Greenpeace Luxembourg has filed a complaint with the OECD National Contact Point in Luxembourg against the country’s pension reserve fund, Fonds de Compensation (FDC).

The NGO’s complaint alleges that FDC’s investment company’s investment activities are in breach of the OECD Guidelines for Multinational Enterprises on Responsible Business Conduct with respect to their recommendations on disclosure, environment, human rights, and consumer interests.

Greenpeace Luxembourg said that FDC must set up a sustainable investment strategy in line with the guidelines and that it should conduct human rights and environmental due diligence to address any adverse impacts linked to their investments and establish a grievance mechanism that allows stakeholders to report sustainability-related issues.

In a statement, a spokesman for FDC said that it is a public institution and not in scope of the OECD guidelines.

“The FDC’s sustainable investment strategy is in line with its legal mission and is set out in its directive of the board of directors, which was approved in January 2023 by the minister in charge of social security,” he added.

A spokesman for Luxembourg’s economy ministry confirmed that Greenpeace had lodged a complaint with the OECD national contact point, which had three months to decide if it was admissible and, the case depending, to carry out an initial evaluation.

The OECD guidelines in question are recommendations addressed by governments to multinational enterprises, but many European investors incorporate them, as well as the UN Guiding Principles on Business and Human Rights into their investment policies on a voluntary basis.

Greenpeace Luxembourg has been campaigning on FDC’s sustainable investment strategy since 2015. In 2020 the fund published a sustainability report after the NGO initiated legal proceedings. Greenpeace said the fund “has not been responsive to its recommendations”.

The NGO’s complaint to the OECD national contact point comes as backers of the EU’s sustainability due diligence law fight for its survival. The next member state vote on the regulation is scheduled for Friday.

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