A/HRC/38/48 66. According to an OECD study, 44 export credit agencies require exporters and/or applicants to provide an undertaking/declaration that neither they nor anyone acting on their behalf, such as agents, have been engaged in or will engage in bribery in the course of the transaction. They include the Russian Federation, which exceeds standard expectations by using multiple channels of communication regarding the requirement for an anti-bribery undertaking/declaration. The Russian export credit agency obtains an undertaking/declaration through both the application forms and stand-alone documents. Brazil similarly uses stand-alone documents submitted by the exporter or applicant. B. Gaps in the OECD Common Approaches 67. As noted above, a large number of non-OECD States do coordinate on export credit policies but have yet to do so on social issues and human rights. Thus the 2016 recommendation on Common Approaches is currently the key document, which sets out good practice for export credit agencies. As noted above, some non-OECD States take part in meetings of the environmental and social practitioners, with an eye to aligning their processes with the Common Approaches. 68. As the Common Approaches only apply to exports for medium- and long-term export credits with a repayment term of two years or more, a variety of export credit financing, insurance and guarantees provided by export credit agencies are not subject to their application. As noted above, there are examples of export credit agencies applying the Common Approaches and hence human rights due diligence across all their product lines, as in the case of the Dutch, but this is still an exception. A key issue is therefore how to extend the role of human rights due diligence across a broader spectrum of products and services. 69. A second issue is which criteria are applied when human rights due diligence is conducted. The Common Approaches default to the IFC Performance Standards, which are not identical to the Guiding Principles. Again, as noted above, some export credit agencies have supplemented their due diligence processes when they needed to address other human rights scenarios, as was the case with Sweden in the telecommunications sector. 70. The Dutch National Contact Point indicated that for Atradius there needed to be a clearer explanation of the gaps in alignment between the Guiding Principles and the Common Approaches. For example, the scope of human rights due diligence is not limited under the Guiding Principles, whereas the Common Approaches apply only to transactions longer than two years.51 71. Another area where improvement is needed relates to the transparency of decisionmaking at export credit agencies. Civil society groups have been critical of them because they do not share the results of their screening with civil society, affected communities and other stakeholders. A recent study of seven Central and Eastern European export credit agencies, also pointed out that greater transparency was needed.52 72. The Common Approaches address the disclosure of information. They include recommendations for public information disclosure as follows: (a) limited project information, including environmental and social impact information, in the case of category A projects, to be made available as early as possible in the review process and at least 30 calendar days before a final commitment to grant official support and (b) environmental 14 51 See Both Ends, “Gaps between the Common Approaches and the OECD Guidelines” (June 2016) 52 and CORE Coalition and Amnesty International UK joint submission to the United Nations Working Group on Business and Human Rights. Finance and Trade Watch and CEE Bankwatch Network “ECAs Go to Market. A Critical Review of Transparency and Sustainability at Seven Export Credit Agencies in Central and Eastern Europe” (December 2017).