See no evil: How Canada is bankrolling companies accused of bid-rigging, graft and human-rights violation

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In Latin America, billions of dollars in Canadian government-backed loans have been funnelled to two of the region’s most notorious oil companies: the state-owned petroleum corporations of Mexico and Brazil, each riddled with frequent reports of bribery, bid-rigging and inflated contracts.

In Africa, hundreds of millions of dollars in financing has been channelled to companies at the heart of South Africa’s worst postapartheid corruption scandal: the state-owned freight rail monopoly and the business empire of the infamous Gupta brothers, whose relationship with ex-president Jacob Zuma triggered a public inquiry into state corruption.

And in Canada, billions of dollars in federal export loans have gone to support transactions that benefit Bombardier Inc. and SNC-Lavalin Group Inc., two companies that have been cited in corruption investigations in Asia, Africa and Europe.

The connecting thread in all of these cases is a Crown corporation called Export Development Canada (EDC), headquartered in a glass tower in downtown Ottawa emblazoned with a red maple-leaf logo.

While EDC remains obscure to most Canadians, it is a crucial cog in the federal government’s machinery for promoting outbound trade. With more than 1,500 employees, the agency offers a wide array of services, from direct loans and guarantees to a variety of insurance products. It served more than 13,000 customers last year, most of them small and medium-sized businesses. EDC says it facilitates some 14 per cent of Canada’s total exports and direct investment outflows.

Yet EDC’s individual transactions, sometimes in the billions of dollars, routinely go unreported by the media and receive little scrutiny from MPs or cabinet ministers. Not that there’s much information to go on. Typically, EDC discloses only the barest details, including a broad value range. “Without the company’s consent, we cannot disclose values of the loans,” EDC said in a statement.

But those deals carry the federal government’s stamp of approval and they are backed by its AAA credit rating. That allows EDC to assume risks that private banks would deem unacceptably high. Its clients include companies that have been dogged for years by corruption allegations and graft investigations. Others have even been accused of human-rights violations or environmental abuses. Even so, EDC has held fast with many Canadian exporters and foreign state-owned companies amid embarrassing scandals, and stood by them as other institutions imposed sanctions on them or cut them loose. In the most severe cases, this exposes the federal government to the risk of receiving tainted funds.

Seeking to understand EDC’s relationships with such clients, The Globe and Mail monitored the agency’s activities during the past year and studied its practices for vetting clients and transactions. This investigation revealed new details of EDC’s secrecy, its favouritism to politically influential companies and how its internal controls and risk-taking culture allow EDC to keep providing those precarious loans. Our investigation included a review of nearly 14,000 transactions since 2001. The review allowed The Globe to build a unique database and to identify EDC’s largest customers for the first time. The Globe also used the courts and the federal Access to Information Act, along with a cache of leaked e-mails, to obtain thousands of pages that document EDC activities. Globe correspondents in South Africa and Colombia studied specific EDC deals. We also examined the federal government’s lax supervision of its wholly-owned subsidiary.

In a statement, EDC president and chief executive Mairead Lavery said the agency recently reviewed its environmental and social-risk management policies and made changes. She added that Canadians can be confident in EDC’s due diligence practices. “Simply put, we believe that business is at its best when it is managed sustainably, transparently and responsibly. Where we can use our influence to leverage improvements in human, environmental and ethical issues, we will not hesitate.”

But enough transactions have gone wrong that Canadians could reasonably ask whether they can trust EDC to avoid corrupt clients, human-rights violators and environmental debacles. This much seems clear: EDC’s political masters don’t know the answer.

EDC’S TOP CUSTOMERS

Although more than four-fifths of EDC’s Canadi-

an customers are small and medium-sized

enterprises, a handful of large companies

received outsized levels of support between

2001 and 2018.

Minimum and maximum possible values of disclosed

EDC financings to large corporate groups, 2001-2018

$19.5

$46.2

Bombardier

General Motors

Trans Mountain

Pratt & Whitney

Enbridge

Chrysler

Borealis

Nortel Networks

TransCanada

SNC-Lavalin

Brookfield

Bank of N.S.

$0.9

$3.3

Nexen

0

5

10

15

20

25

30

35

40

45

$50

BILLIONS

Note: Precise total amounts cannot be determined; EDC

discloses only broad possible values of individual transactions.

These totals include financings in the Canada Account.

