporate Communications:www.aig.com(August2007)(509503)

24 - Open secrets website:Insurance companies top donors table(5June2007)(503494)

25-ExecutiveExcess2004:campaigncontributions,outsourcing,unexpensedstockoptionsandrisingCEO:25October2004(236435)

26-USCIBMembersListwww.uscib.org:www.uscib.org(20July2007)(506784)

27-BBCNewsWebsitewww.bbc.co.uk:InsurerAIGin$1.6bnsettlement(20February2006)(284506)

28-MultinationalMonitor:Vol26no9&10(Sept/Oct2005)(September2005)(281735)

29-CorporateFocusOnlineNewsletter:24January2005(250819)

30-AvivaPlcCorporateCommunications:CSRReport2007(2007)(509618)

2�

31-Hemscott(www.hemscott.com):JohnsonMattheyshareholdersfactsheet(22August2007)(509648)

32 - Hemscott (www.hemscott.com):Premier Oil factsheet (August2007)(509340)

33-YahooFinance:AMECfactsheet(26August2007)(510342)

34-AvivaPlcCorporateCommunications:AnnualReport2006(2007)(509536)

35-GreggsplcCorporateCommunications:AnnualReport&Accounts2003(17December2004)(243992)

36-CorporateWatchnewsletter:issue24(June/July2005)(June2005)(263431)

37 - www.indymedia.org:Gatwick Protest: no more immigration prisons(21April2007)(509596)

3� - Hemscott (www.hemscott.com):GKN factsheet (August 2007)(509274)

39 - Hemscott (www.hemscott.com):Cobham plc factsheet (August2007)(509263)

40-LabourResearch:Vol95no8(August2006)(295340)41 - AXA Corporate Communications:Sustainable development

report2006(2007)(511230)42 - Transnationale website www.transnationale.org:Citigroup

Incwww.transnationale.org/fiches/127.htm(2April2004)(22433�)

43 - Hemscott (www.hemscott.com):Ascent Resources plc factsheet(August2007)(509135)

44 - Bank Track www.banktrack.org:Preparations for a new Fallujah?(16March2006)(289550)

45-Hoovers2007www.hoovers.com:AXAfactsheet(June2007)(511249)

46-AXACorporateCommunications:www.axa.com(June2007)(511253)

47 - Hemscott (www.hemscott.com):BAe Systems factsheet (August2007)(509295)

4� - www.netwerkvlaanderen.be:Belgian bank groups invest in companiesthatabusehumanrights(14November2005)(291868)

49 - European Services Forum website ESF (www.esf.be):ESF Members’biographies(2January2007)(304717)

50-SustainAbility:InfluencingPower:Reviewingtheconductandcontentofcorporatelobbying(2005)(504196)

51-AXACorporateCommunications:AnnualReport2006(2007)(511210)

52 - Saga Group Ltd Corporate Communications:www.saga.co.uk(3September2007)(511563)

53-WorldNuclearIndustryHandbook:2004(237587)54-FivesLilleCorporateCommunications:www.fiveslille.com(3

September2007)(511605)55-EthicalConsumer:75(1February2002)(4139)56-VivarteSociétéAnonymeCorporateCommunications:www.

vivarte.fr(15February2007)(308436)57 - ECRA shop survey:ECRA Shop Survey - Clothes Shops

EC98-JennyRhodes(26October2005)(275467)58-SocialAccountabilityReport2002:1January2002(10411)59-GreeningtheSupermarkets:Greeningthesupermarkets,

November2006(November2006)(312087)60-Ecologist,The:September2004(27August2004)(231716)61-MarineConservationSocietyfishonline:Sustainable

SeafoodSupermarketLeaguetable(March2007)(311963)62-Guardian,The:Thefishlist:howyoursupermarketrates(1

March2006)(285358)63-Co-operativeGroupLtdCorporateCommunications:Emails

from Ryan Brightwell via Ethiscore customer (21 December 2006)(304157)

64-Supermarkets&FarmAnimalWelfare‘RaisingtheStandard’:SupermarketSurvey2005-2006(16June2006)(292513)

65-Supermarkets&FarmAnimalWelfare‘RaisingtheStandard’:1January2002(10686)

66-ShopSurvey:ShopSurvey(24April2007)(311242)67-GuardianUnlimited/Guardianwebsitewww.guardian.

co.uk:BriberyandcorruptiontopCo-op’s‘sinlist’(28June2005)(260896)

68-Workplacelaw.net:Co-opfined£40,000aftermanagementfailings led to lax health and safety culture (31 August 2006)(296348)

69-GuardianUnlimited/Guardianwebsitewww.guardian.co.uk:’Ethical’Co-opangersunions(19July2005)(263281)

