Evaluation of EXIM's Environmental Effects Consideration

EXIM’s Office of the Chairman, in coordination with the Office of Policy Analysis and International Relations, the Office of Board Authorized Finance, and Office of General Counsel, should propose updated Environmental and Social Due Diligence Procedures and Guidelines for Board review and approval that incorporates, as necessary, revisions of applicable international standards.

EXIM’s Office of the Chairman, in coordination with the Office of Policy Analysis and International Relations, the Office of Board Authorized Finance, and the Office of General Counsel, should produce updated Environmental and Social Due Diligence Procedures and Guidelines for Board review and approval that clarify whether and, if so, how the ESPG relates to domestic transactions.

The Office of General Counsel should produce a written opinion on the circumstances under which Board members may withhold or approve transaction based upon environmental effects.

EXIM’s Office of Board Authorized Finance should establish policies and procedures establishing clear milestones for required environmental and social due diligence documentation.

EXIM’s Office of Board Authorized Finance should develop a plan to ensure the Engineering & Environment Division is properly resourced to conduct the required technical reviews and environmental assessments.

EXIM’s Office of Board Authorized Finance should develop a written policy or procedure that outlines the process for addressing when a project’s implementation does not align with EXIM’s Environmental and Social Due Diligence Procedures and Guidelines after the Board has approved the transaction.

EXIM’s Office of Board Authorized Finance should develop a written policy or procedure that defines when an environmental and/or social due diligence review is necessary for any restructuring or modifications requiring Board re-approval.