MATT McCLEARN AND JOHN SOPINSKI/

THE GLOBE AND MAIL, SOURCE: edc

EDC’S TOP CUSTOMERS

Although more than four-fifths of EDC’s Canadian custom

ers are small and medium-sized enterprises, a handful of

large companies received outsized levels of support

between 2001 and 2018.

Minimum and maximum possible values of disclosed

EDC financings to large corporate groups, 2001-2018

$19.5

$46.2

Bombardier

General Motors

Trans Mountain

Pratt & Whitney

Enbridge

Chrysler

Borealis

Nortel Networks

TransCanada

SNC-Lavalin

Brookfield

Bank of N.S.

$0.9

$3.3

Nexen

0

5

10

15

20

25

30

35

40

45

$50

BILLIONS

Note: Precise total amounts cannot be determined; EDC discloses only

broad possible values of individual transactions. These totals include

financings in the Canada Account.

MATT McCLEARN AND JOHN SOPINSKI/THE GLOBE AND MAIL

SOURCE: edc

EDC’S TOP CUSTOMERS

Although more than four-fifths of EDC’s Canadian customers are small

and medium-sized enterprises, a handful of large companies received

outsized levels of support between 2001 and 2018.

Minimum and maximum possible values of disclosed EDC financings

to large corporate groups, 2001-2018

$19.5

$46.2

Bombardier

General Motors

Trans Mountain

Pratt & Whitney

Enbridge

Chrysler

Borealis

Nortel Networks

TransCanada

SNC-Lavalin

Brookfield

Bank of Nova Scotia

$0.9

$3.3

Nexen

0

5

10

15

20

25

30

35

40

45

$50

BILLIONS

Note: Precise total amounts cannot be determined; EDC discloses only broad possible

values of individual transactions. These totals include financings in the Canada Account.

MATT McCLEARN AND JOHN SOPINSKI/THE GLOBE AND MAIL, SOURCE: edc

Canada is far from alone in operating what is known as an export credit agency to help national champions win business abroad. Virtually every country has one, if not two, agencies. But the breadth of EDC’s services set it apart. For example, it lends directly to Canadian companies and their customers. Many of its peers can only act as lenders of last resort, if they are permitted to lend at all. EDC will also lend to foreign companies that have yet to purchase anything from Canada. Internally, the agency refers to such transactions as “pull” loans: They’re supposed to help persuade foreign firms to buy Canadian.

The agency also offers several types of insurance. One is political risk insurance, which protects Canadian companies’ overseas operations against expropriation, civil war and other hazards in frontier markets such as Libya and Yemen. That speaks to EDC’s willingness to do business almost anywhere. There are just four countries it considers off-limits: North Korea, Russia, Saudi Arabia and Syria.

The World According to EDC

EDC has foreign offices across the globe.

Although it’s prepared to do business nearly

anywhere, it assigns ratings to individual

countries that take into account political risks,

the probability that governments will default

on debts, and other factors.

RISK RATING

High Risk

Medium risk

Low risk

Medium -

high risk

Low -

medium risk

EDC foreign

office

MATT McCLEARN AND JOHN SOPINSKI/

THE GLOBE AND MAIL, SOURCE: EDC

The World According to EDC

EDC has foreign offices across the globe. Although it’s

prepared to do business nearly anywhere, it assigns ratings

to individual countries that take into account political risks,

the probability that governments will default on debts,

and other factors.

RISK RATING

High Risk

Medium risk

Low risk

Medium -

high risk

Low -

medium risk

EDC foreign

office

MATT McCLEARN AND JOHN SOPINSKI/

THE GLOBE AND MAIL, SOURCE: EDC

The World According to EDC

EDC has foreign offices across the globe. Although it’s prepared to do business nearly

anywhere, it assigns ratings to individual countries that take into account political risks,

the probability that governments will default on debts, and other factors.

RISK RATING

High Risk

Medium - high risk

Medium risk

Low - medium risk

Low risk

EDC foreign office

MATT McCLEARN AND JOHN SOPINSKI/THE GLOBE AND MAIL, SOURCE: EDC

Because the services offered by export credit agencies vary so widely, it’s difficult to compare them. In a straightforward ranking by assets, however, EDC, at $69.4-billion, is among the world’s largest. It’s smaller than South Korea’s export credit agency, with assets of about $100-billion, but it’s more than twice the size of the Export-Import Bank of the United States.

