Decision

Initial assessment: a complaint against AngloGold Ashanti PLC raised by individuals from the Democratic Republic of Congo

Published 12 December 2025

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 Organisation for Economic Co-operation and Development (OECD) guidelines for multinational enterprises on responsible business conduct (the ‘guidelines’ or ‘OECD guidelines’).

2․ The OECD guidelines’ commentary on the implementation procedures in the 2011 OECD Guidelines for Multinational Enterprises on Responsible Business (page 82) states that generally issues are dealt with by the NCP of the country in which the issues have arisen. When an issue arises in a non-adhering country, the NCP of the country where the multinational enterprise is based can deal with the complaint.

3․ The guidelines set out the following criteria when considering whether the complaint merits further examination:

• identity of the party concerned and its interest in the matter
• whether the enterprise is covered by the guidelines
• whether the issue is material and substantiated
• 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

4․ The UK NCP is assessing the complaint on the basis of the 2011 OECD guidelines, as the alleged harm occurred prior to June 2023.

Summary of the UK NCP decision

5․ The complaint has been filed by John Namegabe Bugabo (‘the Complainant’) on behalf of the men, women and children (‘the affected communities’) from more than 2,360 households in the villages of Mege and Bandayi in the territory of Watsa, Haut-Uele, Democratic Republic of Congo (‘DRC’). According to the Complainant, they were impacted by the alleged actions of the Respondent.

6․ The allegations in the complaint concern the forced relocation of the affected communities and related harms that unfolded in events of 22 October 2021, including the lead up and aftermath of the event. The Respondent refers to incidents between 2010 to 2015 and 2021 in their response, detailed in the latter parts of the initial assessment.

7․ The complaint was filed with the UK NCP against AngloGold Ashanti Plc (‘the Respondent’). The alleged harm occurred near a gold mine (the ‘Mine’) in the northeast of DRC, operated by Kibali Goldmines SA (‘Kibali’). Kibali is a joint venture company incorporated under DRC law. It is owned by:

• the Respondent (45%)
• Barrick Gold Corporation (‘Barrick’) (45%)
• Société Minière de Kilo-Moto (‘SOKIMO’) (10%), a DRC state-owned gold mining company

The Respondent states that Barrick operates the Mine, and the Respondent does not manage the day-to-day operations of the Mine.

8․ The Complainant alleges that the Respondent breached paragraphs in chapter I ‘concepts and principles’, chapter II ‘general policies’, chapter IV ‘human rights’ and chapter XI ‘taxation’ of the OECD guidelines.

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

• chapter II, ‘general policies’, paragraph A(6)
• chapter II, ‘general policies’, paragraph A(7)
• chapter II, ‘general policies’, paragraph A(13)
• chapter II, ‘general policies’, paragraph A(14)
• chapter IV, ‘human rights’, paragraph 3
• chapter IV, ‘human rights’, paragraph 5

10․ The conclusions reached by the UK NCP in this initial assessment are based on all the information provided in English before the start of the initial assessment by the Parties to the complaint. The UK NCP was not able to consider any documents submitted in French.

11․ The UK NCP considers that a further examination is required to establish if the processes and procedures of due diligence were applied in a way which was consistent with the OECD guidelines in relation to the incidents of October 2021.

12․ Given the Respondent’s 45% share in the Mine, the UK NCP deems there is significant leverage the Respondent could have had over the Mine and its operating partners in Kibali.

13․ The UK NCP therefore considers that it would contribute to the purpose and effectiveness of the OECD guidelines for the UK NCP to consider the complaint further, as offering good offices could facilitate an exchange of dialogue between the Parties.

14․ Pursuant to section 4 of the UK NCP’s Procedures for Dealing with Complaints, the UK NCP will now offer mediation to both Parties. The scope of the mediation offer will cover only the 6 paragraphs of the OECD guidelines accepted by the UK NCP at the initial assessment stage.

15․ The decision to accept the complaint means that the UK NCP considers that there is enough information to warrant further examination of the issues raised with regard to the Respondent’s responsibilities under the guidelines. It does not mean that the NCP has concluded that the guidelines have been breached by the Respondent.

