Incorporating ESG Risk in Bank-Lending in Bangladesh

International Research Journal of Finance and Economics

ISSN 1450-2887 Issue 120 March, 2014

http://www.internationalresearchjournaloffinanceandeconomics.com

Incorporating ESG Risk in Bank-Lending in Bangladesh

Sarwar Uddin Ahmed

School of Business, Independent University Bangladesh, Dhaka, Bangladesh

E-mail: [email protected]

Tel: +880-2-8401645; Fax: +880-2-8401991

Matiur Rahman

College of Business, McNeese State University, LA, USA

E-mail: [email protected]

Tel: +1-337- 4755577; Fax: +1-337- 4755986

Abstract

Incorporation of environmental, social and governance (ESG) risk in bank lending

process has been greatly emphasized for ensuring sustainability of banks. The central bank

of Bangladesh has also voiced concerns by formulating two policy guidelines

simultaneously. However, it failed to suggest ways to consider ESG risk quantitatively in

lending decisions. The objective of this study is to close in this gap and suggest ways to

incorporate ESG risk in bank lending process. A revised credit risk grading model has been

suggested by adding environmental, social and governance risk factors. Policy

recommendations have also been suggested for ensuring effective incorporation of ESG

factors in lending decisions by private commercial banks in Bangladesh.

Keywords: ESG risk, credit risk management, private commercial banks, sustainability

1. Introduction Banks are now rapidly shifting focus towards sustainability by promoting efficient uses of resources

without harming the society and the environment. For a wealth maximizing entity, this shift is not

entirely voluntary. The tie between banking and sustainability has stemmed from the combined effect

of growing burden of liability resulting from potential borrower default due to non-compliance of

environmental, social, and governance (ESG) standards and opportunities for new businesses (IISD,

2011). It has become challenging for banks to find ways to tackle current and future environmental

problems, such as, climate change, deforestation, air pollution and biodiversity loss. At the same time,

it is imperative for them to identify and secure new business opportunities that benefit them and the

customers (UNEP-NATF, 2007). Banks’ new pursuit for sustainable development offers both threats

and opportunities.

In the global financial sector, a number of ESG risk incorporation norms and guidelines, such

as UNEP-FI, UPI-FINANCE 2000, Equator Principles, which are voluntary in nature have emerged

during the last two decades. “A Statement by banks on the Environment and Sustainable

Development” signed by 30 banks under the auspices of the United Nations Environment Program

(UNEP) in Rio Earth Summit 1992, provides the basic guidelines to incorporate environmental issues

in lending decisions.Currently, a total of 200 financial institutions, out of which 138 banks in 47

countries are signatories of UNEP- FI (UNEP-FI, 2011). Among the existing guidelines, the Equator

Principles launched in 2003 received wide acceptance in recent years which is based on the

International Research Journal of Finance and Economics - Issue 120 (2014) 24

environmental and social policies, and guidelines of the International Finance Corporation (IFC) (EP,

2012). At present,73 financial institutions operating in more than one hundred countries are committed to

using the EPs to manage environmental and social risk in their project finance businesses (EP, 2012).

In contrast, the status of environmental risks management by banks is not satisfactory in least

developed countries like Bangladesh, largely due to inadequacy and poor enforcement of existing laws

and also inadequate pressure from civil society and interest groups. In June 1997, Bangladesh Bank

(BB), the Central Bank of the country, asked all commercial banks (BRPD-No-12 dated 8.10.1997) to

undertake necessary steps for implementing the provisions of Environment Conservation Act 1995

(ECA). Commercial banks are asked to ensure that steps have been undertaken to control

environmental pollution before financing a new project or providing working capital financing to the

existing enterprises. Later on, a Guideline on Corporate Social Responsibility (CSR) was circulated by

Bangladesh Bank in 2008 in order to encourage the practice of social responsibility among banks and

financial institutions. As a continuation in April 2010, BB published annual review of CSR practices

by the scheduled banks operating in Bangladesh and emphasized socially and environmentally

responsible banking practices (Bangladesh Bank, 2010).