While EDC’s profit margins may not elicit envy from the private sector, last year it paid nearly $1-billion into federal coffers. But the risks of lending are not purely financial. They can also be reputational.

Consider some of EDC’s clients in Latin America. One of its biggest customers for “pull” loans is Petroleos Mexicanos (Pemex), Mexico’s largest company. Since 2001, EDC has disclosed 36 financing transactions to Pemex, worth between $3-billion and $5.8-billion. The company, according to widespread reports, has been permeated with graft for decades. Adrian Lajous Vargas, who was Pemex’s CEO from 1994 to 1999 and is now an energy consultant, said in 2018 that “corruption is everywhere in all areas and at all levels of the hierarchy” at the company. Just this week, the Mexican government issued an arrest warrant for former Pemex director Emilio Lozoya on corruption charges.

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Then there’s Petrobras, Brazil’s huge state-owned oil company. Between 2002 and 2013, EDC provided six loans to Petrobras, collectively worth between $1.6-billion and $3.5-billion. In 2014, Petrobras became ensnared in a sweeping corruption investigation known as Operation Car Wash, which uncovered a sprawling scheme that facilitated hundreds of millions of dollars in bribes to politicians and political parties in Brazil, and falsified financial statements.

Several executives and directors were convicted of corruption-related offences, spanning from 2004 to 2012, and some went to prison. Last September, Petrobras agreed to pay Brazilian and U.S. authorities a fine of more than US$1.8-billion and entered into a non-prosecution agreement.

Other EDC clients have become embroiled in environmental and human-rights controversies.

In Colombia, Empresas Publicas de Medellin, a utility owned by the City of Medellin, received a US$300-million loan for general corporate purposes from EDC in 2016. Much of it went to the construction of the Hidroituango dam, Colombia’s largest hydroelectric project, which has been plagued by severe engineering failures. The dam nearly ruptured last year, resulting in the evacuations of tens of thousands of people. EDC said it “has been engaging with the company to learn how it is resolving the situation and what measures it is implementing to prevent a similar incident from occurring in the future.”

In the Middle East, a Canadian company called Netsweeper Inc. sells technology that filters internet content. The Citizen Lab, a research centre at the University of Toronto, has documented how Netsweeper products helped authoritarian governments to suppress information from political and religious minorities and opposition groups.

In 2016, EDC approved a loan guarantee to the Royal Bank of Canada to finance the sale of Netsweeper’s technology to the Bahraini government. University of Toronto political-science professor Ron Deibert, the director of the Citizen Lab, said in an interview that Bahrain has used that technology to censor political opposition movements, human-rights groups, gay and lesbian advocacy groups and news organizations such as Al Jazeera and the Arab Times. The company did not respond to interview requests.

These cases are part of a larger pattern, according to Above Ground, an Ottawa-based human-rights group. Companies “for which we have very serious concerns on human-rights grounds, are receiving financing – sometimes repeat financing,” said the group’s director, Karyn Keenan. She says she has identified numerous EDC clients who’ve been penalized for their conduct by law enforcement and government regulators, even court rulings. “And yet, this doesn’t seem to be ringing any warning bells for EDC.”

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In the 1990s, the World Bank embarked on a mission to stamp out corruption in the transactions it financed. It hired lawyers, forensic accountants and staff with law-enforcement backgrounds, and established specialized teams to investigate allegations of graft associated with its projects. Wrongdoers could be disallowed from bidding on projects, or debarred, for up to 10 years.

This wasn’t an idle threat. Since then, the World Bank has banned hundreds of companies, including major multinationals such as Siemens AG and Alstom SA. In 2013, the World Bank debarred SNC-Lavalin for a decade, after determining it had bribed its way into the Padma Multipurpose Bridge Project in Bangladesh and another project in Cambodia.

EDC, in contrast, appears to possess little capacity to investigate its own transactions after corruption concerns arise. And it won’t even consider debarring a party unless it has been convicted of bribery by a court of law – an exceedingly rare occurrence, particularly in Canada. Last year, the prominent anti-corruption organization Transparency International dropped Canada’s enforcement rating from “moderate” to “limited.” In the 20 years since Canada criminalized the bribery of foreign officials, there have been just four convictions.

