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The Export and Import Bank of China and the China Development Bank:

understanding the environmental regulations of China’s overseas development


By Tariqul Islam
PhD Candidate and Researcher | Chinese and Indian Aid | Emerging Economies (BRICS) |
ActionAid International


China, like other emerging economies such as Brazil, India, Mexico and Indonesia, has been increasing
development assistance to developing countries in recent years (Woods 2008). Conservative estimates
place the value of donor disbursements from such emerging economies at around US$20,8 billion in
2013, with China giving around US$ 3 billion, placing it in the top four donors behind Saudi Arabia,
United Arab Emirates and Turkey (OECD 2014).

These countries amongst others are often referred to as “emerging donors” in contrast with traditional
“established” donors, including the EU, Japan and USA, who are members of the Organisation for
Economic Cooperation and Development’s (OECD) Development Assistance Committee (DAC). The DAC,
amongst other functions, coordinates setting up common objectives to govern development aid
programmes and issues guidelines on the management of development assistance for member states
(OECD 2015). DAC guidelines outline best practice for development aid programmes on issues such as
development and gender; promoting pro-poor economic growth; natural resource management and
managing environmental impacts of development projects (OECD 2015). Emerging donors like China, not
bound by such guidelines, negotiate development assistance for country aid programmes on their own
terms, setting their own conditions and standards according to their own national development policies.

China’s development assistance policies with developing countries are developed under the framework
of South-South Cooperation (Peoples Republic of China, 2014). Foreign aid disbursements are also
guided by the win-win principle: that aid is given only if it contributes to China’s own national interests
as well as those of the recipient country (Zimmerman and Smith 2011: 732 in Kobayashi 2013). This aims
to ensure mutually beneficial development; combining loans, credits, and debt write-offs with special
trade arrangements and commercial investments with terms that also benefit the Chinese economy,
whether through secured access to natural resources, energy, markets or trade opportunities (Woods
2008, Kobayashi 2013).

China’s foreign assistance policies stipulate that there is no interference in the “internal affairs of the
recipient countries and fully respecting their right to independently choosing their own paths and models of
development” (People’s Republic of China, 2014). This means that, unlike traditional donors, while
providing development assistance China does not stipulate conditions or standards for governance and

accountability mechanisms, including best practice for managing social and environmental risks, leaving
it entirely at the country’s discretion to decide how this is done in alignment with its own national

Channels of Chinese development assistance

The foreign assistance budget is put under the unified management of the Ministry of Finance in line with
the budget and final accounts system and Chinese foreign development assistance is mainly disbursed in
three forms, as grants, interest-free loans and/or concessional loans (Table 1),(People’s Republic of
China, 2014). Three policy banks- the China Development Bank, the Agricultural Development Bank of
China and the Export-Import Bank of China- are responsible for implementing state policies
in industry, foreign trade and economic diplomacy. They are also tasked with providing financial policy
support to promote the export of Chinese products and services. In China, policy banks get government
subsidies or flexibility in compliance for financing projects overseas.

Type Conditions of disbursement

Grant offered to help recipient countries build small or medium-sized social welfare projects,
and to fund human resources development cooperation, technical cooperation,
material assistance and emergency humanitarian aid

Interest-free loans used to help recipient countries construct public facilities and launch projects to
improve people's livelihood

Concessional loans used to help recipient countries undertake manufacturing projects and large and
medium-sized infrastructure projects with economic and social benefits, or for the
supply of complete plants, machinery and electronic products

Table 1. Types of foreign development assistance and conditions of disbursement (People’s Republic of
China, 2014)

China Exim Bank and China Development Bank are the main instruments of China’s foreign development
assistance in developing markets across Africa and Asia (Moss & Rose, 2006). They finance large-scale
infrastructure development projects and do not come with stringent political, environmental, or human
rights conditions to manage environmental and social risk. Through these and similar national
institutions, China has been the development partner of many African and Asian countries since the late
1950s. The massive Tanzam railway construction project, the largest overseas development assistance in
Chinese history demonstrates its political interest in collaborating with postcolonial states in Africa
through a non-Western model of development. (Fahimul Quadir, Apr 2013).

