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Dear
Ben
I refer to your letter of 5
December. You asked for a reply by
today’s date.
TI(UK)’s position on the extent to
which to which representations should be qualified or absolute is as stated in
TI(UK)’s Supplementary Submission sent on
Whilst writing, I would re-emphasise
TI(UK)’s view that if ECGD is serious about limiting
the scope for bribery in contracts to be supported by taxpayers’ money and
limiting its own civil and criminal liability and that of its staff, there is
nothing in TI(UK)’s June 2005 submission that should impose an unreasonable
burden on applicants or banks or require them to undertake enquiries beyond
those that a prudent applicant should be undertaking for its own protection and
risk management. This exercise
seems to have become surrounded by needless complexity and we remain baffled as
to why there should be such resistance to reasonable and credible warranties and
effective due diligence and audit requirements.
Please confirm
receipt.
Yours
sincerely
Graham
Rodmell
Director, Corporate and Regulatory
Affairs
TI(