OECD National Contact Point: what happens when the company does not respond

National Contact Points (NCPs) are the OECD's out-of-court mechanism for handling complaints about the conduct of multinational companies, based on the OECD Guidelines. In Brazil, the NCP operates within the Ministry of Development, Industry, Commerce and Services (MDIC). It is not a court and does not impose sanctions, but its reports carry reputational weight and are read by investors and ESG rating agencies.

Direct answer

The NCP receives the complaint, makes an initial assessment, may offer good offices (mediation) and closes the proceeding with a Final Statement. The companies' participation in good offices is voluntary. If a company does not respond, the NCP may conclude its analysis with the elements available and publish a statement. The draft statement is sent to the parties, who may submit contributions before the final version.

What the OECD Guidelines are

The Guidelines for Multinational Enterprises are governmental recommendations for responsible business conduct. They cover topics such as disclosure of information, human rights (Chapter IV), employment and industrial relations (Chapter V), the environment and anti-corruption. Adhering governments undertake to maintain an NCP. Companies adopt the Guidelines voluntarily, but multinational companies headquartered or operating in adhering countries are their target.

The phases of the proceeding

1. Receipt and initial assessment: the NCP checks whether the complaint is within its competence and deserves examination (identity of the complainant, company, connection to the Guidelines, relevance).
2. Good offices: the NCP invites the parties to a facilitated dialogue. There may be meetings, exchange of documents and a settlement proposal.
3. Final Statement: the NCP closes the instance and publishes a statement describing the proceeding, the conclusions and, where appropriate, recommendations. If there is an agreement, the statement records it.

The OECD procedural guide suggests concluding proceedings in about twelve months.

When the company does not respond

• Taking part in good offices is voluntary. Refusal or lack of response does not prevent the proceeding from continuing.
• The NCP may, based on the elements available, form its assessment and publish the statement.
• The draft statement is communicated to the parties, with a deadline for contributions.
• Companies may respond at any stage.

When the case involves more than one country

When the parent company or the group is headquartered in other countries, the NCP of the country where the facts occurred may notify the NCPs of the countries of the headquarters. The NCPs coordinate among themselves, and each keeps its own competence.

Timeline of Specific Instance no. 02/2026

• 31/03/2026: the claimant brings the matter to the Brazilian NCP under the OECD Guidelines.
• 08/04/2026: urgent communication on risk to life, linking the non-payment of severance to the interruption of medical treatment.
• 14/04/2026: update of the case to the NCPs of France (home of Pernod Ricard SA) and the United Kingdom (home of PageGroup).
• 02/06/2026: fourth update to the Brazilian NCP, with supplementary documents.
• 10/07/2026: the Brazilian NCP agrees to receive the complaint, formalized in the format required by the body, and notifies the NCPs of France and the United Kingdom.
• 15/10/2026: the Brazilian NCP sends the parties the draft Final Statement, with a deadline for contributions until 29/10/2026.
• 29 and 30/10/2026: the claimant's contributions.
• By 13/11/2026: the final version is expected.

According to the information in the proceeding, Pernod Ricard and Page Interim did not respond in the good offices phase.

Points of attention

• The NCP does not replace the courts: it does not convict and does not award compensation.
• Contributions should bring new facts and documents.
• The final report may be cited in other forums.
• Keep a copy of all protocols.

Frequently asked questions

Can anyone bring a matter to the NCP? Individuals and organizations with a legitimate interest in the subject, on the conduct of multinational companies.

Is the company obliged to take part? No, participation in good offices is voluntary.

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