Concessional loans are raised by the Export-Import Bank of China (Exim Bank) linking diplomatic,
development and business objectives (Kobayashi 2008, People’s Republic of China, 2014). Concessional
loans are extended by the China Exim bank, under the designation of the Chinese government, to the
borrowing government as official assistance. The objective of these loans is to promote economic
development and improve living standards in developing countries, and to boost economic cooperation
between developing countries and China. The only condition set around the need to manage
environmental or social impacts being that projects need to have ‘good social benefits’ (China Exim Bank

The China Development Bank (CDB)/Guójiā Kāifā Yínháng is the world’s largest development financial
institution with more assets than the total amount of World Bank, Asian Development Bank, and African
Development Bank (CDB Handbook). CDB operates as a commercial bank and invests in large
international projects for infrastructure development in various sectors and to assist Chinese enterprises
in their endeavours to access new markets (CDB Handbook). The bank states commitment to market
practice but does not have stringent requirements for human rights protection or promotion as part of
its objectives.

This report seeks to determine to what extent China Exim Bank and China Development Bank are
promoting policies that facilitate or control against environmental or land related issues while they are
financing corporations or companies. The study will look into the policies and practices as reflected in
secondary materials such as media report, official websites, research reports and different online data
resources due to the difficulty of accessing official government documents and information from the
People’s Republic of China.

Background: the Export and Import Bank of China (China Exim Bank) and China Development
Bank (CDB):

a. The Export-Import Bank of China

The Export-Import Bank of China/Zhōngguó Jìnchūkǒu Yínháng (China Exim Bank) is owned by the
Chinese government and was founded in 1994. It operates directly under the leadership of the State
Council headquartered in Beijing and has 3 representative offices namely, the Representative Office for
Southern and Eastern Africa, Paris Representative Office and St. Petersburg Representative Office. It has
more than 20 domestic business branches and has established correspondent banking relationship with
more than 1,000 banks.

The main objective of the Bank is to facilitate the export and import of Chinese mechanical and
electronic products, equipments, high-tech products, and assist Chinese companies with comparative
advantages in their offshore project contracting and outbound investment, and promote international
economic cooperation and trade (Exim Bank 2013).

Exim Bank is the sole provider of Chinese government’s concessional loans although it is not limited to
concessional funding and also has commercial operations. China Exim bank also offers preferential
export credits, which are managed directly by the Exim bank and are not considered as official assistance
(China Exim Bank, 2009b). China Exim Bank also provides supplier’s credit in the form of concessional
loans what it called as export buyer’s credit. With this supplier’s credit borrowing country receives
concessional loans from the Chinese government through the export import bank of China to pay the
contracting Chinese agencies which supplies the equipments, goods and technical assistance for the
China funded projects.

Projects financed by China’s development assistance are in different categories. Such as:

 Turnkey Projects (Chinese construction of bridges, stadiums, government run factories, etc.).

 Technical cooperation projects (Chinese teams provide onsite training, advice and ‘learning
by doing’).

 Training programmes: (short to medium term formal courses).

 General humanitarian aid: (disaster relief, medical team support).

 Concessional loan projects: (higher technology exports or construction/ projects developed

by Chinese companies and financed through China Exim bank with low, fixed rate loans,
supplier’s credit/export buyer’s credit etc.).

b. China Development Bank (CDB):

The China Development Bank was established in 1994 to provide development oriented finance for
government projects of national priority. It is under the direct jurisdiction of the State Council of the
Central Government. (CDB, 2013)

CDB is committed to market-based practices; despite the Bank’s importance in Chinese foreign policy
implementation, it operates as a commercial bank and does not provide concessional loans. In fact, a
recent study found that CDB’s loan rates are generally higher than that of the World Bank (Gallagher et
al, 2012).

In 2012, the Bank broadened its collaboration with foreign governments, enterprises and financial
institutions, on the basis of equality and mutual benefits. During that year, it made significant progress in
cooperation under the frameworks of the Shanghai Organization Interbank Association and China-ASEAN
Interbank Association. It further enhanced its alliance with other BRICS countries and established the
China-Portuguese Fund. The Bank continued to invest in a number of large international projects for the

development of infrastructure, agriculture, energy and social sectors in those countries with which it
engaged, and to assist Chinese enterprises in their "Go Global" endeavors. As of December 2012, the
Bank had outstanding foreign currency loans of USD 224.5 billion, and an offshore yuan-denominated
loan balance of 72.6 billion. It has formal relationships with 638 correspondent banks in 101
countries/regions (CDB, 2013)

The CDB Special Loan for the Development of African SMEs is one of the Eight New Measures of the
Chinese government to strengthen China-Africa cooperation under the framework of the Forum on
China-Africa Cooperation (FOCAC). CDB is the sole agency responsible for implementing this measure to
generate employment; develop local market and economy in African countries. The Special Loan
business covers 31 countries including Kenya, Angola, Morocco, South Africa, Nigeria, Ghana,
Mozambique and Ethiopia, etc. The projects supported by the loans have directly and indirectly created
11,020 and over 390,000 local job opportunities respectively, promoted China-Africa trade volume over
US$ 311 million (CDB 2013).

