Decision

Initial assessment: a complaint about McDonald’s Restaurants Limited by a group of trade unions and a Civil Society Organisation

Published 7 January 2026

1. The UK National Contact Point’s (‘NCP’) initial assessment process is a decision on whether the issues raised in the complaint merit further examination. It does not determine whether the respondent has acted consistently with the 2023 Organisation for Economic Co-operation and Development (OECD) Guidelines for Multinational Enterprises on Responsible Business Conduct (‘the guidelines’).

2. The OECD Guidelines Commentary on the Implementation Procedures^{[footnote 1]} states that generally issues are dealt with by the NCP of the country in which the issues have arisen. In this instance, the UK NCP will deal with this complaint, as the respondent is operating in the UK as a wholly owned market of the McDonald’s Corporation.

Summary of the UK NCP decision

3. The complaint has been brought to the UK National Contact Point (NCP) against ‘McDonald’s UK’ (a division of the United States-based multinational enterprise McDonald’s Corporation) in relation to alleged ongoing issues of gender-based violence and harassment in McDonald’s stores in the UK. The complaint is brought jointly by a group of 5 Trade Unions representing workers in a variety of workplaces including fast-food restaurants and one civil society organisation which promotes corporate accountability (collectively referred to as ‘the complainants’). The complaint alleges that McDonald’s UK has not observed the guidelines by failing to appropriately address issues of gender-based violence and harassment (GBVH) in their UK restaurants and franchises.

4. McDonald’s Restaurants Limited (‘MRL’) have confirmed that they are providing the response to the complaint and as such are considered the respondents to the complaint. MRL have clarified in their response, the relationship between MRL, franchises in the UK and the McDonald’s Corporation. The respondents state that “MRL is a wholly owned market of US-based multinational enterprise McDonald’s Corporation operating in the UK” and that “franchisees in the UK are the owners of their restaurant(s) and make all employment decisions in their businesses, consistent with applicable local law and McDonald’s standards”. MRL raised concerns that due to its corporate structure, the issues raised regarding its franchises cannot be included in the UK NCP complaint process as the franchises are not listed as a party to the complaint. MRL states that it is therefore unable to respond on behalf of franchises which are independent businesses operating under the McDonald’s brand and which are the employers of individuals working in their restaurants. The UK NCP notes that the allegations raised by the complainants include issues in McDonald restaurant locations including its owned restaurants, and franchises operating in the UK. The UK NCP further recognises that the guidelines provide that multinational enterprises could be linked to adverse impacts in a number of circumstances including where a multinational enterprise’s operations, products or services are linked by a business relationship.

5. The complaint alleges breaches of provisions under Chapter IV (Human Rights) and Chapter V (Employment and Industrial Relations) of the OECD guidelines in relation to issues of GBVH across the respondent’s UK restaurants (see full provisions in Annex B).

6. After conducting an initial assessment of the complaint, the UK NCP has decided that this complaint merits further consideration under the following paragraphs of the OECD guidelines:

• Chapter II, paragraph 11 – ‘General Policies’
• Chapter II, paragraph 12 – ‘General Policies’
• Chapter II, paragraph 15 – ‘General Policies’
• Chapter IV, paragraph 1, – ‘Human Rights’
• Chapter IV, paragraph 2 – ‘Human Rights’
• Chapter IV, paragraph 3 – ‘Human Rights’
• Chapter IV, paragraph 5 – ‘Human Rights’
• Chapter IV, paragraph 6 – ‘Human Rights’
• Chapter V, paragraph 1 (e) – ‘Employment and Industrial Relations’
• Chapter V, paragraph 1 (f) – ‘Employment and Industrial Relations’
• Chapter V, paragraph 3 – ‘Employment and Industrial Relations’
• Chapter V, paragraph 4 (c) – ‘Employment and Industrial Relations’
• Chapter V, paragraph 8 – ‘Employment and Industrial Relations’

7. The initial assessment decision was made on the basis of information provided by both parties.

8. Pursuant to Section 4 of the UK NCP’s Procedures for Dealing with Complaints^{[footnote 2]}, the UK NCP will now offer mediation to both parties. The scope of the mediation offer will cover only the 13 paragraphs of the OECD guidelines accepted by the UK NCP at the initial assessment stage.

9. The decision to accept the complaint for further examination is not a finding against MRL and does not mean that the UK NCP considers that MRL has acted inconsistently with the OECD guidelines.

