Going forward the bank should actually apply the Equator Principles, a voluntary credit risk management framework with a set of guidelines for environmental and social risk assessment in sustainable project finance activities.

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Putting the cart before the horse, the EPA issued preliminary clean up goals for dioxin on December 31, 2009 before the agency had completed a new risk assessment on the chemical, widely perceived as one of most toxic environmental pollutants (the assessment is due by the end of this year).

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The SEC, he said, has often updated its assessment of what constitutes material risk for investors, beginning with new environmental criteria following the Love Canal toxic dump scandal of the late 1970s.

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