Memorandum from the Export Credits Guarantee
Department
1. This memorandum has been produced in
response to the Committee's letter of 23 April requesting information
on ECGD's sustainable development policies and procedures. It
gives some background and addresses the four main areas that the
Committee is examining. Annex A provides more detailed answers
to each of the questions set out in the Committee's letter. ECGD
will, of course, be happy to provide more information where necessary,
either in a further submission or during the oral evidence session.
2. ECGD welcomes the EAC's interest in its
operations and the contribution the department can make towards
sustainable development. The integration of sustainable development
into ECGD's policies and procedures is an on-going process and
any advice or recommendations that the EAC wish to make will be
appreciated.
ECGD'S ROLE
3. ECGD is the UK's export credit agency
and is a separate Government Department that reports to the Secretary
of State for Trade and Industry. It supports UK exporters of capital
equipment and project-related goods and services by providing:
— Insurance against non-payment to
UK exporters,
— Help in arranging finance packages
for buyers of UK goods by guaranteeing bank loans, and
— Overseas Investment Insurance—a
facility that gives UK investors up to 15 years' insurance against
political risks.
The department typically provides guarantees
and insurance for around £3.5 billion worth of exports and
investments per year, earning premium income of around £80m
to £100m a year.
ECGD AND SUSTAINABLE
DEVELOPMENT
4. ECGD first began considering environmental
issues in a formal way in January 1999 when it introduced its
first Environment Questionnaire. The Mission and Status Review
carried out during 1999 led to a recognition that the Department
needed to address sustainable development in a more rigorous and
professional way. This recognition in turn led to the publication
of the Statement of Business Principles in December 2000 along
with the creation of a dedicated Business Principles Unit and
the introduction of the revised and expanded Impact Questionnaire
and associated project screening procedures. Since December 2000
the Department's policies and procedures have been further enhanced
and these enhancements are discussed in this memorandum.
5. ECGD uses DEFRA's definition of sustainable
development—`A better quality of life for everyone, now
and for generations to come'. This definition encompasses
four key objectives:
— Social progress which recognises
the needs of everyone;
— Effective protection of the environment;
— Prudent use of natural resources;
and
— Maintenance of high and stable levels
of economic growth and employment.
ECGD addresses all of these objectives in its
case impact assessment process.
6. ECGD's commitment to sustainable development
has to be considered alongside its mission to support UK exports
and investments. These aims could be perceived as conflicting
since projects which ECGD supports can have negative environmental
impacts. In order to address these concerns the Department uses
international standards and guidelines and has developed a policy
of constructive engagement with exporters and project developers.
This allows ECGD to set out its minimum requirements (normally
compliance with World Bank Group guidelines) while working with
project developers to improve projects and minimise negative impacts.
ECGD AND GOVERNMENT
POLICY ON
SUSTAINABLE DEVELOPMENT
7. As a Government Department, ECGD recognises
its obligation to implement and support all the relevant policies
and commitments of the Government, including those regarding environmental
protection and sustainable development. Both of these are policy
areas where ECGD has come under close scrutiny in recent years.
8. ECGD's support for Government policies
is demonstrated at a number of different levels, ranging from
the Department's Mission Statement, through the way it assesses
project proposals, down to how it manages its offices and day-to-day
operations. As stated above ECGD has adopted the Government's
definition of Sustainable Development and ECGD's Statement of
Business Principles includes a commitment to `ensure our activities
take into account the Government's international policies, including
those on sustainable development, environment, human rights, good
governance and trade'.
9. The following are some concrete examples
of how ECGD adopts and supports Government policy:
— ECGD regularly seeks direction from
Ministers, primarily the Minister for International Trade and
Investment, both on questions of sustainable development policy
and on individual projects.
— The Minister for International Trade
and the Minister for Environment have agreed to meet regularly
to discuss ECGD policy and individual projects.
— Other departments, including DEFRA,
DFID and FCO, are consulted on all "Sensitive Cases"
and their input is sought on any issues that may potentially conflict
with Government policy.
— ECGD has contributed to the development
of Government initiatives on, for example, debt relief and renewable
energy.
— ECGD is a member of the Green Ministers'
Officials' Working Group and is working to implement the `Framework
for Sustainable Development on the Government Estate'.
10. ECGD has taken steps to improve co-ordination
with the rest of Whitehall. The Parliamentary and Public Affairs
branch has been expanded and the Business Principles Unit has
established good working relations with a network of colleagues
in other departments.
SUSTAINABLE DEVELOPMENT
IN ECGD'S
OPERATIONS
11. The introduction of Business Principles
and the case impact analysis process, including the Impact Questionnaire,
have led to fundamental changes in the way ECGD operates. This
change is probably most notable, and most significant, in the
Department's assessment of applications for support. Before 1999,
repayment risk was almost the sole determinant of whether or not
ECGD provided cover for an export. Now the content, location and
potential environmental, social and human rights impacts of both
the export and any associated project are key considerations.
12. All civil, non-aerospace applications
for support are screened by ECGD for potential environmental,
social and health and safety impact[1]This
screening, which is based on questions now included in all application
forms, allows applications to be classified as high, medium or
low potential impact. This classification determines the level
of further assessment. For low potential impact no further information
is required, for medium the revised Impact Questionnaire must
be completed and for high a full Environmental and Social Impact
Assessment, or the equivalent information, will normally be required.
13. In terms of project standards ECGD has
made it clear it normally expects compliance with the World Bank
Group's environmental guidelines and relevant safeguard policies.
These are the most applicable international standards for the
types of projects ECGD supports and have been widely adopted by
other International Finance Institutions and Export Credit Agencies.
14. As well as procedural changes, the introduction
of the Business Principles has led to cultural changes within
the organisation. The importance of sustainable development is
being recognised and discussed at all levels. Environmental issues
are discussed regularly with all exporters and project developers.
No cases have been turned down on purely environmental or social
grounds but it is believed that this is due to ECGD making its
requirements clear and virtually all projects complying with World
Bank Group guidelines at the time of the application.
15. Staff are now more aware of environmental
issues. An introduction to the Business Principles is included
in the staff induction programme. More detailed training on sustainable
development and project assessments is also provided. This is
primarily aimed at staff in the Business Group, but is open to
others.
16. The Export Guarantees Advisory Council
reviews ECGD's performance against its Business Principles. The
Council's Terms of Reference and membership were revised following
the Mission and Status Review to enable it to take on this new
role. The Council now includes experts on sustainable development
and corporate social responsibility. It can review all approved
guarantees and is consulted on all Business Principles related
policy issues. Both ECGD and the Advisory Council report on the
Department's sustainable development performance in ECGD's annual
report.