Suspension appears to be the harshest measure EDC will entertain, and then only in extreme circumstances. “I believe that we’ve reported to the OECD [Organization for Economic Co-operation and Development] that twice, we have actually halted support for companies,” said Catherine Decarie, a senior vice-president who heads EDC’s Corporate Social Responsibility (CSR) group.

EDC said in a statement that, after the World Bank debarred SNC-Lavalin, it had “increased our due diligence monitoring of the company” and began requiring that SNC-Lavalin sign anti-corruption declarations for each transaction rather than annually, as it had done previously.

Less than a month after the World Bank debarment, EDC extended a loan to SNC-Lavalin worth between $50-million and $100-million. In 2014, the company received another loan in the same range.

EDC eventually turned off the tap in late 2014. “We can appreciate that people will say that we didn’t act soon enough,” EDC acknowledged in a statement. “At the forefront of our decision-making process was weighing the unproven allegations along with our mandate to support Canadian exporters. That said, we could have – and perhaps should have – suspended business earlier.”

Since lifting the suspension in the spring of 2017, EDC provided SNC-Lavalin with three more loans, worth a combined maximum possible value of $1.25-billion.

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Another EDC client, Kinross Gold Corp., purchased two African gold mines in 2010. The U.S. Securities and Exchange Commission (SEC) found that the Toronto-based company subsequently made peculiar payments to government officials and politically connected contractors. In Mauritania, for example, Kinross paid US$715,000 to a politically linked “consultant” and awarded a US$50-million logistics contract to a company favoured by a “very high-level” government official – even though another bidder offered a lower price and had better technical abilities. The SEC charged Kinross with violating the U.S. Foreign Corrupt Practices Act, one of the world’s most stringent anti-bribery laws.

Kinross settled with the SEC in March, 2018, by agreeing to a cease-and-desist order and paying a US$950,000 fine, without admitting or denying the findings.

EDC says it increased its scrutiny of Kinross after becoming aware of the SEC’s allegations. Nevertheless, between 2011 and 2017 it lent Kinross $130-million for general purposes, plus another $40-million to finance a mine in Russia.

EDC also provided a $300-million letter of credit guarantee for reclamation liabilities at several of Kinross’s mines. Kinross hopes to finalize a $300-million loan for a mine in Mauritania from EDC and three other lenders later this year.

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Then there’s the EDC client that has caused the Crown corporation more trouble than any other: the Gupta brothers of South Africa. In 2014, Bombardier hoped to sell a Global 6000 business jet to Westdawn Investments, a Gupta company. Bombardier also sought a slice of a massive locomotive contract to be awarded by Transnet SOC Ltd., the state-owned freight company where the Guptas wielded influence through allied executives. EDC lent Westdawn $41-million – about 80 per cent of the jet’s purchase price. The agency also helped Bombardier win a US$1.2-billion portion of the locomotive contract by lending Transnet US$450-million.

In 2016, the Guptas became embroiled in a sweeping political scandal, and South African banks scrambled to cut ties with them. EDC watched allegations pile up in reports by news organizations and government watchdogs, but maintained its relationship for another year and a half. “Sometimes the best available decision is to proceed while continuing to closely monitor the evolving situation, as was done in the Westdawn case," EDC said in a statement.

When EDC finally began unwinding its relationship in late 2017, the Guptas absconded with the jet, prompting a legal battle to secure its return.

Last year, EDC said it was “actively reviewing” its financing agreement with Transnet. But it won’t disclose the scope of its review, who conducted it or its findings. Using federal Access to Information laws, The Globe requested all records produced during that review. EDC refused to provide a single document. Bombardier, for its part, has dismissed outright the notion it should have foreseen the Guptas’ behaviour.

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The Gupta jet fiasco was that rare transaction that finally prompted parliamentarians in Ottawa to take a closer look at EDC. “There were enough red flags to raise the question of, ‘Why is it in the interests of Canada to pour this money for this loan?’ ” said Charlie Angus, an NDP member of Parliament, in an interview with The Globe. “What is the political/ethical/moral lens that they place on loans, if they’re willing to give that kind of money to people as notorious as the Gupta brothers?”

In early 2018, Mr. Angus and two other New Democrat MPs wrote a letter to then International Trade Minister François-Philippe Champagne, complaining that even “a cursory scan of the Internet” would have revealed the Guptas’ history of corruption. “I feel that the government’s response so far, which has consisted of deflecting blame, has not been appropriate,” he wrote.