Substance of the complaint

10. The complaint was raised on 28 February 2024. The complaint alleges that McDonald’s UK has failed to comply with the following provisions of the guidelines (See Annex B) in relation to ongoing issues of GBVH across their restaurants:

• Chapter IV (Human Rights) paragraphs 1, 2, 3, 5 and 6
• Chapter V (Employment and Industrial Relations) paragraphs 1.e, 1.f, 3, 4.c and 8

11. To support their argument, the complaint also alleges that McDonald’s UK is not compliant with the following sections of the OECD Due Diligence Guidance for Responsible Business Conduct (2018):

• Sections 1.1 to 1.3: Embed responsible business conduct into policies and management systems
• Sections 2.1 to 2.4: Identify and assess actual and potential adverse impacts
• Sections 3.1 to 3.2: Cease, prevent and mitigate adverse impacts

12. The complainants state that their complaint to the UK NCP was prompted by a July 2023 BBC report of widespread sexual harassment in the respondent’s restaurants in the UK, including specific allegations of abuse experienced by employees in McDonald’s UK stores^{[footnote 3]}. This report followed MRL having signed a legal agreement with the Equality and Human Rights Commission (EHRC)^{[footnote 4]} in February 2023, in response to concerns about the handling of sexual harassment complaints made by “staff in its UK restaurants”. The complainants allege that there is further evidence of persistent, deeply rooted gender-based discrimination in the respondent’s restaurants, in violation of the OECD guidelines.

13. The complainants state that they are seeking assistance from the NCP in offering a mediation process that will engage McDonald’s top management in the UK. The complainants also state that the goal of this mediation is to develop agreed practices to address GBVH in conformity with the OECD guidelines, which could serve as a global model of practices and procedures that McDonald’s headquarters management in the US could adopt and extend to the company’s worldwide operations.

14. The complainants state that the key subjects they wish to discuss in mediation include training, grievance mechanisms, tracking implementation, and assessing results, and that they hope to reach an agreement with MRL on “a wide-ranging, bottom-up program of stakeholder engagement that can put a stop to GBVH at McDonald’s UK”.

15. MRL accepted an invitation from the UK NCP to respond to the complaint.

16. MRL pointed to a number of reasons why they believe the complaint should not be accepted including:

• the application of the OECD guidelines: MRL claim that the issues raised in the complaint concern UK domestic matters rather than multi-national cross-border issues
• parallel proceedings: MRL states that it is subject to parallel legal proceedings in the UK that include claims relating to GBVH – successful mediation requires parties to be fully open with one another and MRL cannot comment on the details of parallel proceedings, which precludes meaningful mediation
• actions taken: MRL states that it is exercising the appropriate human rights due diligence in accordance with the guidelines and have already undertaken steps to respond to concerns of GBVH in their restaurants – this includes working with the EHRC to deliver on a robust action plan on GBVH

17. A timeline and details of the UK NCP handling process can be found in Annex A.

UK NCP decision

18. The UK NCP has decided that the 10 paragraphs under the 2 Chapters cited in the complaint merit further examination. The UK NCP’s decision to accept these 10 paragraphs does not mean that it considers MRL to have acted inconsistently with the OECD guidelines.

19. The UK NCP considers the sections of the OECD Due Diligence Guidance which the complainants cite (see paragraph 10) to be relevant to the complaint. However, as the OECD Due Diligence Guidance is intended to supplement the OECD guidelines, the UK NCP also considers paragraph 11,12 and 15 of the OECD guidelines General Policies Chapter to be relevant to the complaint and has accepted these additional paragraphs as part of the complaint.

20. The UK NCP therefore considers that 13 paragraphs of the OECD guidelines (outlined in Annex B) merit further consideration.

21. The UK NCP considers that a further examination is required to establish if the processes and procedures that MRL has in place to tackle issue of GBHV are effective and in line with the OECD guidelines. If they are not, the UK NCP considers that accepting this complaint would contribute to the effectiveness of the OECD guidelines, in ensuring more robust MRL policies and processes are in place. This in turn could act as a positive role model for the wider policies and processes of the McDonald’s Corporation.

22. The UK NCP considers that 2 of the key topics that the complainants have flagged for discussion in a potential mediation – that is, grievance mechanisms and stakeholder engagement (particularly in relation to the reported victims) – are areas where a further examination could be helpful to clarify MRL policies and processes. This is especially important given that these issues cut across the paragraphs of the OECD guidelines in the complaint and because research shows that the victims of GBVH can often remain silent. It is currently unclear what steps have been taken by MRL to identify potential victims and ensure that their views are incorporated into policies and processes to tackle GBVH.

