NCP Finland
This page provides information related to NCP Finland. Directly underneath, you find the scores of the NCP on the NCP Evaluation Project. The NCP is evaluated on the indicators with Yes, No or Partial/Not Applicable. The indicators are ordered per category. Only a few indicators per category are shown on this page. To see them all, click on “more…. indicators To see what indicator scores best among all NCPs go to the NCP Evaluation Overview. At the bottom, there is news related to the NCP..
Related complaints
In the OECD Watch Complaint Database you can find all the related complaints with NCP Finland
NCP considers only the six admissibility criteria set out in the Guidelines and/or has a commitment to do so in its case-handling procedures.
Evaluation
The Finnish NCP's case-handling procedures list the six admissibility criteria as set out in the Guidelines. However, it also includes an additional admissibility criteria of "whether the Finnish NCP is the appropriate party to process the complaint" which should not be considered as part of the admissibility criteria.
Source
Procedure for submitting and processing complaints regarding the OECD Guidelines (March 2024), Initial assessment – Page 3: https://tem.fi/documents/1410877/0/EN+Menettelytapakuvaus+OECD-valitusten+kasittelyst%C3%A4_1.3..pdf/2eb961fb-a9c0-b263-1dea-7b7d6b327ef8/EN+Menettelytapakuvaus+OECD-valitusten+kasittelyst%C3%A4_1.3..pdf?t=1715072072868
NCP assesses the issues raised even if mediation is declined by a party and/or has a commitment to do so in its case-handling procedures.
Evaluation
The Finnish NCP states that "if no agreement is reached and the NCP comes to conclusion that the continuation of the procedure is not likely to be productive or a party or parties refuse mediation, the NCP will continue to examine the complaint". The NCP has done so in practice.
Source
Case-handling procedures, page 4: https://tem.fi/documents/1410877/0/EN+Menettelytapakuvaus+OECD-valitusten+kasittelyst%C3%A4_1.3..pdf/2eb961fb-a9c0-b263-1dea-7b7d6b327ef8/EN+Menettelytapakuvaus+OECD-valitusten+kasittelyst%C3%A4_1.3..pdf?t=1715072072868
Several individuals vs. Nokia: https://www.oecdwatch.org/complaint/several-individuals-vs-nokia/
NCP website shows case-handling procedures for complaint handling in national language(s) and English.
Evaluation
The Finnish NCP has published its case-handling procedures in English and Finnish, but not Swedish.
Source
Case-handling procedures in English: https://tem.fi/en/handling-specific-instances-of-the-oecd-guidelines-for-multinational-enterprises
Case-handling procedures in Finnish: https://tem.fi/oecd-n-monikansallisten-yritysten-toimintaohjeiden-yksittaistapausten-kasittely
Swedish website: https://tem.fi/sv/behandlingen-av-enskilda-fall-vid-tillampningen-av-oecd-s-riktlinjer-for-multinationellla-foretag
NCP does not allow companies to remain anonymous when a complaint is filed and/or has a commitment not to do so in its case-handling procedures.
Evaluation
The Finnish NCP does not state that it does not allow companies to remain anonymous when a complaint is filed. In practice, the NCP has named the company in the public initial assessment of each complaint.
Source
Complaints database: https://tem.fi/en/specific-instances-in-finland
NCP allows complainants to withhold their identity from the company for security reasons, and/or has a commitment to do so in its case-handling procedures.
Evaluation
The Finnish NCP does not state that complainants can withhold their identity from the company when filing complaints.
NCP offers guidance in both national language(s) and English on how to file complaints.
Evaluation
The Finnish NCP provides a fill-in form for filing complaints in both Finnish and English, but not Swedish.
Source
Fill in form (English): https://tem.fi/documents/1410877/0/Submitting_complaints_LO_EN_24082022.pdf/b576c5f3-1ddd-50bd-9b89-52ca0e2eaf3d/Submitting_complaints_LO_EN_24082022.pdf?t=1716910251298
Fill in form (Finnish): https://tem.fi/documents/1410877/0/Yksittaistapauksia_koskevat_valitukset_LO_FI_24082022.pdf/71068e46-a077-b8a4-9aa4-09934e77194c/Yksittaistapauksia_koskevat_valitukset_LO_FI_24082022.pdf?t=1716910251410
Swedish website: https://tem.fi/sv/behandlingen-av-enskilda-fall-vid-tillampningen-av-oecd-s-riktlinjer-for-multinationellla-foretag
NCP follows the expected timeline for each stage of the complaint-handling procedure and communicates punctually with all complaint parties over the status of the complaint, including any reasonable delays, and/or has a commitment to do so in its case-handling procedures.
