| A | B | C | D | E | F | G | H | I | J | K | L | M | N | O | P | Q | R | S | T | U | V | ||
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1 | SIWG - CP REPORT as of December 2023 | *indicates minimum actions | ASSESS | ENGAGE | SUPPORT | REPORT | TRAIN | ||||||||||||||||
2 | Submission Date | Organization Name | Fund Name | Total Investees | We commit: | ASSESS using internal tools or ESG | ASSESS using CP Commit or ALINUS* | ASSESS using other SPI Online tools | ASSESS requiring social rating/certification | ENGAGE - non-binding | ENGAGE - Condition Precedent to sign-up to CP Pathway* | ENGAGE - Condition Precedent & action plan | ENGAGE - Additional binding requirements | Non-financial SUPPORT | Financial SUPPORT | Other REPORTING | TRAINING of staff* | Notes (post submission) | Do you have a minimum CP criteria? | Risk criteria described | Language for binding clauses | Other Commitments | |
3 | 2024-04 | Advans SA | 9 | To conducting CP assessments on our investees. To engaging our investees with the CP Pathway through non-binding ways, such as raising awareness. To monitoring the engagement of our investees (e.g., on the CP Pathway, on specific gaps to address, etc.). To supporting our investees in their improvements on CP (financially or otherwise). To aligning with Cerise+SPTF's minimum recommended approach* | 0% | 11% | 44% | 0% | 100% | 0% | 0% | 0% | 100% | 0% | - Social performance dashboard: Snapshot of key indicators relating to social goals - Social performance annual report: Quantitative and Qualitative report on overall SPM practices and improvements and the achievement of social objectives for the year. Confirming compliance with the requirements of the Environmental and Social Management System, or as the case may be, detailing any non-compliance together with the action being taken to ensure compliance as well as (ii) including, for the avoidance of doubt, reporting on compliance with Client Protection Requirements. - Ad hoc reporting: In addition Advans SA's investees may be asked to provide E&S information or data to partners or shareholders on an ad hoc basis. | 31% | Yes, on a case-by-case basis. | The shareholders' agreements specify that investments must comply with the holding's Social and Environmental Policy, which stipulates that : - Advans SA's investess will seek to analyse and audit their Environmental and Social performance and compare its against industry standards using the following tools (amongst others where appropriate) either using internal or external resources to perform the analysis: SPI5 – Social Performance Indicators 5 –a social performance assessment tool for financial service providers and any relevant updated tools & Client Protection Standards assessments. - Advans SA's investees commit to performing an internal or external analysis using the two tools above every 3 years and will aim to attain certifications of conformity where possible. | |||||
4 | 2024-04 | FS Impact Finance | GLS AI Microfinance Fund | 64 | To engaging our investees with the CP Pathway through non-binding ways, such as raising awareness. | 59% | 41% | 0% | 0% | 100% | 0% | 0% | 0% | 0% | 0% | SFDR reporting on a yearly basis. Fund Annual Report. | 4% | Yes, on a case-by-case basis. | There is no formal list of indicators to be respected or pre-determined minimum score. At eligibility stage, the institution must self-declare compliance with certain basic principals. If that self-declaration turns out to be grossly misleading, the investment process is stopped at due diligence. Since April 2023, our Fund has started using ALINUS for its due diligence. If the institution refuses to provide the required information for ALINUS, the process stops. Further, if the institution is seen to have significant low-hanging fruit but is not making effort to improve, the committee might decide against an investment. | ||||
5 | 2024-04 | SIDI | SIDI | 62 | To conducting CP assessments on our investees. To monitoring the engagement of our investees (e.g., on the CP Pathway, on specific gaps to address, etc.). To supporting our investees in their improvements on CP (financially or otherwise). | 3% | 15% | 37% | 0% | 0% | 0% | 0% | 0% | 0% | 6% | 100% | No | ||||||