23. Furthermore, the UK NCP considers the issue of remediation for the alleged victims of GBVH by MRLs to be unclear throughout the complaint and the response. Given that remediation cuts across most of the paragraphs of the OECD guidelines related to the complaint, the UK NCP considers that further examination of the issues could be beneficial and contribute to the purpose and effectiveness of the OECD guidelines.

24. Overall, the UK NCP considers that accepting this complaint would contribute to the effectiveness of the OECD guidelines, as offering good offices could facilitate an exchange of dialogue between the parties.

25. In reaching the decision on whether the complaint merits further examination, the UK NCP has considered the criteria set out in the OECD guidelines as follows:

• identity of the party concerned and its interest in the matter
• whether the issue is material and substantiated
• whether the enterprise is covered by the guidelines
• whether there seems to be a link between the enterprise’s activities and the issue raised in the specific instance
• the extent to which applicable law and/or parallel proceedings limit the NCP’s ability to contribute to the resolution of the issue and/or the implementation of the guidelines
• whether the examination of the issue would contribute to the purpose and effectiveness of the guidelines

Identity of the party concerned and their interest in the matter

26. The OECD guidelines for NCPs on the Initial Assessment of Specific Instances states that the complainant (or complainants) should have some interest in the matters they raise in their submissions: “organisations with mandates or objectives related to certain Responsible Business Conduct-related themes may also have an interest in issues touching on those themes (for example, instances of environmental harm, forced labour, and so on). An NCP may consider the mandate of an organisation as well as its stated objectives, while considering the legitimacy of its interests in the matter”^{[footnote 5]}.

27. The complaint was filed by:

• Bakers, Food and Allied Workers Union (BFAWU)
• Corporate Justice Coalition (CJC)
• International Union of Food, Agricultural, Hotel, Restaurant, Catering, Tobacco and Allied Workers’ Associations Global Union (IUF)
• European Federation of Food, Agriculture and Tourism Trade Unions (EFFAT-IUF)
• Service Employees International Union (SEIU)
• Trades Union Congress (the complainant) (TCU)

28. The Bakers, Food and Allied Workers Union (BFAWU) states that it is the largest independent trade union in the UK food sector, representing employees in the food sector from production at factories through to sales at shops as well as maintenance engineers, hygiene operatives, canteen staff and more.

29. The Corporate Justice Coalition (CJC) states that it is the UK’s longstanding corporate accountability network, made up of 67 partner organisations spanning civil society, trade unions and law firms. The coalition spans organisations working on human rights, global poverty, trade, tax, workers’ rights, women’s rights and the environment.

30. The International Union of Food, Agricultural, Hotel, Restaurant, Catering, Tobacco and Allied Workers’ Associations (IUF) states that it is the global union for food, farm, hospitality and other sectors. IUF affiliates represent more than 10 million workers in 124 countries.

31. The European Federation of Food, Agriculture and Tourism Trade Unions (EFFAT-IUF) states that it is the European regional organization of the IUF that brings together 120 national trade unions in those sectors throughout Europe, including the fast-food industry.

32. The Service Employees International Union (SEIU) states that it is a US-based trade union representing more than 2 million workers in the US, Canada and Puerto Rico in multiple public and private sector workplaces.

33. The Trades Union Congress (TUC) states that it is the national federation of 48 affiliated unions in the UK representing more than 5.5 million working people.

34. The UK NCP is satisfied that the complainants have a legitimate interest in the issues raised as they have mandates and objectives relevant to the issues raised in the complaint.

Whether the issue is material and substantiated

35. The UK NCP considers that the issues raised regarding GBVH in McDonalds restaurants in the UK are relevant to the implementation of the OECD guidelines. The relevant paragraphs of the guidelines are set out in paragraph 6 of this initial assessment.

36. The information provided by the complainants in support of the complaint focuses on a 2023 BBC News report that includes allegations of abuse, including sexual assault, harassment, racism and bullying from current and former employees at McDonalds restaurants in the UK^{[footnote 6]}. The complainants note that the BBC began investigating working conditions in McDonald’s restaurants in the UK shortly after MRL signed a legally binding agreement with the EHRC in which it pledged to protect its staff from sexual harassment.

