ABN AMRO

ABN AMRO Bank N.V.
Quick Facts
Type	Public
Sector	Financial Services
Headquarters	Amsterdam, Netherlands
Year of Origin	1991
Emissions (All Scopes)	26.3 Megatons of CO2 (2021)
NCI assessment	Low
Total Revenue	7.597 Billion EUR (2021)
Stock Exchange	Amsterdam
Key People	Robert Swaak (Chairman and CEO), Lars Kramer (CFO)
Number of Employees	19,957
Subsidiaries	Retail Banking ABN AMRO Hypotheken Groep ABN AMRO Verzekeringen ABN AMRO Pensions ALFAM International Card Services Moneyou Private Banking Banque Neuflize OBC Bethmann Bank Corporate Banking ABN AMRO Clearing ABN AMRO Commercial Finance ABN AMRO Lease Group Functions ABN AMRO Funding USA LLC Stater Beter

ABN AMRO Bank N.V., stylized as ABN AMRO, the third-largest bank of the Netherlands, has its headquarters in Amsterdam. It was established during the financial crisis of 2007 through a merger of the former Fortis Bank Nederland and former ABN AMRO Holding N.V. In 2015, ABN AMRO was publicly re-listed through an initial public offering (IPO) by the Dutch government. In 2021, ABN AMRO had a total of 19,957 employees (FTEs) worldwide, with 16,925 of that number employed in the Netherlands. The banking company has 24 offices in the Netherlands and is active on 5 continents. Their current stock market value is 10.4 billion EUR and they have over 5 million accounts.

Company Structure

ABN AMRO works with two boards, the Executive Board and the Supervisory Board. The Executive Board is the statutory managing board and is responsible for (i) the general course of business of ABN AMRO, ensuring compliance with laws and regulations and the adequate financing of its activities; (ii) the continuity of ABN AMRO and its business, aimed at long-term value creation for ABN AMRO and taking into account interests of stakeholders, and (iii) setting ABN AMRO's mission, vision, strategy, risk appetite, corporate standards and values, risk framework, main policies, budgets, financial and non-financial targets, and for the realization thereof.. The Supervisory Board, on the other hand, supervises, advises, challenges and supports the Executive Board in the exercise of its power and duties. Together with the Executive Board, the Supervisory Board is responsible for ABN AMRO's long-term value creation, requiring members to execute their duties in a sustainable manner with due observance of the long-term viability of the strategy being pursued.

Executive Board

Executive Board

Name	Function	Remuneration x1000EUR
Robert Swaak	Chairman and Chief Executive Officer (CEO)	770.618
Christian Bornfeld	Vice Chairman and Chief Innovation & Technology Officer	654.159
Tanja Cuppen	Chief Risk Officer	654.159
Dan Dorner	Chief Commercial Officer Corporate Banking	654.159
Choy van der Hooft-Cheong	Chief Commercial Officer Wealth Management	654.159
Lars Kramer	Chief Financial Officer	654.159
Gerard Penning	Chief Human Resources Officer	654.159
Annerie Vreugdenhil	Chief Commercial Officer Personal & Business Banking	654.159

The remuneration includes only the fixed base salary, as determined for the period from 1 July 2021 to 1 January 2022, and excludes benefits such as pension-related contributions, compensation for lease car expenses, and other short-term benefits or bonusses.

Supervisory Board

Supervisory Board

Name	Function	Remuneration x1000EUR
Tom de Swaan	Chairman	99.011
Arjen Dorland	Vice-Chairman	82.955
Laetitia Griffith	Member	80.279
Michiel Lap	Member	80.279
Anna Storåkers	Member	80.279
Mariken Tannemaat	Member	80.279
Tjalling Tiemstra	Member	82.955

Remuneration for Supervisory Board members has been determined as such for the period from 1 July 2021 until 1 January 2022:

• Membership of the Supervisory Board: EUR 53,519 (EUR 69,575 for the Chair)
• Membership of a Committee: EUR 13,380 (EUR 16,056 for the Chair)

The remuneration for Supervisory Board committee membership is limited to two committee memberships.

Accountant

The independent auditors of ABN AMRO are KPMG and Ernst & Young Accountants LLP (EY).