17. Finally ECGD has taken steps to reduce
the environmental impact of its offices in line with the `Framework
for Sustainable Development on the Government Estate'. The scope
for improvements are limited by the fact that ECGD occupies modern,
rented offices that are externally managed, but some useful steps
have been taken. For example a range of recycling bins are provided
on all floors and the Cardiff office and warehouse now source
their electricity from renewable suppliers.
THE TRADING
FUND AND
TRANSPARENCY
18. The Committee has asked what impact
ECGD becoming a Trading Fund will have on public access to environmental
information. The Trading Fund and the associated move toward capitalising
ECGD is intended to improve the way in which the Department quantifies
and manages its financial risks. These changes will provide more
clarity about ECGD's risks and potential liabilities but will
not in themselves have any impact on transparency of environmental
information, which is being addressed by other means.
19. Some of the steps ECGD currently takes
to provide transparency on sustainable development include:
— The department's annual report has
a section on sustainable development and ECGD is developing appropriate
performance indicators to report against.
— Minutes of meetings of the Export
Guarantees Advisory Council are published on the Department's
website.
— Details of all high potential impact
projects that are being considered are published on the Department's
website. This is done with the consent of the exporter or project
sponsor and while this consent may be withheld, this would have
to be fully justified.
— A Transparency Working Group has
been formed to examine areas where ECGD can make more information
publicly available.
20. More generally, ECGD continues to engage
with all stakeholders, including exporters, NGOs, MPs and members
of the public. Seminars for exporters and financiers are held
annually. A meeting with interested NGOs was held in February
2002 to discuss ECGD's case assessment procedures and in May 2002
a seminar on the Business Principles was held in the House of
Lords and was addressed by Baroness Symons. Another NGO meeting
will be held at ECGD's offices in June.
21. ECGD is on course to implement the requirements
of the Freedom of Information Act by January 2005. The Department's
publication scheme has been published and will be reviewed from
time to time.
THE SCOPE
AND NEED
FOR FURTHER
REFORM
22. The forthcoming revision of the OECD
agreement on `Common Approaches on the Environment and Officially
Support Export Credits', normally referred to as the `Common Approaches',
will provide an opportunity for ECGD to re-examine its approach
to sustainable development in due course. The Common Approaches
was agreed in November 2000 by 24 of the 26 members of the OECD's
Export Credit Group. It sets out a methodology for screening projects
and taking account of environmental impacts and has been instrumental
in encouraging other Export Credit Agencies to introduce meaningful
environment assessment systems.
23. A formal review and re-drafting of the
Common Approaches will take place this summer and the revised
version should be completed by November. The discussions are likely
to focus on introducing greater clarity on project standards and
increasing transparency. It is hoped that at the end of this process
the US and Turkey, the two countries that did not adopt the original
version, will be able to join.
24. ECGD is also considering the possibility
of further enhancing its project impact assessment procedure so
that they comply with the requirements of the ISO14001 standard
for Environmental Management Systems.
FURTHER INFORMATION
25. The attached annexes contain additional
information that the Committee may find useful. Annex A gives
answers to each of the questions included in the Committee's letter
of 23 April. Annex B contains the Case Handling Process—Information
Note. Annex C contains the recently revised Impact Questionnaire.
* * *
May 2003
Annex A
ECGD AND SUSTAINABLE
DEVELOPMENT
1. To what extent do ECGD's aims and objectives
reflect the Government's commitments on environmental protection
and sustainable development?
As a Government Department, ECGD recognises
its obligation to implement and support all the relevant policies
and commitments of the Government including those regarding environmental
protection and sustainable development. ECGD's support for Government
policies is demonstrated at all levels, ranging from the Department's
Mission Statement, through the way it assesses project proposals,
down to how it manages its offices.
2. How has ECGD's revised mission statement,
and the subsequent development of a statement of Business Principles
impacted on activities? How is ECGD's performance against these
principles, particularly in relation to sustainable development,
monitored and reported? Can you demonstrate any changes in practice
in relation to sustainable development since the development of
the statement of Business Principles?
The introduction of Business Principles and
the Impact Questionnaire have led to fundamental changes in the
way ECGD operates. Consideration is no longer limited to the risk
of non-payment and account is now taken of the potential impacts
of the overseas projects. This change has been implemented by
the establishment of a dedicated Business Principles Unit that
assesses applications for support through the case impact analysis
process and associated Impact Questionnaire. This process is described
in the `Case Handling Process—Information Note' which is
available on the ECGD website and attached to this memorandum
at Annex B.
All civil, non-aerospace applications for support
are analysed by ECGD for potential environmental, social and health
and safety impact. Cover is only offered if ECGD is confident
that the project will meet appropriate international standards.
In practice this means that ECGD now normally expects compliance
with World Bank Group standards and guidelines.
ECGD's Chief Executive monitors performance
against the Business Principles on a quarterly basis. The Export
Guarantees Advisory Council also reviews their implementation.
The Council reviews cases after guarantees have been issued and
provides advice on questions of policy. The membership of the
Council includes experts on sustainable development and corporate
social responsibility, as well as economists and industry representatives.
Both ECGD and the Advisory Council report on sustainable development
in the Annual Report.
3. How does ECGD implement its commitment
to the promotion of sustainable development? How does your case
impact analysis process take account of sustainable development?
The commitment to sustainable development is
implemented in three main areas—case impact analysis, attention
to good governance issues, and reducing the environmental impact
of the office estate.
Further details of the case impact analysis
process are contained in the `Business Principles Unit—Case
Impact Analysis Process' procedures.* * *
ECGD is also committed to a programme of debt
relief for the world's poorest countries and ensuring that these
countries do not take on new unsustainable debt. For the 67 HIPC[2]and
IDA-only[3]markets
support is limited to exports that will contribute to the social
or economic development of the country without harming its debt
position. These assessments are made jointly by ECGD and DFID.
Treasury reviews the outcome of the assessment of each case.
Within its own estate, ECGD is working to implement
the "Framework for Sustainable Development on the Government
Estate". The Managing Agents of the London office have established
an Environmental Management System for the whole office block
and ECGD has contributed to this. In Cardiff, the electricity
supply to both the office and the warehouse is now being provided
from renewable energy sources.
4. How has the use of the Impact Questionnaire
affected your assessment of applications? Has its use resulted
in a discernable change in practice in the types of applications,
which are accepted or refused? How has it been developed subsequently,
particularly in light of the consultation in 2002?
Until April 2003 the Impact Questionnaire was
ECGD's initial source of information on the environmental and
social impacts of applications. ECGD now includes questions on
these impacts in the revised application forms that customers
are required to submit at the outset. This enables the Department
to judge whether cases have low, medium or high potential impacts.
The Questionnaire has been useful both for collecting information
and also for signalling the topics that ECGD is most interested
in and the standards it expects projects to comply with.
