ECGD Consultation on Proposed Revisions to its Business Principles
NGO submissions and correspondence

by The Corner House and others

first published 3 March 2010

In December 2009, the Export Credits Guarantee Department (ECGD),[1] under pressure from exporters (see, for example, British Exporters Association [BExA]), announced a public consultation on its Proposed Revisions to ECGD's Business Principles and Ancillary Policies. [2]

The consultation covered wide-ranging changes to ECGD's policies on environmental, social and human rights safeguard policies and its anti bribery and corruption measures.

ECGD proposed to revise its policies so that in future they would not be higher than the guidelines for export credit agencies agreed internationally under the OECD's Recommendation on Common Approaches on the Environment and Officially Supported Export Credits or the OECD Recommendation on Bribery and Officially Supported Export Credits.

The Corner House and several other groups (Amnesty International UK, Campaign Against Arms Trade, Jubilee Debt Campaign, Oxfam GB and WWF UK) submitted a joint response to the consultation on 3 March 2010 critiquing the proposals. The groups argued that the proposed changes would have "potentially significant negative impacts for those affected by the projects that ECGD supports", particularly changes covering policies on child labour and forced labour, greenhouse gas accounting, transparency, anti-bribery and financial risks. They considered the proposed changes to be:

"ill-conceived, unjustified, and in a number of areas, potentially in violation of the UK government's legally-binding international undertakings."

The response also raised concerns that ECGD had not conducted a formal impact assessment of its proposed changes as required under the government's Code of Practice on Public Consultations.

After an exchange of correspondence between The Corner House and ECGD on this impact assessment issue (Letters 8 March, 17 March, 22 March and 24 March 2010), ECGD initiated an additional consultation on 17 March 2010 on the Environmental, Social and Human Rights impacts of its proposals.

The Corner House submitted a further response on 30 March 2010 on these impacts, as did Jubilee Debt Campaign and Amnesty International.

Following these consultations, the Government announced on 1 April 2010 that it would implement the changes that the ECGD had proposed back in December 2009.

The Corner House sent a letter to the ECGD's Chief Executive on 12 April 2010 indicating that it intended to challenge this in the courts by requesting a judicial review of the decision.


The Export Credits Guarantee Department (ECGD) is a UK government department that uses taxpayers' money to provide subsidised insurance and guarantees to UK exporting companies against the risks of operating abroad, such as not being paid. It has backed a range of environmentally and socially destructive projects -- large dams, oil pipelines and arms sales -- many of which have involved human rights abuses.


The ECGD's Business Principles were introduced in 2000 to ensure that the ECGD's activities "take into account the Government's international policies, including those on sustainable development, environment, human rights, good governance and trade."