6 | 2024-05 | Developing World Markets | Trill Impact-DWM SDG Credit Fund | 59 | To conducting CP assessments on our investees. To engaging our investees with the CP Pathway through non-binding ways, such as raising awareness. To engaging our investees with the CP Pathway through binding contractual commitments (e.g., requiring joining the CP Pathway, requiring CP Certification, etc.). To monitoring the engagement of our investees (e.g., on the CP Pathway, on specific gaps to address, etc.). To supporting our investees in their improvements on CP (financially or otherwise). To aligning with Cerise+SPTF's minimum recommended approach* | 100% | 0% | 0% | 0% | 5% | 12% | 0% | 88% | 5% | 0% | Public-facing annual impact report and quarterly reporting updates to investors. | 100% | Yes, for all. | At due diligence, all portfolio companies must either join the CP Pathway or demonstrate adherence to a minimum set of client protection practices similar to CP Commit. This is assessed via a questionnaire and backup documentation. During monitoring, DWM's Impact Investment Questionnaire (Impact IQ), administered annually, includes a section assessing client protection practices. | There are two versions depending on the current status of the borrower with respect to the CP Pathway and Standards. For those already certified or on the Pathway, the loan agreement states that they shall maintain their status. For those not yet on the Pathway or certified, the loan agreement states that they shall either join the Pathway within six months or provide evidence that it has implemented practices equivalent to the Client Protection Standards. These clauses were instituted in all loan agreements as of May 2023. Loan agreements signed prior to that date had a clause stating that the borrower shall adhere to the Client Protection Principles. | |||
7 | 2024-05 | Gojo and Company, Inc. | 9 | To conducting CP assessments on our investees. To engaging our investees with the CP Pathway through non-binding ways, such as raising awareness. To monitoring the engagement of our investees (e.g., on the CP Pathway, on specific gaps to address, etc.). To supporting our investees in their improvements on CP (financially or otherwise). To aligning with Cerise+SPTF's minimum recommended approach* | 0% | 33% | 44% | 44% | 33% | 0% | 0% | 0% | 67% | 100% | NA | 100% | No | ||||||
8 | 2024-05 | Invest in Visions | IIV Mikrofinanzfonds | 87 | To engaging our investees with the CP Pathway through binding contractual commitments (e.g., requiring joining the CP Pathway, requiring CP Certification, etc.). To monitoring the engagement of our investees (e.g., on the CP Pathway, on specific gaps to address, etc.). To aligning with Cerise+SPTF's minimum recommended approach* | 0% | 100% | 0% | 0% | 0% | 100% | 0% | 0% | 100% | 0% | SFDR reporting on a yearly basis Impact Report on a yearly basis | 25% | Yes, for all. | In the loan agreement, all FSPs need to commit to the first step of the CP Pathway and to follow the second step in the course of three months. Over the course of the investment, we monitor whether the FSPs follow this commitment. | (a) The Borrower [shall/has] confirm[ed] its commitment to implement the Client Protection Standards in Microfinance by signing the requisite commitment statement (Step 1 of the Client Protection Pathway) and by [providing/agreeing to provide] a self-assessment report on client protection (using a tool provided by the Social Performance Task Force) (Step 2 of the Client Protection Pathway) within six months of signing the commitment to implement the Client Protection Standards and thereby participating in the Client Protection Pathway program. (b) The Borrower shall use reasonable efforts to achieve Client Protection Certification (Step 3 of the Client Protection Pathway) reaching at least the bronze level during the term of this Agreement. If the Borrower has achieved the bronze level, the Borrower shall use reasonable efforts for moving up to the silver or gold level during the term of this Agreement. (c) The Borrower shall operate in accordance with all Client Protection Standards in Microfinance and annually share the state of its client protection practices (using a tool such as SPI4-ALINUS) to inform the Lender on its compliance with the Client Protection Standards, including by adopting the following practices: i. in order to promote the “Transparency” principle, the Borrower will adopt and/or implement policies and procedures to disclose to its clients the total cost of credit (including all fees, commissions, insurance premiums, and other costs); and ii. in order to promote the “Prevention of Over-indebtedness” principle, the Borrower will [continue to] make use of client information from relevant credit bureaus in making lending decisions and will report client data to relevant credit bureaus, where it is commercially reasonable to do so. | |||
