Memorandum submitted by The Corner House
INTRODUCTION
1. The Corner House is a not-for-profit
research and advocacy group, focusing on human rights, environment
and development.
2. Over the past ten years, The Corner House
has closely monitored the human rights impacts of overseas projects
that are operated or financed by UK multinationals, UK government
agencies, commercial banks, investment funds and, more recently,
the "shadow banking" sector.[481] A
particular focus of our work has been the support given to UK
multinationals by the UK Export Credits Guarantee Department (ECGD).[482]468
3. The Corner House is firmly of the view:
(i) that decisions taken in the UK, whether by government or business,
should not adversely impact the human rights of others, whether
those others are in the UK or abroad; and (ii) that the UK government
has a responsibility to ensure that the appropriate laws and policies
are in place to give practical effect to that principle and to
hold those who breach it to account.
4. The Corner House welcomes the Joint Committee's
current inquiry and is grateful for the opportunity to comment
on the issues that the Committee has chosen to examine. This submission
focuses on Part 1 of the Committee's Call for Evidence, namely
"The Duty of the State to Protect Human Rights", with
particular reference to the policies and practices of the UK Export
Credits Guarantee Department (ECGD).
THE EXPORT
CREDITS GUARANTEE
DEPARTMENT (ECGD)
5. The ECGD is the UK's export credit agency.[483] It
derives its functions and powers from the Export and Investment
Guarantees Act 1991.[484] Its
primary function is to facilitate the export of goods and services
by providing companies with guarantees, credits and insurance.
In carrying out its functions, the ECGD makes use of a variety
of different financial instruments including different forms of
credit and insurance. Many of the exports supported by ECGD would
not go ahead without an official credit guarantee.
6. According to the ECGD's 2007-08 accounts,
the value of guarantees and insurance policies issued by the Department
was £1.83 Billion.
7. Although the ECGD is subject to a ministerial
requirement to operate at "no net cost to the taxpayer",[485] the
UK government is ultimately liable for any losses that cannot
be covered by the premiums charged to the ECGD's client businesses
or by debt recovery. In 2005, the UK admitted that the annual
cost of the ECGD to the taxpayer is an annual £150 million.[486]
8. The Corner House believes that that where
companies receive publicly-backed finance, as is the case with
support from ECGD, they should be subject to legally-binding conditions
that require compliance with the UK's international human rights
obligations, and that these conditions should have extraterritorial
scope.
9. As a public agency supporting UK exporters,
the ECGD should therefore give practical effect to the UK's acknowledged
obligation "to promote... the universal respect for, and
observance of the human rights and fundamental freedoms for all"[487] and
the government's stated aim of putting human rights at "at
heart of foreign policy."[488]
10. ECGD has provided guarantees and other
support for a range of projects and programmes that have involved
allegations of human rights abuses, including the export of Hawk
jets to Indonesia,[489] oil
pipelines such as BP's Baku-Tbilisi-Ceyhan project in the Caspian
region,[490] dams
such as Muella in Lesotho[491] and
power plants such as Dabhol in India.[492] The
ECGD has also supported arms sales to countries with authoritarian
governments and poor human rights records, such as Saudi Arabia.[493]
11. In 2000, in response to public and parliamentary
pressure, the ECGD adopted a new mission statement[494] and
accompanying set of "Business Principles".[495] These
committed ECGD to ensuring that "its activities accord with
other Government objectives, including those on sustainable development,
human rights, good governance and trade."[496]
12. The ECGD has since introduced procedures
and policies to give effect to this undertaking.
Procedures
13. All civil, non-aerospace exports and
guarantees are now screened by ECGD for their environmental and
social impacts. Under the screening procedures, ECGD considers
the following human rights concerns:
— Possible impacts arising from involuntary
resettlement, compulsory land acquisition, impacts on minority
or vulnerable groups, the use of child or bonded labour, and the
use of armed security guards;[497]
— Whether or not support for overseas projects
"might breach any international obligations or policies of
the UK government";[498]
— Whether or not the host country has ratified
"the six core UN Human Rights treaties[499] and
eight International Labour Organisation fundamental conventions[500]"
in order to "identify those with which the project should
comply";[501] [502]
— Whether or not the benefits of the project
(including employment opportunities for local people) will be
open to all, regardless of "race, religion, gender, social
grouping etc".[503]
14. Defence sales are not screened at all
by ECGD for human rights impacts However, ECGD requires that any
necessary export licences are obtained as a pre-condition of cover.[504]
Policies
15. ECGD has no dedicated human rights policies.
16. It has, however, made a number of commitments
that pertain to human rights. For example:
— It is now ECGD policy that "projects
should comply in all material respects with the relevant safeguard
policies, directives and environmental guidelines of the World
Bank Group."[505] [506] These
cover a number of areas encompassing human rights considerations
- projects involving involuntary resettlement, for example, must
have an accompanying Resettlement Action Plan.