70-Co-operativeGroupLtdCorporateCommunications:Companywebsite(9May2007)(312133)

71 - Ethical Trading Initiative website www.ethicaltrade.org:MembersoftheEthicalTradingIntiative(17August2005)(17August2005)(266785)

72-BBCNewsWebsitewww.bbc.co.uk:Cancerchemical‘insoftdrinks’(31March2006)(292323)

73-BBCNewsWebsitewww.bbc.co.uk:Unhealthystoreofferscriticisedhttp://news.bbc.co.uk/go/pr/fr/-/1/hi/uk/4468688.stm(25November(277390)

74 - Co-operative Group Ltd Corporate Communications:Our Viewpointswww.co-op.co.uk(26August2005)(268573)

75 - Co-operative Insurance Society (CIS) Corporate Communications:www.cis.co.uk(5September2007)(512034)

76-FoodMagazine:67(250773)77-BigCampaignWebsite(BoycottIsraeliGoods)www.

bigcampaign.org:www.bigcampaign.org(16March2007)(310366)

7� - Co-operative Group Ltd Corporate Communications:The Co-operativeGroupCorporateResponsibilityReport2003(2003)(237981)

79-Report&FinancialStatements2002:1January2002(9890)80-Co-operativeBankPlcCorporateCommunications:

Co-operative Bank Plc (The) The Last Twelve Months FinancialStatements(2003)(226256)

81-BUAVwebsitewww.buav.org:ListofGoCruelty-FreeCompanieswww.buav.org/gocrueltyfree/ukcompanies.html(11August2005)(265636)

�2 - Co-operative Group Ltd Corporate Communications:Co-operativeGroupwebsitewww.co-op.co.uk(27April2005)(255�72)

83-FortisNVCorporateCommunications:SustainabilityReport(2007)(511669)

84-FortisNVCorporateCommunications:www.fortis.nl(4September2007)(511683)

85-FortisNVCorporateCommunications:AnnualReport2006(2007)(511659)

86-NetwerkVlaanderen:BelgianBanksinvestincompaniesthatabusehumanrights(November2005)(511609)

87-FriendsoftheEarthInternational/Link:Majorinternationalbanksinvolvedinfinancingcatasrophicmudvolcano(June2007)(506380)

88-PlanetArkwebsite:Laossecures$1billionloansfordamproject(5May2005)(503479)

89-FortisNVCorporateCommunications:www.fortis.com(4September2007)(511634)

90-EthicalPerformance:Volume7Issue10(March2006)(287602)

91-ConflictandProjectFinance:exploringoptionsforbettermanagementofconflictrisk:ConflictandProjectFinance(January2006)(511626)

92-AllthePresidents’men:1March2002(754)93 - Bloomberg News:UN Ignores Own Standards in Investing

$29BillionPensionFund(1November2005)(276506)94 - HBOS Plc Corporate Communications:Corporate

ResponsibilityReport2005(2006)(511515)95-HBOSPlcCorporateCommunications:2006AnnualReport

(2007)(511527)96-HBOSPlcCorporateCommunications:AnnualReport&

Accounts2004(2004)(281830)97-YahooFinance:BalfourBeattyfactcheet(26August2007)

(510350)9� - Hemscott (www.hemscott.com): Associated British Foods

PlcAdvisers(26January2005)(247044)99 - Austin Reed Group plc Corporate Communications:Report

&Accounts2003/2004(2004)(229108)100-ARCNews:May2005(May2005)(271569)101-EdinburghEveningNews:Anti-pornprotesterstotarget

bankpartyhttp://business.scotsman.com/topics...(14December2004)(249416)

102-BBCNewsWebsitewww.bbc.co.uk:Bankapologiesforpornfunding(22March2004)(250112)

29

103-Hemscott(www.hemscott.com):Scottish&NewcastlePlcAdvisers(26January2005)(247532)

104-Hemscott(www.hemscott.com):ReutersGroupPlc(26January2005)(247513)

105-HBOSPlcCorporateCommunications:GroupEnvironmental Policy Statement and The HBOS Corporate ResponsibilityReport2004(December20(250129)

106-InsuranceAustraliaGroupCorporateCommunications:SustainabilityReport2006(2007)(511930)

107-InsuranceAustraliaGroupCorporateCommunications:www.iag.com.au(5September2007)(511915)

108-www.wbcsd.org:MembercompanieslistJanuary2007(January2007)(306663)

109-InsuranceAustraliaGroupCorporateCommunications:AnnualReport2006(2007)(511944)

