Page 289 - 2019 6th AFIS & ASMMA

But I think what is more complicated is probably has to do the no Now the final requirements refer to the minimum social safeguards Session I
significant harm assessment. Because if you look at the current green that issuers need to comply. For this purpose, the eight fundamental
covered bond market, there are only a few programs that actually discuss conventions of the International Labor Organization were chosen. And
negative impacts at all, and where they do, they definitely don't discuss here it will prove really hard for issuers to actually prove that they meet
all the "do no significant harm" criteria, proposed by the Technical Expert all eight conventions. So, the question is, is it sufficient that an issuer
Group. And I think that if you would ask an issuer to identify, on a loan signs up to these conventions? Does it actually need to prove that it
by loan basis, whether in the case of a construction, whether actually 80 meets all the criteria, not only on a known entity level, but also on its
percent of the ways were reuse of recycled, or whether where a building project level? And I think that if you would have to do that as an issuer,
is built in a water-scarce area, that of water consumption is indeed only that would be quite challenging, particularly within criteria such as equal
80 percent of the average, it would be very hard for them to prove. remuneration for instance.

So, I think if I read through the proposals of the Technical Expert
Group, the idea is to take a more pragmatic approach, because they say
that a lot of their criteria are already built on existing regulation. So, what
this would actually mean for green bond issuers is that they just need to
check as of what date these regulatory requirements do make reference to
these specific "do no significant harm" criteria.

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