— ECGD has introduced a policy "not
to provide support to projects that involve harmful child labour
. . . bonded or forced labour.[507] (Until
as recently as 2004, the ECGD was prepared to consider such projects
in "exceptional circumstances").[508]
CONCERNS OVER
ECGD'S POLICIES
AND PROCEDURES
17. On paper, the ECGD's procedures and
policies on human rights go far beyond those adopted by many other
export credit agencies. However, in practice, the policies lack
teeth and their implementation is weak. As the Chair of the Trade
and Industry Committee remarked in 2004: "at times there
is a tendency towards carelessness or a lack of attention in some
respects, certainly to human rights".[509]
18. The Corner House shares this concern.
In particular, it would draw the Committee's attention to the
following weakness of the ECGD's policies and procedures:
ECGD's human rights policies are considered a secondary
duty
19. ECGD views its Business Principles and
stated policies on human rights as entirely "secondary"
(its wording)[510] to
the fulfillment of what the Department views as its primary purpose:
the facilitation of UK exports.[511] [512]
20. The consequences of this ordering of
priorities are evident at every level of the ECGD's decision-making.
For example, the ECGD recently relaxed its rules so that it could
still support UK exporters even where up to 85 % of the content
of the goods covered had been manufactured outside of the UK.[513] The
Corner House and others raised concerns that this could lead to
the UK facilitating labour abuses abroad, particularly where UK
exporters were taking advantage of cheap labour in developing
countries.[514] However,
the ECGD has declined to adopt new rules to ensure against labour
abuses in the supply chains used by UK exporters. No action will
be taken unless agreement can be reached internationally with
other export credit agencies.[515] As
a result, the ECGD now has a policy that (on paper) prohibits
the use of child, bonded or forced labour in projects but turns
a blind eye to its potential use in the manufacture of the exported
goods. The Corner House believes that unilateral action could
and should have been taken by the UK in order to fulfill the UK's
international obligation to respect and promote human rights.
21. The Corner House believes that ECGD's
founding Act should be amended to ensure that the ECGD's duty
to facilitate exports is subject to a duty to uphold the UK's
international human rights obligations.
ECGD's policies and procedures are discretionary
22. Although ECGD's human rights policies
appear to be unequivocal ("It is ECGD policy that . . .),
ECGD has reserved wide powers to derogate from them, thus seriously
weakening their effectiveness. Categorical policy statements (for
example, that all projects should comply with World Bank safeguard
policies) are hedged by other statements allowing ECGD to exercise
wide discretion in their application (for example, that its procedures
as laid down in its 'Case Impact Analysis Process' paper are "not
a statement of what will be done in every case"[516]).
In the example of BP's Baku-Tbilisi-Ceyhan oil pipeline,[517] for
which ECGD provided cover of £81,703,893, The Corner House
and other non-governmental organization found evidence of 83 breaches
of the World Bank guidelines, many of them related to human rights
abuses.[518]
23. The Corner House believes that the application
of ECGD's human rights policies should be mandatory and that derogations
should be permitted only in very limited circumstances and must
be publicly justified.
Limited extra-territorial application
24. ECGD has adopted a number of policies
that make its support to companies conditional upon their giving
undertakings relating to their actions outside of the UK. An example
is its anti-bribery policy, which requires companies to give a
signed undertaking that they have not paid bribes in the UK or
elsewhere to obtain the contracts that ECGD would underwrite.
25. However, apart from its policy on child,
bonded and forced labour, the ECGD has declined to require similar
extraterritorial undertakings on human rights.
26. Although it assesses a project's compliance
with the UK's policies on human rights, it does not condition
support on companies adhering to those policies. It merely identifies
where there may be gaps in compliance.