Main Activities

ABN AMRO's business performance is made up of Retail Banking, Commercial Banking, Private Banking, Corporate & Institutional Banking, and Group Functions. ABN AMRO sells shares on the public stock market for around 12-13 EUR. Most of these shares, 50.1% of the total, are held by Stichting Administratiekantoor Continuïnteit ABN AMRO Bank (STAK AAB), the rest of the shares, 469.1 million, are held directly by NL Financial Investments (NFLI). ABN AMRO itself has not received NOW support but invests in fraudulent cases regarding these subsidies.

Government

ABN AMRO does not have royal status. ABN AMRO has not received NOW support from the Dutch government.

Paris Agreement until Today

ABN AMRO has provided a corporate loan of 313 million US Dollars from 2013 to 2018 to the soy and palm oil company Bunge, which has been associated with human rights violations against land and environmental defenders and the deforestation of 60,000 hectares in Brazil.

In May 2016 ABN AMRO was involved in providing a loan to Asia Pacific Resources International Limited (APRIL), an Indonesia-based company with activities ranging from paper, palm oil, construction and energy business sectors. This is despite the fact that the bank informed Greenpeace in March 2015 that they would not finance new loans to APRIL until the company had stopped deforestation and proved that it can work sustainably. In June 2019 it was further reported that ABN AMRO was part of a large new syndicated loan to APRIL as of December 2018 and continues engaging with the company.

In 2016 and 2017, ABN AMRO provided 3 billion euros in bank loans to fossil energy companies, which constituted to 82% of its energy loans. This was a relatively large increase compared to the period 2013-2014, when ABN AMRO invested 68% of its energy loans in fossil energy companies.

Over the period January 2016 - September 2021, ABN AMRO provided a corporate loan of USD 196 million to the Cambo oil field.

ABN AMRO was the first bank in Europe to issue a Certified Climate Bond. The bond proceeds will be used to finance loans related to residential and commercial buildings that meet certain energy-efficiency or low-carbon criteria. In April 2018, they were the first issuer of a Certified Climate Bond that uses the new Marine Renewable Energy criteria. This bond supports 4 offshore wind farms in the North Sea.

As of March 2018, ABN AMRO has a share of USD 168 million in Royal Dutch Shell.

In the period 2018-2020, ABN AMRO provided EUR 1.6 billion in bank loans and underwriting to fossil fuels. Over that period, ABN AMRO increased the proportion of renewable energy in its energy sector credits from 31% to 48%. At the end of 2020, ABN AMRO had 234 million euros invested in energy, with a share of 71% in fossil fuels, and 29% in renewables.

In 2019 ABN AMRO signed the Climate Commitment of the financial sector. The 54 signatories committed to make a substantial contribution to the implementation of the Paris Agreement and the Dutch Climate Agreement. Concretely: they will measure the CO2 content of their relevant loans and investments and report on this from 2020 onwards and they will publish action plans by 2022 at the latest, including reduction targets for 2030 for all their relevant loans and investments.

Criticism on this commitment:

• This commitment is without obligation. There are no requirements set for the action plans to be published in 2022. Only 19% of signatories had an action plan in line with the Paris Climate Agreement by 2020. In addition, the commitment does not specify the relevant financing and/or investments on which the institutions must report. In 2020, only 9 out of 54 financial institutions report on all relevant asset classes.
• The pace of implementation of this commitment is too slow. Financial institutions such as ABN AMRO, Aegon, ING and Rabobank already committed themselves to the Spitsbergen ambition in 2018, in which they promised to combat climate change. In 2020, almost half of the institutions did not yet have a climate plan.

As of May 2019, ABN AMRO Clearing (AAC), a subsidiary of ABN AMRO, supports an international project for reforestation aimed at restoring old forests to its former glory. The corporate bank unit started this together with Land Life Company, a Dutch tree planting company. Through this project, AAC aims to achieve tangible sustainable results by planting new forests in Chicago and Spain. The intention is that these two projects form the prelude to more projects spread around the world.

As of March 2019, ABN AMRO holds 0.1% shares, worth 0.3 million US Dollars, in Minerva Foods, a Brazilian livestock company and one of the largest South American companies involved in the production of beef and its by-products, meat processing, and cattle export. In 2020 the bank's shareholding increased to 0.466 million US Dollars. Minerva Foods has caused a lot of controversy due to its deforestation practices and land right abuses in the Amazon.

In February 2020, new research from the 'Eerlijke Bankwijzer' and Greenpeace found that over the period from 2016 to 2019, ABN AMRO lent 643 million euros and invested 146 million euros in oil companies that drill in the Arctic. These loans and investments were made despite a motion being passed in the House of Representatives (Tweede Kamer) in December 2014 that requested "the government to safeguard the Arctic region from oil and gas extraction during the international climate negotiations". The four companies with the largest operations and expansion plans in the Arctic region are all Russian: Gazprom, Novatek, Rosneft, and Lukoil.