Substance of the complaint

16․ The complaint dated 5 February 2024 was formally received by the UK NCP on 22 November 2024 in short succession with the publication of the supporting PAX report. The Complainant alleged that the Respondent has failed to comply with the following provisions of the guidelines (see annex 2):

• chapter I ‘concepts and principles’, paragraphs 1, 2 and 4
• chapter II ‘general policies’, paragraphs A1, A2, A3, A5, A6, A7, A11, A12, A14, A15
• chapter IV ‘human rights’, paragraphs 1, 2, 3, 4, 5 and 6
• chapter XI ‘taxation’, paragraph 1

17․ The Complainant alleges that the Respondent, through its shareholder status in Kibali, is partially responsible for the forced eviction of the population of Mege and Bandayi villages on 22 October 2021. This eviction is said to have further resulted in:

• the destruction of residential and commercial properties, private property, fields, plants and crops
• the deaths of people allegedly shot by security agents working under orders of Kibali

The UK NCP notes the complex history of the events leading up to the events of October 2021, which the complaint contends continue to have repercussions on the affected communities.

18․ The Complainant argues that the Respondent has a responsibility to encourage Barrick as operator of the Mine to ensure that their activities comply with the guidelines. The Complainant contends that the Respondent has failed to comply with:

• not causing or contributing to negative impacts when displacing people from their natural living areas
• engaging with local communities in a meaningful way and integrating them into the planning of the mining site exploitation project

19․ The Complainant alleges that the Respondent and Barrick have artificially maintained their share capital at a low level in relation to the turnover of the Mine to maintain low tax liabilities and low retrocessions to local authority as a mining royalty and therefore are not contributing effectively to the public finance of the DRC.

20․ The Complainant seeks compensation for damages and reparation for the affected communities including the families of the “martyrs”, distributed among more than 1,500 households destroyed in Bandayi and more than 860 houses destroyed in Mege. The Complainant further requests that the Respondent take measures to prevent further similar incidents, these include:

• developing a policy articulating its commitment to respecting human rights
• exercising human rights due diligence commensurate with the nature and context of its activities
• establishing legitimate mechanism to address negative impacts on human rights in Bandayi and Mege

21․ A timeline and details of the UK NCP handling process can be found in annex 1.

Identity of the party concerned and their interest in the matter

22․ The OECD guide for NCPs on the initial assessment of specific instances states that the complainant(s) should have some interest in the matters they raise in their submissions. It states:

In instances where third party organisations are acting as representatives of individuals, or communities, it will be important to ensure that such representation has been requested or authorised by the relevant individuals or communities. Statements by relevant community members authorising such representation may be one way of assessing this.^{[footnote 1]}

23․ The Complainant states that he is a human rights defender in the DRC. He is representing by written request some members^{[footnote 2]} of the affected communities in the villages of Mege and Bandayi, DRC, who were impacted by the resettlements and events of October 2021. Although the NCP notes that the request for representation received from the Complainant relates only to some members of the community affected, the UK NCP considers that assessing the issues could be impactful to the community at large.

24․ The Respondent highlights that the Complainant filed 2 complaints in August 2022 relating to this matter. One against Barrick with the Canadian NCP and one against the Respondent with the UK NCP. The Canadian NCP accepted the case, while the case in the UK was withdrawn on the basis that the Respondent was not incorporated in the UK. The Canadian NCP understood that the Complainant worked on a “no win, no fee basis”, which entitled him to a share of compensation paid to his clients. After the Canadian NCP’s final statement was shared with the parties in February 2023, the new complaint was filed to the UK NCP.

25․ The UK NCP does not consider that the issues raised by the Respondent above disqualifies the veracity or seriousness of the information presented and alleged harms on the community. The UK NCP finds that the Complainant has established a legitimate interest in this matter and considers it pertinent to carry out the initial assessment.