In the follow-up pursuit to encourage green banking and incorporation of ESG risk in the

banking process, Bangladesh Bank (BB) almost simultaneously published and circulated “Policy

Guidelines for Green Banking” and “Environmental Risk Management Guidelines” in 2011. By

publishing these guidelines, Bangladesh Bank has claimed to be the only central bank which has issued

an indicative guideline for green banking (Rahman, 2011). These have greatly emphasized the

adaptation of a comprehensive green banking policy by commercial banks within December 2013

(TDS, 2011). Some incentives were declared for banks promoting green banking such as higher points

in CAMELS rating, priority in opening new branches, separate treatment in capital adequacy

calculation, and positive publicity by inclusion in the list of top ten green banks, etc. Table 1

summarizes below the regulations affecting ESG risk management practices of banks in Bangladesh.

Table 1: Regulations Affecting ESG Risk Management Practice of Banks in Bangladesh

Year Events Purpose/ Effect Impact on Banks

1993 Lending Risk Analysis (LRA) by

FSRP

First regulatory move to introduce best

practice in bank lending.Compulsory for

granting loans above BDT 10 million.

Did not include environmental

and social risks

1995

Environment Conservation Act by

Department of Environment

(DOE)

Provisions regarding environmental

conservation

The first regulation related to

environment in Bangladesh

1997

Environment Conservation Rules,

1997 by Department of

Environment

Made Environmental Clearance

Certificate mandatory

Based on this rule, Bangladesh

Bank initiated environmental

good practices

1997

Circular on Environmental

Compliance by Bangladesh Bank

(BRPD Circular No. 12, 1997)

Directive by the central bank (Bangladesh

Bank) to adhere to Environment

Conservation Rules 1997 and control

environmental pollution in financing

The first circular directing

banks to be environmentally

responsible

2005 Credit Risk Grading Manual

(CRGM) by Bangladesh Bank

Detailed risk management guidelines

replacing LRA and made applicable to all

loans

Did not consider

environmental and social risks

2008

Guideline on Corporate Social

Responsibility by Bangladesh

Bank (DOS Circular No. 1, 2008)

Directives to include environmental and

socially responsible practices in banking

and borrower screening processes

Stressed on socially and

environmentally responsible

banking practices

2010

Review of CSR Initiatives in

Banks (2008 & 2009) by

Bangladesh Bank

Reported CSR compliance status of the

banks

A pressure on the banking

sector to be environmentally

and socially responsible

25 International Research Journal of Finance and Economics - Issue 120 (2014)

Table 1: Regulations Affecting ESG Risk Management Practice of Banks in Bangladesh - continued

2011 Policy Guidelines for Green

Banking by Bangladesh Bank

The policy was divided into three phases

and set three-phased time lines to

promote green banking.BB recommended

to prioritizes eco-friendly business project

financing Compliant banks will get points

under management component of

CAMELS rating BB will announce top

ten banks in green banking and allow to

open branches on a priority basis

No directions were provided

to quantify environmental

risk in CRM

2011 Environmental Risk Management

Guidelines by Bangladesh Bank

Guidelines to incorporate environmental

risk into credit risk management structure

The first qualitative guideline

to rank environmental risk of

lending

Sources: Compiled and rearranged from (Ahmed and Uchida, 2012)

In Bangladesh, implementations of these guidelines by banks are largely voluntary in nature.

Given the nature of bank management practices in Bangladesh, these will get less priority as these are

not mandatory. Also, the credit assessment and management framework prescribed by Bangladesh

Bank are currently followed by all scheduled commercial banks. Credit Risk Management (CRM) does

not include any risk criteria for considering environmental, social and governance aspects of a

particular loan project. Banks are asked to launch their own environmental risks assessment framework

and no clear direction is provided regarding quantification and inclusion of environmental risk in

CRM. However, Bangladesh Bank could not provide a clear quantitative guideline for incorporating

social and environmental aspects into the lending decision making process (Habib, 2010).

In this background, the objective of this study is to fill in this gap and suggest ways to

incorporate environmental, social and governance (ESG) criteria in Credit Risk Management (CRM)

on a compulsory basis and to offer a common platform for all banks for managing these risks in a

holistic manner. The remainder of the paper is structured as follows. Section II briefly discusses credit

risk management practice in Bangladesh. Section III outlines the methodology. Section IV is on

incorporation of ESG risk. Section V proposes credit risk grading system. Section VI offers

conclusions and remarks. Section VII advances policy recommendations.