9 | 2024-05 | Incofin Investment Management | agRIF | 32 | To conducting CP assessments on our investees. To engaging our investees with the CP Pathway through non-binding ways, such as raising awareness. To engaging our investees with the CP Pathway through binding contractual commitments (e.g., requiring joining the CP Pathway, requiring CP Certification, etc.). To monitoring the engagement of our investees (e.g., on the CP Pathway, on specific gaps to address, etc.). To aligning with Cerise+SPTF's minimum recommended approach* | 0% | 100% | 0% | 6% | 100% | 78% | 0% | 78% | 3% | 0% | SFDR periodic disclosure Fund's annual E&S report | 100% | Yes, for all. | During due diligence, if the FI's score on Client Protection (in ALINUS) is below 70%, the case needs to be reviewed by the Risk & ESG department for further evaluation before it can be presented to the Investment Committee. The IC takes it investment decision taking into account the FI's Client Protection performance and whether there are sufficiant mitigants in place if the score is < 70%. | a. [Priority option] Condition precedent. The Borrower confirms its commitment to implement the Client Protection Standards for Financial Services Providers and completion of Step 1 of the Client Protection Pathway which entails: 1) signing the commitment statement on the Cerise+SPTF website, and 2) submitting a self-assessment report on client protection using one of the tools made available by Cerise+SPTF within 6 months after the signature of the commitment statement. a. [2nd option] Condition subsequent. The Borrower confirms its commitment to implement the Client Protection Standards for Financial Services Providers and has formalized this commitment by signing the Client Protection Pathway commitment statement on the Cerise+SPTF website. As a condition subsequent to disbursement, the Borrower will complete Step 1 of the Client Protection Pathway by submitting a self-assessment report on client protection using one of the tools made available by Cerise+SPTF within 6 months after the first disbursement. c. The Borrower shall operate in accordance with all Client Protection Standards for Financial Services Providers and annually share the state of its client protection practices (using a tool such as SPI Online) to inform the Lender on its compliance with the Client Protection Standards, including by adopting the following practices: i. in order to promote the “Transparency” standard, the Borrower will adopt and/or implement policies and procedures to disclose to its clients the total cost of credit (including all fees, commissions, insurance premiums, and other costs); and ii. in order to promote the “Prevention of Over-indebtedness” standard, the Borrower will [continue to] make use of client information from relevant credit bureaus in making lending decisions and will report client data to relevant credit bureaus, where it is commercially reasonable to do so. | |||
10 | 2024-05 | Abler Nordic | Abler Nordic Global, Frontier, Fund III, Fund IV and CSF. | 17 | To engaging our investees with the CP Pathway through non-binding ways, such as raising awareness. To engaging our investees with the CP Pathway through binding contractual commitments (e.g., requiring joining the CP Pathway, requiring CP Certification, etc.). To supporting our investees in their improvements on CP (financially or otherwise). To aligning with Cerise+SPTF's minimum recommended approach* | 100% | 0% | 0% | 35% | 0% | 100% | 0% | 100% | 100% | 24% | Quarterly impact report including high-level indicators of ESG aspects and percentage of investees committed to the pathway and percentage investee with external review (CP certification or Social Rating) | 0% | No | Obtain a Client Protection Certification from any of the official assessors at a time in which a Financial Rating is considered and at least every two to three years and provide the results to the Investor. Technical Assistance Funds from the Investor may be available to support this process. | ||||