37. The BBC report describes a “toxic culture of sexual assault, harassment, racism and bullying” across McDonald’s restaurants in the UK. The complainants provide examples of the alleged harms identified in the report, detailing the age and gender of the reported victims as well as the GBVH allegations. The BBC reports that many of the complaints were from teenagers. The complaint states that the BBC report prompted further reports of GBVH from workers in McDonald’s restaurants around the UK and lists examples of these that were published in a follow-up BBC report.

36. The complainants claim that issues around GBVH in McDonald’s restaurants in the UK are not a new phenomenon and reference the alleged results of a 2019 survey by BFAWU (one of the parties to the complaint) of McDonald’s UK employees which also included claims of GBVH affecting various staff members.

37. In its response to the UK NCP, MRL stated that it “takes all concerns relating to staff wellbeing seriously and considers this issue to be a top priority. MRL stated that it does not accept the allegations raised in the BBC report […]” and that it has a zero-tolerance approach to GBVH and has been working to put in place policies and procedures to implement this since before the report. This includes ‘Speak Up’ channels for employees to report concerns, refreshed ‘Safe, Respectful and Inclusive Workplace’ policies and a McDonalds Global Brand Standard on the prevention of harassment, discrimination, and retaliation. They also reference McDonald’s Human Rights Policy and the voluntary agreement that MRL signed with the EHRC.

38. MRL states that following the BBC report, it moved quickly to establish new procedures to ensure that allegations of GBVH are fully investigated and have made several commitments to review and strengthen their processes. They point to an extensive action plan of training on GBVH new policies on Employee Safeguarding and Customer Safeguarding and employee surveys that are in progress. MRL also appointed a new Culture Team to help accelerate progress and have established an internal working group to assess and review the ‘Speak Up’ channels to ensure they are fit for purpose.

39. However, the complainants argue that the persistence of GBVH in McDonald’s restaurants in the UK since 2019 highlights failures in MRL’s policies and processes and flag the need for “systematic engagement with workers who suffer GBVH, and with trade unions and other organisations to whom workers have turned for help”. They also express concerns that MRL takes a top-down approach to training on GBVH and has not taken sufficient steps to involve ground-level staff.

40. While the UK NCP acknowledges that MRL has put in place new policies and processes in relation to GBVH following the allegations referenced in the complaint, the UK NCP considers that it would be beneficial to assess their effectiveness in line with the OECD guidelines to potentially strengthen them further.

41. While the initial assessment does not involve any factual findings or determination on the merits of the allegations, the UK NCP views the issues raised as material and substantiated sufficiently for the purposes of its initial assessment.

42. Within the scope of the initial assessment, the complainants have provided sufficient information for the UK NCP to conclude that the issues identified merit further examination.

Whether the enterprise is covered by the guidelines

43. In considering whether MRL operating in the UK is an enterprise covered by the guidelines, the UK NCP notes that the OECD guidelines allow for ‘a broad approach’ in identifying which entities may be considered a multinational enterprise and that “the international nature of an enterprise’s structure or activities and its commercial form, purpose, or activities are main factors to consider in this regard.”^{[footnote 7]}

44. The UK NCP notes the respondent’s reference to complaints handled by other NCPs on the issue of whether organisations are deemed a multinational enterprise. Statements by other NCPs do not form binding precedent, and the UK NCP reaches its own independent conclusions on each specific complaint. What constitutes a multinational enterprise for the purposes of the guidelines must be considered on a case-by-case basis.

45. The complainants state that their complaint is against McDonald’s UK. Throughout the complaint, the complainants refer more broadly to the allegations regarding McDonald’s UK staff and workers across UK stores. It describes McDonald’s UK as a “division of the US-based multinational enterprise McDonald’s Corporation” with more than 1,000 restaurants in the UK and employment of more than 175,000 workers.

46. In their response to the UK NCP, MRL explain that McDonald Corporation’s global structure includes 3 key businesses units: the US, International Operated Markets and International Developmental Licensee Markets. MRL describes its operation in the UK as an International Operated Market, also known as a ‘wholly owned market’. It states that 11% of the UK and Ireland market is owned and operated centrally by MRL, while 89% of the market is franchised, meaning that they are independent businesses operating under the McDonald’s brand. With regard to franchises, MRL further notes that franchisees in the UK are the owner of their restaurant(s) and make all employment decisions in their businesses. MRL however states that franchises’ operations are subject to McDonald’s standards including both MRL’s National Franchising Standards, McDonald’s Corporation’s standards and Global Brand Standards.