Key elements in objectives, policy and practice of these two banks:

The primary focus of the China Exim Bank and the CDB is to increase Chinese trade and investment as
well as provide support to Chinese companies investing in foreign markets. The objectives of Exim Bank
and CDB are aligned with the Eight principles of Chinese development assistance (People’s Republic of
China 2014), Box 1).

Key points of the eight principles:

 Equality and mutual benefit in providing aid to other countries; aid is never regarded as unilateral.

 Respect the sovereignty of recipient countries with no conditions with respect to governance or
accountability attached

 Economic aid isinterest-free or through low-interest loans,

 Help recipient countries develop self-reliance and independence through economic development.

 Help recipient countries to increase their income and accumulate capital.

 Provides the best-quality equipment and materials manufactured by China at international market
prices those are needed for the projects.

 Technical assistance will help the personnel of the recipient country to fully master the technology.

 The experts from China will have the same standard of living as the experts of the recipient country.

Summary of the objectives of China Exim Bank and CDB

 Facilitate the export and import of Chinese mechanical and electronic products, complete sets of
equipment and new- and high-tech products,

 Assist Chinese companies with comparative advantages in their offshore project contracting and
outbound investment, and

 Promote international economic cooperation and trade.

Box 1. Summary of the Eight Principles of development assistance and cooperation of the People’s
People’s Republic of China in comparison to the objectives of Exim Bank and CDB

The objectives and principles say that though these two banks are branded as policy bank and have the
mandate to facilitate Chinese overseas development finance, they do not have the mandate to call for
human rights protection or promotion as part of their objectives. This is supported by the Beijing
Declaration of the Forum on China-Africa Cooperation (2000) which states that “[t]he politicization of
human rights and the imposition of human rights conditionalities on economic assistance should be
vigorously opposed.” (Strange et al., 2013)

The only conditions set by the banks for a country to receive development assistance are the guarantee
for payment against their works and the safeguard from the host countries for smooth operation of their
works. Any social and environmental consequences of that work are to be dealt with at the discretion of
the recipient country. This opens the scope for negative environmental impacts or human rights
violations as a result of the financed project, if the country’s national laws on these issues are not strictly
implemented. It depends on how the host country

Environmental protection policies of China Exim Bank and CDB for development projects

The Ministry of Commerce of the People’s Republic of China and Ministry of Environmental Protection of
the People’s Republic of China issued policies on environmental protection in February 2013 for foreign
investment and cooperation. The policies are formulated to regulate environmental protection
considerations in foreign investment and cooperation, provide guidance to actively perform social
responsibilities of environmental protection, and promote the sustainable development of foreign
investment and cooperation by Chinese institutions domestically and abroad. These Guidelines are
applicable to all Chinese enterprises engaged in foreign investment and cooperation activities.

In summery the Guidelines for Environmental Protection in Foreign Investment and Cooperation are to:

 Regularize the environment related behaviors of Chinese companies in foreign investment and
cooperation activities (Article 1)

 Guide for the performance in social responsibilities for environment protection (Article 1)

 Advocate to respect religious belief, cultural traditions, local customs of the community,
safeguard legitimate rights and interest of labours (Article 3)

 Understand and observe host country’s provisions of law and regulations related to environment
protection. (Article 5)

 Conduct environmental impact assessment, take measures to reduce possible adverse impacts
based on impact assessment (Article 8)

 Develop environmental monitoring and evaluation based on the background situation of project
surrounding areas (Article 11)

 Formulate contingency plans for environmental accidents and other emergencies and set up
reporting and communication system for local government, environmental regulatory authority,
general public and company headquarters. (Article 14)

 Post their environmental information on a regular basis, and publish their plans on
implementation of laws and regulations on environmental protection, measures taken, and
environmental performance achieved (Article 18)

 Establish communication and dialogue mechanism to strengthen their communications with

their communities and relevant social groups, take opinions and suggestions with respect to
environmental impacts of their construction projects according to requirements of laws and
regulations of the host country. (Article 20)

 Encourage enterprises to research and learn from the environment protection related principles,
standards and practices adopted by international organizations and multilateral financial
institutions. (Article 22)

