Comments On The Reporting Requirements On Responsible Investment In Burma

We believe the State Department’s Reporting Requirements are critical to monitoring and reducing U.S. involvement in human rights violations in Burma. However, we are concerned that these Requirements have fallen short of effectively meeting these goals. Many U.S. corporate investors are failing to comply with the Requirements and their stated objectives, some key investors declining to submit reports at all. The Requirements themselves are too vague, lacking clarity as to the information they seek, and too narrow, seemingly excluding pertinent areas of investor activities. Thus, even when investors do technically comply, their reports rarely yield useful information. In light of ongoing human rights and corruption concerns in Burma, we propose the State Department amend the Reporting Requirements to maximize their efficacy by: 1. Issuing clear and specific reporting guidelines that - a. define what constitutes “due diligence policies and procedures that address operational impacts on human rights, workers rights…” b. require information regarding compliance mechanisms within the investor’s operations, subsidiaries, subcontractors and business partners; and c. provide instructions and model responses on adequate and inadequate reporting. 2. Requiring investors to disclose the identities of related business entities in Burma, including subcontractors, suppliers and business partners. 3. Requiring reports from key investment industries, such as international garment and footwear brands sourcing products, and issuing notice letters to investors failing to comply