All applications to GIEK are assessed for social (including labour and human rights) and environmental risks, impacts and consequences.

Information from clients and other sources obtained independently by GIEK is used to classify projects as A, B or C, where A has the highest degree of risks and impacts.

In addition to GIEKs internal policies and procedures, we follow the following international standards:

  • OECDs Recommendation of the Council on Common Approaches for Officially Supported Export Credits and Environmental and Social Due Diligence (the "Common Approaches)(2016)
  • UN Guiding Principles on Business and Human Rights.
  • IFC Performance Standards (IPS) (2012, Performance Standards) and World Bank guidelines for environment, health and safety (EHS Guidelines)

It is expected that as part of their own due diligence that our clients have made an evaluation of potential social (including labour and human rights) and environmental risks and impacts related to their project or delivery and have adequate polices and systems in place to avoid or mitigate these where possible.

We recommend that all applicants are familiar with the OECD Guidelines for Multinational Enterprises and how these apply to their business. As part of GIEKs due diligence process, we take into account complaints raised against companies at the Norwegian National Contact Point (NCP) for the OECD, and the willingness of companies involved to cooperate with the NCP.

Useful links:

OECD Common Approches

UNGP business and human rights

World Bank EHS guidelines

OECD Guidelines for Multinational Enterprises

National Contact Point Norway
 

Requirements to our customers

GIEK is committed to integrating environmental and human rights aspects into our risk assessments. Our aim is to provide practical advice that facilitates the management of risk and potential negative impacts in order to decrease the operational, financial, and reputational risks related to specific projects.

GIEK’s policy on the environment and human rights is in line with international commitments and Norwegian governmental policies. GIEKs environmental and human rights due diligence policy is based on the implementation of the OECD’s «Common Approaches on Environmental and Social Due Diligence (2016)» and operationalizing of the UN Guiding Principles on Business and Human Rights. GIEK's Environmental and Human Rights Due Diligience Procedure is available here.

GIEK will evaluate the documentation provided by the client, as well as conduct its own assessment of potential risks and negative impacts related to the transaction in question. Our assessment of projects are based on applicable local law and regulations, and relevant international standards, the most important being the International Financial Corporation (IFC) Performance Standards and Core ILO Labour standards.

Clients should be aware of potential environmental, social and human rights risks within their own operations and within the projects there are involved in. It is expected that they have conducted their own due diligence to identify potential risks and impacts, and have documented how they intend to prevent, mitigate and remediate these.

For industrial, land-based projects and fixed offshore projects an Environmental and Social Impact Assessment (ESIA) and Action Plan (ESAP) are often required.

For maritime projects, ship yard evaluations are required for both construction and hull yards, and include assessments of labour, working conditions, and health and safety. 

GIEK has an extensive due diligence procedure. All transactions are classified on the basis of information obtained during the risk assessment. The risk is divided into three levels: A, B and C, of which A is the highest level of risk or negative impact. According to IFC standards, ESIAs must be published for projects that are classified as category A. In addition, GIEK will conduct a survey and associated facilities will be evaluated.

For category B projects, GIEK requires sufficient documentation of how the environmental and social impacts are identified and handled. For category C projects, only the identification of the risk is required. Irrespective of their classification, all projects must comply with national laws and relevant international conventions that the countries are obliged to observe.

GIEK publishes information on category A and B projects that have applied for export financing. ESIAs (Environmental Social Impact Assessments) for category A projects are published at least 30 days before a guarantee is issued.

A and B projects

A and B Projects under review:

No current projects under review

 

A and B projects assessed/ guarantees issued:

1. NACAOME II Agua Fria solar energy project, Honduras:

2. 25 MW gas power plant, Myanmar:

3. ViQA - River power plant, Kosovo:

4. Belwind II offshore wind farm, Belgium:

5. Thorsil Metallurgical Grade Silicon Plant, Helguvik, Iceland (Category A):

6. Abul Khair Group - gas-based power plant, Bangladesh (Category B):

7. LignoTech Florida (category B):

 

GIEK encourages stakeholder to provide feedback or concerns related to projects currently under review, or projects for which guarantees have been issued. This can include, for example, concerns pertaining to issues such as;  

  • Human rights
  • Labour or health and safety
  • Environment
  • Corruption or bribery
  • Breaches of local laws
  • Other matters that may have negative reputational risks

How to provide feeback?

Send your feedback and comments to: stakeholder.feedback@giek.no

GIEK helps to realise good projects in poor countries by assessing the project’s positive impact on development and ensuring the project does not conflict with Norway’s aid policy.

GIEK’s normal credit-assessment procedure ensures that cases receiving guarantee offers have been assessed as being on a solid foundation with regard to ability to deliver, earnings and debt-service capacity. As regards sales to poor countries, where the state may have less administrative capacity, GIEK will be particularly cautious and ensure that the transaction is justifiable from a development viewpoint.