11 | 2024-07 | Sociedad para la Inclusión de la Microempresa en Centroamérica y el Caribe S.A. | SICSA | 36 | To conducting CP assessments on our investees. To engaging our investees with the CP Pathway through non-binding ways, such as raising awareness. To engaging our investees with the CP Pathway through binding contractual commitments (e.g., requiring joining the CP Pathway, requiring CP Certification, etc.). To monitoring the engagement of our investees (e.g., on the CP Pathway, on specific gaps to address, etc.). To supporting our investees in their improvements on CP (financially or otherwise). To aligning with Cerise+SPTF's minimum recommended approach* We haven't made any commitments Client Protection. Other | 0% | 0% | 0% | 0% | 0% | 0% | 0% | 0% | 0% | 0% | SICSA efectúa dentro de este proceso de inscripción los resultados a partir de 2024 en virtud de la implementación de acciones orientadas a motivas a las IMF a que se adhieran a esta Declaración. Estaremos enviando data requerida a finales de este año 2024. | 6% | No | Incorporar servicios innovadores de finanzas verdes en la región. Incorporación de seguros climáticos para cobertura de la cartera de préstamos en zonas rurales en la región. Levantamiento de un estudio de factibilidad para la incorporación de seguros climáticos en las Instituciones de Microfinanzas de la Región. | ||||
12 | 2024-07 | Investing for Development | LMDF | 43 | To engaging our investees with the CP Pathway through binding contractual commitments (e.g., requiring joining the CP Pathway, requiring CP Certification, etc.). | 2% | 33% | 0% | 0% | 0% | 74% | 0% | 0% | 0% | 28% | LMDF is a signatory of the Pacte national Entreprises et droits de l'Homme and once a year produces a Human Rights Report that grounds, among others on the microfinance part of the fund, on client protection standards. OTHER COMMENTS> The TA and staff training information are provided by ADA. The no. of SPI Online seems small cause they are updated on a rolling base. The traction for SPI Online is more significant in 2024 | 2% | Yes, on a case-by-case basis. | The SPI Online Alinus score of Dimension 4: Client Protection (and the score of Dimension 5: Responsible Human Resource Development), collected using the Alinus or SPI tools, should independently reach a specific threshold differentiated for the Tier type of FSPs. Financial service providers classified as Tier 3 who score in one of the two above mentioned dimensions below the minimum threshold, can still be presented to the Investor Committee if the remedy for improvement is highlighted in the due diligence proposal. | Within 6 months of the Disbursement Date, the Borrower agrees to join the Client Protection Pathway, to sign its commitment to implement client protection, and to submit a client protection assessment to the Client Protection Pathway within 6 months of its joining date. | |||
13 | 2024-07 | Fondation Grameen Crédit Agricole | 61 | To conducting CP assessments on our investees. To engaging our investees with the CP Pathway through non-binding ways, such as raising awareness. To engaging our investees with the CP Pathway through binding contractual commitments (e.g., requiring joining the CP Pathway, requiring CP Certification, etc.). To aligning with Cerise+SPTF's minimum recommended approach* | 0% | 74% | 0% | 0% | 100% | 70% | 0% | 7% | 15% | 0% | For the Fondation, we report on Client Protection and ESG in our annual activity report. | 100% | Yes, for all. | ALINUS score Client Protection (Dim4) - Tier 1 > 70% - Tier2 > 60% - Tier 3 > 50% ALINUS score Prevention of over-indebtedness (Dim4a) - Tier 1 > 70% - Tier 2 > 50% - Tier 3 > 50% | We put as a condition precedent to disbursement "The Borrower formally commits to the Client Protection Standards by becoming a signatory online of the Client Protection Pathway (listed in committed institution that submitted their client protection assessment)." | ||||