27. Such conditions as it does apply amount
to little more than a requirement that companies comply with host
country legislation on human rights. For example, the requirement
that companies observe the six core UN Human Rights treaties and
eight International Labour Organisation fundamental conventions
only applies where these have been ratified by the host government:
it does not apply to projects in countries where the treaties
and conventions have not been ratified. India, where ECGD is currently
considering a High Impact project, is a case in point.[519]
28. The Corner House believes that the ECGD
should condition its support for companies on their undertaking
to comply with those human rights conventions to which the UK
is a party.
29. The Corner House accepts that the extent
to which the UK has a duty under international human rights law
to regulate the extra-territorial activities of UK businesses
is contested, not least by the UK government. However, it notes
the recent report to the UN General Assembly of the Special Representative
on Human Rights and Business, in which he states:
"The extraterritorial dimension of the duty
to protect remains unsettled in international law. Current guidance
from international human rights bodies suggests that States are
not required to regulate the extraterritorial activities of businesses
incorporated in their jurisdiction, nor are they generally prohibited
from doing so provided there is a recognized jurisdictional basis,
and that an overall test of reasonableness is met. Within those
parameters, some treaty bodies encourage home States to take steps
to prevent abuse abroad by corporations within their jurisdiction".[520]
30. The Corner House believes that one such
test of reasonableness would be whether or not a government is
making taxpayer-backed finance available to companies to support
their activities abroad.
Limited due diligence
31. NGOs have also questioned the thoroughness
of the ECGD's due diligence on human rights and that of the Foreign
Office, on which the ECGD relies for advice.[521]
32. There is also concern that the focus
of the ECGD's due diligence is too limited. For example, there
is no requirement to assess the extent to which freedom of expression
is guaranteed in the host country and thus the extent to which
affected communities might face repression should they raise concerns
over the project. This is of concern given allegations of intimidation
(or worse) of those who have challenged a number of projects that
ECGD has backed. In the case of BP's Baku-Tbilisi-Ceyhan oil pipeline,
those seeking to uphold the rights of villagers affected by the
Turkish section of the pipeline have been accused of being "traitors
to their country" and of supporting the outlawed PKK Kurdish
guerilla movement.[522] Ferhat
Kaya, a human rights defender who was working to assist affected
communities in the Ardahan region of Turkey, was also subject
to arbitrary arrest and alleged mistreatment by the police for
his work in assisting villagers obtain proper compensation or
redress for grievances arising from the expropriation of their
land.[523]
33. The reliance on the World Bank Group's
safeguard policies as the primary benchmark for assessing human
rights impacts is also problematic. Although, as noted, the World
Bank safeguard policies cover a number of areas that involve human
rights considerations, they do not explicitly require adherence
to binding international human rights conventions.
34. The Corner House believes that the ECGD
should be required to screen fully all applications for their
potential human rights impacts and that an independent Human Rights
Impact Assessment should be mandatory for "High Impact"
projects. Projects that do not meet the UK's international human
rights obligations should be excluded from ECGD support. Such
screening would require the human rights context of a project
to be taken into account.
35. The Corner House notes that a range
of specific human rights screening procedures are already available
and could easily be adopted by ECGD. Examples include the Danish
Human Rights and Business Project's Human Rights Compliance Assessment
(developed with industry to meet industry's requirement that screening
should take no more than 40 hours to complete), the Norwegian
development agency (NORAD)'s Human Rights Impact Assessment, and
Rights & Democracy's human rights impact assessment[524] currently
being developed in collaboration with affected communities.
Lack of grievance mechanisms
36. The ECGD has no grievance mechanism
through which those affected by the projects it supports could
seek redress. By contrast, a number of other export credit agencies,
such as Canada's Export Development Corporation, have introduced
ombudsman or other grievance mechanisms. The Corner House would
recommend that the ECGD does the same.
37. The Corner House believes that ECGD
should also be accountable in law to those impacted by the projects
and exports it facilitates. The Corner House would therefore urge
the amendment of ECGD's founding Act to include a 'Duty of Care'
clause with regard to the human rights of those affected by ECGD-supported
projects.
CONCLUSION
38. The Corner House believes that the UK's
duty to promote and respect human rights should be given full
effect through conditions placed on the use of taxpayer-backed
finance to support UK industry in its activities abroad, notably
through the ECGD.
39. The ECGD's current policies and procedures
on human rights are inadequate. Parliament should consider amending
the ECGD's founding Act to ensure that UK support for exporters
is conditional on protecting and not infringing human rights.