ECGD cannot say with any certainty that the
introduction of the Impact Questionnaire has resulted in changes
in the types of application either received or accepted, as there
is no relevant environmental information available for the pre-impact
analysis period. It is the case though that exporters now recognise
that sustainable development is important to ECGD and almost all
project proposals already meet the required international standards.
The consultation in 2002 led to the decision
being made to include some initial questions in the application
forms, with the Impact Questionnaire being revised slightly and
used only for medium potential impact cases (low impact cases
require no further information, high impact cases require a full
Environmental Impact Assessment Report). This change is intended
to eliminate unnecessary bureaucracy and allow ECGD to focus its
limited resources on those projects that have the most significant
impacts. The revised Impact Questionnaire is attached at Annex
C.
5. What other tools does ECGD use to assess
the environmental and sustainable development implications of
the applications it receives?
In addition to the Impact Questionnaire, ECGD
uses a number of tools for gathering information including the
Internet, news databases, other departments, FCO posts, other
Export Credit Agencies and International Finance Institutions.
Environmental and Social Impact Assessments and Resettlement Action
Plans are used for high potential Impact projects and ECGD may
also require the appointment of an independent environmental consultant.
An ECGD specialist will visit the project site if necessary and
for high potential impact cases will require the production of
Environmental Management and Monitoring Programmes.
6. What definition of sustainable development
does ECGD use? How do you respond to the charge that it is too
narrowly focused on environmental protection and does not take
account of socio-economic matters, such as labour standards, human
rights and debt adequately?
ECGD uses DEFRA's definition of sustainable
development—"A better quality of life for everyone,
now and for generations to come".
Socio-economic issues such as labour standards
and human rights are an integral part of the case impact analysis
process and are specifically addressed in question 8 of the new
Impact Questionnaire (questions 10 and 11 of the 2001 Impact Questionnaire).
ECGD uses the Safeguard Policies of the World Bank Group as benchmarks
of good practice for involuntary resettlement, damage to sites
of cultural, historic or scientific interest, impacts on minority
or vulnerable groups, and child or bonded labour. (See sections
6 & 9 of Case Impact Analysis Process).* * *
Debt sustainability is a key part of ECGD's
case risk analysis. In addition, when the buyer is in a HIPC (heavily
indebted poor country) or IDA-only country, the case is subjected
to the "productive expenditure" check. This checks that
the project contributes to social and economic development and
also does not lead to the build up of new unsustainable debt burdens.
Although much of the analysis is done by ECGD, the productive
expenditure check is formally carried out by DFID and the decision
confirmed by Treasury. (See section 6.3 of Case Impact Analysis
Process).* * *
7. Has ECGD ever declined an application
solely on the grounds of a negative impact on the environment
or sustainable development? If so, please give details.
ECGD has never declined an application solely
on the grounds of the direct environmental or social impacts of
the project but it has recently turned one down on the basis that
it did not constitute productive expenditure. In addition a few
applications have been withdrawn when it became apparent that
the resource implications relating to demonstrating full compliance
with requirements of ECGD (and other ECAs) would compromise the
commercial viability of the contracts concerned.
The following is an extract from the ECGD's
contribution to sustainable development section of the 2001-02
Annual Report. "No applications were rejected on Business
Principles grounds during the year. This is our target for the
future as it is one of our policies to improve projects through
constructive engagement with the exporter and project sponsor
rather than to reject applications and prevent UK exporters from
gaining business." A similar statement will be included in
the 2002-03 Annual Report but which will take account of the rejection
on productive expenditure grounds.
8. Has the incorporation of sustainable development
considerations into your processes improved ECGD's performance
or efficiency in broader terms and if so, how?
The introduction of the case impact analysis
process has not impeded the flow of business through the Department
as it has always been completed prior to the completion of other
parts of the overall analysis process. It has, however, led to
a much greater understanding of the technical details of the goods/services
being exported and the overseas projects. In some cases this has
resulted in a better understanding and handling of the risks involved
in the case.
9. Changes in practice introduced unilaterally
by ECGD may have limited impact in buyer countries as suppliers
may choose to source goods and services from other countries.
What has ECGD done to promote and encourage the incorporation
of sustainable development principles into the operations of other
ECAs? With what success?
ECGD is well aware that unilateral action would
have limited impact and is committed to multilateral reform across
a range of export credit issues. The Department has a dedicated
International Relations team which works through the OECD Export
Credits Group and the Berne Union to achieve this. A major success
in this was the agreement by 24 of the 26 OECD countries to implement
the "Common Approaches on the Environment and Officially
Supported Export Credits" (the Common Approaches) in November
2001. (The other two countries were the USA and Turkey. The USA
already had a system in place which exceeded the requirements
of the Common Approaches, while Turkey took exception to a minor
part of the text of the Common Approaches but has, nevertheless,
implemented a similar system.)
10. To what extent has ECGD been involved
with, supported or led OECD initiatives to promote the incorporation
of sustainable development principles into ECAs operations?
ECGD played a key pro-active role in the development
of the Common Approaches. It will continue to share its expertise
and experience with other ECAs in order to achieve a positive
outcome from the review that is scheduled for completion by the
end of this year.
ECGD played a similar role within the OECD in
the development of the Statement of Principles relating to support
for only productive expenditure in HIPCs (July 2001) and the Action
Statement on bribery and export credits (November 2000).
11. What is best practice in terms of the
promotion of sustainable development and environmental protection?
Are you aware of examples of best practice in other ECAs? To what
extent can or has ECGD learnt from these examples?
Overall best practice by financial institutions
in terms of the promotion of sustainable development and environmental
protection is demonstrated by the major multilateral financial
institutions (the World Bank Group, Asian Development Bank, African
Development Bank, Inter-American Development Bank and the European
Bank for Reconstruction and Development (EBRD)). However these
institutions have a clear development mandate and, as providers
of investment and loan funds, are usually involved at an earlier
stage of a project's development than export credit agencies.
ECGD uses the policies and procedures of these institutions as
benchmarks of good practice whenever it is appropriate.
Within the ECA group, best practice is demonstrated
by different ECAs for different aspects.
— In terms of transparency through
prior disclosure the USA and Australia have for some time been
the most transparent. Last year Japan and Switzerland introduced
prior disclosure and ECGD has recently implemented its own system
for this.
— ECGD is the most progressive ECA
in terms of consideration of social issues such as labour standards
and human rights and was successful in obtaining agreement that
involuntary resettlement and impacts on cultural property and
vulnerable groups should be included in the Common Approaches.
We will press for consideration of other social issues to be included
in a future version of the Common Approaches.
— CESCE, the Spanish ECA, uses an interactive
web-based environmental screening tool to screen initial applications.
ECGD will consider the practicalities of adopting a similar system.
12. How has your commitment to implement
the OECD's Common Approaches on Environment and Officially Supported
Export Credits affected your operations in practice?