Evaluation
The Finnish NCP states that "as a general principle, the NCP should strive to conclude the procedure within 12 months (14 months if coordination to determine a lead NCP is needed) from receipt of the complaint". In addition, it states that the NCP "should keep the parties informed in a timely manner" where there are any delays. The NCP's case-handling procedures also include expected timeframes for each stage of the complaint.
NCP website contains a permanent record of every complaint received by the NCP, including parties to the complaint, the issue(s) addressed, and the status of the complaint.
Evaluation
The Finnish NCP has a record of all cases received, with links to initial assessments and final statements that included the details listed.
Source
NCP website: https://tem.fi/en/specific-instances-in-finland
NCP prevents or addresses potential or perceived conflicts of interest of any person playing a role for the NCP in the complaint and/or has a commitment to do so in its case-handling procedures.
Evaluation
The Finnish NCP states that "if a member has a conflict of interest, they must recuse themself and cannot participate in the processing of the complaint".
NCP recommends consequences from its government for companies that engage in bad faith in the proceedings or fail to implement agreements reached, and/or has a commitment to do so in its case-handling procedures.
Evaluation
The Finnish NCP does not recommend consequences from its government.
NCP clarifies how it will engage with other NCPs in relation to the handling of complaints, including explaining when complaints may be jointly handled or transferred to other NCPs.
Evaluation
The Finnish NCP states that if complaints concern multiple NCPs, it will inform and coordinate with those NCPs to select the lead and supporting NCPs.
NCP makes determinations in its final statements when no agreement is reached explaining how the company has (not) observed specific provisions of the Guidelines, and/or has a commitment to do so in its case-handling procedures.
Evaluation
The Finnish NCP states that "when the parties cannot reach an agreement or when a party is unwilling to participate in the proceedings" the NCP will publish a final statement that "should contain the view of the NCP as to whether or not, in the light of the evidence presented, the company acted in breach of the Guidelines". The NCP has made determinations in practice.
Source
Case-handling procedures, page 5: https://tem.fi/documents/1410877/0/EN+Menettelytapakuvaus+OECD-valitusten+kasittelyst%C3%A4_1.3..pdf/2eb961fb-a9c0-b263-1dea-7b7d6b327ef8/EN+Menettelytapakuvaus+OECD-valitusten+kasittelyst%C3%A4_1.3..pdf?t=1715072072868
Several individuals vs. Nokia: https://www.oecdwatch.org/complaint/several-individuals-vs-nokia/
NCP ensures a low threshold to assess whether the issue is material and substantiated and/or has a commitment to do so in its case-handling procedures.
Evaluation
The Finnish NCP states that it will consider the issue material if it is relevant to the implementation of the Guidelines and substantiated if it is supported by sufficient and credible information.
NCP ensures it has access to and, where relevant, uses investigative resources and broad external subject-matter expertise to support its complaint handling functions, and/or has a commitment to do so in its case-handling procedures.
Evaluation
The Finnish NCP states that "during examination of a complaint, the NCP may, if necessary, seek the advice of relevant authorities and consult external experts". In addition, it states that if necessary it will consult with other NCPs and "seek information on similar complaints from the OECD Secretariat or guidance from the Working Party on Responsible Business Conduct (WPRBC) if it has doubt about the interpretation of the Guidelines".
NCP always engages in follow-up and publishes follow-up statements where relevant, and/or has a commitment to do so in its case-handling procedures.
Evaluation
The Finnish NCP states that it "will carry out follow up on agreements it facilitates or recommendations it makes where relevant". However, the NCP has not published any follow-up statements for recent complaints.
Source
Case-handling procedures, page 5: https://tem.fi/documents/1410877/0/EN+Menettelytapakuvaus+OECD-valitusten+kasittelyst%C3%A4_1.3..pdf/2eb961fb-a9c0-b263-1dea-7b7d6b327ef8/EN+Menettelytapakuvaus+OECD-valitusten+kasittelyst%C3%A4_1.3..pdf?t=1715072072868
Complaints database: https://tem.fi/en/specific-instances-in-finland
NCP plays a guiding role in mediation, ensuring agreements reached further the implementation of the Guidelines and address past harms.
