On 11 March 2024, Greenpeace Luxembourg filed a complaint against Fonds de Compensation de la Sécurité sociale (FDC) SICAV FIS (‘the Fund’) to the Luxembourg NCP. The Fund was created by the Fonds de compensation commun au régime général de pension (FDC), a public establishment created by law in 2004, relating to the management of the assets of the general pension insurance scheme. The complainant alleges, among other things, that the Fund does not have a risk-based human rights and environmental due diligence policy in line with the OECD Guidelines, nor does the Fund conduct due diligence in line with the Guidelines, including preventing and mitigating impacts linked to its investments. The Fund also does not align with the goals set in the Paris Agreement and has not implemented measurable objectives, targets, and strategies for addressing the environmental impacts such as climate change. According to the complainant, the Fund has also made misleading claims relating to the sustainability of its investments.

The complainant seeks for the Fund to establish a sustainable investment strategy in line with the standards in the Guidelines, including on risk-based due diligence and climate commitments in line with the Paris Agreement; carry out human rights and environmental due diligence in relation to investments; and establish a grievance mechanism, including an ethics committee, in line with the expectations in the United Nations Guiding Principles on Business and Human Rights (UNGPs) allowing stakeholders to report sustainability related issues.

The complaint is filed under both the 2011 and 2023 versions of the OECD Guidelines. The following paragraphs of the 2023 Guidelines are cited:

Chapter II (General policies), paragraphs 11, 13, 14 and 15;
Chapter III (Disclosure), paragraph 3, a) and d)
Chapter IV (Human rights), paragraphs 1, 3 and 5
Chapter V (Environment), paragraph 1, a), b), c), d)
Chapter VIII (Consumer interests), paragraph 4

Relevant OECD Guidelines

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