14 | 2024-09 | Global Partnerships | Global Partnerships Social Investment Fund 6.0, LLC | 49 | To conducting CP assessments on our investees. To engaging our investees with the CP Pathway through non-binding ways, such as raising awareness. To monitoring the engagement of our investees (e.g., on the CP Pathway, on specific gaps to address, etc.). To supporting our investees in their improvements on CP (financially or otherwise). To aligning with Cerise+SPTF's minimum recommended approach* | 100% | 0% | 0% | 0% | 24% | 0% | 0% | 0% | 14% | 27% | 100% | Yes, for all. | For each potential financial service provider (FSP) investee, the Global Partnerships (GP) team conducts a CP screening as part of due diligence. GP has an internal CP screening tool designed for this purpose, adapted from the CP Pathway scoring tool and covering the 8 Client Protection Principles. An FSP must pass this screening in order to receive GP-affiliated Fund investment. | |||||
15 | 2024-09 | Global Partnerships | Global Partnerships Impact-First Development Fund, LLC | 33 | To conducting CP assessments on our investees. To engaging our investees with the CP Pathway through non-binding ways, such as raising awareness. To monitoring the engagement of our investees (e.g., on the CP Pathway, on specific gaps to address, etc.). To supporting our investees in their improvements on CP (financially or otherwise). To aligning with Cerise+SPTF's minimum recommended approach* | 100% | 0% | 0% | 0% | 24% | 0% | 0% | 0% | 12% | 27% | 100% | Yes, for all. | For each potential financial service provider (FSP) investee, the Global Partnerships (GP) team conducts a CP screening as part of due diligence. GP has an internal CP screening tool designed for this purpose, adapted from the CP Pathway scoring tool and covering the 8 Client Protection Principles. An FSP must pass this screening in order to receive GP-affiliated Fund investment. | |||||
16 | 2024-09 | Global Partnerships | Global Partnerships Impact-First Growth Fund, LLC | 23 | To conducting CP assessments on our investees. To engaging our investees with the CP Pathway through non-binding ways, such as raising awareness. To monitoring the engagement of our investees (e.g., on the CP Pathway, on specific gaps to address, etc.). To supporting our investees in their improvements on CP (financially or otherwise). To aligning with Cerise+SPTF's minimum recommended approach* | 100% | 0% | 0% | 0% | 26% | 0% | 0% | 0% | 9% | 22% | 100% | Yes, for all. | For each potential financial service provider (FSP) investee, the Global Partnerships (GP) team conducts a CP screening as part of due diligence. GP has an internal CP screening tool designed for this purpose, adapted from the CP Pathway scoring tool and covering the 8 Client Protection Principles. An FSP must pass this screening in order to receive GP-affiliated Fund investment. | |||||
17 | 2024-09 | MIV A | MF Fund | 104 | To conducting CP assessments on our investees. To engaging our investees with the CP Pathway through non-binding ways, such as raising awareness. To supporting our investees in their improvements on CP (financially or otherwise). To aligning with Cerise+SPTF's minimum recommended approach* Other | 79% | 1% | 0% | 14% | 0% | 0% | 0% | 0% | 0% | 0% | We report via EET under SFDR and we publish annual Impact Report | 20% | Yes, for all. | During DD or periodic monitoring client protection practices are assessed or reviewed as a mandatory part of overall assessment or monitoring. We use an in-house developed tool to score each investee and have a minimum acceptable score as well as requirement to engage with an investee who's score is decreasing. | ||||
18 | 2024-09 | MIV A | Other fund | 99 | To conducting CP assessments on our investees. To engaging our investees with the CP Pathway through non-binding ways, such as raising awareness. To supporting our investees in their improvements on CP (financially or otherwise). To aligning with Cerise+SPTF's minimum recommended approach* | 83% | 0% | 0% | 15% | 0% | 0% | 0% | 0% | 0% | 0% | We report via EET under SFDR and publish annual Impact report | 20% | Yes, for all. | During DD or periodic monitoring client protection practices are assessed or reviewed as a mandatory part of overall assessment or monitoring. We use an in-house developed tool to score each investee and have a minimum acceptable score as well as requirement to engage with an investee who's score is decreasing | ||||
