Mr. Chair and members of the committee, thank you for the invitation to appear today as part of your study on the granting of export permits.

As you will know from the chambers of commerce in your communities, we have in our membership companies of all sectors, including both large corporations as well as small and medium-sized enterprises.

I'd like to thank the members of this committee for taking up this study and exploring the issues around the export permitting system. Although the system is quite complex and, admittedly, this is a difficult topic, it is important for parliamentarians to hear from a wide range of stakeholders.

I readily acknowledge the media coverage over the last number of years of export permits for certain markets. There are indeed challenging geographic areas where, given the intersection of foreign policy, commercial and human rights considerations, it can make for fairly fraught discussion. However, I will focus my remarks on the export permits on a macro level, since I am not well-placed to comment on specific companies or permit applications.

It is important to note also that the export permits are used by a wide range of sectors and the challenges with the system are not just for those who are exporting offensive weapons system platforms.

As you heard from Global Affairs Canada officials at their earlier testimony to this committee, industry has had ongoing contact with the department on the need to improve the processing of export permits across the board.

I would like to go on the record and recognize the efforts of departmental officials to seek to understand the concerns of industry. We also welcome the announcement in Budget 2021 of increased funding for the trade controls work of Global Affairs Canada, which includes the export permitting system among other things. However, there is still a need for improvement in the system, and I would like to offer a number of areas that we hope the committee will reflect in its recommendations.

First is to increase information sharing in the export permit application process. Companies invest significant money and years of business development to secure foreign contracts. The export permit is usually the last step in the process after a contract is signed and products and/or services are ready for delivery. Communicating earlier regarding a particular export and destination country would be very beneficial and allow companies to focus on the contracts that are most likely to have government support. Additionally, written guidance would aid companies in evaluating potential bids, including not only understanding how rules are applied on a country basis but also how assessment criteria are being applied during the evaluation process so that companies can know what considerations they need to proactively address.

Industry acknowledges that there are broader foreign policy implications to publishing written guidance. However, we feel that it is important to strike a suitable balance between managing bilateral relations, predictability for companies and not undermining the government's need to respond to changing conditions.

Second, it is critical to ensure consistency in the messaging that companies receive from government officials. Companies with a low level of awareness of how the wheels of government grind may not be as sensitive to the division of responsibilities within or between departments. This is particularly the case in trying to differentiate between the parts of government that regulate export permits versus those that have mandates to promote industry and exports.

While companies acknowledge that the rigour required for export permitting by necessity requires independence for evidence-based decisions, businesses do feel caught between different parts of government when expectations are not met. Therefore, enhancing messaging consistency from government would help businesses manage their expectations.

Third, we think there is a benefit to having an explicit triage system and expedited service standards for existing permits. Given the length of contracts, companies will sometimes need to resubmit an application for an export permit. Although there can be circumstances where the context changes for an application, it can also remain the same. The introduction of a triage system and expedited service standards for reapplications with no context changes would aid companies and enable departmental resources to focus on more complex applications.

Fourth, and finally, and at the risk of saying the obvious, we need a whole-of-government approach where the departments that have a role to play are all properly resourced to enable the attainment of service standards. This is particularly the case, given that changes from the ATT and the new nature of interdepartmental approaches.

Getting the aforementioned areas right is not optional if we want Canada to have a reputation as a reliable business partner. This includes supporting not only Canadian companies acting as prime contractors, but also Canadian businesses that are supply chain participants feeding into OEMs, such as those in the United States perhaps, where we have deep supply chain integration, and that need reliable input sources.

In closing, I would like to emphasize that we do not operate in a risk-free world. This is especially the case for the products that require export permits. I hope to leave the message that the system needs to be regulated thoughtfully, and this means ensuring that we are supporting foreign policy and human rights goals, and also recognizing the important role that exporters play in the economy.

Thank you for your attention. I look forward to your questions.

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