Whether the enterprise is covered by the guidelines

26․ Although the OECD guidelines do not include a single definition of the term ‘multinational enterprise’, it reads:

[t]he international nature of an enterprise’s structure and its commercial form, purpose, or activities are main factors to consider in this regard.^{[footnote 3]}

27․ At the outset, it is worth noting that a complaint of a similar nature was filed to the UK NCP in 2022, in parallel to a case against Barrick filed to the Canadian NCP. At the time, the UK NCP did not find any significant link between AngloGold Ashanti and the UK as the company was not incorporated in the UK. Both the UK and Canadian NCPs consulted with the Complainant about this issue. In July 2022, the Complainant withdrew the complaint submitted to the UK NCP. In February 2023, after the Canadian’s NCP final statement was published, the new complaint was filed to the UK NCP.

28․ The Respondent completed its corporate restructuring on 25 September 2023 with a primary listing of its ordinary shares on the New York Stock Exchange (NYSE) and a corporate domicile in the UK.

29․ As stated above, Kibali is co-owned by the Respondent (45%), Barrick (45%) and SOKIMO (10%), a state-owned gold mining company. The consolidated lease is made up of 10 mining concessions. The Respondent states that Barrick operates the Mine, which comprises both open pit and underground operations, and that the Respondent does not manage the day-to-day operations of the Mine.

30․ The UK NCP considers the Respondent is a multinational enterprise, as it operates on diverse mining projects and portfolios over the world. The Respondent’s website highlights: “11 operations in Argentina, Australia, Brazil, the Democratic Republic of the Congo (DRC), Egypt, Ghana, Guinea and Tanzania” in 2024.^{[footnote 4]}

31․ In light of the above, the UK NCP finds that the Respondent is an enterprise covered by the guidelines. The UK NCP finds it to be appropriate to undertake an initial assessment of the February 2024 complaint.

Whether the issue is material and substantiated

32․ The Complainant asserts that the Respondent is directly linked to economic and human loss to the local community by destroying homes, peoples’ livelihoods, and in the shooting of live ammunition on protesters. The forced evictions allegedly led to the loss of personal valuable items and human stress and suffering.

33․ The Complainant also alleges that the Respondent and Barrick have exerted undue influence in local political activities, as they have a police force commanded by Kibali.

34․ The Complainant alleges that the Respondent failed to ensure that Kibali implemented the guidelines and argues that the Respondent should have adhered to the laws of DRC relating to relocation procedure with dignity. The Complainant states that Kibali failed to cooperate with the affected communities in the process of the relocation and did not provide prior compensation or a suitable site for relocation. The Complainant further claims that the forced eviction of the affected communities is not good corporate governance practice.

35․ The Complainant states that “no company can be taxed beyond its share capital” in the DRC and that the Respondent must comply with DRC laws relating to 10% taxation in the event of an increase in share capital. The Complainant does not explain how they have reached this conclusion or why they consider 45% to be an artificially maintained figure.

36․ The Respondent provides some helpful background to the case. It distinguishes between the following 3 events:

• The Kibali Implemented Resettlement (KIR), which took place in 2010 to 2015, allegedly in accordance with DRC law, international standards and the guidelines. The Respondent states that the KIR was a joint effort between Kibali and the DRC Government, there was significant stakeholder engagement, and legal residents were compensated and successfully relocated to a new area with improved structures and services. After this process, exclusion zones were created, demarcating the area as a prohibited zone, and a moratorium was implemented prohibiting new settlements on the designated exclusion zones to ensure human safety
• The DRC Government Implemented Resettlements (GIR), which took place in 2021 in relation to occupants who settled illegally in the exclusion zones after the KIR and which form the basis of the Complainant’s submission. The Respondent asserts that Kibali was not involved in this resettlement programme, and it was carried out under the responsibility of the DRC Government. The Respondent asserts that Kibali did exercise its leverage by raising the importance of human rights and humanitarian considerations with the DRC Government, offered to share its experiences from the KIR programme, met with DRC Government officials and emphasises the importance of maintaining good relations with the surrounding communities, respect for human rights and continued awareness campaigns. The Respondent states that the GIR was delayed by 5 months to allow for the appropriate assessment of human rights considerations
• The 22 October 2021 incident (which also features in the complaint), which took place in the village of Durba, when community members protested against the DRC Government’s clampdown on illegal mining activities. The Respondent asserts that it was not involved with this incident. The Respondent strongly refutes the allegations that it, Barrick or Kibali directed or instructed policy or other state authorities in relation to this incident on the basis that it (nor Barrick or Kibali) cannot direct security forces or policy (which are DRC institutions/prerogatives) and while it does have a written agreement with local police units in relation to the protection of the Mine, these units are under their own command. The Respondent avers that the police units that attended on the day of the demonstrations were different police units. Kibali does have a private security contractor, but their personnel are unarmed

