Written evidence submitted by The Corner
House and Jubilee Debt Campaign
INTRODUCTION
1. This Memorandum supplements our previous submissions
and focuses on the following areas where the Committee has sought
evidence:
- The effectiveness of CDC compared with other
similar institutions
- The reforms proposed by the Secretary of State
for International Development
- The extent to which the proposed reforms will
be sufficient to refocus CDC's efforts, especially with respect
to poverty reduction
THE EFFECTIVENESS
OF CDC COMPARED
WITH OTHER
SIMILAR INSTITUTIONS
2. We are not aware of any systematic attempt
to compare the effectiveness of CDC with that of the other major
Development Finance Institutions (DFIs).1 But a number
of reports, both governmental and non-governmental, have been
published that evaluate aspects of specific DFIs, such as Germany's
DEG, Sweden's Swedfund, The Netherlands' FMO, the European Union's
European Investment Bank (EIB) and the World Bank's International
Finance Corporation (IFC). The Corner House has also initiated
its own research into the standards, means of delivery and impacts
of the major European DFIs.
3. Based on preliminary research, The Corner
House and Jubilee Debt Campaign offer the following observations
as to the effectiveness of CDC when compared with other DFIs.
4. CDC is alone in offering only one vehicle
for mobilising capital for the private sector - namely, private
equity funds of funds. Other DFIs offer a wider range of products
- from direct equity participation to loans, insurance guarantees,
credit lines and advice services. Whilst some of these services
(insurance guarantees, for example) are provided in the UK by
government agencies other than CDC, the exclusive reliance of
CDC on funds of funds renders it less able to respond to the varied
capital-raising needs of the private sector in developing countries.
In fact, as noted in our previous submissions, the fund of funds
model is largely inappropriate to the development mandate of CDC
- private equity funds are wholly unsuited to delivering positive
development outcomes (particularly poverty alleviation).
5. A number of DFIs do not provide finance directly
to the private sector in developing countries but instead support
private sector companies based in their own countries that are
doing business abroad. The US agency OPIC is one of these.2
The Dutch FMO is another, but only it would appear in respect
of its Fund Emerging Markets.3 Swedfund also seems
to fulfil a similar role through some of its activities.4
We would contend that such an approach is directed less at building
capacity and relieving poverty in the developing countries and
more at subsidising the private sector in the DFI's home country.
6. Whilst CDC has no restrictions limiting its
support to UK companies, it is noteworthy that many of its funds
are based in the UK (Actis being a case in point) or other Northern
countries (Emerging Capital Partners, for example). In these cases,
it is likely that the profits accrued through CDC support are
not retained in the developing countries but return to the country
of origin. This is especially likely to be the case when the funds
concerned use tax havens or where "investor-friendly"
tax regimes are in place in the developing country. If part of
CDC's purpose is to promote capital development in developing
countries, it is imperative that capital remains in the invested
country. CDC's policies and procedures should ensure that this
happens.
7. Support for Small and Medium Sized Enterprises
(SMEs) is stated to be a major focus of at least two DFIs (Germany's
DEG5 and The Netherlands' FMO).6 The IFC
also has a number of programmes targeted at SMEs and "grassroots"
enterprises,7 although the bulk of its support goes
to large projects or transnational investors.8 Even
in the case of DEG, which is committed to a target of providing
340 million euros per year to SMEs, its SME portfolio represents
just over one-third of its total financial support.9
This, however, is significantly greater than CDC's support for
SMEs, which amounted in 2008 to just four per cent of its investment
portfolio,10 despite the recognised role of SMEs in
providing the bulk of employment and economic activity in many
(though by no means all) developing countries.11 CDC
must set more ambitious targets for SME investment, recognising
too that greater advisory support in terms of improving social
and environmental impacts may be necessary when dealing with SMEs
who are unused to reporting standards.
8. Loans form a major part of the portfolios
of several DFIs, including IFC, EIB, OPIC and DEG. Whilst direct
loans to companies offer many advantages over other forms of finance,12
they can adversely affect development when they are backed by
sovereign counter guarantees (which entail that defaults are added
to a country's national debt), particularly where countries are
already heavily indebted. Some of CDC's previous loans remain
on the books of developing countries.
