11 July 2021

Euler Hermes’ updated response to our Grievance letter unfortunately further substantiates the gross negligence and clear failure of EH’s due diligence procedures; initially as a result of the applicant’s misrepresentation and failure to disclose crucial project details, but later as a result of the conduct of Euler Hermes while monitoring and investigating our claims. EH have not only disregarded their own Code of Conduct, the OECD Common Approaches and ESG – Environment Social & Governance, but are also breaching the UN BHR Guiding Principles as well as Germany's own National Action Plan on BHR...

Failure to disclose crucial project details and material facts has resulted in EH misclassifying the project and providing the credit guarantee, and has effectively created a false endorsement of the project...

Clearly, without an ECA covering the export credit, there would have been no finance and therefore no illegal project. At the very least, a different, more appropriate site for such an industrial wind energy project could be investigated by it’s investors. Euler Hermes should never have covered the export credit for a project in a 1st- and 2nd-degree Natural Protected Area without an EIA/EISA report in the first place. Knowing fully well that when erecting wind turbines, huge amounts of land is needed, and that for this project planned on very valuable and fertile private property in an historical and touristic site such as Ceşme, extensive expropriation would be required, EH should never have approved the coverage they did...

To mitigate further damage to the victims and their private property, The Federal Government of Germany and Euler Hermes should immediately act accordingly...

Euler Hermes should revisit their due diligence based on the current state of knowledge and re-evaluate the failure to disclose crucial information and misrepresentation of the project... The court verdicts should be enforced, the area restored and the deeds transferred back to their real owners. All of the unfortunate locals impacted adversely from this project, who would have been spared years in court, living under constant threat, and all the other negative impacts that comes with an illegal 24 million Euro Wind project being constructed on their private properties, should be returned to living their lives as it was before this project was begun.

[full response attached]