Financial Results since 2015

Financial situation ABN AMRO

Year	Revenue	Profit (loss)	Dividend
2015	8.455 billion EUR	1.919 billion EUR	0.761 billion EUR
2016	8.227 billion EUR	1.805 billion EUR	0.789 billion EUR
2017	9.290 billion EUR	2.721 billion EUR	1.363 billion EUR
2018	9.093 billion EUR	2.207 billion EUR	1.363 billion EUR
2019	8.605 billion EUR	2.046 billion EUR	1.203 billion EUR
2020	7.916 billion EUR	(0.045) billion EUR	0 billion EUR
2021	7.597 billion EUR	1.231 billion EUR	0.573 billion EUR

Note: In response to the exceptional and challenging circumstances of COVID-19 and the net loss recorded in 2020, the European Central Bank (ECB) recommended temporary suspension of all cash dividends and share buybacks in March 2020 .

Current Emissions

ABN AMRO have been capturing and reporting the greenhouse-gas (GHG) emissions from their business operations for a number of years. The majority of their overall GHG footprint lies in their lending and client-investment portfolio (i.e., scope 3), and initially there was no consistent approach to capturing this information across the industry. To address this, in 2015 ABN AMRO partnered with 13 other Dutch financial institutions to launch the Partnership for Carbon Accounting Financials (PCAF). Since 2018, ABN AMRO used PCAF to disclose the emissions financed by their lending and investment portfolios across all asset classes on their balance sheet that currently have a methodology available (currently out-of-scope asset classes include consumer lending, institutions, central banks and governments).

• Scope 1: Direct GHG emissions that occur from owned or controlled sources
• Scope 2: Indirect GHG emissions from the generation of purchased or acquired electricity, steam, heating or cooling
• Scope 3: All indirect GHG emissions (not included in Scope 2) occurring in the value chain, including air travel and financed emissions

The financed GHG emissions are calculated according to the PCAF Global GHG Accounting and Reporting Standard for the Financial Industry (2020) for the corporate loan book, mortgage portfolio and client asset portfolio. Scope 1, scope 2 and scope 3 related to air travel are calculated in accordance with the guidelines from the Greenhouse Gas Protocol.

Total emissions: 26.293 Megatonnes of CO2 (2021)

Scope 1	Scope 2	Scope 3
0.00349 Megatonnes of CO2 (2021)	0.00316 Megatonnes of CO2 (2021)	26.287 Megatonnes of CO2 (2021)

Scope 1 and 2

ABN AMRO reported a total of 0.00665 MtCO2e in scope 1 & 2 carbon emissions of their private-banking operations (down from 0.00938 MtCO2e in 2020).

GHG Emissions (Megatonnes of CO2e)

GHG Emissions	2018	2019	2020	2021
Scope 1 GHG Emissions - Tank-to-Wheel (TTW): Energy (natural gas + solar PV + other)	N/A	0.00280	0.00044	0.00055
Scope 1 GHG Emissions - Tank-to-Wheel (TTW): Mobility (lease cars - internal combustion engine)	0.01239	0.01049	0.00554	0.00294
Scope 2 GHG Emissions - Tank-to-Wheel (TTW): Energy (electricity, heating and cooling)	0.00192	0.00817	0.00340	0.00316
Scope 2 GHG Emissions - Tank-To-Wheel (TTW): Mobility (lease - electric vehicles)	N/A	N/A	N/A	N/A
Total Scope 1 + Scope 2 GHG Emissions	0.01431	0.02146	0.00938	0.00665

Note: (1) The increase in Scope 1 and 2 emissions from 2018 to 2019 is due to newly added data for ABN AMRO's activities outside of The Netherlands; (2) The decrease in Scope 1 and 2 emissions observed in 2020 and 2021 is mainly due to COVID-19 effects.

Scope 3

Over 2021, ABN AMRO reported a total of 26.287 MtCO2e (kilo tonnes of carbon-dioxide equivalents) in GHG emissions in scope 3 (down from 41.170 MtCO2e in 2020). The vast majority of this, over 80%, are from corporate loans and non-listed equity.