9. In addition, there is an increasing trend
for loans to be made via intermediaries, with the DFIs having
little or no prior knowledge of where onward sub-loans will be
disbursed. A recent study by a group of international Non-Governmental
Organisations (NGOs) has revealed major concerns in the intermediated
loan portfolios of the major Multilateral Development Banks (MDBs),
many of which now channel up to half of their private sector support
via intermediaries. The NGOs conclude:
"MDBs' procedures have not been sufficiently
adapted to intermediary financing, and this part of the MDB investment
portfolios is extremely poorly monitored, based almost exclusively
on self-reporting. Furthermore, there is evidence that the environmental
and social performance of MDBs' financial sector investments is
consistently low".13
Similar criticisms have been raised against the EIB's
intermediated loan portfolio.14
10. The Corner House and Jubilee Debt Campaign
would strongly recommend against the generalised use of intermediated
loans and against the use of sovereign guarantees by a reformed
CDC. Where intermediaries are used they should be rigorously screened
and monitored to ensure that their onward lending complies with
responsible lending standards.15 We note that the US agency OPIC
has recently introduced rules that require intermediaries to obtain
prior written consent before lending to subprojects.16
In addition, all of OPIC's environmental and social standards
apply equally to intermediated loans. Where an intermediated loan
is likely to have high environmental and social impacts, for example,
the applicant is required to conduct "and certify that they
have conducted" third-part audits to certify that the project
complies with all of OPIC's environmental and social conditions.17
The auditor's certificate and a summary of the findings are publicly
disclosed. CDC should implement similarly policies if it develops
an intermediated loan portfolio.
11. The majority of the DFIs we have looked into
currently operate with no binding restrictions on the use of tax
havens by those funds and companies which they support, a practice
that has drawn widespread criticism, both because of the role
played by tax havens in facilitating corruption and because of
the adverse development impacts of denying developing countries
much-needed tax revenues.18 The only undertaking is
a voluntary agreement by DFIs that are members of the Association
of European Development Finance Institutions (EDFI) to "self
regulate" by using "acceptable" secrecy jurisdictions
as defined by the OECD.19
12. However, three DFIs - Norfund (Norway), Swedfund
(Sweden) and Proparco (France) - have been operating under stricter,
mandatory restrictions on their use of secrecy jurisdictions since
2009.20 For Norfund, this means that it cannot invest
in funds that are domiciled in tax havens that appear on OECD's
"grey list" and which do not have tax agreements with
Norway.21 A recent study undertaken for Norad, Norway's
bilateral aid agency, confirms that the policy has resulted in
Norfund declining to participate in one project in Tanzania and
"a re-routing of one fund to Luxembourg from Mauritius".22
Proparco has similarly confirmed a greater use of Luxembourg by
funds it supports.23
13. Jubilee
Debt Campaign and The Corner House have already set out our concerns
about the use of tax havens in our previous submissions and will
not repeat them here. We would however draw the Committee's attention
to a recent report by a group of international NGOs on the use
of tax havens by DFIs and their development impacts.24
We share the report's conclusion that tax havens have no place
in development finance, a position that, as the NGO report notes:
"accords with the United Nations consensus reached
in Monterrey in 2002 when developing countries committed to delivering
effective and efficient, transparent and accountable tax systems
in exchange for increased international development assistance"
.25
14. In terms of environmental and social standards,
all the DFIs that are members of the EDFI have committed to "benchmarking"
their support against the "UN Declaration of Human Rights,
the ILO Core Conventions and the International Finance Corporation's
Performance Standards on Economic and Social Sustainability and
associated Environmental and Health and Safety Guidelines".26
Such benchmarking does not require compliance with the referenced
standards, simply that the project is assessed against them. By
contrast, for OPIC, compliance with the Performance Standards
is mandatory.27 OPIC also reserves the right to impose
stricter standards and requires compliance with host government
obligations under international law, which would include human
rights obligations.28
15. Monitoring by DFIs of the development outcomes
of their portfolios appears to differ considerable. Some, like