2. Credit Risk Management Practice 2.1. Historical Development

Credit Risk Management System development in Bangladesh has a long history. In order to reduce

loan losses, Bangladesh took a regulatory step in 1993 to introduce the first quantitative approach to

analyze lending risk. Upon recommendation from the World Bank sponsored Financial Sector Reform

Project (FSRP), the Lending Risk Analysis (LRA) manual was introduced in 1993. Use of this manual

was made compulsory for the banks and other financial institutions for loan size of BDT 10 million

and above (BB, 2005).

However, the LRA manual has various shortcomings, such as, high subjectivity, inability to

provide post-sanction follow-up and grading for monitoring purposes, considered only financial and

security risk (Kabir et al, 2010). Accordingly, in order to overcome the limitations of LRA, Bangladesh

Bank developed guidelines for credit risk management by banks recommending the introduction of

Risk Grade Score Card (RGSC) for risk assessment of credit proposals (BB, 2005). But this created

confusions among the financial institutions with two sets of lending risk standards.

2.2. Current Credit Risk Grading System

In order to resolve the perplexities developed due to two contrasting sets of standards (LRA and

RGSC), Bangladesh Bank took the initiative to integrate the lending analysis standards into one Credit


Risk Grading Model. Accordingly, Credit Risk Grading Manual (CRGM) was developed for

implementation in 2005 by banks and financial institutions in processing credit decisions and

evaluating the magnitude of risk involved. It has been made compulsory for all banks for all exposures

and all volumes except those covered under Consumer and Small Enterprises Financing Prudential

Guidelines and also under The Short-Term Agricultural and Micro-Credit. In this manual, lending

projects were graded in eight categories as follows:

Table 2: Credit Risk Grading Scales

Grading Abbreviation Review Frequency

Superior SUP Annually

Good GD Annually

Acceptable ACCPT Annually

Marginal/Watchlist MG/WL Semiannually

Special Mention SM Quarterly

Sub standard SS Quarterly

Doubtful DF Quarterly

Bad & Loss BL Quarterly

Source: Credit Risk Grading Manual (BB, 2005)

3. Methodology The research methodology involves analyses of both primary and secondary data. As a first step,

secondary data are gathered from multiple sources to have an idea about the current practice of ESG

risk management. The sources include various publications of Bangladesh Bank (BB), Bangladesh

Securities and Exchange Commission (BSEC), Dhaka Stock Exchange (DSE) and UNEP Finance

Initiatives.

3.1. Survey Instrument

A primary survey has been conducted with a structured questionnaire to learn about the current status

and to seek suggestions for ESG factors incorporation in lending decisions. The questionnaire was

developed, based on the guidelines provided in EP(2009), BB (2011a and 2011b), UNEP-FI-ATF

(2007), Cowton and Thompson (2000) and Ahmed et al (2014). The questionnaire contains questions

ranging from general status to specific ones on ESG risk incorporation of each bank.

3.2. Sample

There are 47 scheduled banks operating in Bangladesh, regulated by Bangladesh Bank under the

Bangladesh Bank Order, 1972 and the Bank Company Act, 1991. Among them, there are 30 private

commercial banks (PCBs). This study covers all the PCBs. The questionnaires are filled out by the four

key officials working in the credit department at the head office of the respective bank during

September through December, 2012. The responses are cross-matched with available public

information on each bank, e.g., annual reports, websites, regulatory notifications and newspaper

articles. Also, the data have been complemented and validated with the Bangladesh Bank official

responsible for auditing and inspecting the PCBs. Finally, the screened data of each bank are used in

this study for analyses.

3.3. Credit Risk Grading

Based on the opinions found in this survey and credit risk grading mechanism suggested in various

literatures a revised credit risk grading process has been suggested. Fig. 1 elaborates on it as follows:


Figure 1: Risk factors to be included in Credit Risk Grading

4. Incorporation of ESG Risk 4.1. Importance of Incorporating ESG Risk

With regard to the importance of incorporating ESG risk in credit assessment, 100% of the respondents

commented that it is important and should be integrated. This certainly expresses the positive attitude

of the banks and acknowledgement of its importance by the banks. Responses in this regard are shown

in Fig. 2 as follows:

Figure 2: Importance of incorporating ESG risk

Source: Survey Results

4.2. Current Measurement of ESG Risk

About the question regarding the current ways the banks are measuring ESG risk, 90% of the banks

reported that they are doing it qualitatively. Whereas, only 10% stated that they are quantifying it, but

the method of quantification is not clear. Hence, there is a problem with regard to the quantification of

ESG risk as reported by the banks. Fig. 3 shows the responses as follows:


Figure 3: Current measurement of ESG risk

5. Proposed Credit Risk Grading System 5.1. Proposed Credit Risk Grading System

Based on the findings of the survey, guidelines provided by Bangladesh Bank, practice suggested by

EP, UNEP-FI-ATF, UNEP-FI, a revised framework is proposed in this study for incorporating ESG

risk components in lending decisions ((EP, 2009; BB, 2011a and 2011b; Ahmed et al, 2014).