ECGD's case impact analysis process needed only
minor amendments to comply fully with the Common Approaches. In
many areas, such as consideration of social, labour and human
rights issues, ECGD's process exceeded the requirements of the
Common Approaches. With the introduction of prior disclosure of
high potential impact cases, ECGD has moved even further ahead.
13. Has there been any increase in transparency
on the part of ECGD as a result of the consultation, which took
place last year?
As a result of the consultation ECGD now discloses
details of high potential impact cases on its website. This is
done with the consent of the exporter or project sponsor and while
this consent may be withheld, this would have to be fully justified.
14. How will the transition to a Trading
Fund affect ECGD's operations, particularly in terms of transparency?
Will there be greater access to information on the social and
environmental impacts of the projects that ECGD is invited to
support?
The transition to a Trading Fund will provide
more clarity about ECGD's risks and potential liabilities but
will not in itself have a significant impact on environmental
transparency. This is not to say that transparency is not important,
just that it is being taken forward by different means including
the Annual Report, increased use of the department's website and
regular dialogue with all stakeholders.
15. What, if any, further reforms are required
and/or planned to ensure that ECGD's operations work towards the
Government's sustainable development objectives?
The forthcoming revision of the OECD `Common
Approaches' provides an opportunity for ECGD to re-examine its
approach to sustainable development. A formal review and re-drafting
will take place this summer and the revised version should be
completed by November. The discussions are likely to focus on
greater clarity on project standards and increasing transparency.
It is hoped that at the end of this process the US and Turkey,
the two countries that did not adopt the original version, will
be able to join.
ECGD is also considering the possibility for
further enhancing its project impact assessment procedure so that
they comply with the requirements of the ISO14001 standard for
Environmental Management Systems.
Annex B
ECGD'S CASE
HANDLING PROCESS—INFORMATION
NOTE
This note gives a brief description of how ECGD
will process applications for support from April 2003 onwards.
Given the range of transactions, the differing ways contract negotiations
are pursued and the variety of products involved, it is difficult
to provide a succinct statement that will cover every circumstance.
This note seeks to illustrate the general process adopted for
handling cases.
INDICATIONS OF
ECGD SUPPORT
In the early stages of considering whether to
pursue an investment or export opportunity potential customers
typically will approach ECGD for a preliminary indication of the
possibility that such support might be considered and an idea
of potential premium and/or interest rates that might apply. If
there is no current prospect of ECGD support for any business
in the country in question, customers will be told this immediately.
Otherwise, an indication is likely to be given
reflecting ECGD's capital constraints[4]
Such indications will say whether the proposed payment/repayment
terms are acceptable in principle but do not involve a detailed
assessment of the case (and are given entirely without commitment).
They carry a reminder that ECGD will need to consider the case
in greater detail to satisfy itself on various matters (including
environmental and other impacts) before any commitment can be
considered. Attention is drawn to ECGD's impact analysis process
at this stage, and that the initial questions relating to environmental
and social impacts are contained within the standard application
forms. Once a formal application for support is submitted and
the application has been identified as a Medium potential impact
case then the Impact Questionnaire must also be completed.
All standard application forms and the Impact
Questionnaire are posted on the ECGD website together with supporting
guidance so that at the outset potential customers can gain a
clear understanding of the sort of information it will be necessary
to provide to enable ECGD to make a full assessment before deciding
whether to provide a commitment of cover. They should be read
in conjunction with this note as it is an integral part of the
case handling process.
COMMITMENTS OF
ECGD SUPPORT
Formal proposals/applications for support are
normally made where the potential customer judges that they have
a reasonable prospect of securing a deal and wish ECGD to undertake
a detailed assessment with a view to providing a commitment of
cover. Those cases that progress to the formal application stage
will be considered in accordance with ECGD's underwriting procedure.
The ECGD Case Manager will be responsible for examining the application
and supporting documentation and making the underwriting recommendation
to ECGD's Underwriting Committee.
The application forms contain a warranty to
confirm that neither the customer nor anyone acting on their behalf
has engaged or will engage in corrupt activity in connection with
either the contract or investment for which ECGD support is requested.
Additionally customers are required to warrant that they do not
appear on the World Bank blacklist and have not been convicted
of corruption at any time.
The Case Manager's recommendation will be made
against the background of due diligence and a number of risk assessments
undertaken in ECGD on key aspects of the case. These may include,
amongst other things, a detailed analysis of financial statements
to determine the acceptability of the payment risk/security structure,
sensitivity analysis on cash flow projections, our economists'
opinion on sectoral risk, our lawyers' opinions on any legal issues
or documents and an assessment based on financial statements,
track record and other checks to determine the financial and technical
ability and probity of the customer to undertake the contract
satisfactorily.
For exports (including the sale of defence equipment)
to and investments in IDA-only countries (ie poor countries eligible
to receive highly concessional IDA loans from the World Bank)
ECGD will only support those that represent "productive expenditure".
Exports and investments to these countries are assessed to ensure
that they contribute to economic and social development without
harming the recipient country's debt position. This assessment
will not always preclude sales of defence or dual-use equipment,
provided that such expenditure is not deemed excessive and that
the equipment is considered necessary for national security, will
create a stable platform for development, or is required to combat
the drugs trade, piracy, smuggling etc. The consideration of productive
expenditure issues is additional to the requirement for any necessary
export licences to be obtained.
ECGD's Business Principles Unit is responsible
for ensuring the case complies with ECGD's Business Principles.
It examines the completed application forms and uses this information
together with information obtained from other relevant sources
to identify any environmental, social and human rights issues
that the case may present and categorise the case into one of
three categories. Cases categorised as having Low potential impacts
will not normally be scrutinised further. For cases categorised
as having Medium potential impacts an Impact Questionnaire will
be required. (This is a revised version of the Impact Questionnaire
introduced in January 2000.) Cases relating to greenfield projects
or major expansions will normally be categorised as having High
potential impacts and for these cases a formal environmental impact
assessment, social impact assessment and/or a resettlement action
plan will be required.
The Business Principles Unit will recommend
to the appropriate underwriting authority whether support should
be provided for a contract or investment, whether any additional
information or reports are required or whether support would not
be in conformance with ECGD's published Business Principles. It
is ECGD policy to constructively engage with the exporter/investor
to improve exports/projects to bring support of the export/investment
into conformance with the Business Principles. However if this
were not possible then support would not be provided.
Separate screening arrangements are adopted
for defence exports, civil aircraft and aero engines, and for
all other business as follows:
DEFENCE EXPORTS
The export of strategic goods (which includes
defence equipment) is subject to strict Government licensing arrangements
and by its nature such defence equipment does not lend itself
to normal environmental screening or mitigation of any potential
environmental impact by ECGD. Any defence business which does
not require an export licence[5]for
instance that involving defence infrastructure (e.g. barracks,
airfields) is subject to ECGD's general impact screening and analysis
process.
