December 9, 2004
Mr. Gilles Ross
Acting President and CEO
Export Development Canada
151 O'Connor Street
Ottawa, ON K1A 1K3
Dear Mr. Ross,
In July 2003, the NGO Working Group on EDC, a Working Group of the Halifax Initiative Coalition, filed a complaint with EDC's Compliance Officer. The complaint alleged that EDC had failed to comply with a number of its policies in supporting the Cernavoda 2 nuclear reactor in Romania, and provided evidence to substantiate the allegations. EDC's Compliance Officer investigated the complaint, an internal audit was conducted, reports released in May and June, and the file closed on June 15th 2004.
Please find attached some comments outlining our experience in using this mechanism, and a number of broader and more specific recommendations on improving EDC's compliance mechanism that flow from the lessons we learned in filing the complaint and best practices among other institutions.
We welcome the existence of EDC's Compliance Mechanism, but would like to highlight our concerns that without some substantial changes, EDC risks losing substantial credibility for, and confidence in, this mechanism among both civil society and partner financial institutions.
I would appreciate it if you could provide copies of this letter and these recommendations to EDC's Corporate Social Responsibility Advisory Group in advance of their meeting on December 15th. I have provided an electronic version of this letter and these comments to EDC's Compliance Officer and CSR Advisor to allow for speedy distribution.
Yours sincerely,
Fraser Reilly-King
Programme Manager - Project Finance
Cc.: Alison Lawford, Compliance Officer, EDC
Yolanda Banks, Corporate Social Responsibility Advisor, EDC