5.2. Risk Component Weights

Under the proposed risk grading system environmental, social and governance risk factors are included

with Financial Risk, Business/Industry Risk, Management Risk, Security Risk, and Relationship Risk.

This incorporation changes the risk component weights. A total of 20% risk weights were reduced

from the existing five categories of risk on a proportionate basis. In assigning the credit risk weights,

guidelines provided by the Bangladesh Bank are followed.

Accordingly, the risk weights are 40% in financial risk, 14% in business/industry risk, 10% in

management risk, 8% in security risk, 8% in relationship risk, 10% in environmental risk, 6% in social

risk and 4% in governance risk. They are shown in Table 3 as follows:

Table 3: Risk Components and Weights

Risk Components Existing Weight Revised Weight

Financial Risk 50% 40%

Business/Industry Risk 18% 14%

Management Risk 12% 10%

Security Risk 10% 8%

Relationship Risk 10% 8%

Environmental Risk 10%

Social Risk 6%

Governance Risk 4%

Total 100% 100%

5.3. Revised Credit Risk Grading Score Sheet

A revised credit risk grading score sheet has been suggested by incorporating ESG risk components.

However, all of these might not be applicable to all categories of risk. In that case, the risk factor

should be left blank and the total denominator be reduced by 0.5 points for each such case. Tables 4-11

below show how various types of risks are to be calculated.


Table 4: Calculation of Financial Risk

Criteria Weight

Score A. Financial Risk 40%

1. Leverage: 12

2. Liquidity: 12

3. Profitability: 12

4. Coverage: 4

Total Score–Financial Risk 40

Table 5: Calculation of Business Risk

Criteria Weight

Score B. Business/Industry Risk 14%

1. Size of Business 3

2. Age of Business 3

3. Business Outlook 2

4. Industry Growth 2

5. Market Competition 2

6. Entry/Exit Barriers 2

Total Score-Business/Industry Risk 14

Table 6: Calculation of Management Risk

Criteria Weight

Score C. Management Risk 10%

1. Experience 4

2. Second Line/ Succession 3

3. Team Work 3

Total Score-Management Risk 10

Table 7: Calculation of Security Risk

Criteria Weight

Score D. Security Risk 8%

1. Security Coverage (Primary) 4

2. Collateral Coverage 2

3. Support (Guarantee) 2

Total Score- Security Risk 8

Table 8: Calculation of Relationship Risk

Criteria Weight

Score E. Relationship Risk 8%

1. Account Conduct 3

2. Utilization of Limit 2

3. Compliance of Covenants / Conditions 2

4. Personal Deposits 1

Total Score-Relationship Risk 8

Table 9: Calculation of Environmental Risk

Criteria Weight

Parameter Score F. Environmental Risk 10%

Compliance with environmental laws

• Fully complies

• Partially complies

• Does not comply

0.50

0.25

0


Table 9: Calculation of Environmental Risk - continued

Project location vulnerability from environmental perspectives

• Totally safe

• Potentially vulnerable

• Vulnerable

0.50

0.25

0

Protection against climate change impacts such as cyclones,

storm, floods and droughts

• Well protected

• Partially protected

• Vulnerable

0.50

0.25

0

Commitment of the client for environmental management

• Well committed

• Partially committed

• Not committed

0.50

0.25

0

Provision for solid waste management

• Full provision

• Partial provision

• No provision

0.50

0.25

0

Provision for wastewater management such as Effluent

Treatment Plan (EFT): industries; Sewerage: Housing

• Full provision


• No provision

0.50

0.25

0

Provision for handling, storage and management of hazardous

materials and chemicals

• Full provision


• No provision

0.50

0.25

0

Air emission prevention and control measures

• Full provision


• No provision for

0.50

0.25

0

Noise pollution control measures

• Full provision


• No provision

0.50

0.25

0

Fire or explosions prevention and control measures

• Full provision


• No provision

0.50

0.25

0

Provision for genetic resource management (for pharmaceutical

industries)5

• Full provision


• No provision

0.50

0.25

0

Provision for bioethics management (for pharmaceutical

industries)