47. MRL does not explicitly dispute that it is not a multinational enterprise for the purposes of the guidelines, however MRL argues that “this matter does not implicate OECD guidelines: rather, it is a domestic matter that does not relate to multinational cross border concerns”. It calls on the UK NCP to reject the complaint on the basis that the issues are purely domestic.

48. The UK NCP notes that the guidelines are clear that some matters covered by the guidelines may also be regulated by national law or international commitments, and this is not a bar to bringing complaints under the guidelines. As noted in the guidelines, “the Guidelines are addressed to all the entities within the multinational enterprise (parent companies and/or local entities)”.^{[footnote 8]} It also notes that enterprises “usually comprise of companies or other entities established in more than one country and so linked that they may co-ordinate their operations in various ways. While one or more of these entities may be able to exercise a significant influence over the activities of other entities in a group, their degree of autonomy within the group may vary widely from one multinational enterprise to another.”^{[footnote 9]}

49. In accepting the complaint for further examination, the UK NCP confirms that it considers MRL (including through its ownership of restaurants and business relationship with its franchises), to meet the criteria of a multinational enterprise for the purposes of the OECD guidelines. The NCP notes that different corporate governance structures can be considered to have an international dimension, for example the existence of international branches or being a local franchise of a multinational enterprise. MRL’s response to the UK NCP describes activities conducted in accordance with and under direction of the McDonald’s Corporation’s Global Standards, including reporting actions related to GBVH, as well as adherence to McDonald Corporation’s Human Rights Policy. The UK NCP finds that there is an international dimension to MRL’s operation as a wholly owned market of the McDonald’s Corporation. Any due diligence carried out in MRL restaurants could influence the wider McDonald’s Corporation and supply chains.

Whether there seems to be a link between the enterprise’s activities and the issue raised in the specific instance

50. The issues raised in the complaint are related to alleged harms experienced by current and former employees of MRL restaurants and franchises across the UK.

51. The complainants claim that these harms occurred as a result of MRL allowing a culture of deeply rooted GBVH to persist in McDonald’s UK stores. They also claim that a failure to properly handle complaints and the inadequate provision of training has allowed the exploitation of its young workforce.

52. In its response to the UK NCP, MRL stated that its operations are distinct from those of the franchises operating in the UK and that only issues related to “MRL” owned restaurants should be considered as part of the complaint. MRL further stated that within the scope of the UK NCP complaint it is unable to respond on behalf of the franchises given that they are independent businesses operating under the McDonald’s brand. The UK NCP notes that in their response MRL set out the steps they take “to monitor and support franchisees in complying with standards”. This includes Business Reviews, Operations Performance and Customer Excellence (PACE) process and network of Franchisee Consultants. The UK NCP considers that the information provided by MRL seems to indicate a possible link between MRL’s activities, including in respect of franchises operating in the UK, and the issues raised in the complaint. This link is sufficient to warrant further examination.

53. The UK NCP recognises that the OECD guidelines state that businesses should “seek to prevent or mitigate an adverse impact where they have not contributed to that impact, when the impact is nevertheless directly linked to their operations, products or services by a business relationship” and “encourage, where practicable, entities with which an enterprise has a business relationship to apply principles of responsible business conduct compatible with the guidelines”.^{[footnote 10]} Furthermore, the OECD Due Diligence Guidance provides that business relationships covered by due diligence can include business relationships with “franchisees […] linked to its business operations, products or services”.^{[footnote 11]}

The extent to which applicable law and/or parallel proceedings limit the NCP’s ability to contribute to the resolution of the issue and/or the implementation of the OECD guidelines

54. In their response to the UK NCP, MRL state that following the BBC report it has been subject to inquiry and litigation in relation to the issues raised in the complaint. This includes:

• a Select Committee in the UK Parliament questioning MRL
• a UK law firm has brought claims against MRL in the UK’s Employment Tribunals
• working with the EHRC on the issues raised in the complaint

55. In their response to the UK NCP, MRL express concerns that the UK NCP accepting the complaint could potentially trigger “serious adverse consequences” to the ongoing domestic proceedings by causing unfair prejudice to MRL defences. MRL states that any statement from the UK NCP may be open to misinterpretation and raise concerns around the potential for mediation to cause confusion to the other parallel proceedings and undermine UK domestic law. MRL further state that they would be unable to discuss ongoing legal proceedings in any mediation.