Scope 3 emissions from ABN AMRO's own operations relate to air travel, international business rail travel, hotel visits, mobility (commuting in private vehicles and business travel), public transport, home workplace, and IT. The increase in scope 3 GHG emissions related to own operations is due to the fact that prior to 2021 only business air travel was recorded under Scope 3 emissions related to own operations.

Scope 3 emissions from the lending portfolio relate to residential mortgages, corporate loans and commercial real estate. The scope 3 emissions related to lending and investment activities totaled 26.2 million tonnes, which is down 36% from 2020. This is also impacted by the wind-down of ABN AMRO's non-core Corporate & Institutional Banking operations. In 2021, their rating from the CDP - formerly the Carbon Disclosure Project - declined from A- to B.

GHG Emissions (Megatonnes of CO2e)

GHG Emissions	2018	2019	2020	2021
Scope 3 GHG Emissions - Total	30.257	29.447	41.170	26.287
Scope 3 GHG Emissions - Tank-to-Wheel Own Operations (TTW)	0.01179	0.01039	0.00148	0.047
Scope 3 GHG Emissions - Emissions of Lending Portfolio	30.245	29.437	34.536	19.743
Scope 3 GHG Emissions - Emissions of Client Assets	N/A	N/A	6.633	6.498
Scope 3 GHG Emissions - Well-to-Tank (WTT)	N/A	N/A	N/A	0.00796

Climate Policies and Plans

ABN AMRO has stated that they are subject to the French Law on Energy Transition and Green Growth. They also recently adopted further regulations through the Law of No. 2019-1147 regarding Energy and Climate.

Climate Statement

In July 2020, ABN AMRO released a climate statement acknowledging its role in achieving the Paris Agreement objective and stating that their purpose "Banking for better, for generations to come" and their bank-wide strategy to "Accelerate the sustainability shift" aligns with the Paris Agreement's goals. In this statement, the bank presents the 'ABN AMRO Climate Strategy'. The goal of this strategy is formulated as follows: "The ABN AMRO bank-wide goal is to bring our lending and client investment portfolio in line with at least a well-below 2-degree scenario and to support the transition to a net-zero economy in 2050. The bank mentions that key to achieving their goal is their cyclic approach of measuring, setting targets and reporting, which is taken at all relevant levels: their lending profile, their investment portfolio and their own operations. They mentioned that the cyclic approach follows from their commitments on climate such as the Principles for Responsible Banking and the Dutch Financial Sector Climate Accord and that their Climate Statement is a living document that will be updated at least annually to reflect their actions and endeavors.

Related to their investment profile, ABN AMRO has stated that they want to increase their sustainable investments (client assets) to 22.5 billion euros in 2020 and 30 billion euros by 2022. However, when comparing this to their total investments in client assets of EUR 213.9 billion in 2021, this represents just a meagre 14% of their investment portfolio.

Related to their own operations, ABN AMRO states that they banned business air travel for the trajectories Amsterdam - Brussel - Paris, and that they compensate their CO2 emissions related to air travel, car lease and the energy usage of the buildings they use. In their Integrated Annual Report 2021, they state that they do so by investing in VCS verified carbon emission reduction projects. According to research by Germanwatch (2016), VCS scores very high for the criteria 'climate integrity' (85%) and 'project viability' (72%), but scores a lot lower for the criteria 'biodiversity conservation' (5%) and 'human and community rights, stakeholder participation & sustainable community development' (2%). From the absence of strong provisions for the latter two criteria and other aspects that aim to guarantee long-term project viability, it follows that VCS is not a good choice if you are looking at benefits beyond carbon offsetting. Reforestation projects with such a complete disregard for biodiversity conservation could even result in ecosystem 'disservices'.

ABN AMRO furthermore adds to their statement that they do not yet know with certainty where they stand in their pathway to bringing their portfolios in line with the Paris Agreement and that measuring is therefore a crucial starting point. It is only in recent years that the bank started measuring their scope 3 emissions and benchmarking their energy portfolio against the Paris Agreement objective. They have stated that they are currently reviewing and updating the requirements for their corporate clients in the energy sector and that they are also reviewing the climate requirements for their corporate clients in other sectors.