37․ The Respondent refers to its human rights report which states that it has implemented a comprehensive human rights due diligence process, underpinning its commitment to the UN Guiding Principles on Business and Human Rights and that it supports the management of human rights risks. The Respondent also states that it has a human rights framework, human rights standard and that it subscribes to the voluntary principles on security and human rights, among other initiatives (which it does not list).

38․ The Respondent claims that Kibali is compliant with DRC law and states that the allegation by the Complainant about artificially maintaining low share capital is unwarranted and unsubstantiated.

39․ The Complainant has not fully explained how the aspects of DRC law that it has cited are relevant, and has not provided a detailed explanation regarding, or any evidence of, breaches of such laws. The UK NCP deems that there is no substantiated basis for the allegations made regarding noncompliance to DRC tax law.

40․ Having analysed all the information provided in English by both Parties, the UK NCP does believe that the alleged harm to the affected community is material. The complaint details the various violations and the impacts on human rights and economic loss to the affected communities allegedly caused by the displacements, which are further substantiated by the PAX report.

41․ However, the complaint lacks clarity to demonstrate that the Respondent was directly involved in causing these damages. Some of the allegations are broad and may be perceived as general assertions rather than specific and actionable complaints. The PAX report submitted by the Complainant does cast doubt on some of the claims made by the Respondent and by Barrick. However, this report predominantly focuses on Barrick’s involvement, as well as the roles of Kibali and the DRC Government in the events associated with the Mine.

42․ In light of this, the UK NCP understands that the Respondent was not involved in day-to-day operations but does consider that the use of leverage and influence is a key part of any human rights due diligence policy.

43․ The Response provides helpful information regarding the Respondent’s approach to human rights diligence and standards. It does not, however, state when the Respondent adopted the relevant policies and standards or give a breakdown of the actions it conducted to ensure Barrick respected the implementation of said standards.

44․ It is also unclear to the UK NCP how the Respondent chose to engage with Kibali at each stage of the different events outlined in the Response.

45․ The UK NCP considers that further examination would be required to establish if the Respondent’s approach to due diligence and stakeholder engagement were applied in a timely, practicable and appropriate way. It would need to be consistent with the OECD guidelines in respect of the incidents of October 2021, including the lead up and aftermath of the event, that continue to have repercussions on the affected communities as the Complainant contends. The UK NCP considers that some of the issues raised in the complaint seem to be material and substantiated.

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

46․ The OECD guidelines state that leverage is considered to exist where the enterprise has the ability to effect change in the wrongful practices of the entity that causes the harm.^{[footnote 5]}

47․ The Complainant alleges that the Respondent is accountable for the actions taken by Barrick (as the Mine operator) on its behalf at the Mine due to the joint venture relationship. This requires Barrick and the Respondent to cooperate, assist each other, and ensure Kibali’s compliance with the guidelines.

48․ As stated previously, the information relayed by the Complainant, including the PAX report, predominantly focuses on Barrick’s involvement, as well as the roles of Kibali and the DRC Government in the events associated with the Mine. There is little mention of the Respondent’s involvement positive or negative.

49․ To reiterate, it is also unclear whether the extent to which appropriate due diligence and leverage was applied by the Respondent during the incidents of October 2021, and what steps were undertaken by the Respondent specifically, to ensure the OECD guidelines were respected. Given the Respondent’s 45% share in the Mine, it is the UK NCP’s position that there could be benefits to the Parties engaging in dialogue on the responsibility to prevent, mitigate and address the issue at hand and further similar incidents.

