Implementing a Corporate Social Responsibility (CSR) strategy is an important consideration for many organizations today as it provides the framework for ethical business conduct. The following outlines the guiding principles of the Canadian Commercial Corporation’s (CCC) commitment to CSR and illustrates how these principles are incorporated in the way we do business. Moreover, it reflects the fact that CCC has implemented a number of CSR policies and practices and forms the basis for future policy development.
At CCC, we commit to operating in an environmentally, socially, and ethically responsible manner, and to respect Canada’s international commitments, while upholding the Corporation’s public policy mandate and acting within its resources. To this end, CCC employees annually sign a Code of Conduct and Code of Business Ethics.
Social responsibility
Describing the world as a global village rings especially true for CCC, as the Corporation does business with foreign governments on behalf of Canadian exporters in many countries around the world. Representing both the Government of Canada and Canadian exporters means that CCC must carefully consider all the implications of business activities not only here at home but also abroad.
CCC's vision in the area of CSR is to operate in an environmentally, socially and ethically responsible manner and respect Canada's international commitments, while upholding the Corporation's public policy mandate within its resources. CCC is taking various steps to make Corporate Social Responsibility an integral part of its governance, planning and operations, and to strengthen its capacity in CSR.
Bribery and corruption
CCC is subject to the Corruption of Foreign Public Officials Act, which stipulates that bribing foreign government employees is a criminal activity. The Corporation has therefore included in all its domestic contracts with Canadian suppliers a clause prohibiting the bribery and corruption of government officials. Should a Canadian supplier be caught bribing a government official while under a contract with the CCC, the Corporation reserves the right to apply various sanctions, including the termination of the contract with the supplier.
The Department of Justice also issued a guide to explain the Act which can be found on
http://www.justice.gc.ca/eng/dept-min/pub/cfpoa-lcape/guide.pdf
Environment
Through the Canadian Environmental Assessment Act (CEAA), the federal government is committed to supporting sustainable development by assessing the environmental effects of its decisions, operations, projects and activities before irrevocable decisions are taken that commit the government to a course of action. However, the CEAA is not applicable to CCC in its usual role as either procurement agent or prime contractor as CCC is neither the proponent nor the funding agency of the project as described in section 5 of CEAA. Nevertheless, in the formulation of its own environmental policy, CCC has adopted the spirit and intent of CEAA such that CCC will not support projects which will cause significant adverse environmental effects.
CCC Environmental Assessment Policy
In June of 2010, CCC’s Board of Directors formalized its environmental review process by adopting the CCC Environmental Assessment Policy, replacing the 2002-2003 interim corporate Environmental Review Framework. The CCC Environmental Assessment Policy adopts the requirements of CEAA and provides guidelines for the obtaining and review of environmental assessments based upon the CEAA requirements, including the Projects Outside Canada Environmental Assessment Regulations pursuant to the CEAA. In cases where projects are funded through other export credit agencies or international organizations such as the World Bank, the Corporation, as part of its own due diligence and in keeping with CEAA, reviews the environmental assessments completed for these institutions to assure that the project will not have significant adverse environmental effects.
Canadian Environmental Assessment Act
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