Redaction in the subject line, name in the header: the e-mail MDIC calls "another procedure" carries "Pernod Ricard x Bruno" on every page

The Ministry of Development, Industry, Trade and Services (MDIC) says the e-mail from France's National Contact Point (NCP), dated 25/09/2026, concerns an "autonomous and independent procedure" with "other interested parties". The document MDIC itself delivered says, on every page: "2026 - 02 - Pernod Ricard x Bruno - PCN - OECD Guidelines for Multinational Enterprises".

Both statements sit in the same file, and it is the Ministry that has to reconcile them.

1. What MDIC decided

On 29/10/2026, the Minister of State, Márcio Fernando Elias Rosa, signed the answer to the second-instance appeal in the access-to-information request registered under NUP 52016.008279/2026-41. Decision: "access partially granted". Ratifying the SE-Camex answer, the Minister stated that:

• the French NCP e-mail of 25/09/2026 and the communications that followed it concern a "distinct procedure", with information of "identified or identifiable third parties" (Access to Information Law, art. 31; Decree 7,724/2012, arts. 3, V, and 55);
• at the 30/09/2026 meeting "several subjects were addressed, among them Specific Instance no. 2/2026", but the meeting request made by the French NCP "did not have this Specific Instance as its object";
• the suppressed passages concern "exclusively a matter unrelated to the object of this request".

Specific Instance no. 02/2026 is the complainant's, before the Brazilian NCP.

2. What the PDF itself shows

The file has four pages, printed on 23/10/2026. On the e-mail pages, the subject field and the recipients are covered by black redaction bars. The title of the Outlook window, which reproduces the subject of the open message, appears without redaction at the top of every page:

2026 - 02 - Pernod Ricard x Bruno - PCN - OECD Guidelines for Multinational Enterprises

In order, what remains legible:

• 25/09/2026, French NCP: "Dear colleagues from the Brazilian NCP, I would like to inform you that the French NCP has received this complaint", followed by a redaction. It ends with "Please let me know when you have time to exchange/coordinate on the matter".
• 25/09/2026, 8:48 pm, Brazilian NCP: "Thank you for reaching out in regards to that case." It proposes a virtual meeting on Wednesday, 30/09, at 10 am Brasília time.
• 28/09/2026, French NCP: confirms 10 am Brasília (3 pm CEST) and sends the link.
• Invitation: "Meeting with French NCP", 30/09/2026, 10 am to 11 am, status "Accepted". Organizer and participants redacted.

3. The numbers that do not add up

The Ministry maintains that the e-mail concerns another case, involving other people. The document shows, without redaction:

1. a title with "Pernod Ricard", "Bruno" and "02", the number of the complainant's Specific Instance in 2026;
2. a message from the French NCP about "this complaint", answered by the Brazilian NCP as "that case";
3. a Minister who, in the same answer, acknowledges that Specific Instance no. 2/2026 was one of the subjects of the meeting arranged by those messages.

An e-mail whose title names the complainant, the company and the instance number is not a "matter unrelated" to the request of the person who asked for the information. And if the subject of the message contained a third party's personal data, that data would be in the header of every page. The redaction covers the field in the body of the page and leaves the same text at the top.

4. What the Access to Information Law requires of a redaction

Law 12,527/2011 treats access as the rule. Art. 7, §2, provides that, where part of a document is classified, the body delivers the non-classified part, by certificate, extract or copy with the restricted part concealed. Art. 31 protects personal information of an identified or identifiable natural person. A redaction is legitimate when it protects a third party's personal data. It ceases to be when it covers what concerns the requester himself, or when its basis is not explained.

In the appeal, the complainant asked for the legal provision and the nature of the information to be indicated for each redaction (art. 11, §1, II). The answer cites the same articles for all the redactions, without indicating what each one covers.

5. What MDIC also confirmed

• The 30/09/2026 meeting was not recorded and had no minutes or any other record. The body states that the Law does not oblige it to produce a new document (Decree 7,724/2012, art. 13, III). The invitation and the e-mails that arranged it are therefore the only records, and they are redacted.
• The United Kingdom NCP did not answer the communications of 29/04 and 10/08/2026, and there was no further follow-up.
• The Brazilian NCP received no information about measures possibly adopted by other NCPs.
• The form ticks "Yes" for active transparency. The first instance was asked about the page, and its ruling did not identify it.

6. Questions MDIC has not answered

• What is the number, and who are the parties, of the "autonomous and independent procedure" mentioned?
• Which provision supports each redaction, and what information does each one cover?
• Does the redacted passage right after "this complaint" refer to the complainant's case?
• If the printed title names "Pernod Ricard x Bruno", what does the "unrelated matter" refer to?
• What were the "several subjects" of the 30/09 meeting, if there are no minutes or records?

7. Next steps

The 29/10/2026 answer closes the second instance within MDIC. The complainant has already filed a third-instance appeal with the Office of the Comptroller General (CGU). Specific Instance no. 02/2026 remains under way: on 29 and 30/10/2026, the complainant submitted his contributions to the draft Final Statement, with the final version expected by 13/11/2026.

What is legible in MDIC's document does not square with the answer the Minister signed. This is Human Case's reading, published in the exercise of freedom of expression (Constitution, art. 5, IV and IX) and based on the documents listed below.

Source documents

• Answer to Access to Information Request, SIC MDIC, SEI no. 65495405 (29/10/2026).
• SE-Camex ruling on the first-instance appeal, NUP 52016.008279/2026-41.
• E-mails and invitation for the meeting with the French NCP, four-page PDF, with redactions.

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