the Dutch FMO, assess the performance of investee companies "after
five years, or on exit from a transaction."29
Others, like Germany's DEG, conduct monitoring throughout the
lifetime of an investment, with a full-blown review every two
years.30 But the monitoring and screening procedures
used by DFIs are open to criticism. With apparently rare exceptions
(OPIC)31 all monitoring is conducted internally. Moreover,
commercial outcomes are often given greater priority than development
outcomes,32 a criticism that has been made not only
of CDC but also the MDBs. Moreover, independent evaluation has
often been critical of the monitoring undertaken. As the Swedish
Agency for Development Evaluation (SADEV), which conducted an
external evaluation of Sedfund in 2008, notes:
"Swedfund should develop better in-house capacity
for monitoring and evaluation of its investments"
and
"Swedfund has not systematically and over time
collected the type of data necessary to draw conclusions on impact
issues".33
FMO's 2008 internal evaluation of its funds likewise
reports:
"To date, evaluations have, at times, been hampered
by the fact that monitoring and annual credit reviews have often
focused almost exclusively on client risk, while insufficiently
tracking progress towards investments' expressed development objectives".34
Action Aid and other NGOs report similar deficiencies
for the MDBs:
"The MDBs' project selection, monitoring and
evaluation procedures have tended to prioritise commercial
rather than social and environmental returns . . . Monitoring
and evaluation methodologies have also been insufficiently focused
on poverty reduction, and transparency and disclosure of information
has been weak".35
16. CDC is not the only DFI to be criticised
for failing to meet its development goals - though CDC's exclusive
use of funds of funds means that identified systemic failures
are more likely to be spread throughout its entire portfolio.
SADEV's independent evaluation of Swedfund reports that the investments
it scrutinised "cannot . . . be said to consistently have
been chosen on the basis of their potential to have an impact
on the situation for poor or disadvantaged groups".36
An internal evaluation conducted by DEG of 16 projects found five
cases where companies "showed clear deviations from DEG environmental
and social standards", and a further five where "minor
deviations" evident, leading DEG to conclude that there was
"room for improvement".37
17. FMO's 2008 internal evaluation of its Small
Enterprise Fund and its Seed Capital fund also found shortcomings,
with 25% of its investments failing to achieve successful development
outcomes.38 The evaluation also notes of FMO's agricultural
portfolio:
"Only one of the five agriculture-related investments
made in 2000-2002 managed to achieve a satisfactory level of environmental
and social performance. In the others, agreed action plans were
insufficiently carried out; in one case, the client's lack of
willingness to carry through agreed improvements even led to termination
of FMO's financing".39
18. If CDC is to become a world leader, it will
need to learn from such shortcomings and research and utilise
better ways of enforcing development outcomes.
19. As with CDC, Non-Governmental Organisations
working on the ground report problems with several of the projects
supported by the DFIs that we have researched to date. Criticism
has been raised, for example, of FMO's support for cut flower
production in Kenya, with labour rights and environmental impacts
raising being major concerns. FMO's and DEG's funding of the Xacbal
hydroelectric dam in Guatemala has been the subject of protests
by affected communities who, even after the dam was completed,
had no access to electricity and whose land was allegedly illegally
appropriated to build the dam.40 DEG's support for
palm oil production in Indonesia has led to accusations by WWF
of causing major adverse tropical forest loss.41 A
number of DFIs - CDC, OPIC, EIB, Swedfund and IFU (Denmark) -
are also invested in Emerging Capital Partners, whose investments
in Nigeria have been the subject of concern over alleged corruption,
as documented in our previous submissions. Such investments suggest
that the anti-corruption due diligence conducted by the investing
DFIs suffers from the same deficiencies as those identified for
CDC. CDC will also need to find new ways of raising human rights,
social and environmental standards across the private sector.
20. The Corner House and Jubilee Debt Campaign
conclude that many of the problems identified with CDC are also
to be found in other DFIs, strongly suggesting that the problems
are in part systemic. They arise from the investment model employed
by DFIs, and in particular from the failure to prioritise development
outcomes in the design of programmes and the choice of investments.