• Full provision


• No provision

0.50

0.25

0

Appropriate measures to control dust pollution

• Full provision


• No provision

0.50

0.25

0

Provision for odour prevention and control

• Full provision


• No provision

0.50

0.25

0

Environmental requirement of the buyer or importer

• Fully complies

• Partially complies

• Does not comply

0.50

0.25

0

Periodic environmental monitoring arrangements

• Full arrangement

• Partial arrangement

• No arrangement

0.50

0.25

0

Environmental impact of energy and resource consumption

• Not detrimental

• Partially detrimental

• Detrimental

0.50

0.25

0

Environmental impacts associated with products and services

• Fully considered

• Partially considered

• Does not consider

0.50

0.25

0


Table 9: Calculation of Environmental Risk - continued

Potential for new regulations to have negative impact on

product or service acceptability

• Absolutely no such possibility

• Some possibility

• Not clear

0.50

0.25

0

Potential new markets for environmental services and

environmentally friendly products

• Good potential

• Some potential

• Not clear

0.50

0.25

0

Total Score- Environmental Risk 10

Table 10: Calculation of Social Risk

Criteria Weight

Parameter Score G. Social Risk 6%

1. Workplace health, safety

and working conditions

• Surpass the standards

• Maintains minimum standard

• Does not maintain good working condition

0.50 0.25

0

2. Equal opportunity in

employment

• Implemented equal employment opportunity policy

• Has a written equal employment opportunity policy

• No equal employment opportunity policy

0.50 0.25

0

3. The use of forced or

child labor

• Does not employ forced or child labor and discriminate

between workers

• Does not employ forced or child labor

• Employs forced or child labor

0.50 0.25

0

4. Involvement of

employees in

management

• Allow employee involvement and train them to do so

• Allow employee involvement

• Does not allow employee involvement

0.50 0.25

0

5. Freedom of association

in union/ society

activities

• Allow union activities and managers meet union leaders

periodically

• Allow union activities

• Does not encourage union activities

0.50 0.25

0

6. Profit sharing,

performance bonuses

and stock option

• Allow profit sharing and performance bonuses and stock option

• Allow profit sharing / performance bonuses / stock option

• Does not allow profit sharing and performance bonuses and

stock option

0.50 0.25

0

7. Caring activities for the

employee family and

children

• Provide l child care leave and facilities

• Provide leave for child care

• Does not provide leave for child care

0.50 0.25

0

8. Training and

development of human

resources

• Sponsor universal educational program and training

• Sponsor training programs

• Does not sponsor training programs

0.50 0.25

0

9. Handling of transfer and

dismissal

• Avoid dismissal and in unavoidable circumstances offers

relocation support

• Avoid dismissal

• Dismisses employees without providing explanation

0.50 0.25

0

10. Preparation for

retirement of employees

• Offer programs to prepare employees for retirement by

social engagement

• Offer program to prepare employees for retirement.

• Does not care about the retirement of employees

0.50 0.25

0

11. Community relations

• Maintain relation and take feedback from the community

• Maintain relation with the community

• Does not maintain relation with the community

0.50 0.25

0

12. Charitable donations

• Fund independent charitable trust

• Make cash or kind charitable donations regularly

• Does not make charitable donations

0.50 0.25

0

Total Score- Social Risk 6


Table 11: Calculation of Governance Risk

Criteria Weight Parameter Score

H. Governance Risk 4%

1. Board size, structure and

composition

• Fully complies with SEC CG Guideline 2006

• Meets minimum standard

• Vague

1 0.50

0

2. Frequency and quality of board

meeting

• Held regularly and members actively participate

• Held regularly

• Not held regularly

1 0.50

0

3. Meeting with stakeholders and

proper records of minutes

• Meets regularly with all stakeholders

• Meets regularly with the stockholders

• Does not meet regularly with stakeholders

0.50 0.25

0

4. Disclosure of performance through

financial statements in annual reports

• Three yearly financial statements are published

• Financial statements are published

• Financial statements are not published regularly

0.50 0.25

0

5. Disclosure of Corporate Social

Responsibility (CSR) activities

• Both annual reports and website

• Only in annual reports

• Does not disclose

0.50 0.25

0

6. Audit committee structure and

independence of auditors

• Have audit committee with independent member

• Have audit committee but no independent member

• There is no separate audit committee

0.50 0.25

0

Total Score- Governance Risk 4

Grand Total- All Risk 100

6. Conclusion and Remarks While the importance of environmental, social and governance (ESG) factors in lending processes of

