APPENDIX 13
Supplementary memorandum by the CBI
Thank you for the opportunity to express out
members' views at the sub-committee hearing on 17 May. We thought
you might find it helpful if we were to reiterate the following
points which were all touched on to some extent during the sessions
which we attended.
1. UK exporters are subject to the relevant
English Law anti-corruption legislation wherever they operate
in the world, irrespective of which Export Credit Agency's support
they are employing and indeed, even if they are not employing
any Export Credit Agency support at all.
2. It is that legislation, not ECGD's procedures,
which constitutes the primary deterrent and which provides the
most severe sanctions against bribery and corruption by UK exporters.
The significance of the legislation is internationally recognised.
The OECD Bribery Working Group reviewed the legislation in 2003
and concluded that "UK law now addresses the requirements
set forth in the [OECD] Convention".
3. Our members' well publicised concerns
about ECGD's procedures should not be interpreted as a desire
to "water down" ECGD's provisions or to weaken the UK's
stance on bribery and corruption. The points at issue have been
principally the practicalities of compliance, and the ability
of ECGD to manage commercially confidential information. The first
issue has we believe been substantially addressed by the recent
consultation's Final Response, and the second is the subject of
the continuing discussion on ECGD's "Special handling arrangements".
We hope you find these additional comments to
be useful and remain at your disposal to answer any other questions
you feel we could usefully address.
26 May 2006
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