Evaluation
The Finnish NCP states that the NCP "should explain the provisions of the Guidelines relevant to the issues raised as a way to support parties in reaching an agreement compatible with the Guidelines. The goal is a commitment by the company to further the implementation of the Guidelines in the future and, where relevant, address, in accordance with the Guidelines, adverse impacts that may have occurred".
NCP accepts complaints in national language(s) and English and covers the cost of translation of key filings and statements and interpretation during mediation, and/or has a commitment to do so in its case-handling procedures.
Evaluation
The Finnish NCP will accept complaints in Finnish, Swedish, or English. However, its case-handling procedures do not state that it covers the cost of translation and interpretation.
NCP holds mediation in the most accessible manner for complainants and/or has a commitment to do so in its case-handling procedures.
Evaluation
The Finnish NCP states that "if necessary, the NCP may use videoconferencing ad Finnish mission networks to organise hearings with the parties, but the NCP will not reimburse any travel expenses".
NCP works to accept complaints despite parallel proceedings and/or has a commitment to do so in its case-handling procedures.
Evaluation
The Finnish NCP accepts complaints despite parallel proceedings. The NCP assesses the extent to which parallel proceedings may limit the NCP's ability to contribute to the resolution of the issues and/or the implementation of the Guidelines, and refers to Paragraph 35 of the OECD Implementation Procedures, which addresses parallel proceedings and outlines the specified details.
NCP provides an external review process for parties to pursue if they believe the NCP has not followed its internal procedures.
Evaluation
The Finnish NCP does not provide an external review process.
NCP consults parties on and publishes a final statement that includes the basic information required after the case reaches that stage, and/or has a commitment to do so in its case-handling procedures.
Evaluation
The Finnish NCP states that "at the end of the examination process, the NCP will publish a final statement" and explains the information that should be included in the statement in line with the Implementation Procedures of the Guidelines.
NCP website shows the initial assessment for every complaint received which is published after the initial assessment stage is concluded, and/or has a commitment to do so in its case-handling procedures.
Evaluation
The Finnish NCP publishes an initial assessment on its website for every complaint received.
Source
Procedure for submitting and processing complaints regarding the OECD Guidelines (March 2024), Initial assessment – Page 4: https://tem.fi/documents/1410877/0/EN+Menettelytapakuvaus+OECD-valitusten+kasittelyst%C3%A4_1.3..pdf/2eb961fb-a9c0-b263-1dea-7b7d6b327ef8/EN+Menettelytapakuvaus+OECD-valitusten+kasittelyst%C3%A4_1.3..pdf?t=1715072072868
NCP makes recommendations in its final statements on specific company action needed to support remediation of past harm and/or observe the Guidelines in future, and/or the NCP has a commitment to do so in its case-handling procedures.
Evaluation
The Finnish NCP states that it "may make recommendations on the implementation of the Guidelines, even if there is agreement or partial agreement between the parties". The NCP may also make recommendations when one party refuses to engage in mediation.
NCP proclaims zero tolerance for reprisals against the NCP and implements measures to respond to (risks of) reprisals, and/or has a commitment to do so in its case-handling procedures.
Evaluation
The Finnish NCP does not assert zero tolerance for reprisals against the NCP or explain measures it will take to respond to (risks of) reprisals.
NCP proclaims zero tolerance for reprisals against complainants and assesses and implements measures to prevent and respond to (risks of) reprisals, and/or has a commitment to do so in its case-handling procedures.
Evaluation
The Finnish NCP does not have a zero-tolerance policy for reprisals against complainants and does not set out any actions to assess, prevent, or respond to the risks of reprisals. The NCP refers to paragraph 9 in the Implementation Procedures of the OECD Guidelines (page 61), but does not explain how the NCP intends to implement this in practice.
NCP supports transparency between the parties in the complaint process generally, including by the sharing of all relevant facts and arguments brought forward by each party during the proceedings with other parties, requiring confidentiality only over the personal identities of parties for security/privacy reasons or legitimately sensitive business information, and/or has a commitment to do so in its case-handling procedures.
Evaluation
The Finnish NCP states that it "will act with transparency and make the parties to the complaint aware of all relevant facts and arguments brought to the NCP by other parties". In addition, it should "wherever possible, avoid basing fundamental aspects of its decisions on information that is not available to both parties".
NCP supports transparency during the complaint process by allowing complainants to publish their own complaint and communicate about the stages of the process. The NCP requires confidentiality only over the personal identities of parties for security/privacy reasons, legitimately sensitive business information, and documents shared and discussions had during the mediation stage, and/or has a commitment to do so in its case-handling procedures.