While the UK Government supports the right of
all countries to provide for their legitimate defence, it operates
a strict export control regime to ensure compliance with international
obligations and the proper use of equipment supplied. The Government
has significantly tightened up the export licensing systems to
ensure that defence sales are scrutinised rigorously for human
rights and other concerns.
Licences to export strategic goods, including
arms and dual use goods, are issued by the Secretary of State
for Trade and Industry, and the Export Control Organisation of
the DTI is the licensing authority. All relevant individual licensing
applications are circulated by DTI to other Government departments
with an interest, as determined by their policy responsibilities—these
may include the Foreign and Commonwealth Office, the Ministry
of Defence and the Department for International Development.
Individual applications for licences are considered
against published criteria[6]on
a case-by-case basis. An export licence will not be issued if
the arguments for doing so are outweighed by the need to comply
with the UK's international obligations, or by concern that the
goods might be used for internal repression or international aggression,
or by the risks to regional stability or other considerations.
ECGD is not a party to the export licence process.
However, to ensure compliance with wider Government policies,
for exports of defence equipment to all countries, ECGD requires
that any necessary export licences are obtained as a pre-condition
of its cover.
AEROSPACE SECTOR
All civil aircraft and aero engines that ECGD
supports must conform to agreed EU and US environmental standards.
Global standards on noise and emissions are set by the International
Civil Aviation Organisation. The Federal Aviation Authority also
sets standards on noise for the United States. ECGD is satisfied
that all aircraft it supports do conform to the environmental
standards set by these bodies and have common environmental features
by aircraft type. This makes environmental screening on a case-by-case
basis by ECGD unnecessary.
ALL OTHER
BUSINESS
ECGD's Business Principles Unit reviews all
application forms and supporting information and the case is assigned
a potential impact level of High, Medium or Low (equivalent to
the OECD Common Approaches[7]categories
A, B and C) that identifies the degree of its potential environmental,
social or human rights impacts. This potential impact level is
largely determined by the project's sector, scale and location
and it will influence the degree of analysis required for each
case. A matrix providing further explanation of this process is
contained in Annex 1 of this Information Note.
Cases considered by the Business Principles
Unit to be Low potential impact are not normally assessed further
and continue through the underwriting process.
For Medium and High potential impact cases significant
environmental, social or human rights impacts are benchmarked
against internationally accepted standards. ECGD's normal reference
standards for assessing the acceptability of potential impacts
are the World Bank's environmental guidelines and social safeguard
policies (details are available on the World Bank website at www.worldbank.org).
When a case has been identified as having Medium
potential impacts, applicants for support will be required to
provide additional information through the completion of an Impact
Questionnaire.
For High potential impact projects ECGD will
require the information normally contained in a full Environmental
Impact Assessment (EIA), Social Impact Assessment (SIA) and/or
Resettlement Action Plan (RAP). For any case where such an appraisal
or any other independent external advice or report is required,
but is not already available, ECGD will normally require the exporter
or project sponsors to undertake this and bear any relevant costs.
Also, for High potential impact cases ECGD will
publish on its website details of the project (project name, location,
a brief description and the source of the environmental or social
impact assessment reports) prior to its underwriting decision.
This prior disclosure will normally be made following a formal
application for ECGD cover. Although there will be no fixed minimum
disclosure period, ECGD will normally publish information at least
60 days before decisions to commit cover are taken. To avoid jeopardising
competitive positions, disclosure will be subject to the agreement
of the UK customer, whose anonymity we would expect to preserve.
All cases identified as having High potential
impacts will be submitted to ECGD's Underwriting Committee for
consideration. The Underwriting Committee will, in deciding whether
to recommend providing support for a contract or investment, review
submissions on all the key risk assessments relevant to the case
and as part of this process will decide whether any additional
information or reports are required.
SENSITIVE CASES
All cases for which ECGD requires an EIA, SIA,
or RAP have the potential to be progressed under ECGD's "Sensitive
Cases" mechanism, which involves consultation with other
Government Departments. Sensitive Cases are those that have significant
adverse impacts that potentially conflict with other Government
policies. As soon as ECGD's Underwriting Committee has confirmed
the requirement for an EIA, SIA or RAP, ECGD will circulate key
details of the relevant case, together with copies of the relevant
documentation, to the nominated representatives of other potentially
interested Government Departments[8]who
will be bound to respect the applicant's commercial confidentiality.
These other Departments will identify those cases where ECGD support
may conflict with Government policies for which they have responsibility
and indicate to ECGD, within an agreed timescale, the nature of
their concerns and whether they wish to engage in discussion of
such cases. ECGD and the relevant other Departments will identify
on a case-by-case basis an appropriate mechanism for ensuring
that impacts are properly considered, paying due regard to the
need for ECGD to provide good Customer service.
ECGD will seek to ensure that all cases are
considered on their individual merits so that judgements are made
following an evaluation of the different risk assessments referred
to earlier in this note. ECGD will not support cases unless they
meet its minimum financial risk standard. It will also decline
(following Underwriting Committee consideration or advice, where
appropriate, from other Government Departments or referral to
Ministers) cases where the adverse impacts identified cannot be
mitigated to ECGD's satisfaction and thus are considered to outweigh
the potential benefits of providing support.
MONITORING IMPLEMENTATION
To mitigate any financial, environmental or
other concerns identified, ECGD may make its support conditional
on the fulfilment of conditions or the adherence to covenants
determined by ECGD on a case-by-case basis, taking into consideration
the degree of influence that ECGD and other parties involved have
on the relevant contract, project or investment, and the nature
of ECGD's support. Where covenants and other conditions relating
to post issue implementation have been included in any documents
relating to the relevant contract/project/investment or its financing,
monitoring reports will be reviewed on a regular basis throughout
ECGD's financial exposure to the project. Where such reports indicate
that remedial action is required, ECGD will use such leverage
as it may have to bring the appropriate parties together to address
the problem and to mitigate any significant adverse effects.
Annex C
A Summary of ECGD'S Impact Analysis Procedures
It is UK Government policy to promote Sustainable
Development. ECGD, therefore, must consider, in its risk assessment,
environmental, social and human rights issues, which could impact
materially on the construction, operation or economic viability
of the project, the local and global environment and the relevant
communities. We will provide support only if, in our judgement
and after taking account of all mitigating measures, the positive
effects of the project are likely to outweigh any adverse impacts.
PROVISION OF
INFORMATION
Since each case is unique, its circumstances
will determine what information is available to our customers.
Our request for information is based on three principles:
1. We will analyse all requests for support.
2. We expect investors, project leaders
and suppliers of components which form a major part of a project
to provide us with full information about the impacts of the business/project/goods.
