Letter to the Canadian Commercial Corporation RE: Human Rights Assessment – Indirect Transfers of Military Equipment and Parts to Israel
Mr. Douglas Harrison
Chair, Board of Directors
Canadian Commercial Corporation
RE: Human Rights Assessment – Indirect Transfers of Military Equipment and Parts to Israel
Dear Mr. Harrison,
I am writing with respect to the CBC news articles of Feb 5 and 24, 2026 previously reported by The Maple in May 2025.
Crown corp. reviewed U.S.-bound arms exports over potential transfer to Israel | CBC News
Government Export Agency Noted 99 Israeli Crimes, But OK’d Arms Sale | The Maple
I commend CCC for conducting a Human Rights Assessment of “Indirect Transfers” of Canadian-made military equipment and parts for use by Israel in Gaza. I understand that the Corporation carried out this assessment in response to the March 2024 motion passed in the House of Commons ceasing further arms transfers to Israel, as well as a statement by then foreign affairs minister Mélanie Joly saying no Canadian arms should be sent, directly or indirectly, for use in Gaza.
Most of the report was redacted, including the conclusions, which leaves unanswered the question of whether Canadian military equipment and parts are used in Israel by way of transfer through the United States or other jurisdictions. This is unsatisfactory. As a Crown Corporation, the CCC owes it to the Canadian public to disclose if it has identified any risks of Canadian military equipment or parts sent to Israel, directly or indirectly. If no risk has been identified, the CCC should be able to state so with confidence, thus putting the concerns of parliamentarians – and all Canadians – at rest. On the other hand, if the CCC is hiding a risk of indirect transfer, I would consider that the board has been in dereliction of its duty of care. Any such risk, and any mitigation measures that may have been put in place, should be disclosed in full, so that Canadians can judge for themselves if the country is protected from complicity in grave violations of international humanitarian law.
In addition to a clear statement on the risk of direct or indirect transfers and any mitigation measures, I would respectfully ask that you publicly release the report in unredacted form (except for issues narrowly related to commercial confidentiality).
I remind the board that your review of risks should not be seen merely as a response to a Parliamentary motion, statements by the Minister of Foreign Affairs, or the Export and Import Permits Act. The question of Canadian complicity in arms transfers to conflicts involving serious international law violations, including plausible genocide, centers on peremptory norms (jus cogens). These are fundamental principles of international law, such as the prohibition of genocide, from which no state or party can derogate.
The responsibility of state actors such as CCC is especially clear. The UN Independent International Commission of Inquiry on the Occupied Palestinian Territory said in their October 2024 position paper:
The Commission also takes note of State responsibility through complicity, namely when a State knowingly aids or assists another State in the commission of an internationally wrongful act. The Commission notes, for violations of international humanitarian law, it has already reported that Israel has committed war crimes in the context of the war in Gaza since 7 October 2023. On the issue of genocide, the Commission notes the provisional measures orders issued by the Court in the Application of the Convention on the Prevention and Punishment of the Crime of Genocide in the Gaza Strip . . . . The Commission finds that all States are on notice that Israel may be or is committing internationally wrongful acts in both its conduct in the military operations in Gaza and its unlawful occupation of the West Bank, including East Jerusalem. Thus, the Commission finds that, unless States cease their aid and assistance to Israel in the commission of these acts, those States shall be deemed to be complicit in those internationally wrongful acts.
On the question of whether Canada has a risk of direct or indirect transfer of military equipment or parts to Israel, therefore, there is no room for equivocation or ambiguity. If there are measures put in place to mitigate risk, these measures must be spelled out publicly for them to be credible.
The Corporation is right to have conducted a risk assessment. Given the gravity of the issue, the next step is to let Canadians know the findings of that assessment and to release more information from the report.
I look forward to hearing from you.
Yours sincerely,
The Honourable Yuen Pau Woo
cc. Robert Kwon, President and CEO