A/HRC/38/48 and social information on projects classified in categories A and B at least annually after a final commitment to provide support.53 73. In exceptional cases, the Common Approaches allow for the information for category A projects, referred to in paragraph 71, not to be disclosed. In those cases, export credit agencies are only required to report to the OECD Export Credit Group. As category A and B projects cover only a small part of the total portfolio of projects supported by export credit agencies, civil society groups have criticized the Common Approaches for lack of transparency across product lines. 74. Based on the mediation which took place between Atradius and two civil society groups before the Dutch national Contact Point, Atradius agreed to change its information disclosure policy in order to be more transparent, as required under the Guiding Principles. The final statement of the National Contact Point indicates that Atradius and the Ministry of Finance agreed to develop a more specific information disclosure policy that starts from the assumption that relevant information should be public, unless specific clearly defined considerations bar such disclosure (as in the case of confidential business information). Atradius agreed to improve the ex-post publication of information on all project categories (A, B, C, M and E), for example by disclosing the nature of the product for each relevant transaction. For category A projects, including transactions with a repayment period of less than two years, an adequate summary of the transaction and the framework of the assessment will be published.54 75. Because of the national contact point decision, Atradius took the step of crafting a new environmental and social policy, effective in 2018, that will presumably, among other changes, make more information public, with limited exceptions. It asked Shift, a nonprofit organization, to review its prior policies and procedures. The review explored the extent of the alignment of its policies and processes with the Guiding Principles and what changes would be needed to create greater alignment. The report done by Shift recognizes that Atradius goes beyond some of those requirements in practice, but that the Guiding Principles expect even more when it comes to transparency. The authors found that the environmental and social policy framework of Atradius did not articulate a broad approach that recognized the potential value to the business that greater transparency and communication could play. As a result, public disclosure was positioned more as a burden, where the company must meet very narrow and specific requirements, rather than as an opportunity.55 C. Moving beyond the OECD export credit agencies 76. A larger issue is whether other forums can provide platforms for discussion of State responsibilities with respect to environmental and social considerations, including human rights. The OECD Common Approaches are evidence of the value of multilateral harmonization to avoid a race-to-the-bottom approach to human rights and business. However, while the Common Approaches are an important precedent, export financing is no longer an activity carried out exclusively by OECD member States. As of 2013, 44 per cent of global official export support came from export credit agencies outside OECD, including Brazil, China, India and the Russian Federation. As a result, the BRICS Forum could play an important role in aligning State duties under pillar I of the Guiding Principles in the area of export credit. The Berne Union could provide another vehicle for such dialogues, as could the International Working Group on Export Credits. 77. The European Union is yet another forum where export credit agencies could better align their practices with the Guiding Principles. The European Union export credit agency regulation refers to the obligation of member States to comply with the Union’s general 53 54 55 See OECD Council recommendation on common approaches for officially supported export credits and environmental and social due diligence (2016), section VII. See final statement notification Both ENDS- Fórum Suape vs Atradius DSB (30 November 2016). See Shift, “Integrating human rights due diligence: a review of Atradius DSB’s environmental and social policy and procedure”. 15