The Chinese government also introduced a "green credit" guideline for commercial lenders in 2012 to
facilitate economic restructuring in a manner that's environmentally friendly and saves energy (CBRC
2013). The China Banking Regulatory Commission, the top banking regulator, ordered lenders to cut
loans to industries with high-energy consumption and high levels of pollution, and to strengthen
financial support for green industries and projects. The CBRC encouraged banks to evaluate, classify and
rate the environmental and social risks inherent in their clients' businesses and take the results as a key
reference in their ratings and access to credit. In future the CBRC will set up some key indexes to make
the guideline more specific and try to include adherence to the plan in the rating system. Lenders also

need to improve management of any overseas projects that they support, to ensure that the initiators of
those projects comply with local environmental, land, healthcare and security legislation, according to
the guideline (China Daily, 2012).
Practices of Exim Bank and CDB:
Even though there are Chinese national policies and regulations governing the lending practices of both
banks they may also develop country specific procedures. For example in Bangladesh Exim bank outlined
the following seven steps as the process for dealing Chinese development financing (Financial Express
a) Selection and communication of the proposed project to the Chinese government
b) Letter of confirmation by the Chinese government,
c) Loan applications with reports on feasibility and environmental studies that are sent to the
Chinese government,
d) Selection of contractor by the Chinese government and its communication to the government of
e) Negotiation and finalization of commercial contract between the Chinese contractor and the
relevant agency of the government,
f) Signing of commercial contracts, and
g) Negotiation and signing of financial contracts.
On the other hand there are some requirements which the borrowing country needs to fulfill. The
following requirements shall be satisfied when applying for Export Buyer's Credit:
 The economic and political environment of the borrower's country should be stable;
 The borrower should demonstrate sound credit standing and good debt servicing capacity;
 The value of the commercial contract shall exceed USD 2 million, and the export project shall fall
into the financing area of this credit;
 The Chinese content of export products should be no less than 50% of the total contract value.
For the overseas contracting projects, no less than 15% of the project shall come from the export
of Chinese equipment, construction mechanics, materials, engineering work, technical and
managerial expertise, and labor services;
 The borrower shall provide a repayment guarantee acceptable to the Bank;
 Export credit insurance shall be sought if required;
 Other requirements the Bank deems necessary

Outside of environmental feasibility assessments as part of the loan application to Exim Bank, there is no
real requirement to have environmental management or social protection plans in place for any
development project. These requirements, in relation to the procedures, encourage the contracting

agencies to devise their bank financed project as a commercially viable project rather than a socially and
environmentally sensitive development project. On the other hand, placing a strong requirement for
social development and environmental protection may decrease the future probability of the contracting
agencies or governments qualifying for development finance from the banks. This is a particularly huge
risk where the host government may have weak regulatory frameworks governing environmental and
social protection.

However, it is important to note that the standards applied (or not) in China’s overseas projects are not
necessarily out of line with the standards set within China for similar projects (Woods 2008).
Furthermore, the fact that there are Chinese policies guiding standards of environmental and social
protection for foreign development assistance projects does not necessarily mean they are implemented
by the contracting agencies as seen in the Shwe Gas Case study below.

Case Study: The “Shwe” Oil and gas project financed by China Development Bank

This case study is taken from the Shwe Gas Movement website, an NGO comprised of community
organizations representing affected peoples throughout Arakan State, that is tracking the
environmental and social impacts of the project as it develops.

In September 2009 China Development Bank (CDB) provided a USD 30 billion as loan for five-
years to the China National Petroleum Corporation to finance the company’s overseas
expansion. After getting the loan from CDB, CNPC invested in the Shwe oil and gas project in
Myanmar. . The ‘Shwe' project is for exploitation of the underwater natural gas deposits off the
coast of western Burma's Arakan State and dual oil and gas pipelines that will transport this gas
along with oil imports from Africa and the Middle East, to southwest China. A consortium of four
Indian and South Korean companies led by Korea’s Daewoo International is teaming up to exploit
natural gas from two blocks in the Bay of Bengal. The project comprised of an offshore
production platform, an underwater pipeline and an onshore gas terminal in Kyauk Phyu
Township on the Arakan coast which will cost an estimated US$ 3.73 billion to develop. The
consortium expects to extract 500 million cubic feet of natural gas per day. The gas will then be
transported through Burma to southwest China (possibly as far as Nanning, capital of Guangxi
Province), via a 2,800 km gas pipeline to be built by the China National Petroleum Corporation
(CNPC). The gas will be distributed by CNPC's subsidiary PetroChina. The Burmese government is
expecting to get profit at least US$29 billion over 30 years from the revenues.

