July 16, 2007
153 Chapel Street
Ottawa ON KIN 1H5
Dear Ms. Keenan:
I am writing to comment on the recent report, Dirty Business, Dirty Practices: How the Federal Government Supports Canadian Mining, Oil and Gas Companies Abroad, to which you contributed. Firstly, let me acknowledge the efforts that the Halifax Initiative and others have made to participate in the discussion and debate around Canadian government support to Canadian mining and oil and gas companies operating abroad. This is a topic that concerns us all.
In the interest of accuracy, it is only fair to point out certain errors concerning EDC activities as referred to in the report. You state that "EDC does not require companies to consult with communities that would be affected by proposed investments". In fact, our Environmental Review Directive (ERD) explicitly states that "EDC expects that for each Category A project public consultations with affected parties, if any, will be held in the host country, and that the results of these consultations will have been taken into account in the environmental assessment of the project". Furthermore, we benchmark our review of environmental and social impacts of projects against international standards, notably World Bank standards which contain requirements for community consultations.
In the human rights section of the report, you incorrectly describe EDC's analysis of human rights impacts. You state that "EDC focuses on how human rights violations could adversely affect a client company's investment". In fact at EDC, human rights impacts are, in the first instance, analyzed from the perspective of how a project might affect the local human rights situation. An assessment of how the local human rights situation might affect a project is conducted as well, but is of a secondary nature.
We would be pleased to meet with you and the co-authors of the report to explain our processes and practices on these and other issues.
Vice-President, Corporate Communications and External Relations