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2004 October Report of the Auditor General of Canada
October 2004 Report—Environmental Review at Export Development Canada
Exhibit 7—Elements of an environmental review process for an international financial institution
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|
Main element |
Sub-elements |
Category |
|---|---|---|---|
|
General features |
Documented environmental and social review process appropriate to the organization's mandate |
Demonstrate that an environmental and social scan of the mandate has been undertaken (such as an assessment, minutes of management meetings) |
Standard1 |
|
List key objectives of the process |
Standard | ||
|
Define key terms used in the process (such as project, environment, environmental risk, and environmental effect) |
Emerging2 | ||
|
Demonstrate management commitment (such as a public statement on process, a management review process) |
Standard | ||
|
Demonstrate management accountability (such as a designated management representative responsible for decisions under the process) |
Standard | ||
|
Demonstrate organizational capacity to implement the process (such as trained staff and resources) |
Standard | ||
|
Provide for monitoring of process conformance |
Standard | ||
|
Provide for public reporting on the nature and extent of the application of the process |
Standard | ||
|
Include a policy commitment and procedures to promote continual learning and improvement in the organization and to inform clients of changing requirements |
Standard | ||
|
Review of financial services applications |
Systematic procedures for financial services applications |
Provide objective criteria and/or procedures for |
|
|
Emerging | ||
|
Standard | ||
|
Standard | ||
|
Standard | ||
|
Standard | ||
|
Standard | ||
|
Require third-party review (at arm's length) of the client's environmental assessment, where the financial institution's process has determined the potential for significant environmental risks |
Emerging | ||
|
Include tools for process implementation (such as guidelines for clients, training packages for internal staff) |
Standard | ||
|
Contents of environmental assessment reports |
Specification of the expected contents of environmental assessment reports |
Describe the surrounding environment |
Standard |
|
Describe the intended use of funds or financial support and any related physical structures |
Standard | ||
|
Describe host country laws, regulations, standards, and other applicable environmental requirements |
Standard | ||
|
Assess and describe known and potential environmental risks (for example to air, water, land, protected areas) |
Standard | ||
|
Identify mitigation measures and monitoring required |
Standard | ||
|
Identify residual impacts after mitigation |
Standard | ||
|
Prepare an analysis that justifies accepting residual impacts |
Standard | ||
|
Describe emergency response procedures where there is a significant potential impact on the environment in the case of an incident |
Emerging | ||
|
Identify and assess public and stakeholder concerns |
Standard | ||
|
Consider alternatives to the undertaking |
Standard | ||
|
Consider cumulative effects |
Emerging | ||
|
Environmental and social standards |
Documented policy and procedures respecting environmental and social standards |
Comply with host country regulations and standards |
Standard |
|
Apply international environmental standards and guidelines (such as World Bank Group's standards, ISO 14000, or a numeric standard such as the World Health Organization's air quality guidelines) |
Standard | ||
|
Apply home country standards in the absence of host country or international standards |
Emerging | ||
|
Ensure due regard for global environmental agreements and conventions (such as Convention on Climate Change, Kyoto Protocol, Montreal Protocol, Convention on Biodiversity, Convention on Environmental Impact in a Transboundary Context, Aarhus Convention) |
Standard | ||
|
Co-operation among institutions |
Documented policy and procedures for co-operation |
Co-ordinate environmental review and monitor efforts when more than one financial institution is involved (for example, co-financing) |
Standard |
|
Allow flexibility to use existing environmental assessments |
Standard | ||
|
Disclosure
|
Documented policy and procedures for active disclosure |
Define information to be disclosed, by whom and when |
Standard |
|
Establish a format for public disclosure of environmental assessment findings |
Standard | ||
|
Public consultation |
Documented policy and procedures for public consultation |
Determine the need for public consultation |
Standard |
|
Identify relevant stakeholders |
Emerging | ||
|
Notify stakeholders |
Standard | ||
|
Receive and summarize public consultation results |
Standard | ||
|
Document gaps in consultation (for example, where consultation was not possible for cultural or political reasons) |
Emerging | ||
|
Disclose results of public consultations |
Standard | ||
|
Environmental covenants |
Documented procedures that establish and include environmental covenants in contractual agreements |
Document any changes or covenants imposed on the application as a result of internal policies, environmental assessment, and public consultations |
Emerging |
|
Monitor and report on compliance with the covenants by the client or a third party |
Standard | ||
|
State the applicant's obligation to take corrective action if monitoring indicates a problem |
Emerging | ||
|
Supervision and monitoring |
Documented procedures to define how transactions are to be supervised and monitored by the institution and to ensure compliance with established covenants |
Arrange occasional inspections by the institution or a local agent to verify compliance reports |
Standard |
|
Establish follow-up procedures where non-compliance has been identified |
Standard |
1 Standard elements are included in the procedures of the majority of the institutions that we examined.
2 Emerging elements reflect the process of only a minority of the institutions that we examined.