The OECD has prepared guidelines for use when considering new credit to countries with a limited capacity to raise new loans. The result, in brief, is that GIEK will only provide a guarantee if the project is in accordance with the recipient country’s economic and social strategy. GIEK will also ensure that the project does not conflict with the country's obligations to the IMF and World Bank. Such restrictions apply to around 60 countries and only relate to transactions with public-sector buyers or state-owned companies and transactions where there is a state counter-guarantee.

GIEK complies with the OECD’s sustainable lending principles. These rules include a requirement that export loans to certain countries must contain a gift element (a minimum grant element for external financing). Some countries that are entitled to a gift element can nonetheless raise commercial loans, but only within certain limits. Since Norway does not offer export loans with a gift element, so-called tied aid, GIEK can only offer guarantees if the IMF agreements allow limited commercial loans.

The list of countries covered by the sustainable lending rules can be found here.

Shipping and maritime project evaluations are divided into 2 phases – (1) construction and (1) operation. The exact nature of the evaluation will depend on the transaction type, but the general considerations and requirements are provided below.

The construction phase

The construction and hull yard will be evaluated by GIEK in relation to labour, health, safety and working conditions. There is a general requirement for documentation of appropriate management systems for labor and employment that includes both directly hired employees as well as subcontractors, with an emphasis on migrant workers.  Certifications such as ISO 9001, ISO 14001, OSHAS 18001 and SA 8000 are acknowledged in the evaluation.  If the yard does not have appropriate documentation or relevant certification, particularly in relation to labour and working conditions (SA 8000), or has not previously been evaluated by GIEK, it may be necessary to obtain a third party assessment of the shipyard’s management systems and practices in relation to these issues.

In the event that an assessment is required, GIEK will provide advice in scoping the assessment and identifying qualified third party consultants. If the report identifies points that need improvement, an Action Plan is agreed upon with the yard, with timelines and responsible persons.  Critical findings related to issues such as forced labour, serious breaches to labour law, or critical health and safety practices need to be remedied immediately. Other findings need to be addressed in a timely manner in the  action plan after issuing of a guarantee , and will be followed-up based on the timing of the transactions GIEKs approach is one of improvement over time. Therefore, the focus is on commitment to on-going improvement which is followed up and can be demonstrated.

The scope of reviews of yards include the following:

  • Management systems pertaining to environmental, labour, and health and safety

  • Child labor/Young workers

  • Forced labor

  • Health Safety and Environment

  • Freedom of association and right to collective bargaining

  • Grievance/ complaint mechanism

  • Disciplinary practices

  • Working hours

  • Local laws and regulations

  • Follow-up by the authorities

  • NB: Particular focus is given to (1) "migrant workers" and (2) management of "subcontracted workers'

 

GIEK has these points as a minimum requirement from the shipyards:

• No child labor

• No forced labor

• The yard complies with all applicable local laws

• No serious violations of health and safety routines and regulations

• Shall cooperate with the applicant and/or GIEK 

 

Yards that GIEK has already been reviewed and have been through the action plan/follow-up process will be expedited. Periodic updates on the status at the yard may be requested in relation to a specific transaction so as to confirm on-going compliance.

 

Operational phase

The operator and / or the ship owner need to document the following in relation to the operational phase:

  • The class of the ship

  • Relevant certifications such as ISO 9001 and ISO 14001

  • Appropriate management systems for health, safety and environment, as well as for labor and employment.

  • The flag, or intended list of flags for the vessel. NB: GIEK accepts flags that are on the Paris white list based on the International Chamber of Shipping flag state performance list.

  • Confirmation that the ILO Maritime Labour Convention 2006 is followed.

  • Information as to whether the vessel will operate in environmentally sensitive areas, if known (such as the Arctic, RAMSAR protected areas, known fish reproductive areas, etc.) or business that involves possible vulnerable activities (i.e. drilling, seismic testing, dredging, fishing etc.).

GIEK receives a wide range of application types for land-based projects. The risk picture can vary greatly for the same type of product in different countries, and for similar projects within the same country.

The applicant is primarily responsible for obtaining and making available information on environmental and social risks and impacts of the project and associated facilities, as well as risks in value chains. GIEK will provide guidance as to what type of information is relevant to provide and, by approval by the applicant, can have direct communication with technical experts from the counterparty to facilitate the process. The amount of information required will vary depending on the type of export, project and country involved.