In CDC's case, these problems are more concentrated because of
its exclusive focus on funds of funds as a delivery method.
21. If correct, such an analysis would suggest
that addressing the failings of CDC would require more than simply
diversifying its programmes. It would also require CDC to take
steps to avoid the problems identified with other delivery mechanisms
- for example, by avoiding intermediated funding, the use of sovereign
guarantees and banning the use of tax havens. In addition, it
would, in our view, require closer collaboration between CDC and
poorer communities, with CDC backing a more diverse range of companies
(cooperatives, for example, or community banks) that are Southern-based
and arise from the communities, rather than fund managers identifying
what investments might best address their needs. In effect, it
will require moving from developing finance to financing development.
THE REFORMS
PROPOSED BY
THE SECRETARY
OF STATE
FOR INTERNATIONAL
DEVELOPMENT
22. Jubilee Debt and The Corner House welcome
the Secretary of State's announcement that CDC is to be reformed
and are supportive of the move towards a broader range of financing
channels, subject to the concerns expressed above in respect of
intermediated loans and the continuing proposed use of funds of
funds.
23. But The Corner House and Jubilee Debt regret
that the Secretary of State has already decided that the Department
for International Development (DfID) will continue its "hands
off" approach, only setting the broad framework for CDC's
operations. We believe that if CDC is to avoid the problems that
beset other DFIs, new solutions will need to be evolved that will
require the expertise of staff with development experience, rather
than fund managers. In our view, extra staff will therefore be
needed. Developing and implementing more effective forms of monitoring,
utilising a greater range of instruments and providing support
for a more diverse range of companies - including companies that
might produce lower returns and incur greater risk and therefore
require a higher degree of oversight - across a wider range of
sectors, will all require a more hands-on approach by DfID. It
will also require greater accountability to, and monitoring by,
Parliament.
THE EXTENT
TO WHICH
THE PROPOSED
REFORMS WILL
BE SUFFICIENT
TO REFOCUS
CDC'S EFFORTS,
ESPECIALLY WITH
RESPECT TO
POVERTY REDUCTION
24. As discussed above, merely broadening the
range of products offered by CDC will not by itself improve development
outcomes, any more than it has with other DFIs. If CDC is to prioritise
poverty reduction, as it should, then its approach to the choice,
development, monitoring and mentoring of projects will need to
be radically rethought. In particular, mechanisms that allow for
direct funding, with ongoing oversight and monitoring will be
critical, as will the development of mechanisms that allow poorer
people to participate in the design and implementation of programmes,
for their own benefit.
REFERENCES
1 The main multilateral
and bilateral agencies with private sector development functions
are: African Development Bank, Asian Development Bank, Bio (Belgium),
BMI-SBI (Belgium), CDC Group (UK), Cofides (Spain), DEG (Germany),
European Investment Bank (EIB), European Bank for Reconstruction
and Development (EBRD), FinnFund (Finland), FMO (The Netherlands),
IFC (World Bank Group), IFU (Denmark), Norfund (Norway), OeEB
(Austria), OPIC (USA), PROPARCO (France), Private Infrastructure
Development Group (PIDG), and Swedfund (Sweden). DEG is the largest
national DFI.
2 OPIC, "Overview",
http://www.opic.gov/about-us.
OPIC states:
"OPIC helps U.S. businesses invest overseas,
fosters economic development in new and emerging markets, complements
the private sector in managing risks associated with foreign direct
investment, and supports U.S. foreign policy".
3 FMO, "FOM", http://www.fmo.nl/smartsite.dws?id=1676.
FMO states:
"FOM stimulates the Dutch private sector to
invest in emerging markets by furnishing capital and experience."
4 Swedish Agency
for Development Evaluation (SADEV), "Evaluation of Swedfund
International: An analysis of private sector development impacts",
2008,
http://www.sadev.se/Documents/Publikationer%202008/SADEV%20Report%202008_3.pdf
SADEV notes:
"Swedfund had several goals during the period
studied here; to promote the establishment of profitable companies
in developing countries; to support Swedish industry in establishing
itself abroad by giving priority to joint ventures with Swedish
companies . . ."