Evaluation
The Finnish NCP states that it should act in a transparent manner, but allows for confidentiality over sensitive business information and "other confidential information". It states that "the parties and the NCP may, however, communicate publicly and to third parties on the existence of the complaint, except where otherwise agreed between the parties and the NCP" and "the parties may communicate publicly about the stage of the process...and publish their own initial submission".
NCP has a dedicated detailed budget that is published on its website.
Evaluation
The Finnish NCP does not have a dedicated budget.
Source
Annual Report 2023, question 12
NCP has an independent expert structure whereby complaints are handled strictly by non-governmental independent experts.
Evaluation
The Finnish NCP does not have an independent expert structure; it has a multipartite structure.
Source
Annual Report 2023, question 1
NCP is not housed within a ministry focused on economics, trade, or investment to limit risk of real or perceived conflict of interest.
Evaluation
The Finnish NCP is housed within the Ministry of Economic Affairs and Employment together with the Committee on Corporate Social Responsibility.
Source
NCP Website: https://tem.fi/en/questions-and-answers-about-the-oecd-national-contact-points
Annual Report 2023, question 2
NCP is led or overseen by senior officials that are actively engaged with the NCP’s work.
Evaluation
The Chair of the Finnish NCP is the Director-General of the Employment and Well-Functioning Markets department of the Ministry of Economic Affairs and Employment.
Source
Annual Report 2023, question 2
NCP employs two or more full-time staff that hold permanent (non-rotating and not short-term) positions.
Evaluation
The Finnish NCP does not have any full-time staff. It has 2 part-time staff that each spend approximately 20% of their time on the NCP, and who both hold permananent positions.
Source
Annual Report 2023, question 8 – 9
NCP has a multi-stakeholder advisory body involving all three core stakeholder groups (NGOs, labour unions/workers organisations, businesses). The advisory body is meaningfully consulted by the NCP on its promotional and complaint-handling activities at least 2 times a year.
Evaluation
The Finnish NCP does not have an advisory body.
Source
Annual Report 2023, question 6
NCP structure ensures all three core stakeholder groups (NGOs, labour unions/workers organisations, businesses) at minimum advise on individual complaints.
Evaluation
The Finnish NCP appoints in each case "a subcommittee consisting of members and/or deputy members of the [Committee on Corporate Social Responsibility] to process the complaint. The subcommittee typically consists of a representative from employer organisations, a representative from employee unions, a representative from civil society, and representatives from different Ministries". The subcommittee is responsible for the initial assessment, mediation, and further examination. The CSR committee will "prepare its view for a final statement" and the Ministry of Economic Affairs and Employment "makes the final decision on the matter after receiving the Committee's view".
NCP has a website that shows:
- Contact information for the NCP;
- Links to the Guidelines and translations of the Guidelines in national language(s) and English;
- Links to the OECD Due Diligence Guidance documents;
- A comprehensive description of the Guidelines, due diligence, and the dual mandate of the NCP in national language(s) and English; and
- The NCP’s most recent annual report to the OECD.
Evaluation
The Finnish NCP has a website that includes contact information, links to the Guidelines in both Finnish and English, links to the OECD Due Diligence guidance documents, and a description of the Guidelines and NCP in both Finnish and English. The NCP has not published its 2023 Annual Report on its website.
Source
NCP website: https://tem.fi/en/social-responsibility
NCP annually promotes the Guidelines and due diligence guidance to civil society.
Evaluation
The Finnish NCP has not (co-)organised nor participated in any promotional events or materials specifically targeted towards civil society.
Source
Annual report 2023, question 26 & Annex, Table 1 & 2
NCPs annually promotes the Guidelines and due diligence guidance to its government.
Evaluation
The Finnish NCP promotes the Guidelines through relevant government representatives that are part of its CSR committee. However, the NCP has not proactively promoted the Guidelines to its government beyond this.
Source
Annual Report 2023, question 49 – 50 & Annex, Table 1 & 2
NCP supports its government in developing, implementing, and fostering policies, programmes, and/or laws on responsible business conduct that are coherent with the Guidelines.
Evaluation
The Finnish NCP has supported its government through its involvement in drafting EU legislation on due diligence, including the EU CSDDD and Forced Labour Ban, by attending quarterly meetings on topic.
Source
Annual report 2023; questions 51 – 59