3. We expect applicants who are suppliers
of goods/services which may form only a minor part of a project
to provide full information about the impacts of these goods/services
and to assist us in obtaining information about the impacts of
the project.
Where necessary, the relevant Underwriter and/or
ECGD's Business Principles Unit will provide guidance on what
further information is needed in order to enable ECGD to take
a decision on project impacts.
We recognise that, in some circumstances, not
all the information requested will be available at the time of
the submission of the application/proposal form. The existence
of relevant company policies, ISO14001/EMAS certification and
a record of good performance will be helpful if this is the case.
STANDARDS
— As a minimum, ECGD expects all projects/goods/services
to comply with host/destination country legislation, regulations
and standards.
— For goods and services forming only
a minor part of a project ECGD normally expects these goods/services
to comply with UK legislation, regulations or standards. Any departures
from this will need to be justified to the satisfaction of ECGD.
— Projects/goods/services that comply
with an international standard (eg World Bank, IFC or relevant
regional Development Bank) will not normally be investigated further
for environmental impacts (except, possibly, for verification
of compliance).
— Host/destination country or project
standards that are below international standards would normally
be unacceptable and, in line with the World Bank Guidelines, would
need site specific justification. We will look to the customer/exporter
to provide this justification wherever possible.
Impact Questionaire
(Form IQ2)
Details of ECGD's case impact analysis process
are contained in the Case Handling Process: Information Note
(February 2003) that is available on the ECGD website http://www.ecgd.gov.uk.
Customers are required to submit Impact Questionnaires
(together with, where appropriate, any necessary supplementary
information) when their case has been identified through the screening
process as having Medium potential impacts. When customers have
been requested to complete an Impact Questionnaire, all
questions of this questionnaire should be answered for all applications
for support.
Questions must be answered fully and truthfully
to the best of your knowledge and belief. If the space provided
is insufficient, please continue your answers on your headed notepaper
and attach it to the form. (If completing the questionnaire in
the electronic form, please start text responses in the grey boxes
provided.)
Please read the Introduction and Guidance
Notes before starting to complete the questionnaire.
Detailed notes regarding specific questions
(marked bkimage) are provided in Annex 1 of the questionnaire.
Further assistance may be obtained by contacting the relevant
Underwriter or the Business Principles Unit at ECGD.
Subject to our obligations to Parliament as
a Government Department all information provided in this questionnaire
will be treated as Commercial in Confidence until you tell us
otherwise. Please tell us when you can release us from this commitment.
Exporter's/Investor's Name:
Buyer's/Enterprise Name:
Project Country/ies:
ECGD Proposal Form Dated:
DECLARATION
We declare that:
1. if there are any material changes in
the information provided in response to this Impact Questionnaire
prior to ECGD approving support we will advise ECGD immediately;
2. if this Impact Questionnaire has been
transmitted by electronic means, we have not amended any of the
declarations or the questions contained in the Impact Questionnaire
(form IQ2) provided to us by ECGD;
3. the facts stated and the representations
made in this form and in any related discussions or correspondence
are, to the best of our knowledge and belief, true and that we
have neither misrepresented nor omitted any fact nor failed to
provide any information known to us which is material to ECGD's
assessment of the impact of the contract or the project to which
it relates.
| Signed on behalf of (Company Name)
| : |
| Signature | : |
| Name (block capitals) | : |
| Capacity of signatory | : |
| (Signatory must be an authorised officer on behalf of the Company)
| |
| Date | : |
Annex 1—Guidance Notes
These notes provide detailed guidance to customers
as they complete ECGD's Impact Questionnaire (IQ). They are intended
to help you identify the quantity and quality of information required
when answering some of the less straightforward questions which
are marked with the  book symbol
underneath the question number.
If further assistance is required, it may be obtained by
contacting the relevant Underwriter or the Business Principles
Unit at ECGD.
QUESTION 1
Are any other Export Credit Agencies (ECAs) or International
Financial Institutions (IFIs) involved in the project?
If yes, please state names of IFIs or ECAs involved.
GUIDANCE NOTE
Your answer will assist us in reducing the duplication of
requests for information and in establishing common project standards
eg the use of the World Bank standards. For example, ECGD may
be able to make use of assessments/investigations undertaken by
or for International Finance Institutions (IFC, EBRD etc) or other
ECAs and may wish to co-ordinate its activities with them in order
to streamline the process of investigation and analysis. Provision
of contact details for the relevant people involved would facilitate
this.
QUESTION 2
(a) If you have corporate Environment, Occupational Health
and Safety, Social Issues or Human Rights policies and/or your
company subscribes to ISO 14001/EMAS accreditation, please attach
relevant details (if not previously provided).
GUIDANCE NOTE
ECGD encourages its customers to demonstrate their commitment
to Sustainable Development through the development and publication
of relevant policies and the implementation of appropriate environmental
management systems (EMS) that should be verified/accredited where
possible. Since EMS certificates are awarded for individual sites,
please provide copies of the certificate(s) for the site(s) connected
with each specific request for support.
Your Human Rights policies might contain, for example, your
policy on equal opportunities.
QUESTION 3
(a) Is the project which you are supplying goods/services
to or investing in designed to meet recognised environmental standards?
(b) If the project/business is designed to meet any other
environmental performance standards please identify and provide
a copy of these.
GUIDANCE NOTE
ECGD is interested in the impacts of both the goods/services
being supplied and also any associated project of which the goods/services
form a part.
ECGD `benchmarks' projects against a range of internationally
recognised standards (UK, EU, WHO, World Bank, IFC, and relevant
regional Development Banks). You should assume that ECGD has copies
of all the major international standards. If Host country standards
or some other standard is being used then please provide a copy
of these.
Host country or project standards that are below international
environmental standards would normally be unacceptable and, in
line with the World Bank Guidelines[9]would
need site specific justification.
If there are no applicable or appropriate environmental standards
please provide an explanation of why this is the case.
QUESTION 4
Please indicate whether the goods/services/project that you
are supplying/investing in will be compliant with UK or Destination/Host
Country Health and Safety standards and supply details of any
Health and Safety guidance that you supply to the users/operators
of your goods/ projects.
GUIDANCE NOTE
ECGD needs to satisfy itself that due regard is being paid
to Health & Safety issues. If the guidance that you normally
supply is extensive then please provide a contents list only in
the first instance.
The World Bank Group has produced guidelines relating to
occupational health and safety which are available from the IFC
website at: http://www.ifc.org/enviro/EnvSoc/pollution/Gen_h_s.pdf
http:// www.ifc.org/enviro/EnvSoc/pollution/occupation/DraftOHS.pdf
ECGD uses these guidelines as the benchmarks of good practice
for the occupational health and safety aspects of projects.