110-LabourResearch:vol94no2(1February2005)(251879)111 - Hemscott (www.hemscott.com):Roxi Petroleum factsheet

(August2007)(509175)112-EarthIslandJournal:Spring2007(April2007)(311920)113 - Yahoo Finance :Chasemonitor.org press release (7

December2006)(302844)114-CSRAsiaWeekly:Vol1week32(11August2005)

(270840)115 - National Australia Bank Ltd Corporate Communications:

AnnualReport2003(2003)(227500)116-NationalForeignTradeCouncilwww.nftc.org:22February

2004(221632)117 - National Foreign Trade Council www.nftc.org:www.nftc.org

(25May2007)(502550)118-Legal&GeneralGroupplcCorporateCommunications:

www.legalandgeneralgroup.com(June2007)(510523)119 - Hemscott (www.hemscott.com):Royal Dutch Shell

factsheet(August2007)(509331)120-Hemscott(www.hemscott.com):CairnEnergyplc(August

2007)(509317)121 - Hanson plc Corporate Communications:Annual Report

2006/7(April2007)(510353)122 - Hemscott (www.hemscott.com):Tesco factsheet (August

2007)(509308)123 - Hemscott (www.hemscott.com):Balfour Beatty

shareholders(22August2007)(509632)124-KingfieldHeathCorporateCommunications:www.opinfo.

net(16July2005)(263036)125-www.officegiant.co.uk:www.officegiant.co.uk/products(12

July2005)(262124)126-Hemscott(www.hemscott.com):AlexonGroupPlc

Shareholders(16July2004)(229156)127-HooversOnlinewww.hoovers.com:Legal&General

factsheet(29August2007)(510500)12� - Hemscott (www.hemscott.com):Imperial Tobacco Group

factsheet(August2007)(509228)129-KingfieldHeathCorporateCommunications:www.

kingfieldheath.com(12July2005)(262089)130-Hemscott(www.hemscott.com):BritishAirwaysfactsheet

(August2007)(509285)131-LiverpoolVictoriaFriendlySocietyCorporate

Communications:AnnualReport2006(2007)(511071)132-www.trustnet.com:LiverpoolVictoriaPortfolioManagers

factsheet(31August2007)(511133)133-LiverpoolVictoriaFriendlySocietyCorporate

Communications:www.lv.com(31August2007)(511078)134 - Lloyds TSB Group plc Corporate Communications:

CorporateResponsibilityReport2006(5September2007)(5117�4)

135 - Hemscott (www.hemscott.com):Smiths Group Plc Advisers (26January2005)(247599)

136-Hemscott(www.hemscott.com):JohnsonMattheyPlcAdvisers(26January2005)(247195)

137 - Lloyds TSB Group plc Corporate Communications:www.lloydstsb.com(5September2007)(511729)

138-Hoovers2007www.hoovers.com:LloydsTSBGroupfactsheet(5September2007)(511720)

139-Juniper:WhobankswithwhomFTSE100companiesforEC94(9February2005)(248105)

140-Hemscott(www.hemscott.com):Smith&NephewPlcAdvisers(26January2005)(247585)

141-Hemscott(www.hemscott.com):ShellTransport&TradingCoPlcAdvisers(26January2005)(247579)

142-Hemscott(www.hemscott.com):Tate&LylePlcAdvisers(26January2005)(247607)

143 - Lloyds TSB Group plc Corporate Communications:Human RightsPolicy(16March2007)(310446)

144 - Bank Track www.banktrack.org:Cluster munitions producers(2007)(508268)

145-Ecologist,The:March2006(291501)146-BBCNewsWebsitewww.bbc.co.uk:LloydsTSBleaflet

‘misleading’(25October2006)(300881)147-GuardianUnlimited/Guardianwebsitewww.guardian.

co.uk:Bank criticised over loan to man who gave money away(11August2005)(266005)

14� - Munchener Ruckversicherungs-Gesellschaft Aktiongesellschaft Corporate Communications:Perspectives-environmentalreportfor2005(May2006)(504240)

149 - MEAG New York Corp Corporate Communications:SEC 13Ffilingfor30/6/2007(30June2007)(512188)

150-MunchenerRuckversicherungs-GesellschaftAktiongesellschaft Corporate Communications:www.munichre.com(June2007)(504237)

151-Hoovers2007www.hoovers.com:MunchenerRuckversicherungsfactsheet(June2007)(504227)

152 - Munchener Ruckversicherungs-Gesellschaft Aktiongesellschaft Corporate Communications:Annual Report2006(2007)(504245)

153 - National Farmers Union Mutual Insurance Society Limited Corporate Communications:www.nfumutual.co.uk (4 September2007)(511692)