The letter led to a meeting with EDC officials. “They still weren’t able to answer why it was in Canada’s interest to make these loans,” Mr. Angus said.

EDC’s support for Netsweeper’s internet-filtering technology also proved to be embarrassing, since Canada was a founding member of the Freedom Online Coalition, a group of 30 countries which opposes state-sponsored internet censorship.

During a hearing of the Senate committee on human rights in 2017, senator Thanh Hai Ngo asked an EDC official, Christopher Pullen, whether the Crown corporation had considered the human-rights implications of supporting Netsweeper in Bahrain. “I can’t speak specifically about the structure of a particular transaction in which EDC provided support to a bank,” Mr. Pullen responded.

Unsatisfied, the senator asked again. Mr. Pullen rebuffed his inquiry a second time.

One reason EDC won’t answer many basic questions about its due diligence – even from parliamentarians – is because it treats its conclusions as confidential information belonging to its customers. This principle is enshrined not only in EDC’s enabling legislation, the Export Development Act, but also the federal Access to Information Act. So when EDC transactions go awry, one can typically learn nothing about what happened or how the agency responded.

Patricia Adams, of Toronto-based Probe International, has followed EDC for decades. In an interview, she accused EDC of being “above the law.” Canadians “are the investors in these projects,” she said, "and none of us can find out the nature of these investments. The institution is out of control, it is not accountable.”

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Officially, EDC is accountable – to the Minister of International Trade (currently Jim Carr). He’s supported by a small group in Ottawa called the Crown Corporations Governance Unit, which according to a federal directory appears to have a single employee. (The government refused to disclose how many employees are responsible for supervising EDC.)

The Trade Department has acknowledged no role in addressing apparent, high-profile failures in the Crown corporation’s due diligence. Asked whether it was satisfied with EDC’s supervision of its loan to the Guptas, the department responded: “It is up to EDC to undertake the actions it deems necessary to ensure its actions are in compliance with its governance and stewardship policies.”

In the wake of the Netsweeper controversy, Mr. Carr ordered EDC last September to review its human-rights screening practices. That review is currently under way, but it’s unclear whether the results will be made public. In a written response, EDC chairwoman Martine Irman assured the minister that EDC continued "to build on what is already a strong foundation in human rights screening and assessment.”

Ottawa’s hands-off approach toward EDC contrasts strongly with how it regulates private-sector financial institutions. The Office of the Superintendent of Financial Institutions (OSFI) supervises federally registered banks, insurers, trusts and lenders. It can prevent a bank from doing business until it improves its anti-money-laundering procedures. It can even assume management of a dysfunctional bank. But OSFI doesn’t supervise EDC.

Banks, credit unions, trust and loan companies and most other financial institutions must also abide by the Proceeds of Crime (Money Laundering) and Terrorist Financing Act. This law specifies the recordkeeping and client-identification rules, requiring institutions to report suspicious transactions. But EDC is exempt from that, too.

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Differing regulatory requirements and supervision may go a long way in explaining why EDC behaves differently than other financial institutions. Consider the South African banks that rushed to close Gupta accounts in early 2016. Ian Sinton, former general counsel for Standard Bank of South Africa, testified to a state inquiry that the many allegations against the Guptas were enough to terminate the relationship. “For us the test is, from all information available, is there sufficient [evidence] for us to suspect that our systems may be used for some or other offence?" Mr. Sinton said. "And if we reach that conclusion, we will make a decision. We don’t wait for there to be an actual conviction.”

In early 2018, Ottawa lawyer Mora Johnson told the House of Commons finance committee that EDC is at high risk of being repaid with the proceeds of corruption – money that could wind up in the government’s own coffers through EDC’s dividends.

EDC’s executives must answer to a board of directors, but Ottawa has often failed to appoint directors in a timely manner. In 2018, the Auditor-General found that the terms of eight of EDC’s 12 directors had expired, and one position was vacant.

The Globe identified a handful of incidents where EDC’s practices received outside scrutiny, but Canadians are not entitled to learn the outcomes of such exercises.

Using the Access to Information Act, The Globe confirmed that in 2014, the Minister of International Trade ordered EDC to hire a consultant to review its risk-management practices. As part of a federal review of all financial Crown corporations, OSFI examined EDC’s processes for monitoring and managing risk, including money laundering and corruption, and identified issues “that could pose material financial risk to EDC.”

