The work of Jubilee Australia and other advocates helped lead to the November 2011 establishment of a Productivity Commission Inquiry into Australia's export credit arrangements. The Commission's final report suggested widespread changes to the EFIC Act, often directed to improving transparency and accountability. Yet the Amendment Bill now before parliament ignores key recommendations. Jubilee Australia made this submission with the aim of ensuring the tax payer funded work of the Commission and its key recommendations are adequately incorporated into legislation.

Jubilee Australia is of the strong opinion that approval of funding for this project by international financial institutions and export credit agencies, including EFIC, on the basis of what has been provided by Oyu Tolgoi LLC to date is premature.

EFIC may be considered merely a financing body overcoming market imperfections, externalities or other barriers for Australian exporters, but decisions EFIC makes can have serious impacts on the development and well-being of countries and communities hosting the projects it helps to finance.

It is the view of Jubilee Australia that unsanctioned codes of good intention from which business can opt-in and out, together with non-legislative ʻencouragementʼ by government of firms to be socially responsible, is an inadequate response in todayʼs competitive global marketplace.