5 DEG, "Promoting Small and Medium Enterprises:
Their importance and the Role of DFIs in supporting them",
November 2010, p.25,
http://www.deginvest.de/EN_Home/Service/Online_library/PDFs_Online-Library/DEG_Atrium_Dialogues_2010_Studie.pdf
6 FMO, "Finance",
http://www.fmo.nl/smartsite.dws?id=1481.
FMO states: "We focus
especially on providing finance to micro-, small- and medium-sized
business, specifically in low-income countries".
7 IFC, "SMEs:
Frequently Asked Questions", http://www.ifc.org/ifcext/sme.nsf/Content/FAQ.
The IFC gives a figure of $650 million I financial
market support for SMEs in 2004.
8 Bretton Woods
Project, Evidence to International Development Committee Inquiry
into the World Bank, 19 October 2010,
http://www.brettonwoodsproject.org/art-567067.
See also:
Ellmers, B., Molino, N. and Tuominen, V., "Development
Diverted: How the International Finance Corporation fails to reach
the poor", Eurodad, November 2010,
http://www.eurodad.org/uploadedFiles/Whats_New/Reports/IFC%20final%20for%20website.pdf?n=9645.
9 DEG, "GPR Evaluation Report: New Commitments
2009", March 2010, p.3,
http://www.deginvest.de/EN_Home/About_DEG/Our_Mandate/Development_Policy_Mandate/GPR_Reports/GPR-Auswertung-Neuzusagen-2009_English.pdf.
DEG support for SMEs fell from 38% of total financial
support in 2008 to 35% in 2009
10 National Audit
Office, "Investing for Development: The Department for International
Development's Oversight of CDC Group plc. Report by the Comptroller
and Auditor general", p.7, 2008,
http://www.nao.org.uk/idoc.ashx?docId=1a2db916-cf91-4ce9-89c9-7f821b3f0d12&version=-1
11 DEG, "Promoting
Small and Medium Enterprises: Their importance and the Role of
DFIs in supporting them", November 2010, p.25,
http://www.deginvest.de/EN_Home/Service/Online_library/PDFs_Online-Library/DEG_Atrium_Dialogues_2010_Studie.pdf
See also:
DEG, "The Engine of Growth and employment",
16 November 2010,
http://www.deginvest.de/EN_Home/Press/Press_archive/2010/20101116_21190.jsp
DEG notes: "In many countries, small and medium-sized
enterprises (SME) account for up to 95% of all companies, frequently
generating more than half of the gross national product".
SMEs are also the major employers in many countries,
although this can vary considerably. As DEG records:
"It is clear that in all countries SMEs account
for the vast majority of firms. Even in the United States firms
with less than 500 employees make up 99.8% of all firms that employ
workers. The picture becomes more differentiated when considering
the share of SMEs in employment and value-added (GDP), using the
World Bank standardized database with a cut-off of 250 employees
as the upper limit for SMEs. At one end of the spectrum, Azerbaijan,
Belarus, Georgia, Russia and Ukraine record that between 5 and
15% of workers are employed in SMEs. That may reflect the legacy
of communism. Yet Bulgaria, for example, shows 50%. Nigeria and
Zimbabwe say the number is around 15%. At the other end of the
spectrum Chile, Greece and Thailand claim that roughly 86% of
all employees work for SMEs. In Germany the number is 60%."
12 DEG, "Promoting Small and Medium Enterprises:
Their importance and the Role of DFIs in supporting them",
November 2010, p.25,
http://www.deginvest.de/EN_Home/Service/Online_library/PDFs_Online-Library/DEG_Atrium_Dialogues_2010_Studie.pdf.
DEG notes:
"Straight equity finance for SMEs is problematic.
Loans are much simpler. Loan contracts specify how much the borrower
has to repay and when. If she or he does not repay, there is default.
When loans are of short maturity, there is constant monitoring
of performance with minimal transaction costs. Pure equity has
infinite maturity. So there is always a judgment to be made whether
things will look up in the future. Equity returns come out of
profit that is left over after the firm has made all other decisions.
