Explore with expert partner organisations possible further Ethical Policy development in connection with animal testing and 'trophy hunting'. Chris Mills, Ethical Policy Manager

Commentary

Context Animal welfare issues have been prominent within the bank's Ethical Policy since its launch in 1992, and initially covered animal testing for cosmetic purposes, factory farming, the fur trade and blood sports. In the 1998 Ethical Policy review, the bank's position on animal testing was expanded to include a statement precluding investment in businesses involved in testing household products on animals. CIS is opposed to cruelty to animals; which is defined as indifference to the infliction of pain, as set out in legislation. It is envisaged that CIS' stance will evolve substantially as part of the development of a new CIS Socially Responsible Investment Policy.

Ethical Policy screening - Bank During 2003, bank Business Development Managers referred 28 finance opportunities in connection with animal welfare. In ten instances (as described below) a conflict was found and the business declined. In a further instance, the bank declined to partner a sportswear retailer promoting fur-lined garments.

Animal Testing During 2003, the bank campaigned with WWF-UK for the identification and phase out of persistent and bioaccumulative chemicals, further details here. Campaigning centred on the proposed EU Registration, Evaluation and Authorisation of Chemicals (REACH) programme. However, the campaign drew criticism from the British Union for the Abolition of Vivisection (BUAV),i who were concerned that the bank's position might lead to an increase in animal testing. The REACH consultation document, published in May 2003, proposed that any determination of bioaccumulation should be based on an assessment of aquatic species, with fish stock testing being the default position. Therefore, any increase in bioaccumulation testing might lead to a sizeable increase in animal testing. However, whilst the bank considered that the identification of bioaccumulation is absolutely essential, it did not agree with the EU legislation that fish stock testing was needed to demonstrate bioaccumulation in all instances, and replied to this effect in July 2003. For example, the bank argued that, where scientists have already discovered/demonstrated wildlife contamination exists (particularly in relation to human breast milk or tissue, marine mammals or top predators), then this, in itself, is sufficient proof of 'bioaccumulation'. In addition, the bioaccumulation of many chemicals can be determined in-vitro (i.e., without recourse to animal testing) via an octanol/water shake flask test or via high performance liquid chromatography i.e., organic chemicals with a Log Kow up to 6. However, the bank believes that, regrettably, there are a relatively small number of instances where in-vivo bioaccumulation testing may be necessary (e.g., with highly lipophilic substances) as in-vitro techniques are not yet advanced enough to consistently give an accurate and reliable result. This position is consistent with the bank's current Ethical Policy, which states that the bank should not invest in animal testing in so far as it relates to cosmetics and household products.

In 2004, the bank will sponsor a plenary session at an international conference which, amongst other things, will investigate the feasibility of moving forward in-vitro (non-animal) testing.

Tailored ethical products In May 2003, a bank branded generic affinity card was launched to support the League Against Cruel Sports.ii

Influence and action

Hunting As part of the League Against Cruel Sports' ongoing campaign to ban hunting with dogs in the UK, the bank supported a 'League' Parliamentary reception in March 2003. This event was attended by over 110 Members of Parliament and Peers, and took place while the Hunting Bill was in the committee stage, prior to its return to the House of Commons for further consideration.

Chemicals In July 2003, as part of its response to the EU REACH consultation, the bank argued that fish stock testing should not be the default position for the determination of bioaccumulation.

i www.buav.org/f_home.html
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ii www.league.uk.com/
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Performance

Bank - Animal welfare business declines 2003

	Estimated Income Foregone 2003
Food producer Conflict with the bank's position on intensive farming. This business was engaged in the annual intensive production of some 26 million chickens in Europe alone.	£10,000
Poultry breeder Conflict with the bank's position on intensive farming. This business provided some 40 percent of the annual global breeding stock of broiler chickens and turkeys for intensive production.	£1,000
Food producer Conflict with the bank's position on intensive farming. This business was engaged in the weekly intensive production of some four million chickens and 25,000 pigs.	£1,000
Toiletries manufacturer Conflict with the bank's position on animal testing of cosmetic products. This business manufactured moisturising lotions and did not have a fixed cut-off date for the testing of its ingredients on animals.	£28,500
Cosmetics manufacturer Conflict with the bank's position on animal testing of cosmetic products. This business manufactured cosmetic products and did not have a fixed cut-off date for the testing of its ingredients on animals.	£10,000
Healthcare and household products manufacturer Conflict with the bank's position on animal testing of cosmetic and household products. This business manufactured soap, detergents, cleaning and polishing preparations and did not have a fixed cut-off date for the testing of its ingredients on animals.	£2,000
Chemicals manufacturer Conflict with the bank's position on animal testing for cosmetic products. This business manufactured chemical intermediates, such as bactericides and fungicides, that are used in cosmetics products. The business did not have a fixed cut-off date for the testing of its ingredients on animals.	£1,000
Chemicals manufacturer Conflict with the bank's position on animal testing for cosmetic and household products. This business manufactured chemical intermediates, such as surfactants, that are used in detergents, cleaners, household soaps and cosmetics. The business did not have a fixed cut-off date for the testing of its ingredients on animals.	£1,000
Landowner Conflict with the bank's position on blood sports. This business allowed licenced fox hunting on its land. For the purposes of Ethical Policy implementation, businesses that provide land for fox hunting are considered actively involved in this activity.	£500,000
Campaigning group This organisation campaigned on animal welfare issues. Concern that the organisation was engaged in practices that were not constructive to the progression of animal welfare issues.	£2,000
Total	£556,500

Source: Sustainable Development Team 2004

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