Monitoring, Evaluation and Exclusion List

Monitoring Compliance

Monitoring of the S&E performance of direct investments and FIs financed by Norsad is undertaken by means of annual S&E monitoring reports and periodic monitoring visits when necessary. In cases where the investee company has accepted to carry out an S&E Action Plan, there maybe more frequent follow up in the initial year(s), according to the time frame as set in the action plan.

Consistent with our categorization approach, Category A direct investments and S&E Risk FI clients will be accorded a higher degree of annual scrutiny than other investments. The level of monitoring of all clients will depend on the nature of the S&E risks and Norsad’s comfort with the client’s ability to effectively and responsibly manage the S&E impacts, and will vary from a simple compliance statement, reliance on company or third party information, or more comprehensive reporting and site visits as appropriate.

All Category A projects, require appointment of an independent social and/or environmental expert, or require that the borrower retain qualified and experienced external experts, to verify its monitoring information.

Monitoring and compliance requirements are formalized in our legal documentation. Where an investee company is non-compliant with its S&E commitments, Norsad will work with the client to bring it back into compliance to the extent feasible, and if the client fails to re-establish compliance, exercise remedies when appropriate.

Evaluation

Norsad recognizes that there will be times when we are not able attain our S&E sustainability commitments to their fullest potential, or where the actions of our clients result in disproportionately negative S&E impacts. For us these are important learning opportunities that will allow us to reflect on and evaluate both our actions and those of our investee companies.

We will therefore conduct ex post reviews of our investments to determine ways in which we can improve our sustainability approach and in so doing further contribute to the achievement of our development objectives.

Norsad Exclusion List