FMO signed up for the SMART Campaign and endorses the Client Protection Principles.

The CPPs aim to facilitate a risk-based assessment of financial institutions, non-banking financial institutions and corporates providing finance to natural persons. CPPs define the minimum standards that end-clients should expect to receive when doing business with an entity providing financing to natural persons. FMO contractually agrees ESG conditions and reporting requirements with its clients; these ESG conditions could include implementation of a Consumer Protection Principles Action Plan (CAP). FMO uses capacity development funds to conduct CPP assessments and draw CPP action plans through external consultants.

FMO has embedded a CPP assessment in its investment process whereby high risk clients are identified early on (all clients rated on a risk scale ranging from A, B, or C). Depending on this risk category, extra attention is dedicated during Due Diligence on CPP issues, consultants are hired to do a CPP assessment, and in some cases a CPP action plan is drafted. The process is systematic and is applied uniformly to all new investments in financial institutions, investment funds, and holdings. FMO continues to refine and expand its approach to Client Protection. Client protection issues extend beyond the financing of financial institutions, for example in off-grid energy solutions.

In a few cases in the past, FMO has used margin reduction incentives for CPP implementation.
FMO occasionally resorts to Client Protection covenants or clauses in shareholder agreements, but these are not core tools that the bank uses to address client protection.