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Letter from Minister of International Trade Diversification to Canadian Commercial Corporation chair board of directors

September 24, 2018

Mr. Douglas Harrison
Chair, Board of Directors
Canadian Commercial Corporation
700–350 Albert Street
Ottawa ON K1A 0S6

Dear Mr. Harrison:

It was a pleasure to speak with you on August 24, 2018. The Canadian Commercial Corporation (CCC) performs a vital role in helping our exporters secure international contracts, succeed in the global marketplace, and create jobs and prosperity for Canadians. As you settle into your new role, I would like to reiterate the Government of Canada’s commitment to an ambitious and inclusive trade agenda that expands and diversifies our export markets while ensuring everyone can benefit from trade.

The Government of Canada is committed to ensuring that all segments of society benefit from the opportunities that flow from trade and investment. Trade and investment are essential vehicles for improving the quality of life of citizens. Inherent in this approach is the imperative that we hold ourselves to a higher standard—and show leadership on the issue of responsible business conduct and respect for human rights. To this end, and with CCC’s vital assistance to exporters in mind, I ask that you undertake a thorough review of CCC’s ongoing risk assessments and transaction due diligence to ensure that human rights, transparency, and responsible business conduct are core guiding principles for CCC. It is my expectation that CCC’s policies and procedures in these areas would be best-in-class among its peers.

Given the complexity of CCC’s operating environment, I would ask that CCC, in the context of this review, closely study Canada’s pending accession to the Arms Trade Treaty (ATT), currently before Parliament under Bill C-47. The ATT asks member states to conduct assessments on foreign transactions to determine how that transaction would impact international peace and security, and whether the transaction could lead to violations of international humanitarian law or human rights law. While the ATT deals solely with the export of conventional arms, I would ask that you take all necessary steps to ensure that CCC’s due diligence assessments seek to ensure that all transactions meet this threshold going forward. I would further ask you to consider how you comply in a commercial context with Canada’s international human rights obligations, including standards supported by the Government of Canada (including the Organisation for Economic Co-operation and Development’s Guidelines for Multinational Enterprises and the UN Guiding Principles on Business and Human Rights).

As part of this review, you should also actively consult with non-governmental organizations, industry, the multi-stakeholder Advisory Body on Responsible Business Conduct abroad, and the Canadian Ombudsperson for Responsible Enterprise, which was recently established. I have asked my officials to ensure that they support you in undertaking this review. I encourage you to work closely with them as you conduct this review and adopt any new approaches. I have also instructed my department to ensure that existing Global Affairs Canada resources and expertise are made available to CCC as part of any long-term due diligence process developed through this review. Moreover, it is my expectation that CCC will flag any sensitive transactions to my office and department and continue to conduct risk assessments and ongoing monitoring going forward.

In summary, I would ask that CCC ensure that Canada’s international human rights obligations be explicitly and transparently incorporated into its corporate social responsibility objectives and procedures. I would ask for an update on the status of this review by the end of November 2018. This update should include a detailed timeline for full implementation of any new procedures by the end of June 2019. In the interim, please work closely with my office and Global Affairs Canada officials during your consideration of any transactions that warrant close analysis.

I look forward to the results of this review.


The Honourable Jim Carr, P.C., M.P.

c.c.: The Honourable Chrystia Freeland, P.C., M.P.
Minister of Foreign Affairs

Mr. Ian Shugart
Deputy Minister of Foreign Affairs

Mr. Tim Sargent
Deputy Minister for International Trade

Mr. Martin Zablocki
President and Chief Executive Officer
Canadian Commercial Corporation

Members, Board of Directors
Canadian Commercial Corporation

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