The applicant will need to provide:

  • A human rights risk evaluation of potential risks related to the transaction/ project

  • Information about quality management systems and certification, as well as national permits and approvals of the project/ facility where relevant

  • Labour and procurement policies (including polices related to sub-contractors where relevant)

  • Health and Safety polices and systems (including OHSAS 18001 certification)

  • Stakeholder engagement policies and practices including grievance/ complaint mechanisms

  • Information about the supply chain and subcontractors

  • Information on any associated facilities (such as access roads, pipelines, transmission lines, etc. that may be required as a result of the project)

Is the export to an existing facility? We need to know:

  • Will the export result in large changes to resource use, output, increase of emissions to air/water/soil, or result in reduction in the number of employees?

  • Is the facility near locations in or near sensitive areas? (i.e.: National parks, RAMSAR, coastal areas)

  • Are the activities environmentally sensitive? (i.e. mining, forestry, etc)

  • Health and safety track record and if there have been protests and/or disputes

Is the export a small delivery to a larger project?

  • GIEK will need to receive as much environmental and social information as possible about the project, and we expect the applicant to make efforts to obtain information or contact details of counterparties GIEK can communicate with directly.

  • If the exporter has not been able to obtain the needed information then GIEK will evaluate the transaction based on available information, and its own due diligence. If the risk is deemed too great then, and dialog with the counterparties to mitigate the risks is not possible, the application will be denied.

Is this a Greenfield project?

  • There will need to be an Environmental and Social Impact Assessment (ESIA) and Environmental and Social Action Plan (ESAP) (Action Plan) for category A projects and corresponding information for B projects in English or Norwegian. The reports may require additional information or studies unless they meet international standards (namely, the IFC Performance Standards). Contact GIEK as early as possible for advice on scoping of the ESIA and overview of types of consultants that should be used.

  • The applicant must demonstrate that the project has management systems in accordance with IFC Performance Standards and that all relevant national permits and approvals are obtained.

  • An ESMP (Environmental and Social Management Plan) will be needed in all A projects and some B projects, depending on the nature and scope of the impacts. Reporting to GIEK based on the ESMP may be required.

  • It is not always possible for the project proponents to meet all the requirements before a guarantee is provided. In the cases where the discrepancy cannot be remedied before issuance the guarantee, a guarantee will be given with certain conditions through conditions precedent and conditions subsequent in the loan documentation. Non-compliance of these conditions may lead to delay in payment or in the event where it cannot remedied, an event of default.

  • GIEK reserves the right to evaluate projects where reporting to GIEK is required through:

    • evaluation performed by an independent third party

    • evaluation by an approved third party consultant

    • GIEK’s own assessments in the form of spot inspection and / or via hired expertise

  • The ESIA and general information about A and B projects must be published on GIEK's website. ESIAs for Category A projects should be published at least 30 days before an approval for issuing a guarantee.

GIEK's ethical guidelines

Corruption undermines lawful business activity, leads to a distortion of competition, destroys reputations and exposes companies and individuals to risk. As a public enterprise reporting to the Ministry of Trade, Industry and Fisheries, GIEK looks on anti-corruption work as part of its overall social responsibility.

GIEK is opposed to all forms of corruption and will strive to reduce the risk of corruption or bribery occurring in GIEK or in projects in which GIEK is involved.

In order for them to respect our decisions, it is essential that customers and business partners trust GIEK.

It is not enough to make the right decisions; those around us must also be able to see that we are making the right decisions.

Objectivity and impartiality apply as general norms within state administration.

GIEK employees must never accept, for themselves or for others, accept – or make conditions suitable for accepting – gifts, travel, hotel accommodation, food, drinks, discounts, loans or other benefits or advantages that are likely, or are intended by the giver, to influence their actions at work.

GIEK employees may not use their job to obtain an unwarranted benefit for themselves or others. This also applies in cases where these benefits will not affect our actions at work.

All GIEK employees are to read, understand and comply with GIEK’s anti-corruption policy and report non-conformances in accordance with the routines for handling unwanted incidents and/or whistleblowing routines.

 

GIEK issues guarantees that bind the Norwegian state, and has thus been assigned both authority and trust. It is important to protect GIEK’s reputation and contribute to a high level of ethical awareness and integrity among all employees and board members.

GIEK’s ethical principles are intended to help in the creation of a shared attitude to ethical issues. They are also to serve as a basis and framework for more detailed routines determined by GIEK’s management. GIEK’s ethical principles are subject to the approval of GIEK’s board of directors.

GIEK’s employees shall help to uphold the trust in and reputation of GIEK by maintaining a high ethical standard, behaving in a socially responsible manner and complying with prevailing laws and rules. We undertake to behave loyally to GIEK both at work and in our private lives.

All employees have an independent responsibility to help safeguard GIEK’s reputation. This includes a requirement to act in an ethically justifiable manner and to refrain from illegal acts and other derelictions of duty that might weaken GIEK’s reputation.

GIEK’s management are to ensure that all GIEK employees and directors have access to, and knowledge of, the ethical guidelines. The individual is responsible for becoming familiar with and complying with guidelines.