Comments on EDC's Draft Disclosure and Environmental Review Policies - September 16, 2005

Policy and Government Relations
Export Development Canada (EDC)
151 O'Connor Street
Ottawa, ON K1A 1K3

September 16, 2005

Re: Comments on EDC's draft disclosure and environmental review policies

Dear Director, Policy and Government Relations:

The Halifax Initiative Coalition is pleased to submit our comments on the new draft Environmental Review Directive (ERD) and Disclosure Policy. We are particularly pleased at this opportunity, as it was not afforded in 2001 when EDC first adopted its ERD. The early consultation, this comment period and some of the revisions made in the new drafts reflect the positive developments at EDC as it strives to do better business.

The Halifax Initiative is a coalition of 23 Canadian non-governmental organisations concerned about the social, human and environmental impacts of public financial institutions. Through the Coalition, we promote adherence by export credit agencies (ECAs), especially EDC, to internationally accepted standards regarding human rights, the environment and sustainable development.? A list of our members can be found at

Our detailed comments are in the attached document. In sum, we urge EDC to take this opportunity to not only reflect its own best practice in the new policies, but at a minimum, existing best practice among other national ECAs. With the largest team of staff dedicated to policy implementation of any ECA, EDC's new policies should reflect international best practice. For example,

  • The British, Japanese, Australian, French, American, Belgian, Finnish, Swiss and Dutch ECAs all require more in regards to the disclosure of environmental assessment information than what EDC would be required in the current draft ERD.
  • The Overseas Private Investment Corporation (OPIC) in the United States discloses individual transaction information for financing and insurance transactions. As well, it notifies stakeholders when Category A projects are listed on its website.
  • The Asian Development Bank releases monitoring reports.
  • US Ex-IM is held to Freedom of Information Act legislation.
  • A number of ECAs have an exclusion list of projects that will not be supported on environmental or social grounds.

More examples of best practice and the subsequent recommendations for changes to the draft policies are attached.

In this revision, we look forward to seeing EDC move beyond the minimum requirements of the Common Approaches, and at the very least meeting the new bar set by other ECAs.


Fraser Reilly-King
on behalf of the Halifax Initiative Coalition