banks is widely discussed, there is no quantitative approach to do so. This study is a modest attempt to

fill in this gap by conducting an in-depth study in the context of Bangladesh. Accordingly, this study

has made a number of significant contributions in the domain of ESG risk management. There is a

dearth of literatures, both theoretical and empirical, discussing ESG risk management approaches of

developing countries. ESG risk management status, approach and recommendations outlined in this

study are expected to assist policy makers and regulators in developing countries to formulate ESG risk

management policies for banks. Finally, ESG risk management approach recommended in this study

will help practitioners incorporate ESG factors in quantitative credit risk grading.

Banks in Bangladesh are still in evolving stage with regard to the integration of ESG factors in

credit risk management. However, the bankers and the regulators (Bangladesh Bank and SEC) show

positive attitude towards such integration. Policy measures, such as, building awareness, developing

techniques to incorporate ESG factors, reporting and evaluating performance, and providing incentives

are needed to reap further benefits. ESG status reported, motivating factors revealed and risk grading

techniques recommended in this study might be used as a benchmark.

This study has some limitations. For example, the sample choice of the study is based only on

the scheduled private commercial banks (PCBs). State-owned banks or the specialized banks which

also make significant volumes of loans are not considered in this study. Thus, the findings of this study

cannot be generalized for all banks in Bangladesh. However, the ESG risk quantification methodology

as proposed in this study can also be applied by other categories of banks for the same nature of

operation. To close, further research is needed on this topic because of growing interests in it among

policymakers and academicians.

7. Policy and Recommendations This research has a number of significant and practical implications for practitioners, policymakers and

scholars, particularly for those who are in the domain of dealing with ESG risk management.


Formulating a credit risk grading system is not adequate enough to warrant successful incorporation of

ESG factors in lending decisions, particularly in developing nations. The policymakers may be guided

by the following policy recommendations and summarized through Fig. 4, as shown below:

Figure 4: Policy Recommendations for ESG Risk Incorporation

A. Short-Term (One year to less than two years)

In the short-run, the policymakers may concentrate on building awareness and capacity of the relevant

stakeholders such as bank executives, credit risk analysts, borrowers, investors and also regulators.

This will prepare them in terms of policy and techniques to deal with ESG risk.

B. Medium-Term (Two years to three years)

Once the ESG risk factors incorporation policy and techniques have been developed, next the

policymakers should take initiatives to implement them. Bangladesh Bank as the central bank should

provide a new CRGM to the banks by incorporating ESG risk factors quantitatively.

C. Long-Term (Above three Years)

A standard uniform reporting and evaluation format should also be developed under the leadership of

the Bangladesh Bank to disclose and report ESG risk management practices and lending risk exposure

of individual banks. These reports should be disclosed to public through annual reports and web sites.

In the long run, the policymakers should try to achieve what can be termed as DEAR: Disclosure,

Evaluation, Advice, and Reward.

Finally, positive (negative) performance or initiatives must be rewarded (punished). Bangladesh

Bank in its Green Banking Policy Guideline (BB, 2011b) already declared rewards such as improved

CAMELS rating, preference in opening new branches, inclusion in the list of top 10 green banks, etc.

These are good initiatives, but a more distinct reward system, such as, some rating index like Dow

Jones Sustainability Group Indices (DJSGI) might be developed. This will motivate the banks to be

more conscious of ESG risk factors to benefit themselves.


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Business Review of AGU, 91(4), pp. 55-66.

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Social Performance: Linkage towards Sustainable Development”. Corp. Soc. Responsib.

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[3] Bangladesh Bank, 2005. “Credit Risk Grading Manual,” Dhaka, Bangladesh.

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[14] The Daily Star (TDS), 2011. “BB Draws Green Banking Roadmap” (published in Feb 28, 2011).

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[16] UNEP-FI-ATF, 2007. “Banking On Value: A New Approach to Credit Risk in Africa”, a report of the

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Incorporating ESG Risk in Bank-Lending in Bangladesh

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