However, in this project CDB was unable to ensure the implementation of its own environmental
policies as well as China’s new Green Credit Policy Directive. CDB’s environmental policy requires
the preparation of an Environmental Impact Assessment (EIA). Chinese law also requires at least
summary EIAs to be disclosed and in some cases it needs to be consulted with the affected
people. According to the Shwe Movement the EIA for the Shwe Gas project has not been
publicly released. The project does not comply with the Green Credit Directive’s requirement for
following international best practice, in relation to the impacts on endangered species. The UN
Guiding Principles for Business and Human Rights are also not being fully upheld by this project,
as one would expect given that CDB and CNPC are both state-owned enterprises.

China National Petroleum Corporation, through its subsidiary the Southeast Asia Pipeline Co.
Ltd., is constructing:

 A deep-sea port and oil storage facilities on Maday Island that will allow oil tankers to
offload oil from the Middle East and Africa before further transporting it to China via
overland pipelines. According to Oil and Gas Journal, construction on the deep-sea port
began in October 2009.

 Dual trans-border pipelines that will transport the Shwe gas 2,800 km from Arakan State
to Nanning in southern China’s Guangxi Province and will carry oil from the deep-sea
port 1,100 km to a refinery near Kunming of China’s Yunnan Province. According to CNPC
and Caijing Magazine, construction began on the Myanmar (Burma) side in June 2010
and in southern China during September of that same year.

According to the information provided in the Shwe Gas Movement website, Building the pipe-
lines and extracting the gas are fuelling conflicts and human rights abuses: battles between
armed groups and the government have broken out near the pipeline route and land
confiscation and forced labor has started in project areas.” The movement’s website provides
further information as below:

 Due to this project the displacement of villages along the anticipated pipeline corridor,
which in the case of the Yadana/Yetagun pipelines were up to 15 miles on each side of
the pipeline,

 exporting an important energy source in exchange for cash will put further pressure on
Burma’s precious rain forest as a source of fuel.

 The Mangroves along the Arakan coastline are now further threatened by the
infrastructure of the Shwe gas project. Already endangered animals such as the Arakan
forest turtle are under greater pressure

 The construction of drilling and production platforms, leakage of chemicals used in the
drilling process as well as potential gas blowouts will be detrimental to the Arakan
coastal area.

[** Unless otherwise noted, all information is derived from the Shwe Gas Movement’s Sept 2011 report Sold Out: Launch of China pipeline
project unleashes abuse across Burma. The organization based its report on field investigations done by local people and desk research. For
more information, see Shwe Gas Movement’s website at]


Traditionally, the role of a policy bank is to supply soft loans. When the CDB became a commercial lender
in 2007 the Chinese government required it to cap its outstanding soft loans and focus on commercial
lending (Caixin, 2013). In comparison, China Exim Bank does not provide commercial loans but the
nature of the concessional loans provided by Exim bank is close to commercial lending, considering the
general practice of defining grant elements (interest rate, grace period, maturity period etc.) of the loans
it provides. Although both banks operate under the umbrella of foreign development assistance they
both place great emphasis on maximizing commercial returns on their investments. Chinese legislation
does outline the need for environmental impact assessments of development projects, neither bank
stipulates the standards to which environmental and social risks/impacts should be managed once
assessed. Rather there is greater emphasis and pressure on the contracting agencies to complete the
development projects and to maximize commercial returns on the investment, opening up the scope for
environmental and human rights issues in the host countries.

Policy Recommendations:

 A participatory and externally carried out environmental and consequence assessment need to
be incorporated in the financing requirement. This should not be only done by the government
department and it should be the basis for financing decision.

 Host country should be consulted for selecting the contracting agency and suppliers. The
credibility rating and performance profile of the contracting agency need to disclose to the host

 For financing government to government project a long term framework need to be developed
based on the host country’s national strategy to fulfill the mutual benefit and need based
financing policy of Chinese government.

 Commercial and governmental financing need to be clearly categorized in the host country and
make available for disclosing to the public.

 Should not consider to finance any proposed projects, those are controversial or disputed by the
people or people’s movement in the host country.

 In the environmental protection policy guideline of PRC, there should be provision for
punishment for the non-complying companies

 Host country should have a mechanism for making available the information and people’s report
on environmental and rights violation.

 Host country should have the list of organizations those are black listed in China or have weak
performance related to environmental and people’s rights violation.


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4. Caixin online (2013) an online media portal -

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