19 | 2024-09 | MCE Social Capital | MCE Social Capital | 58 | To conducting CP assessments on our investees. To engaging our investees with the CP Pathway through non-binding ways, such as raising awareness. To monitoring the engagement of our investees (e.g., on the CP Pathway, on specific gaps to address, etc.). To supporting our investees in their improvements on CP (financially or otherwise). To aligning with Cerise+SPTF's minimum recommended approach* | 84% | 0% | 0% | 0% | 84% | 0% | 0% | 0% | 84% | 0% | MCE's annual impact survey collects data on client protection practices. Moreover, MCE funds several 60 Decibels studies on FSPs that include stakeholder feedback on client protection. The results are reported internally to senior management and, when relevant, the board. In the future, as the new client protection processes are implemented, MCE may report externally as well. | 100% | Yes, on a case-by-case basis. | Until 2023, MCE had established a list of red flags on client protection that guided investment decision making. In 2024, MCE is updating its client protection processes. MCE has decided to use the CP Commit assessment to evaluate both portfolio CP performance and risk, and to carry out Due Diligence on new investments. MCE will establish risk categories to inform investment decision making and a baseline aligned with entry level CP Commit indicators. | ||||
20 | 2024-09 | MCE Social Capital | MESA | 19 | To conducting CP assessments on our investees. To engaging our investees with the CP Pathway through non-binding ways, such as raising awareness. To monitoring the engagement of our investees (e.g., on the CP Pathway, on specific gaps to address, etc.). To supporting our investees in their improvements on CP (financially or otherwise). To aligning with Cerise+SPTF's minimum recommended approach* | 100% | 0% | 0% | 0% | 100% | 0% | 0% | 0% | 100% | 0% | MCE's annual impact survey collects data on client protection practices. Moreover, MCE funds several 60 Decibels studies on FSPs that include stakeholder feedback on client protection. The results are reported internally to senior management and, when relevant, the board. In the future, as the new client protection processes are implemented, MCE may report externally as well. | 100% | Yes, on a case-by-case basis. | Until 2023, MCE had established a list of red flags on client protection that guided investment decision making. In 2024, MCE is updating its client protection processes. MCE has decided to use the CP Commit assessment to evaluate both portfolio CP performance and risk, and to carry out Due Diligence on new investments. MCE will establish risk categories to inform investment decision making and a baseline aligned with entry level CP Commit indicators. | ||||
21 | 2024-09 | PROPARCO | 45 | To conducting CP assessments on our investees. To engaging our investees with the CP Pathway through non-binding ways, such as raising awareness. To engaging our investees with the CP Pathway through binding contractual commitments (e.g., requiring joining the CP Pathway, requiring CP Certification, etc.). To monitoring the engagement of our investees (e.g., on the CP Pathway, on specific gaps to address, etc.). To supporting our investees in their improvements on CP (financially or otherwise). To aligning with Cerise+SPTF's minimum recommended approach* | 0% | 100% | 0% | 0% | 0% | 0% | 0% | 33% | 0% | 16% | N/A | 100% | Yes, on a case-by-case basis. | High reputation risk, high market risk (overindebtedness, for example in Cambodia and lack of regulation. This only concerns a few FSPs as our strategy prevents us from working in high risk markets, such as Mexico at the moment. | |||||