QUESTION 7
(a) Please identify and quantify the annual consumption
or extraction by the project and provide details relating to the
following resources:
GUIDANCE NOTE
ECGD encourages the use of renewable resources and minimisation
of the use of non-renewable resources. Through asking its customers
to provide quantified information about this, ECGD ensures that
its customers are fully aware of the long-term sustainability
of their business and its impact on the global environment. If
the project sources its electrical power from the national grid,
please state this. If the project has a dedicated power plant,
please provide details of the fuel and technology used.
Also, in the future ECGD may wish to report on the sustainability,
or otherwise, of the projects for which it has provided cover
and this information will provide part of the basic data.
(b) Please identify and quantify the annual production
or use by the project of greenhouse gases, ozone depleting substances,
hazardous substances or persistent organic pollutants (POPs):
Greenhouse gases (UNFCCC and Kyoto Protocol)
ECGD discourages release of greenhouse gases and encourages
the use of renewable power sources. Through asking its customers
to provide quantified information about this, ECGD ensures that
its customers are fully aware of the long-term sustainability
of their business and its impact on the global environment.
Also, in the future ECGD may wish to report on the sustainability,
or otherwise, of the projects for which it has provided cover
and this information will provide part of the basic data.
Further information about the United Nations Framework
Convention on Climate Change and the Kyoto Protocol
can be found on the website: http://unfccc.int/
Ozone depletion (Montreal Protocol)
Are CFCs or HCFCs used in refrigeration or air-conditioning
systems? Have alternatives been considered? Are any other ozone
depleters used? Details of the Montreal Protocol including a list
of ozone depleters can be found on the UNEP website at: http://www.unep.ch/ozone/mont-t.htm.
Hazardous substances
What hazardous substances are used or produced in the project,
eg are polychlorinated biphenyls (PCBs) present in transformers,
capacitors or gas pipelines? What processes or procedural systems
are there to prevent or deal with the escape of any such hazardous
substances?
The IFC has produced guidelines for the management of hazardous
materials and PCBs in particular. These are available from the
IFC website at: http://www.ifc.org/enviro/EnvSoc/pollution/guidelines.htm.
Persistent Organic Pollutants
Persistent Organic Pollutants (POPs) are chemical substances
that persist in the environment, bioaccumulate through the food
web, and pose a risk of causing adverse effects to human health
and the environment. There is evidence of long-range transport
of these substances to regions where they have never been used
or produced and the consequent threats they pose to the environment
of the whole globe. ECGD encourages actions to reduce and eliminate
releases of these chemicals.
Further information about POPs may be obtained from the UN
Environment Programme website at: http://www.chem.unep.ch/pops/.
QUESTION 8
Will the goods or project cause, require, bring about or stimulate
any of the following?
GUIDANCE NOTES
Please provide sufficient information for ECGD to determine
whether or not the impacts that you are aware of, after enquiry
appropriate to your role in the project, are significant. This
should include information about potential impacts outside the
immediate project area, for example, downstream or downwind. The
following questions may assist in determining the appropriate
answer (yes/no) and the type and detail of information required.
Resettlement of the local population
Are people being moved from or excluded from the site of
the project, particularly on an involuntary basis? How many are
involved? How long have they lived or worked on the site? What
is the source of this data and how reliable is it?
The World Bank Group has an Operational Directive relating
to Involuntary Resettlement (OD 4.30) available from the IFC website
at: http://www.ifc.org/enviro/EnvSoc/Safeguard/Resettlement/OD_430_Involuntary_Resettlement.pdf.
The IFC has also produced a handbook to assist in the preparation
of Resettlement Action Plans—further details are available
at: http://www.ifc.org/enviro/Publications/ResettlementHandbook/resettlementhandbook.htm.
ECGD uses OD 4.30 as the benchmark of good practice for projects
involving involuntary resettlement.
Compulsory acquisition of land
Is land being acquired by or on behalf of the project company
through compulsory purchase systems? How and by whom are the assets
and resource base being valued? Are current inhabitants/users
being offered alternative land or cash or both? Are equivalent
or better services and infrastructure being provided? Compulsory
land acquisition is sometimes referred to as `economic resettlement'
and many of the practices described in OD 4.30 can be adopted
in these circumstances.
Displacement of or damage to existing industry or agriculture
Are alternative jobs (with appropriate training) being offered?
Is the whole community being consulted?
Job losses among the local population
Are job losses expected to arise as a result of the project?
What opportunities for re-employment or re-training are being
provided?
Child labour
Are any children under 14 employed? What mechanisms are being
put in place to monitor this? Do any children accompany their
parent(s) onto the business premises?
In common with most countries around the world, the UK has
ratified the United Nations convention on the Rights of the Child
and the International Labour Organisation conventions on the abolition
of child labour. There must, therefore be exceptional circumstances
for ECGD to provide cover to projects which involve child labour.
The World Bank Group has produced a Policy relating to harmful
child and forced labour which is available from the IFC website
at: http://www.ifc.org/enviro/enviro/childlabor/child.htm.
ECGD uses this policy as the benchmark of good practice for
projects involving child labour.
The IFC has also produced a Good Practice Note entitled Addressing
Child Labor in the Workplace and the Supply Chain. This is
a good source of information for situations where child labour
is considered essential.
Bonded or forced labour
Is any of the work extracted for no payment and/or under
threat of force or penalty e.g. does the employer hold workers'
identity documents? Is work extracted as payment for debt?
In common with most countries around the world, the UK has
ratified the International Labour Organisation Conventions on
the elimination of forced or compulsory labour. It is difficult
to imagine circumstances in which ECGD could provide cover to
projects which involve forced labour.
The World Bank Group has produced a Policy relating to harmful
child and forced labour which is available from the IFC website
at: http://www.ifc.org/enviro/enviro/childlabor/child.htm.
ECGD uses this policy as the benchmark of good practice for
projects involving bonded or forced labour.
Large-scale influx of workers
Will the business (or sub-contractors) import a non-local
work-force requiring accommodation and access to facilities for
a period of more than three months eg during a construction phase?
How many will be employed and for how long? Have opportunities
been offered to local workers?
Damage to sites of cultural, historic or scientific interest
Does the project affect a religious or ancestral site, or
natural resources ascribed by local people with cultural or sacred
significance? Is the site near to a recognised World Heritage
site? Is the site near to a recognised site of special scientific
interest?
The World Bank Group has produced an Operational Policy Note
relating to cultural property (OPN 11.03) which is available from
the IFC website at: http://www.ifc.org/enviro/EnvSoc/Safeguard/Property/property.htm.
ECGD uses OPN 11.03 as the benchmark of good practice for
projects involving cultural property.
Impact on minority or vulnerable communities
Are any of the above impacts likely to have a disproportionate
effect on national, ethnic or religious minority communities or
other vulnerable groups in the country concerned?