The Corner House
May 2009
481 For a discussion of the role of the "shadow
banking system" in financing projects involving human rights
abuses, see: Hildyard, N., "A (Crumbling) Wall of
Money: Financial bricolage, derivatives and power", The Corner
House, October 2008, http://www.thecornerhouse.org.uk/pdf/briefing/39wallmoney.pdf. Back
482
For example, The Corner House has participated in nine field missions
to assess the social and environmental impacts of a number of
projects for which ECGD support has been sought and undertaken
in-depth research into a number of ECGD-backed projects that have
been tainted by allegations of bribery. Back
483
Export credit agencies are public, quasi-public or private agencies
that provide loans, guarantees, credits and insurance to private
corporations from their home country to assist them doing business
overseas. Such support is particularly requested in relation to
projects in the developing world because of the perceived financial
and political risks involved in such projects and would be more
expensive if obtained through the private sector. Where the ECA
is public or quasi-public, the loans are backed by the agency's
national government. Back
484
Under the Export and Investment Guarantees Act 1991, the ECGD,
acting on behalf of the Secretary of State for Business, Enterprise
and Regulatory Reform, is required to " facilitat[e], directly
or indirectly" the supply of British exports. Back
485
National Audit Office, ECGD and Sustainable Development, 2008,
para 9, http://www.nao.org.uk/publications/0708_ECGD_and_sustainability.pdf. Back
486
Secretary of State for Trade and Industry/ Chief Secretary to
Treasury, "Estimating the economic cost of ECGD", 16 March
2005, http://www.berr.gov.uk/files/file16384.pdf Back
487
Foreign and Commonwealth Office, "Promoting Human Rights,
Good Governance and Democracy, http://www.fco.gov.uk/en/fco-in-action/conflict/human-rights/,
accessed 7 April 2009: "As a member of the United Nations
it is our obligation to promote: 'the universal respect for, and
observance of the human rights and fundamental freedoms for all,
without distinction as to race, sex, language or religion'".
See also: Foreign and Commonwealth Office, "The Obligation
to Promote Human Rights",
http://collections.europarchive.org/tna/20080205132101/http://www.fco.gov.uk/servlet/Front?pagename=OpenMarket/Xcelerate/ShowPage&c=Page&cid=1028302591752,
accessed 7 April 2009: "The duty not to intervene in
matters within the domestic jurisdiction of other States is a
recognised principle of international law, reflected in Article
2(7) of the UN Charter. However, Articles 55 and 56 of
the Charter set out the obligations of all UN Members to promote
'universal respect for, and observance of, human rights and fundamental
freedoms for all without distinction as to race, sex, language
or religion'. This obligation was expressly recognised at the
Vienna World Conference, which declared that: 'The promotion and
protection of all human rights is a legitimate concern of the
international community'. The UK Government strongly supports
this view. It is for countries to decide whether to accede to
legally binding international human rights instruments. But failing
to accede cannot exempt a country from international attention
and criticism." Back
488
Foreign and Commonwealth Office, "Human Rights", accessed
7 April 2009, http://collections.europarchive.org/tna/20080205132101/www.fco.gov.uk/servlet/Front%3fpagename=OpenMarket/Xcelerate/ShowPage&c=Page&cid=1028302591712. Back
489
Gilby, N., "Arms Exports to Indonesia", Campaign Against
Arms Trade, http://www.caat.org.uk/publications/countries/indonesia-1099.php. Back
490
The 1,760 kilometre-long Baku-Tbilisi-Ceyhan (BTC) oil pipeline
runs from Baku in Azerbaijan, through Tbilisi in Georgia to a
new marine terminal at Ceyhan on Turkey's Mediterranean coast.