Excellent accounts are needed to establish basic facts. Close
monitoring of business practices is needed to prevent managers
or owners reducing profit for outside shareholders. The required
complexity of accounting, auditing and corporate governance arrangements
is typically not suitable for SMEs".
DEG, "Promoting Small and Medium Enterprises:
Their importance and the Role of DFIs in supporting them",
November 2010, p.25,
http://www.deginvest.de/EN_Home/Service/Online_library/PDFs_Online-Library/DEG_Atrium_Dialogues_2010_Studie.pdf.
13 Action Aid,
Bretton Woods Project, Christian Aid, Campagna per la Riforma
della Banca Mondiale, Eurodad, Third World Network, "Bottom
lines, better lives? Rethinking multilateral financing to the
private sector in developing countries", 22 April 2010,
http://www.brettonwoodsproject.org/doc/private/privatesector.pdf
14 Counterbalance,
"Trusted and experienced financial partners?The European
Investment Bank''s controversial use of intermediated loans and
private equity funds in developing countries", November 2010.
15 The European Network
on Debt and Development has set out a Charter of Responsible Finance:
http://www.eurodad.org/whatsnew/reports.aspx?id=2060
16 OPIC, "Environmental and Social Policy
Statement", August 2010,
http://www.opic.gov/sites/default/files/docs/final_environmental_social_policy_statement.pdf.
OPIC states at Paragraph 2.6:
"OPIC screens, reviews and provides prior written
consent to all Subprojects on the basis of potential environmental
and social risks."
17 OPIC, "Environmental
and Social Policy Statement", August 2010, paragraph 5.20,
http://www.opic.gov/sites/default/files/docs/final_environmental_social_policy_statement.pdf.
18 See:
Counterbalance, "Secret Havens, Secret Policies:
The Scandal of EIB loans to companies based in tax havens",
29 May 2009,
http://www.counterbalance-eib.org/component/option,com_datsogallery/Itemid,98/func,detail/id,109/
Counterbalance, "Flying in the face of development:
How European Investment Bank loans enable tax havens", July
2009.
Murphy, R, "Investments for Development: Derailed
for Tax havens - A report on the use of tax havens by development
finance institutions", IBIS, NCA, CRBM, Eurodad, Forum Syd,
Tax Justice Network, September 2010,
http://www.eurodad.org/uploadedFiles/Whats_New/Reports/Investment%20for%20development.pdf?n=7931
19 EDFI, "Summary
of EDFI Guidelines for Offshore Financial Centres", October
2009,
http://www.edfi.be/component/downloads/downloads/13.html.
20 Bracking,
S. (ed.), Future Directions for Norwegian Development Finance:
Evidence and Appendices, Norad, ref. no: 0902364-54, 2010.
See also:
Bracking, S, Hulme D, Lawson, D, Sen, K and Wickramasinghe
D, Future Directions for Norwegian Development Finance, Norad,
ref.no: 0902364-55, 2010.
21 Bracking,
S. (ed.), Future Directions for Norwegian Development Finance:
Evidence and Appendices, Norad, ref. no: 0902364-54, 2010.
See also:
Bracking, S, Hulme D, Lawson, D, Sen, K and Wickramasinghe
D, Future Directions for Norwegian Development Finance, Norad,
ref.no: 0902364-55, 2010.
22 Bracking,
S. (ed.), Future Directions for Norwegian Development Finance:
Evidence and Appendices, Norad, ref. no: 0902364-54, 2010.
See also:
Bracking, S, Hulme D, Lawson, D, Sen, K and Wickramasinghe
D, Future Directions for Norwegian Development Finance, Norad,
ref.no: 0902364-55, 2010.
23 Bracking,
S. (ed.), Future Directions for Norwegian Development Finance:
Evidence and Appendices, Norad, ref. no: 0902364-54, 2010.
See also:
Bracking, S, Hulme D, Lawson, D, Sen, K and Wickramasinghe
D, Future Directions for Norwegian Development Finance, Norad,
ref.no: 0902364-55, 2010.
