Recent reform of the case impact analysis
process
14. ECGD told us that it first began to consider
environmental issues "in a formal way" in January 1999,
before the review of its mission and status, when its first Environmental
Questionnaire was introduced.[9]
The 1999 review concluded that ECGD needed to consider sustainable
development - not just environmental issues - in a more rounded
and rigorous manner. In response a Business Principles Unit was
created within ECGD. In December 2000, a Statement of Business
Principles was published in which ECGD said, inter alia, that:
"We will provide a responsible approach to business
and will ensure our activities take into account the Government's
international policies, including those on sustainable development,
environmental, human rights, good governance and trade".[10]
15. The Statement of Business Principles also included
a commitment on the part of ECGD to "further develop…
existing guidelines and working procedures to assist detailed
implementation of our policies at a practical level. These will
be kept under review and updated to take account of international
developments and operational experience".[11]
16. Alongside the publication of the Statement of
Business Principles, ECGD introduced a revised and expanded Impact
Questionnaire and other associated screening procedures (collectively
known as the case impact analysis process). These measures were
designed to put ECGD's Business Principles, including its commitment
to sustainable development, into practice.[12]
17. ECGD told us that "the introduction of Business
Principles and the case impact analysis process… led to fundamental
changes in the way ECGD operates"[13]
and indicated that the most significant change was in the way
in which it assessed applications. Previously applications were
assessed almost solely on the ground of repayment risk. Since
the revised procedures were introduced ECGD has also considered
"content, location and potential environmental, social and
human rights impacts of both the export and any associated project".[14]
All civil, non-aerospace applications for support are screened
by ECGD against these considerations (see paras 21-23).[15]
18. Until recently ECGD's initial source of information
on the environmental and social implications of a proposed project
was the revised Impact Questionnaire. Since April 2003, following
extensive consultation with stakeholders in 2002, initial screening
has been based on questions included in every application form.[16]
Analysis of responses to these questions results in each application
being classified as high, medium or low potential impact. The
classification determines the nature of any subsequent assessment.
For low potential impact applications there will be no further
action; medium potential impact applications require completion
of the revised Impact Questionnaire, which may led to further
measures; for those classified as high potential impact, a full
Environmental and Social Impact Assessment is normally required.
9 Ev 58. Back
10
Export Credits Guarantee Department, ECGD's Business Principles,
December 2000. Back
11
Export Credits Guarantee Department, ECGD's Business Principles,
December 2000. Back
12
Ev 58. Back
13
Ev 59. Back
14
Ev 59. Back
15
Aerospace applications are not screen as all UK-manufactured aircraft
and aircraft components comply with international environment
and safety standards. We discuss defence related exports at paras
21-23. Back
16
Ev 62. Back
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