The aim of the project is to carry up to 1 million barrels
of oil per day from the Caspian Sea to the Mediterranean. For
details of human rights and other concerns, see: Baku Ceyhan Campaign,
http://www.baku.org.uk/. Back
491
The Muela Hydropower Project (ECGD support: £16 million)
is part of the Lesotho Highlands Water Project, which resulted
in the forced resettlement of 27,000 people, the shooting
of striking construction workers, proven corruption and major
environmental impacts. See: Pottinger, L., "Police Kill Striking
Workers in Leostho", World Rivers River, September 1996,
http://internationalrivers.org/files/WRR.V11.N4.pdf;
International Rivers, "Lesotho Water Project", http://internationalrivers.org/en/africa/lesotho-water-project. Back
492
Human Rights Watch, "The Enron Corporation: Corporate Complicity
in Human Rights Violations", 1999, http://www.hrw.org/legacy/reports/1999/enron/. Back
493
Campaign Against Arms Trade, "Saudi Arabia", http://www.caat.org.uk/issues/saudi-arabia.php. Back
494
ECGD, Mission, http://www.ecgd.gov.uk/index/about-ecgd/mission-and-objectives.htm. Back
495
ECGD, Business Principles, http://www.ecgd.gov.uk/ecgds-business-principles.pdf. Back
496
ECGD, Mission Statement, http://www.ecgd.gov.uk/index/aboutecgd/ecgdmissionandobjectives.htm. Back
497
ECGD, Business Principles Unit, Case Impact Analysis Process,
May 2004, para 5.11, http://www.ecgd.gov.uk/ecgd_case_impact_analysis_process_-_may_2004-4-1-1-0.pdf. Back
498
ECGD, Business Principles Unit, Case Impact Analysis Process,
May 2004, para 5.13, http://www.ecgd.gov.uk/ecgd_case_impact_analysis_process_-_may_2004-4-1-1-0.pdf. Back
499
See Annex 5 of FCO Human Rights Annual Report 2003: www.fco.gov.uk/Files/kfile/Annexes,0.pdf Back
500
See: www.ilo.org/ilolex/english/newratframeE.htm. Back
501
ECGD, Business Principles Unit, Case Impact Analysis Process,
May 2004, para 5.18, http://www.ecgd.gov.uk/ecgd_case_impact_analysis_process_-_may_2004-4-1-1-0.pdf. Back
502
Where applicable, the European Convention on Human Rights is also
taken into account . See: ECGD, Business Principles Unit, Case
Impact Analysis Process, May 2004, footnote 10, http://www.ecgd.gov.uk/ecgd_case_impact_analysis_process_-_may_2004-4-1-1-0.pdf. Back
503
ECGD, Impact Questionnaire, 2007, question 9, http://www.ecgd.gov.uk/impact_questionnaire_april_2007_-_final.doc. Back
504
ECGD, Business Principles Unit, Case Handling Process Information
Note, September 2008, p.5, http://www.ecgd.gov.uk/ecgds-case-handling-process-information-note-september-2008.pdf. Back
505
ECGD, Business Principles Unit, Case Impact Analysis Process,
May 2004, para 2.6, http://www.ecgd.gov.uk/ecgd_case_impact_analysis_process_-_may_2004-4-1-1-0.pdf. Back
506
These guidelines include: the ten "Safeguard Policies"
operated by the Bank's International Bank for Reconstruction and
Development (IBRD); and the recently introduced Performance Standards
operated by the International Finance Corporation (IFC), the private
sector arm of the World Bank. See: www.worldbank.org/safeguards;
http://www.ifc.org/ifcext/sustainability.nsf/Content/EnvSocStandards. Back
507
ECGD, Impact Questionnaire, 2007, p.iv, http://www.ecgd.gov.uk/impact_questionnaire_april_2007_-_final.doc Back
508
Previously, the ECGD allowed for such projects under exceptional
circumstances. In its April 2003 Guidance Notes for its Impact
Analysis Procedures, for example, it stated: "There must
be exceptional circumstances for ECGD to provide cover to projects
which involve child labour". A similar derogation was applied
to the ILO Convention on Forced Labour, although the ECGD states
that "it is difficult to imagine circumstances in which the
ECGD could provide cover to projects which involve forced labour." Back
509
Trade and Industry Committee, "Export Credits Guarantee Department",
11 May 2004, Q499. The quote is taken from an uncorrected
transcript of evidence and its use is subject to the following
caveat: "Neither witnesses nor Members have had the opportunity
to correct the record. The transcript is not yet an approved formal
record of these proceedings". Back
510
ECGD, Sustainable Development Action Plan 2007, http://www.ecgd.gov.uk/sdap_final_2007-3.pdf.