It’s unclear what recommendations OSFI made, whether EDC responded to them or how. Citing exemptions in the act, OSFI withheld all but two pages of its 58-page final report.

At the request of EDC’s board, the law firm Bennett Jones conducted a separate review of EDC’s anti-corruption practices that same year. The Globe requested a copy of its 37-page report. Citing solicitor-client privilege, EDC withheld all but a few paragraphs.

There is one external audit that occurs in a more public setting. The minister must hire a consultant once a decade to conduct a review of EDC’s enabling legislation, the Export Development Act.

The latest review is in progress, led by Diana Smallridge. Her report is expected to be tabled in Parliament by the end of June. Ms. Smallridge, herself a former EDC employee, conducted the previous legislative review in 2008. At the time, she strongly warned against imposing new human-rights, environmental or social requirements on EDC “in such a way as to put Canadian exporters at a disadvantage.”

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EDC’s Ottawa headquarters is often referred to throughout the organization simply as “the building.” Inside, three teams are responsible for sleuthing out potential hazards with deals and clients. An environmental and social-risk advisory team specializes in labour, human-rights and environmental concerns. The compliance and ethics team may become involved if there are concerns around sanctions. There’s also a CSR team – which includes a subgroup for anti-corruption and anti-money-laundering.

Justin Taylor, a senior risk manager on the CSR team, said EDC has maintained a database of active and prospective customers since at least the early 1990s. That database includes flags indicating whether companies or their principals have been penalized, appeared on terrorism-financing lists or been convicted of corruption offences.

EDC requires clients to sign declarations in which they vow not to violate anti-corruption laws. Like banks, EDC monitors transactions in progress. It also maintains a “Heightened Awareness List,” which includes a relatively small number of clients identified as being potentially hazardous to EDC’s finances or reputation.

According to Mr. Taylor, EDC’s senior leadership makes the final decision on whether to support risky transactions. Its risk-management committee is composed of vice-presidents and senior vice-presidents, and meets weekly.

EDC’s critics have called all this window-dressing. But between the redactions, internal e-mails reviewed by The Globe suggested EDC has rejected at least a few deals on anti-corruption and environmental grounds. The e-mails also suggest tensions between EDC’s due diligence teams and the front-line employees who assist exporters.

A former EDC official interviewed by The Globe said that during his tenure, EDC “stopped deals when they had to be stopped” – except when it came to large, politically important clients in Quebec and Southern Ontario.

“There were a couple of firms which had the clout to go all the way to the top of the house and say, ‘Look, on paper nothing exists. You’ll never be caught out. You’ve gotta do this for us.’ And that decision-making process was very murky.”

In the months ahead, this apparatus could face one of its most daunting tests yet.

In May, The Globe reported that a World Bank audit had found that Bombardier had colluded with senior officials at Azerbaijan Railways to win a US$339-million contract in 2013. Those findings remain unproven, and Bombardier disputes them. But if the allegations are upheld, the company could be banned from participating in future World Bank contracts. The World Bank announces debarments and publishes lists of banned companies on its website.

Bombardier is EDC’s largest client. The Globe determined that EDC provided more than 230 loans to the company and its affiliates and customers between 2001 and 2018, with a combined values between approximately $20-billion and $46-billion. No other recipient approached even the bottom of that range. Ms. Lavery, who was appointed as EDC’s new president and CEO in February, is a former Bombardier executive.

Although EDC didn’t finance the Azerbaijan deal, spokesman David Bhamjee said EDC would follow the World Bank’s investigation closely. “We will not hesitate to take any action that we deem appropriate, which could include suspending future business support,” he said in a statement.

It’s unprecedented for Canada’s export agency to speak so sternly to its largest customer.

Although employees interviewed by The Globe seemed unaware of the fact, EDC also maintains something called the “Anti-Corruption Debarment Procedures.” EDC declined to provide a list of companies it has debarred under that policy because it is considered privileged information.

Under the Access to Information Act, The Globe then requested the total number of parties EDC has debarred in its history. EDC said it was unable to provide that information because no relevant records existed. It seems Canada’s export credit agency has never debarred any firm, even briefly, at any point in its history – a conclusion EDC neither confirmed nor denied.