Cases of complaint at the German National Contact Point

Please note the following:

At no point in the procedure does the German National Contact Point determine whether or not the company acted in line with the OECD Guidelines.

Acceptance of a specific instance for further investigation and the German National Contact Point’s mediation offer do not mean that the issues raised have been given final consideration. It is not a determination on whether or not the corporate behaviour or actions in question were consistent with the OECD Guidelines and should not be equated with a determination on the merits of the issues raised in the submission.

The criteria for accepting a specific instance are low-threshold. Among others, it is sufficient that a specific instance is sufficiently substantiated, i.e. that it is supported by sufficient and credible information. There is no requirement to prove the case like in court.

The existence of a specific instance and the acceptance of a specific instance for further investigation do not justify any disadvantages for companies. However, if a company fails to deal constructively with the allegations raised in a specific instance, this can influence negatively the evaluation for the decision about granting export credit guarantees, investment guarantees and guaranties for untied financial loans by the German government.

Neither the existence of a specific instance nor the acceptance of a specific instance for further investigation in and of themselves justify a negative ESG rating for the company addressed by the specific instance. ESG rating providers integrating NCP processes into their assessments should also take into account the company's response to the alleged adverse impact, its good-faith engagement throughout the proceedings, as well as any mitigation or remediation measures undertaken, amongst others.

*Overview of the OECD Guidelines’ Chapters

• Chapter I – Concepts and Principles
• Chapter II – General Policies
• Chapter III - Disclosure
• Chapter IV – Human Rights
• Chapter V – Employment and Industrial Relations
• Chapter VI - Environment
• Chapter VII – Combating Bribery and Other Forms of Corruption
• Chapter VIII – Consumer Interests
• Chapter IX – Science, Technology and Innovation
• Chapter X - Competition
• Chapter XI - Taxation