Para 10: "ECGD also has certain secondary duties set
for it by Ministers. These include compliance with its Statement
of Business Principles . . ." (emphasis added). Back
511
The ECGD's statutory powers derive from the Export and Investment
Guarantees Act 1991, under which the Department, acting on behalf
of the Secretary of State for Business, Enterprise and Regulatory
Reform, is required to " facilitating, directly or indirectly"
the supply of British exports. Back
512
It is perhaps of note that the ECGD does not even mention sustainable
development objectives as part of its statement of aims on the
Department's home web page. The ECGD's aim is stated as being
"to help UK exporters of capital equipment and project-related
goods and services win business and complete overseas contracts
with confidence. See: ECGD, "Welcome to ECGD", http://www.ecgd.gov.uk/. Back
513
ECGD, "Consultation on changes to ECGD's policy support for
foreign content", June 2006, http://www.ecgd.gov.uk/foreign_content_consultation_pdf.pdf. Back
514
The Corner House et al, Submission to ECGD Consultation on Foreign
Content, 2006, http://www.ecgd.gov.uk/revised_cornerhouse--att364533.pdf. Back
515
ECGD, Public Consultation on ECGD Support for Foreign Content,
March 2009, http://www.ecgd.gov.uk/ecgd-support-for-foreign-content-supply-chain-2009-03-10.pdf. Back
516
ECGD, Business Principles Unit, Case Impact Analysis Process,
May 2004, para 2.1,
http://www.ecgd.gov.uk/ecgd_case_impact_analysis_process_-_may_2004-4-1-1-0.pdf. Back
517
The 1,760 kilometre-long Baku-Tbilisi-Ceyhan (BTC) oil pipeline
runs from Baku in Azerbaijan, through Tbilisi in Georgia to a
new marine terminal at Ceyhan on Turkey's Mediterranean coast.
The aim of the project is to carry up to One million barrels of
oil per day from the Caspian Sea to the Mediterranean. Back
518
See: The Corner House et al., "Review of the Environmental
Impact Assessment for the Turkish section of the Baku-Tbilisi-Ceyhan
oil pipeline", 8 October 2003, , http://www.bakuceyhan.org.uk/eia_review.htm. Back
519
ECGD's due diligence on child labour in project in India is of
concern. In 2005-06, it gave support for an export to a steel
mill in India operated by Jindal Vijayanagar Steel Ltd, a company
which has been accused of using raw materials derived from mines
where child labour is alleged to be employed. Although the charge
has been denied by the company, The Corner House believes that
the ECGD's absolute ban on the use of child labour should have
triggered enhanced due diligence. The completed screening form
for the project, however, gives no indication that ECGD was even
aware of the allegations. Indeed, ECGD appears to approved the
project despite key questions in the impact questionnaire for
the project being left unanswered by the applicant, including
those relating to resettlement and whether or not the project
would "cause, require, bring about or stimulate" child
labour. The completed forms, which were released under Feedom
Of Information legislation, are available on request from The
Corner House. Back
520
Para 15, http://www2.ohchr.org/english/bodies/hrcouncil/docs/11session/A.HRC.11.13.pdf. Back
521
See, for example: "Correspondence between the Foreign and
Commonwealth Office and the Kurdish Human Rights Project and the
Corner House: Letter from the Kurdish Human Rights Project and
the Corner House-quality of human rights advice supplied by FCO
to ECGD on BTC pipeline project", http://www.publications.parliament.uk/pa/cm200405/cmselect/cmtrdind/374/374we08.htm. Back
522
See: "Baku-Tbilisi-Ceyhan oil pipeline: Human Rights, Social
and Environmental Impacts - Turkey Section", Final Report
of Fourth Fact Finding Mission, September 2004, http://www.baku.org.uk/publications/turkey_ffm_2004.pdf,
in particular "Section 6: Human Rights abuses and intimidation";
"International Fact Finding Mission: Baku-Tbilisi-Ceyhan
pipeline - Turkey Section", http://www.baku.org.uk/publications/Tu_FFM.pdf,
in particular, "Section 1: BTC, Security and Human Rights". Back
523
Ferhat Kaya, "Witness Statement", reproduced at pages
45-52 in "Baku-Tbilisi-Ceyhan oil pipeline: Human Rights,
Social and Environmental Impacts - Turkey Section", Final
Report of Fourth Fact Finding Mission, September 2004, http://www.baku.org.uk/publications/turkey_ffm_2004.pdf. Back
524
For further details, see: http://www.dd-rd.ca/site/publications/index.php?subsection=catalogue&lang=en&id=2094;
and http://www.dd-rd.ca/site/_PDF/publications/Getting-it-right_HRIA.pdf. Back
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