154 - www.trustnet.com:NFU Mutual funds factsheet (5 September2007)(511706)

155 - National Farmers Union Mutual Insurance Society Limited CorporateCommunications:AnnualReport2004(2004)(284566)

156-NaturesavePoliciesLtdCorporateCommunications:www.naturesave.co.uk(19June2007)(503872)

157 - Prudential plc Corporate Communications:Corporate ResponsibilityReport2006/7(2007)(510316)

15� - Hemscott (www.hemscott.com):Tullow Oil factsheet (August2007)(509160)

159-Independent,The:World’sleadingcompanieslackplanonclimatechange(18September2006)(509679)

160-PrudentialplcCorporateCommunications:www.prudential.co.uk(August2007)(510313)

161-Hoovers2007www.hoovers.com:Prudentialplcfactsheet(25August2007)(510308)

162-Royal&SunAllianceInsuranceGroupPlcCorporateCommunications:CorporateResponsibilityreport2006(2007)(510337)

163-www.trustnet.com:F&CAssetManagementfundsfactsheet(5September2007)(512044)

164-Hemscott(www.hemscott.com):Royal&SunAlliancefactsheet(29August2007)(510705)

165-Royal&SunAllianceInsuranceGroupPlcCorporateCommunications:www.royalsunconnect.co.uk (29 August 2007)(510710)

166-Royal&SunAllianceInsuranceGroupPlcCorporateCommunications:www.royalsunalliance.com(August2007)(510334)

167-Hoovers2007www.hoovers.com:Royal&Sunfactsheet(August2007)(510330)

168-Royal&SunAllianceInsuranceGroupPlcCorporateCommunications:AnnualReport2006(2007)(510390)

169-RoyalBankofScotlandGroupplcCorporateCommunications:CorporateResponsibilityreportfor2006(26August2007)(510403)

170-ENDSReport:383(December2006)(December2006)(303375)

171 - Hemscott (www.hemscott.com):Old Mutual Plc Advisers (26January2005)(247473)

172 - Hemscott (www.hemscott.com):United Utilities Plc Advisers(26January2005)(247633)

173 - 3i Group plc Corporate Communications:3i Group webpagewww.3i.com(2March2004)(222319)

30

174 - UKI Partnerships Corporate Communications:www.ukipartnerships.com(August2007)(510366)

175 - Royal Bank of Scotland Group plc Corporate Communications:CorporateProfile:AbouttheGroup&GroupStructurewww.rbs.co.uk/Group_Information/Corporate_Profil(248116)

176-Hemscott(www.hemscott.com):BootsGroupPlcAdvisers(26January2005)(247022)

177-Hemscott(www.hemscott.com):AvivaPlcAdvisers(26January2005)(247016)

178-Hemscott(www.hemscott.com):NextPlcAdvisers(26January2005)(247242)

179 - CORE (Corporate Responsibility) Coalition reports:A Big Deal? Corporate Social responsibility and the Finance SectorinEurope(1December2005)(277881)

180-BBCNewsWebsitewww.bbc.co.uk:RBSventureeyeswealthyChinese(20March2007)(310847)

181-Hemscott(www.hemscott.com):DiageoPlcAdvisers(26January2005)(247032)

182-Hemscott(www.hemscott.com):BPPlcAdvisers(26January2005)(247082)

183-Hemscott(www.hemscott.com):GlaxoSmithKlinePlc(26January2005)(247172)

1�4 - International Chamber of Commerce ICC www.iccwbo.org:www.iccwbo.org(16May2007)(312527)

1�5 - Corporate Power over EU Trade Policy: Good for business,badfortheworld:26January2007(307456)

186-GuardianUnlimited/Guardianwebsitewww.guardian.co.uk:JPMorganpays$1bntosettleEnronclaim(17August2005)(266820)

187-PowerFinance:March2002(9548)1�� - Coutts Group Corporate Communications:www.coutts.com

(16January2006)(281953)1�9 - Zurich Financial Services Corporate Communications:

AnnualReview2006(13June2007)(503626)190-Zurich.co.ukwebsite:9November2002(12805)191-WorldNuclearIndustryHandbook:2007edition(2007)

(312221)192-Hoovers2007www.hoovers.com:ZurichFinancial

Servicesfactsheet(13June2007)(503611)193 - Zurich Financial Services Corporate Communications:

www.zurich.com(23November2004)(240702)194-WorldEconomicForumwebsitewww.weforum.org:www.

weforum.org(23January2007)(307223)195-WorldBusinessCouncilforSustainableDevelopment

(WBCSD)www.wbcsd.org:www.wbcsd.org/aboutus/member.htm(1March2002)(6935)

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