22 | 2024-09 | Triple Jump B.V. | ASN Microkredietfonds | 89 | To conducting CP assessments on our investees. To engaging our investees with the CP Pathway through non-binding ways, such as raising awareness. To engaging our investees with the CP Pathway through binding contractual commitments (e.g., requiring joining the CP Pathway, requiring CP Certification, etc.). To monitoring the engagement of our investees (e.g., on the CP Pathway, on specific gaps to address, etc.). To supporting our investees in their improvements on CP (financially or otherwise). To aligning with Cerise+SPTF's minimum recommended approach* | 100% | 79% | 21% | 0% | 100% | 100% | 0% | 100% | 26% | 0% | Sustainable Finance Disclosure Regulation (SFDR) | 80% | Yes, for all. | The Borrower shall publicly commit to the CERISE + SPTF Client Protection Pathway[1] and remain committed to the same during the duration of the Loan. If the Borrower has not committed to the Client Protection Pathway before the first Disbursement Date, the Borrower must commit to implement the Client Protection Standards and submit a client protection assessment to CERISE + SPTF no later than six (6) months following the first Disbursement Date. | ||||
23 | 2024-09 | Triple Jump B.V. | Triple Jump Financial Inclusion Resilience Fund | 10 | To conducting CP assessments on our investees. To engaging our investees with the CP Pathway through non-binding ways, such as raising awareness. To engaging our investees with the CP Pathway through binding contractual commitments (e.g., requiring joining the CP Pathway, requiring CP Certification, etc.). To monitoring the engagement of our investees (e.g., on the CP Pathway, on specific gaps to address, etc.). To aligning with Cerise+SPTF's minimum recommended approach* | 100% | 0% | 100% | 0% | 100% | 100% | 20% | 100% | 100% | 0% | Sustainable Finance Disclosure Regulation (SFDR) | 80% | Yes, for all. | Minimum score on dimension 4 | ||||
24 | 2024-09 | Triple Jump B.V. | MicroBuild Fund | 22 | To conducting CP assessments on our investees. Other | 100% | 100% | 0% | 0% | 100% | 100% | 9% | 100% | 100% | 0% | Sustainable Finance Disclosure Regulation (SFDR) | 80% | Yes, for all. | We have not made investments since 2022. And for those Financial Institutions that are still in the portfolio we requested to commit to the SMART campaign. | ||||
25 | 2024-09 | Invest in Visions | IIV Mikrofinanzfonds | 87 | To engaging our investees with the CP Pathway through binding contractual commitments (e.g., requiring joining the CP Pathway, requiring CP Certification, etc.). To monitoring the engagement of our investees (e.g., on the CP Pathway, on specific gaps to address, etc.). To aligning with Cerise+SPTF's minimum recommended approach* | 0% | 100% | 0% | 0% | 0% | 100% | 0% | 0% | 0% | 0% | SFDR reporting on a yearly basis Impact Report on a yearly basis Factsheet on a monthly basis | 1% | Yes, for all. | Commitment to the CP principles in the Loan Agreement. | a. The Borrower has confirmed its commitment to implement the Client Protection Standards in Microfinance by signing the requisite commitment statement (Step 1 of the Client Protection Pathway) and by agreeing to provide a self-assessment report on client protection (using a tool provided by the Social Performance Task Force) (Step 2 of the Client Protection Pathway) within six months of signing the commitment to implement the Client Protection Standards and thereby participating in the Client Protection Pathway program. b. The Borrower shall use reasonable efforts to achieve Client Protection Certification (Step 3 of the Client Protection Pathway) reaching at least the bronze level during the term of this Agreement. If the Borrower has achieved the bronze level, the Borrower shall use reasonable efforts for moving up to the silver or gold level during the term of this Agreement. c. The Borrower shall operate in accordance with all Client Protection Standards in Microfinance and annually share the state of its client protection practices (using a tool such as SPI4-ALINUS) to inform the Lender on its compliance with the Client Protection Standards, including by adopting the following practices: i. in order to promote the “Transparency” principle, the Borrower will adopt and/or implement policies and procedures to disclose to its clients the total cost of credit (including all fees, commissions, insurance premiums, and other costs); and ii. in order to promote the “Prevention of Over-indebtedness” principle, the Borrower will continue to make use of client information from relevant credit bureaus in making lending decisions and will report client data to relevant credit bureaus, where it is commercially reasonable to do so. | |||
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