24 Murphy, R,
"Investments for Development: Derailed for Tax havens - A
report on the use of tax havens by development finance institutions",
IBIS, NCA, CRBM, Eurodad, Forum Syd, Tax Justice Network, September
2010,
http://www.eurodad.org/uploadedFiles/Whats_New/Reports/Investment%20for%20development.pdf?n=7931
25 Murphy, R,
"Investments for Development: Derailed for Tax havens - A
report on the use of tax havens by development finance institutions",
IBIS, NCA, CRBM, Eurodad, Forum Syd, Tax Justice Network, September
2010,
http://www.eurodad.org/uploadedFiles/Whats_New/Reports/Investment%20for%20development.pdf?n=7931
26 EFDI, "Principles
of Sustainable Lending", May 2009,
http://www.edfi.be/component/downloads/downloads/25.html
27 OPIC, "Environmental
and Social Policy Statement", August 2010, paragraph 3.6,
http://www.opic.gov/sites/default/files/docs/final_environmental_social_policy_statement.pdf.
28 OPIC, "Environmental
and Social Policy Statement", August 2010,
http://www.opic.gov/sites/default/files/docs/final_environmental_social_policy_statement.pdf.
OPIC states (paragraph 4.2):
"Applicants are required to meet the Performance
Standards, Industry Sector Guidelines, and host country laws,
regulations and standards related to environmental and social
performance, including host country obligations under international
law."
29 FMO, "Investment
Procedures and Policies", http://www.fmo.nl/smartsite.dws?id=451
30 DEG, "Corporate
Policy Project Rating", February 2010,
http://www.deginvest.de/EN_Home/About_DEG/Our_Mandate/Development_Policy_Mandate/GPR-Brief-Description-Englisch_02-2010.pdf.
31 As noted,
OPIC requires third-party certification of compliance with its
standards for projects with high environmental and social standards.
See:
OPIC, "Environmental and Social Policy Statement",
August 2010, paragraph 5.20,
http://www.opic.gov/sites/default/files/docs/final_environmental_social_policy_statement.pdf.
32 An exception
is DEG which gives equal weighting to commercial and development
outcomes.
See:
DEG, "Corporate Policy Project Rating",
February 2010,
http://www.deginvest.de/EN_Home/About_DEG/Our_Mandate/Development_Policy_Mandate/GPR-Brief-Description-Englisch_02-2010.pdf.
33 Swedish Agency
for Development Evaluation (SADEV), "Evaluation of Swedfund
International: An analysis of private sector development impacts",
2008,
http://www.sadev.se/Documents/Publikationer%202008/SADEV%20Report%202008_3.pdf
34 FMO, "FMO's
internal evaluations: Informing Policy and Strategy - FMO's 6th
Annual Evaluation Review 2007/08, along with the response from
FMO's Management Board", May 2008, p.12
http://www.fmo.nl/FMO/documents/ESG/Annual%20Evaluation%20Review%202007_2008.pdf
35 Action Aid,
Bretton Woods Project, Christian Aid, Campagna per la Riforma
della Banca Mondiale, Eurodad, Third World Network, "Bottom
lines, better lives? Rethinking multilateral financing to the
private sector in developing countries", 22 April 2010,
http://www.brettonwoodsproject.org/doc/private/privatesector.pdf
36 Swedish Agency
for Development Evaluation (SADEV), "Evaluation of Swedfund
International: An analysis of private sector development impacts",
2008,
http://www.sadev.se/Documents/Publikationer%202008/SADEV%20Report%202008_3.pdf
37 DEG, "Summary
of the most important results of the evaluation regarding Corporate
Social Responsibility of DEG financing projects", undated,
http://www.deginvest.de/EN_Home/About_DEG/Our_Mandate/Development_Policy_Mandate/GPR_Reports/Summary_of_the_results_of_the_CSR_evaluierung_Internet_version.pdf
38 FMO, "FMO's
internal evaluations: Informing Policy and Strategy - FMO's 6th
Annual Evaluation Review 2007/08, along with the response from
FMO's Management Board", May 2008, p.12
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http://www.fmo.nl/FMO/documents/ESG/Annual%20Evaluation%20Review%202007_2008.pdf
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