56. The OECD guidelines state that “if parallel proceedings have been conducted, are under way or are available to the parties concerned, this does not preclude the NCP from offering good offices to the parties. NCPs should evaluate whether an offer of good offices could make a positive contribution to the resolution of the issues raised and/or the implementation of the guidelines going forward and would not create serious prejudice for either of the parties involved in these other proceedings or cause a contempt of court situation.”^{[footnote 12]}

57. The UK NCP notes the potential existence of parallel proceedings. However, in line with its procedures^{[footnote 13]}, the UK NCP can accept a complaint when appropriate, in instances where there are parallel legal proceedings underway. Following the publication of an initial assessment, a party to a complaint can then request a suspension on the grounds that continuation of the process may cause serious prejudice to parallel proceedings. The UK NCP will only consider a request for a suspension once a complaint has been accepted for consideration and has become a Specific Instance. The UK NCP has shared the parallel proceedings guidance with MRL and will treat any application by MRL to suspend proceedings following the publication of the initial assessment in accordance with the UK NCP’s procedures.

Whether the examination of the issue would contribute to the purpose and effectiveness of the OECD guidelines

58. The UK NCP’s process seeks to provide, through independent mediation, a forum for discussion with a view to resolving the specific issues raised.

59. MRL raised concerns that any good offices offered by the UK NCP will not facilitate a resolution to the issues raised by the complainants. They argue that MRL will be unable to participate in mediation in a meaningful way as they cannot discuss issues that are the subject of ongoing parallel proceedings – either with the complainants directly or with any third party. The UK NCP met with MRL to discuss these parallel proceedings and McDonald’s concerns around the sharing of potentially prejudicial information directly with the complainants. The UK NCP stressed that the parties would have the opportunity to agree to the Terms of Reference of mediation which will cover confidentiality in detail.

60. The UK NCP notes that the complainants have a clear plan of what they want to discuss with MRL at mediation and that the topics they outlined for discussion are linked to the guidelines. The complainants are also clear that they hope any agreement made with MRL management during mediation to help address GBVH in MRL’s UK restaurants would serve as a global model for McDonald’s Corporation to adopt and influence positive change (in line with the guidelines) to the company’s global operations.

61. The UK NCP considers that accepting this complaint would contribute to the effectiveness of the OECD guidelines, as offering good offices could facilitate an exchange of dialogue between the parties on issues covered by the OECD guidelines.

Next steps

62. Pursuant to section 4 of the UK NCP Procedures for Dealing with Complaints, the UK NCP will offer mediation to both parties following the conclusion of the initial assessment.

63. The mediation offer is voluntary and if any party to the complaint declines mediation, the UK NCP will conduct a further rxamination of this complaint.

64. A further examination would include the UK NCP providing a determination on whether the company has acted consistently with the OECD guidelines. Should the UK NCP determine that the company has not adhered to the OECD guidelines, the UK NCP may provide non-binding recommendations for improving the company’s adherence to the OECD guidelines.

Annex A

Table 1: Timeline and details of the UK NCP handling process

Date	Action
28 February 2024	The UK NCP receives the complaint
24 April 2024	The UK NCP acknowledges receipt of the complaint by return of email to the complainants and informs them that the complaint has been passed to the respondent
24 April 2024	The UK NCP informs MRL of the complaint
29 April 2024	The UK NCP is contacted by MRL acknowledging receipt of the complaint
2 May 2024	The UK NCP spoke with representatives of the MRL to explain the complaint process
14 May 2024	The UK NCP spoke with representatives of the complainants to explain the complaint process.
31 May 2024	The UK NCP receives a letter from MRL in response to the complaint
7 June 2024	The UK NCP shares MRL’s response with the complainants
2 August 2024	The UK NCP held a further meeting with MRL to discuss the UK NCP process
13 January 2025	UK NCP drafts the initial assessment and shares both the initial assessment draft and the factual commentary grid with parties for comment
10 April 2025	Both parties submit factual commentary grid to UK NCP with their response
23 September 2025	UK NCP incorporates factual comments in the initial assessment
22 October 2025	UK NCP re-shares the draft initial assessment for further factual commentary
1 December 2025	UK NCP incorporates further factual comments into the initial assessment

