Export credit agencies
Many countries have their own banks or other institutions which support companies in exporting their products abroad, called Export Credit Agencies (ECAs). ECAs provide loans, guarantees and insurance of exports for certain projects. China ExIm Bank is one such bank, however it was treated separately here due to its exceptional size and difficulty in accessing information about it or contacting its staff.
In the coal sector, the Japan Bank for International Co-operation (JBIC) has been the most active in recent years, followed by the US ExIm Bank which has however now virtually withdrawn from coal financing. You can find out about planned and current JBIC projects here.
Some governments separate such activities into different institutions, so for example in Japan NEXI – Nippon Export and Investment Insurance – insures exports, including in the coal sector. In Germany, Euler Hermes is actually a private company rather than part of the government, but is officially mandated to provide export credit guarantees.
Due to their participation in some extremely controversial projects, ECAs are monitored by an international NGO network called ECA-Watch which also provides useful information about some of the individual ECAs.
Policies of individual ECAs can vary vastly between countries, however the OECD has come up with a Recommendation on Common Approaches on Environment and Officially Supported Export Credits (PDF) which is not legally binding but is agreed on by the participating ECAs and can be quoted in correspondence as a standard that should be adhered to.
EU-based export credit guarantee agencies
If the Export Credit Agency or government bank is based in the EU, such as Euler Hermes or the Czech Export Bank, it should follow EU legislation, the legislation of its home country and the legislation of the host country, as well as the OECD’s Common Approaches. We recommend contacting ECA-Watch members for assistance in understanding the obligations of each individual ECA.
Friends of the Earth Japan has produced a very useful Citizens’ Guide to Environmental and Social Guidelines of Japanese Public Financial Institutions Involved in Projects Overseas (PDF) which may help.
JBIC and NEXI have their own environmental policies (JBIC’s here, and NEXI’s here), which are very similar to one another. In some ways they are similar to the EBRD and IFC’s policies, dividing projects into several categories according to their likely environmental impact and requiring stricter assessment for those in higher categories. JBIC and NEXI provide some information (project name, place, categorization, and environmental impact assessment) during their environmental review before any decision of approval (JBIC here, and NEXI here). In other ways they are more stringent than the IFC and EBRD, for example stating that in principle, projects must take place outside of protected cultural or natural heritage areas, although the implementation of this provision could be improved.
Also the Environmental Impact Assessment for projects with a large environmental impact must systematically compare “feasible alternatives to the proposed project site, technology, design and operation including the “without project” situation in terms of their potential environmental impacts; the feasibility of mitigating these impacts; their capital and recurrent costs; their suitability under local conditions; and their institutional, training and monitoring requirements”. For each alternative, it has to quantify the environmental impacts to the extent possible, and attach economic values where feasible. The basis for selecting the particular project design proposed must be stated and justification offered for the recommended emission levels and approaches to pollution prevention and abatement. This is more concrete and elaborated than the EU Directive on environmental impact assessment for example, which only requires an explanation of the alternatives examined and the reason for the selected course of action.
Both the JBIC and NEXI have complaint mechanisms (see Contacts section). In principle these should be approached after one of the institutions already approved financing for a project that is not in compliance with their standards, however it can also be worth sending a complaint also before this happens so that the complaint mechanisms can alert the institutions to take action.
If approaching one of the Export Credit Agencies, it is worth checking whether ECA Watch has a member group (under ‘About us’) in the relevant country who might give you some tips.
Some contacts for the most relevant ECAs that may back coal projects in southeast Europe and Turkey are:
It is difficult to find out the exact person to write to, but this organization chart can at least give some ideas about which departments to approach.
If you write a letter to JBIC/NEXI, we recommend that the letter addresses the top management (the governor of JBIC/the Chairman of NEXI).
In the case of JBIC, you can also email such letter or any comments regarding environmental and social problems to email@example.com (the official email address of the environmental division of JBIC.)
4-1 Ohtemachi 1-chome,
Tel: +81 3-5218-3100
Fax: +81 3-5218-3955
JBIC Paris office (responsible for EU member countries (excluding United Kingdom and Ireland), Switzerland, Norway, Turkey, Tunisia, Algeria, Morocco, Madagascar and other European and African countries)
Address: 21, Boulevard de la Madeleine,
75038 Paris Cedex 01,
JBIC complaint mechanism
Office of Examiner for Environmental Guidelines,
Japan Bank for International Cooperation
4-1, Ohtemachi 1-chome, Chiyoda-ku,
Chiyoda First Building, East Wing 3rd Floor,
NEXI Paris office
c/o JETRO 27, rue de Berri,
75008 Paris France
NEXI complaints mechanism
Examiner: Mr. Kazuo Matsushita
Nippon Export and Investment Insurance
Chiyoda First Building 3rd Floor 3-8-1,
Nishikanda, Chiyoda-ku Tokyo 101-8359, Japan
Czech Export Bank
Vodičkova 34, P.O. Box 870, 111 21 Praha 1,
Tel.: +420 222 843
Fax: +420 224 226 162
Director of the Export and Project Finance Dept:
Ing. Pavel Mráz[open e-mail to:firstname.lastname@example.org]
Director, Export and Project Finance Dept
Vodičkova 34, P.O. Box 870, 111 21 Praha 1,
Fax: 224 226 162,
Tel.: +420 222 843 228
Fax: +420 224 218 111
Czech Export Guarantee and Insurance Corporation (EGAP)
Ing. Ladislav Řezníček, MBA (email@example.com)
Project Risks Management Department
Export Guarantee and Insurance Corporation (EGAP)
111 21 Prague 1
Fax: +420 222 844 120
ECA-Watch network of NGOs monitoring and campaigning on ECAs