Rule Out Insurance for Expansion of Coal, Oil and Gas Projects in Bangladesh

May 31, 2021


Mr. Satoru Komiya, Group Chief Executive Officer

Mr. Hiroo Shimada​, Manager, Sustainability Division, Corporate Planning Department

Mr. Masaaki Nagamura, General Manager, International Initiatives, Corporate Planning Dept.

Junko Komori, General Manager, Corporate Social Responsibility, Corporate Planning Dept.


Copy to:

Mr. Akira Harashima, Group Co-Head of International Business

Mr. Kenji Okada, Group Chief Risk Officer

Mr. Yoshinari Endo, Group Chief Investment Officer

Yoichi Moriwaki, Group Deputy Chief Financial Officer



Dear Mr. Komiya, Mr. Shimada and Mr. Nagamura

We are, 40 civil society organizations from different 14 countries of the world writing on behalf of the Bangladesh Working Group on External Debt (BWGED), an alliance of non-profit groups representing thousands of families of Bangladesh who practice and depend upon the sustainable stewardship of local land and marine-based ecosystem commons.

We are concerned that the Tokio Marine Group may become – or already may be – implicated in the development of the 6,200 MW Matarbari Coal Power Hub (Matarbari Phase 1 to 4 and Kohelia 1&2), including associated acquisition, shipping and stockpiling of the required coal supplies as well as port construction and infrastructure.

If these projects in Matarbari get underway, it is projected that:

  • tens of thousands of people will be dispossessed of their homes;
  • there will be severe contamination of waterways, soil and groundwater;
  • air will become so heavily polluted from the emissions that our people will face the prospect of premature deaths; and
  • unique ecological wetlands that provide habitats for rare migratory birds and endemic fish species will be destroyed.(*1)

Bangladesh already has a serious overcapacity of power (*2) and is among the most climate vulnerable countries in the world. There is no need for th​is build out of energy​ projects, nor for a reliance on the dirtiest fossil fuel available on the market. Instead, these projects will compound problems faced by not only the subsistence based populations of the Matarbari area, but also consumers nationwide.

BWGED is among the many groups in Bangladesh and worldwide that oppose ​these and other similar coal related developments. ​If they go ahead as planned, you should be aware that there is no foreseeable or ​practical ​​way they could contribute postively towards achieving the​ SDGs in Bangladesh​​.

E​ngagement in these projects ​will leave insurers, investors and companies exposed to significant reputational, legal and financial risks.

As such, we are asking the Tokio Marine Group to:

  1. disclose whether agents in any of your Group companies are brokering contracts related to the Matabari or Matarbari Kohelia coal projects​; or ​have already signed off on ​such ​contracts (including surety bonds, commercial multiple peril insurance, and reinsurance offers);
  2. divest from any current support holdings in these projects, including associated works (shipping)​ and rule out future​ investments ;​ 
  3. without exception, rule out offering insurance of any kind to the projects or associated business ventures; and​
  4. Make information about the extent of these commitments publicly available in English, Japanese and Bengali​.​

In light of your upcoming Investor Relations Conference and Annual General Meeting, we ask that before 28 June 2021, you publicly disclose information that identifies which coal, oil or gas projects in Bangladesh (existing and under development) for which any of the Tokio Marine Group of companies are offering insurance in English, Japanese and Bengali.

We are also requesting you respond by or before 15 June 2021 to clarify what actions you will take ​in​ regard​ to the aforementioned steps​. T​hank you for your consideration and time.

Sincerely Yours

Hasan Mehedi

Member Secretary

Bangladesh Working Group on External Debt (BWGED)


With support and endorsement from the following 39 groups worldwide:

  1. AsiaRegional
  2. JapanJapan
  3. AEPA FalconVenezuela
  4. Ambiente Desarrollo y Capacitación (ADC)Hondurus
  5. BandhanBangladesh
  6. Bangladesh Environmental Lawyers Association (BELA)Bangladesh
  7. Bangladesh Krishok Federation (BKF)Bangladesh
  8. BankTrackNetherlands
  9. Both ENDSNetherlands
  10. Center for Environment and participatory Research (CEPR)Bangladesh
  11. Change InitiativeBangladesh
  12. CLEAN (Coastal Livelihood and Environmental Action Network)Bangladesh
  13. Climate WatchThailand
  14. Friends of the Earth JapanJapan
  15. Global Energy MonitorUSA
  16. GrowthwatchIndia
  17. INCIDIN BangladeshBangladesh
  18. INSAF (Indian Social Action Forum)India
  19. Japan Center for a Sustainable Environment and Society (JACSES)Japan
  20. KRuHA (People’s Coalition for the Right to Water)Indonesia
  21. Mangrove Action Project (MAP)United States
  22. Mekong WatchJapan
  23. Mines Mineral and People (Mm&P)India
  24. Mongla Nagorik SomajBangladesh
  25. Nadi Ghati MorchaIndia
  26. National Committee for Saving the Sunderbans (NCSS)Bangladesh
  27. NGO Forum on ADBRegional
  28. Oil Change International (OCI)United States
  29. Pakistan Fisherfolk Forum (PFF)Pakistan
  30. Paribartan-RajshahiBangladesh
  31. Participatory Research Action Network (PRAAN)Bangladesh
  32. Phulbari Solidarity Group (PSG)United Kingdom
  33. PrantojonBangladesh
  34. Project Affected People’s Association (PAPA)India
  35. Society of Canton Nature Conservation – China
  36. SongshoptaqueBangladesh
  37. The Sunrise ProjectAustralia/USA
  38. UrgewaldGermany
  39. Voices for Interactive Choices and Empowerment (VOICE)Bangladesh

See the PDF version: English, Japanese



*1 For further information, see: Centre for Research on Energy and Clean Air, “Air quality, health and toxics impacts of the proposed coal power cluster in Chattogram, Bangladesh” (2020) <>.

*2 See for example: Institute for Energy Economics and Financial Analysis, ​”​Power Overcapacity Worsening in Bangladesh Switch in Focus From Coal and LNG To Renewables and Grid Can Address the Problem​”​ (Jan 2021) <>

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