The World Bank Group has produced an Operational Directive
relating to indigenous peoples (OD 4.20) which is available from
the IFC website at: http://www.ifc.org/enviro/EnvSoc/Safeguard/Indigenous/indigenous.htm.
ECGD uses OD 4.20 as the benchmark of good practice for projects
involving indigenous peoples.
Use of armed personnel
Please indicate, as far you are aware, the extent of armed
security that the contract or project will use (eg number of armed
personnel). If possible, include details of rules or procedures
in place governing conduct of personnel and sub-contractors, including
on the use of force.
Projects making use of extensive security arrangements may
need to take account of the impact of those arrangements in a
Social Impact Assessment (SIA).
Social benefits
ECGD is keen to recognise social benefits arising from the
project.
QUESTION 9
Will the benefits of the goods/project (including employment
opportunities for local people) be open to all, regardless of
race, religion, gender, social grouping, etc ?
GUIDANCE NOTES
Please indicate whether you are aware of, and, if possible,
give reasons for, any discriminatory practices relating to the
opportunities to derive benefits from the exported goods or the
various phases of the project (construction, operation, product
use, and decommissioning).
In common with most countries around the world, the UK has
ratified the United Nations conventions on the elimination of
all forms of racial discrimination and the elimination of all
forms of discrimination against women and the International Labour
Organisation conventions on the elimination of discrimination
in respect of employment and occupation. Whilst ECGD does not
expect positive discrimination to ensure equality in the distribution
of benefits, we do encourage equality of opportunity to share
in the benefits.
QUESTION 10
Please give details of any other information that you think
may be relevant to ECGD's assessment of the impact of this project,
including any positive impacts not previously identified.
GUIDANCE NOTES
Please ensure that all positive environmental, health and
safety, and social impacts are clearly identified and quantified
where possible. Positive impacts could include reduction in pollution,
improved efficiency of energy usage, generation of electricity
from renewable resources, technology transfer, skills transfer
and training, opportunities for local entrepreneurs such as micro-credit
schemes and other associated community projects.
Annex 2—Contents List for EIA
CONTENTS OF
AN ENVIRONMENTAL
IMPACT ASSESSMENT
WORLD BANK
(OPERATIONAL DIRECTIVE
4.01 OF WORLD
BANK)
ECGD requires that Environmental Impact Assessments (EIAs)
of projects conform to a recognised format and coverage. This
is the content page list used by the World Bank. EIAs which conform
to other internationally recognised standards of good practice
would also be acceptable.
1. Description of project
— location, type, purpose & scope of project,
size, onsite and offsite components, technologies to be employed,
construction scheduling
— information on the applicant and the role of the
host country government
2. Description of existing environment
— project area and size, location and physical ecological
and socio-economic/cultural conditions
— results of site audit, if conducted, and results
of participatory input from affected population, if conducted
3. Potential environmental impacts of a proposed project
— analysis of beneficial and adverse impacts of
the project, and their significance, potential mitigation for
adverse impacts and identification of impacts for which no mitigation
is available
4. Host country regulatory requirements and permits
— host country regulatory framework, including ECA
and applicable host country regional and local requirements
5. Description of project monitoring and environmental
management plan
— discussion of the scope and effectiveness of existing
environmental monitoring or proposed environmental management
programs and recommendations for any additional monitoring if
needed or appropriate
6. Discussion of identified environmental issues and
potential mitigation measures applicable to project specifics
such as
— air quality and the maintenance of ambient air
quality
— water use and quality including protection of
surface and groundwater resources
— wastewater management such as handling, processing,
storage and disposal of dangerous or toxic materials
— effect of natural hazards including measures to
mitigate environmental risks due to seismicity, landslides, flooding,
etc
— ecological considerations such as protection of
biodiversity and ecosystems and conservation of natural resources
in conjunction with sensitive sites such as those containing endangered
species
— maintaining the socio-economic and cultural context
through development of resettlement plans, measures to preserve
historical sites and artefacts etc
In addition, the following aspects should be addressed
— Public participation within the host country in
the preparation of the EIA
— Procedure for comparing the environmental effects
of alternatives to the project and other elements.
Annex 3—Contents List for RAP
Contents of a Resettlement Action Plan (World Bank
Operational Policy 4.30)
ECGD requires that Resettlement Action Plans (RAPs) of projects
conform to a recognised format and coverage. This is the content
page list used by the World Bank Group. RAPs which conform to
other internationally recognised standards of good practice would
also be acceptable.
Extract from World Bank Operational Policy 4.30 (June 1990)
The content and level of detail of resettlement plans, which
will vary with circumstances, especially the magnitude of resettlement,
it should normally include a statement of objectives and policies,
an executive summary, and detailed provision for the following:
(a) organizational responsibilities;
(b) community participation and integration with host
populations;
(c) socioeconomic survey;
(e) alternative sites and selection;
(f) valuation of and compensation for lost assets;
(g) land tenure, acquisition, and transfer;
(h) access to training, employment, and credit;
(i) shelter, infrastructure, and social services;
(j) environmental protection and management; and
(k) implementation schedule, monitoring, and evaluation.
Cost estimates should be prepared for these activities, and
they should be budgeted and scheduled in coordination with the
physical works of the main investment project.
1
Aerospace applications are not screened as all UK-manufactured
aircraft or components comply with international environmental
and safety standards. Sharp-arms are screened by the DTI export
licensing system. ECGD is not party to this process but will only
support export for which a valid export licence has been granted.
Defence cases involving non-sharp arms (eg construction of barracks)
are assessed using the impact assessment procedures. Back
2
HIPC-Heavily indebted Poor Countries. Back
3
IDA-only countries are those that can borrow from International
Department Association only on highly concessional terms. Back
4
ECGD operates on the basis that it has a fixed amount of capital
that limits the maximum financial exposure that the Department
can take on. Individual cases are allocated a proportion of this
capital based on the calculated repayment risk. Back
5
or the alternative Form 680 procedure for Government to Government
contracts. Back
6
The criteria for considering individual application for licenses
of strategic goods set out in a House of Commons statement by
the Secretary of State for Foreign and Commonwealth Affairs on
26 October 2000 (Hansard/Official Report Columns 199W/203W). Back
7
"Common Approaches on Environment and Officially Supported
Export Credits" published by the OECD in November 2001. the
full text is available at: http://www.oecd.org/pdf/M00023000/M00023467.pdf Back
8
Other Government Departments consulted will normally include the
following: Trade Partners UK/British Trade International, DTI,
DEFRA, DFID, FCO, MOD (DESO). Back
9
See "Using the Guidelines" in Part III of the World
Bank's Pollution Prevention and Abatement Handbook 1998 available
at: http://wbln0018.worldbank.org/essd/essd.nsf/Docs/PPAH. Back
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