50․ The UK NCP therefore considers that it would contribute to the purpose and effectiveness of the OECD guidelines for the UK NCP to consider the complaint further. 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.

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

51․ The Complainant invokes DRC domestic law:

• article 285 bis of the DRC mining code, which states any holding of mining or quarry rights is responsible for damages caused to people
• articles 16, 29, 34 and 35 of the constitution of the DRC, which focuses on the right to life, physical integrity, free development of personality, protection of the affected communities’ home and property, and the freedom to engage in private initiatives, with the State ensuring respect, protection, and fair compensation under the law
• decree of the Sovereign King of 27 February 1887, articles 6 and 13 a, b, c, which outline the legal requirement for companies’ formation, environmental obligation and procedures for obtaining and transferring mining rights in the DRC

52․ The Respondent states that the issues raised in this complaint have already been considered by the Canadian NCP in relation to Barrick. Most of these issues were dismissed, with one put forward for mediation (without any adverse findings). The Canadian NCP issued its recommendations in February 2024, which are either in the process of being implemented, or have already been implemented, by Kibali.

53․ The Canadian specific instance was brought against Barrick as the Mine operator. The UK NCP’s position is that this does not absolve the Respondent, with its considerable share of the Mine, of responsibility it would have under the guidelines, in influencing partners and applying appropriate due diligence. This is not a link the Canadian NCP has previously assessed.

54․ Unlike the UK NCP, the Canadian NCP does not make determinations of whether a company has or has not observed the guidelines. The absence of such a finding does not imply endorsement of the company’s conduct, nor does it preclude further examination by another NCP on issues not addressed in the Canadian process.

55․ The UK NCP has informed both parties that it is communicating with the Canadian NCP about the case.

56․ The UK NCP considers 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. It would not create serious prejudice for either of the Parties involved in these other proceedings or cause a contempt of court situation.

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

57․ The UK NCP has considered all the information provided by Parties. It has concluded that it remains unclear how the Respondent’s due diligence policies and leverage were applied throughout the 2021 incidents of relocation, especially in relation to Barrick their main operating partner.

58․ As noted above, the OECD guidelines state that leverage is considered to exist where the enterprise has the ability to effect change in the wrongful practices of the entity that causes the harm.^{[footnote 6]}

59․ The use of leverage in or influence over remediation is a key part of any human rights due diligence policy. Given the Respondent’s 45% share in Kibali, the NCP considers that the complaint merits further consideration.

60․ 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.

Next steps

61․ Pursuant to section 4 of the UK NCP Procedures for Dealing with Complaints, the UK NCP will offer mediation to both Parties after the conclusion of the initial assessment.

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

63․ 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.^{[footnote 7]}

64․ If the UK NCP concludes in its further examination that Respondent’s conduct was inconsistent with the OECD guidelines, that finding will be noted in the final statement. A copy of which will be published on the UK NCP website and forwarded to the UK Export Finance Department.

Annex 1: the UK NCP process

Date	Action
5 February 2024	UK NCP receives the complaint
22 November 2024	UK NCP confirms receipt of the complaint
19 December 2024 and 17 January 2025	UK NCP offers separate meetings with the Parties to discuss the initial assessment process and the Parties’ prospective interest in mediation
3 March 2025	UK NCP receives Respondent’s response to the complaint
27 June 2025	UK NCP drafts the initial assessment and shares both the initial assessment draft and the factual commentary grid with Parties for comment
18 June 2025	Both Parties submit factual commentary to UK NCP with their response
11 November 2025	UK NCP incorporates factual comments in the initial assessment
12 December 2025	UK NCP publishes the initial assessment on GOV.UK

Annex 2: provisions of the OECD Guidelines raised in the complaint

The Complainants refer to the following summary of the provisions of the guidelines.