ABN AMRO states that they are committed to climate action through, among others, the following initiatives:

1. Accounting for Sustainability (A4S)
2. Dutch Climate Accord (financial sector)
3. Equator Principles
4. Getting to Zero Coalition
5. Partnership Carbon Accounting Financials (PCAF)
6. Poseidon Principles
7. Science Based Targets initiative (SBTi)
8. Spitsbergen ambitie
9. Sustainable Development Goals (SDGs)
10. Task Force on Climate-related Financial Disclosures (TCFD) - Pilot 2.0 for Banks
11. UN Principles for Responsible Banking (PRB)
12. UN Principles for Responsible Investing (PRI)

Paris Alignment Report

In March 2021, ABN AMRO released a report called 'Guiding a Bank's portfolio to Paris: Our journey of Paris alignment 2021', in which they state the actions the bank is taking to achieve the Paris climate goals and how they measure their progress. In this report, the bank formulates their goals and targets for five identified sectors: (1) Business operations, (2) Energy (fossil fuels and power generation), (3) Commercial real estate, (4) Residential real estate - mortgages, and (5) Investment services.

One of the mentioned targets is to reduce the absolute Scope 1, 2 and 3 greenhouse gas emissions of its business operations by 80 percent in 2025 compared with 2015. However, steps still need to be taken in the area of carbon emission reporting in order to accurately measure ABN AMRO's total emissions and be able to implement reduction plans. For their investment services, the bank considers the starting point of the companies in the client's investment portfolio using a carbon emissions measurement that is primarily focused on documenting Scope 1 and Scope 2 emissions. Scope 3 emissions are not included in their analyses due to poor data availability and reliability and there are no specific thresholds that companies need to meet to be selected for investments.

By 2024, ABN AMRO aims to increase the proportion of renewable energy in their Energy portfolio as a whole (including all subsectors) to 45 percent. The bank has not committed itself to fully divest from carbon intensive energy.

By 2030, ABN AMRO is aiming for its commercial real estate portfolio to have a weighted average energy label A. The first intermediate goal is to have a weighted average energy label C for this portfolio in 2025, which can be achieved with existing and proven solutions like improved glazing, solar power and LED lighting. For the transition from energy label C to A, they rely on the expectation that new technologies will provide their clients with the necessary tools to reach this goal.

Due Diligence

Due Diligence

ABN AMRO refers to the OECD due diligence guidelines in its governance reporting, but does not provide explicit information on the implementation of these guidelines. They have stated that they test whether their clients comply with sustainability standards, such as the OECD Guidelines and the UN Guiding Principles on Business and Human Rights. In doing so, they investigate both the customer's own activities and the entire production chain. ABN AMRO scored on the lower side on the four assessment pillars for the policy assessments of Dutch banking groups. They scored a 5.6 regarding forest and biodiversity conservation, a 7.5 regarding human rights and animal welfare protection, and a 5.7 on transparency and accountability.

Animal welfare

According to the research Financing less meat and more plants (2021) ABN AMRO has a mediocre score regarding animal welfare as the bank does not set concrete targets for advancing the protein transition. According to Risking Animal Welfare (2019) ABN AMRO has provided loans totaling 77 million euros in the period 2014 to 2019 to 3 of the 28 researched high-risk companies that do not have or have very low standards for animal welfare. The companies that the bank provided loans to are Ahold Delhaize, Tyson Foods and WH Group. ABN AMRO also invested another 118 million euros to 15 of the 28 researched companies.

Forests and biodiversity

According to Funding destruction of the Amazon and the Cerrado-savannah (2020) ABN AMRO provided loans worth 2,090 million US Dollars to international soy and beef supply chains in the period from 2015 to 2020. The companies to which the bank provided loans are either directly or indirectly connected to deforestation in the Brazilian Amazon and the Cerrado-savannah. ABN AMRO provided the largest loan (namely 782.10 million US Dollars) to Cargill, a major US soy exporter. Cargill has been involved in numerous scandals including fatal food poisonings, deforestation, agricultural pollution, and allegations of child enslaved labor. ABN AMRO also provided a sizable loan to the Louis Dreyfus Company (namely 562.69 million US Dollars), a Dutch agricultural commodity trader known to source palm oil from deforested indigenous lands in the Peruvian Amazon.

Climate change

In the report Fossil fuel versus renewable financing by financial institutions active in the Netherlands (2021) it became apparent that in the last three years 71% of the loans that ABN AMRO provided in the energy sector went to fossil fuels.

The bank did mention in their climate statement, which was released in 2020, that they exclude new coal-fired power plants, the acquisition or building of thermal coal mines and large-scale agricultural plantations and ruminant farming from financing because of their impact on the climate.

