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This will allow the financial institution to evaluate if there are any difficulties with implementing any aspects of the ESMS that will need to be modified before full roll-out to all operations.

In particular, the financial institution should obtain feedback from operational staff who will be responsible for implementing the procedures at the transaction level. Operational staff should provide feedback on any difficulties with implementing the procedures for screening transactions, categorizing transactions based on their environmental and social risk, conducting environmental and social due diligence and monitoring the client’s/investee’s environmental and social performance. Operational staff may also require the development of additional guidance notes to help clarify implementation of various aspects of the ESMS.

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