Annex B

Table 2: Relevant chapters of the OECD guidelines in relation to the complaint

Relevant OECD guidelines chapter and paragraph	Chapter text extract
Chapter II: General Policies, paragraph 11	Carry out risk-based due diligence, for example by incorporating it into their enterprise risk management systems, to identify, prevent and mitigate actual and potential adverse impacts as described in paragraphs 12 and 13, and account for how these impacts are addressed. The nature and extent of due diligence depend on the circumstances of a particular situation.
Chapter II: General Policies, paragraph 12	Avoid causing or contributing to adverse impacts on matters covered by the guidelines, through their own activities, and address such impacts when they occur, including through providing for or co-operating in the remediation of adverse impacts.
Chapter II: General Policies, paragraph 15	Engage meaningfully with relevant stakeholders or their legitimate representatives as part of carrying out due diligence and in order to provide opportunities for their views to be taken into account with respect to activities that may significantly impact them related to matters covered by the guidelines.
Chapter IV: Human Rights, paragraph 1	Enterprises should respect human rights, which means they should avoid infringing on the human rights of others and should address adverse human rights impacts with which they are involved.
Chapter IV: Human Rights, paragraph 2	Within the context of their own activities, avoid causing or contributing to adverse human rights impacts and address such impacts when they occur.
Chapter IV: Human Rights, paragraph 3	Seek ways to prevent or mitigate adverse human rights impacts that are directly linked to their business operations, products or services by a business relationship, even if they do not contribute to those impacts.
Chapter IV: Human Rights, paragraph 5	Enterprises should carry out human rights due diligence as appropriate to their size, the nature and context of operations, and the severity of the risks of adverse human rights impacts.
Chapter IV: Human Rights, paragraph 6	Enterprises should provide for or co-operate through legitimate processes in the remediation of adverse human rights impacts where they identify that they have caused or contributed to these impacts.
Chapter V on Employment and Industrial Relations: Enterprises, paragraph 1e	Be guided throughout their operations by the principle of equality of opportunity and treatment in employment and not discriminate against their workers with respect to employment or occupation.
Chapter V on Employment and Industrial Relations: Enterprises, paragraph 1f	Provide a safe and healthy working environment in line with the International Labour Organization (ILO) Declaration on Fundamental Principles and Rights at Work.
Chapter V on Employment and Industrial Relations: Enterprises, paragraph 3	Promote consultation and co-operation between employers and workers and their representatives through legitimate processes, structures or mechanisms on matters of mutual concern.
Chapter V on Employment and Industrial Relations: Enterprises, paragraph 4c	Maintain the highest standards of safety and health at work.
Chapter V on Employment and Industrial Relations: Enterprises, paragraph 8	Allow the parties to consult on matters of mutual concern with representatives of management who are authorised to take decisions on these matters.

1. OECD, OECD Guidelines for Multinational Enterprises on Responsible Business Conduct: 2023, page 69, paragraph 30 ↩

2. UK NCP, UK national contact point procedures for dealing with complaints brought under the OECD guidelines for multinational enterprises: section 4, page 10 ↩

3. BBC News, McDonald’s workers speak out over sexual abuse claims, 18 July 2023. And BBC News, McDonald’s workers come forward with new abuse claims, 19 July 2023 ↩

4. EHRC, McDonald’s signs a legal agreement with EHRC to protect staff from sexual harassment, 8 February 2023 ↩

5. OECD, Guide for National Contact Points on the initial Assessment of Specific Instances, OECD Guidelines for Multinational Enterprises 2019: page 6 ↩

6. BBC News, McDonald’s workers speak out over sexual abuse claims, 18 July 2023. And BBC News, McDonald’s workers come forward with new abuse claims, 19 July 2023 ↩

7. OECD, OECD Guidelines for Multinational Enterprises on Responsible Business Conduct 2023: page 12 ↩

8. OECD, OECD Guidelines for Multinational Enterprises on Responsible Business Conduct 2023: page 12, paragraph 4 ↩

9. OECD, OECD Guidelines for Multinational Enterprises on Responsible Business Conduct 2023: page 12, paragraph 4 ↩

10. OECD, OECD Guidelines for Multinational Enterprises on Responsible Business Conduct 2023: page 15, paragraphs 13 and 14 ↩

11. OECD, Due Diligence Guidance for Responsible Business Conduct, 2018: page 10 ↩

12. OECD, OECD Guidelines for Multinational Enterprises on Responsible Business Conduct 2023: page 70, paragraph 25 ↩

13. UK NCP, UK NCP handling of parallel legal proceedings for complaints ↩