Scandals and controversies

Dakota Access Pipeline

In 2016, a year after the Paris Agreement, ABN AMRO made an investment of 45 million US Dollars in Energy Transfer Equity (ETE), who financed the Dakota Access Pipeline. Forbes reported that, after the pipeline's first year of operation, it was transporting over 79,000 m3 of oil per day and had already transported 29.02 million m3 of oil. Besides the detrimental effects on the climate, the pipeline flows directly underneath the Missouri River - threatening the water source of many Americans - and crosses territories of indigenous nations, such as the Lakota Treaty Territory and Standing Rock Sioux Reservation, - infringing on their rights as native people. Following this, the planned construction of the Dakota Access Pipeline became subject to numerous protests for indigenous rights and climate change activism. In a press release published on February 2nd 2017, ABN AMRO stated that they will stop the financing of Energy Transfer Equity (ETE), the mother company of Energy Transfer Partners (ETP). ETP is one of the companies involved in the construction of the pipeline. ABN AMRO's decision was precedented by media publicity and protests by, among others, Oxfam Novib, Fossil Free NL and De Eerlijke Bankwijzer.

Money Laundering Scandal

On April 19 2021, ABN AMRO released a statement that it has accepted a settlement offer of 480 million euros from the Dutch Public Prosecution Service (DPPS) in connection with the DPPS' investigation into ABN AMRO' compliance with its obligations under the Dutch Anti-Money Laundering and Counter Terrorism Financing Act (Wet ter voorkoming van witwassen en financiering van terrorisme, AML/CFT Act). The DPPS accused ABN of violating anti-money laundering laws on a structural basis in its activities in The Netherlands during the period between 2014 and 2020. They stated that the bank "must have missed numerous signals of money laundering and other forms of financial-economic crime" because of failures in every business line its home market. Prosecutors said that the 480 million euro fine "reflected the amount of money the lender saved by failing to meet requirements". ABN AMRO stated that they had already identified shortcomings in the way they implemented their 'Client Life Cycle' processes. To address these issues, they have invested heavily in remediation and enhancement programs over several years. However, they recognized that, despite these efforts and intentions, their improvement programs have not had the desired effect.

Conclusion

ABN AMRO is a major financial player, being the third largest bank in The Netherlands. Despite its primary function within the Dutch financial sector, the bank has so far not set targets that align with the 1.5 degree target of the Paris Agreement. While the bank has made considerable steps in reporting their own scope 3 emissions since 2018, it is difficult to assess their reduction in emission compared to previous years due to the continued re-evaluation of the method and inclusion of different categories for their scope 3 emissions.

With regard to their investment portfolio, ABN AMRO does not currently have sufficient requirements that need to be met in order for a company to be eligible for investment. In the recent years after the Paris Agreement, ABN AMRO has invested and continues to invest in multiple controversial companies and projects, such as Shell, the Cambo Oil Field and Minerva Foods. Their retracting of financial support from controversial projects such as the Dakota Access Pipeline and the goal of increasing their sustainable investments to 30 billion euros by 2022 is a start. However, in comparison to their total investments in client assets in 2021, this would represent just a meagre 14% of their investment portfolio. In addition, the bank has not committed itself to fully divest form carbon intensive energy.

With regard to their own operations, ABN AMRO refers at times to the development of new technologies in the future that would be crucial to lowering their carbon footprint. However, it can be debated whether companies should rely on the assumption that new technologies will be developed to reach their goals and whether it is not better to develop targets that are realistic and reachable with current technologies.

ABN AMRO also reported that they offset a large quantity of their emissions through VCS certified carbon emission reduction projects. While VCS does well in certain aspects such as 'climate integrity' and 'project viability', it has zero to no regard of 'biodiversity conservation' and 'human and community rights, stakeholder participation & sustainable community development'. This makes it questionable whether VCS certified carbon emission reduction projects offer any benefits beyond carbon offsetting, potentially even resulting in ecosystem 'disservices' and whether these projects are viable on the long-term.

All in all, ABN AMRO displays themselves as a very ambitious company, with their purpose being "Banking for better, for generations to come" and their bank-wide strategy being to "Accelerate the sustainability shift". While they have made a start to develop targets that align with the Paris Agreement's objective, more ambitious goals and targets could and should be expected from a player like ABN AMRO. Throughout their Climate Statement, ABN AMRO downplays their own responsibility by referring to the lack of regulatory guidelines and the difficulty of obtaining scope 3 data and setting regulations for the companies they invest in.