Submission to the consultation on the review of FinDev Canada´s Environmental and Social Policy

The Danish Institute for Human Rights (the DIHR) welcomes FinDev Canada´s consultation of stakeholders in advance of the review of its Environmental and Social (E&S) Policy.

The DIHR provided feedback on a number of select issues based on its recent and ongoing work on development finance and human rights, including through direct collaborations with development finance institutions (DFIs) and research and analysis. The DIHR´s feedback focused on investments via financial intermediaries, remediation, responsible exit and human rights risks related to the digital transition. Specifically, the DIHR recommended that FinDev Canada:

• Provide more information about the implementation of its E&S Policy when investing through other financial institutions, such as information on how its E&S requirements apply to the clients of financial intermediaries;
• Provide more specificity as to how it envisions its role in enabling remediation where adverse impacts connected to its investments might occur by explicitly drawing from internationally authoritative standards such as the UN Guiding Principles on Business and Human Rights;
• Explicitly embed human rights considerations in its approach to planned and unplanned exits;
• Clarify the approach to managing human rights risks in digital investments, including by specifying the E&S requirements for clients in the technology sector.

The DIHR submission draws from the expertise of the Human Rights and Business Department, which has worked for over 20 years with development finance institutions and other financial institutions, companies, states and civil society to build a global environment in which negative impacts on human rights by business activities are minimised, including through implementation of the UN Guiding Principles on Human Rights and the OECD Guidelines for Multinational Enterprises.