Chapter I: concepts and principles

Paragraph (1)

The guidelines are recommendations jointly addressed by governments to multinational enterprises. They provide principles and standards of good practice consistent with applicable laws and internationally recognised standards. Observance of the guidelines by enterprises is voluntary and not legally enforceable. Nevertheless, some matters covered by the guidelines may also be regulated by national law or international commitments.

Paragraph (2)

Obeying domestic laws is the first obligation of enterprises.

Paragraph (4)

Precise definition of multinational enterprises is not required for the purposes of the guidelines.

Chapter II: general policies

Paragraph (A)(1)

Contribute to economic, environmental, and social progress with a view to achieving sustainable development.

Paragraph (A)(2)

Respect the internationally recognised human rights of those affected by their activities.

Paragraph (A) (3)

Encourage local capacity building through close co-operation with the local community, including business interests, as well as developing the enterprise’s activities in domestic and foreign markets, consistent with the need for sound commercial practice.

Paragraph (A)(5)

Refrain from seeking or accepting exemptions not contemplated in the statutory or regulatory framework related to human rights, environmental, health, safety, labour, taxation, financial incentives, or other issues.

Paragraph (A)(6)

Support and uphold good corporate governance principles and develop and apply good corporate governance practices, including throughout enterprise groups.

Paragraph (A)(7)

Develop and apply effective self-regulatory practices and management systems that foster a relationship of confidence and mutual trust between enterprises and the societies in which they operate.

Paragraph (A)(11)

Avoid causing or contributing to adverse impacts on matters covered by the guidelines, through their own activities, and address such impacts when they occur.

Paragraph (A)(12)

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. This is not intended to shift responsibility from the entity causing an adverse impact to the enterprise with which it has a business relationship.

Paragraph (A)(13)

In addition to addressing adverse impacts in relation to matters covered by the guidelines, encourage, where practicable, business partners (including suppliers and sub-contractors) to apply principles of responsible business conduct compatible with the guidelines.

Paragraph (A)(14)

Engage with relevant stakeholders in order to provide meaningful opportunities for their views to be taken into account in relation to planning and decision making for projects or other activities that may significantly impact local communities.

Paragraph (A)(15)

Abstain from any improper involvement in political activities.

Chapter IV: human rights

Paragraph (1)

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.

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.

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.

Paragraph (4)

Have a policy commitment to respect human rights.

Paragraph (5)

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.

Paragraph (6)

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 XI: taxation

Paragraph (1)

It is important that enterprises contribute to the public finances of host countries by making timely payment of their tax liabilities.

In particular, enterprises should comply with both the letter and spirit of the tax laws and regulations of the countries in which they operate.

Complying with the spirit of the law means discerning and following the intention of the legislature. It does not require an enterprise to make payment in excess of the amount legally required pursuant to such an interpretation.

Tax compliance includes such measures as providing to the relevant authorities timely information that is relevant or required by law for purposes of the correct determination of taxes to be assessed in connection with their operations and conforming transfer pricing practices to the arm’s length principle.

1. OECD (2019), Guide for National Contacts Points on the Initial Assessment of Specific Instances, OECD Guidelines for Multinational Enterprises Guide for National Contact Points on Coordination when handling Specific Instances, page 6. ↩

2. At least 300 names featured on the written request the UK NCP received. ↩

3. Clarification made in OECD (2023), OECD Guidelines for Multinational Enterprises on Responsible Business Conduct, OECD Publishing, Paris, chapter 1, paragraph 4. ↩

4. AngloGold Ashanti, ‘Corporate profile’. ↩

5. OECD (2011), OECD Guidelines for Multinational Enterprises on Responsible Business Conduct, paragraph 19, page 24 of the commentary on “chapter 2: general policies of the OECD guidelines”.  ↩

6. OECD (2011), OECD Guidelines for Multinational Enterprises on Responsible Business Conduct, paragraph 19, page 24 of the commentary on “chapter 2: general policies of the OECD guidelines”.  ↩

7. Note that OECD guidance states that recommendations and agreements as part of the NCP process are future-looking and should refer to the version of the guidelines in effect at the time the recommendation or agreement is being made. The UK NCP will therefore base any recommendations on the 2023 version of the guidelines. ↩