Responsible Business Conduct (RBC) is an important part of the investment climate. It helps attract investments that support sustainable development and enhance access to markets with RBC expectations. This chapter assesses progress achieved and identifies opportunities and challenges for promoting and enabling RBC in Uzbekistan. It considers and reviews the legal and policy environment and efforts by government and other stakeholders. It provides recommendations to the Government of Uzbekistan on key areas where it can further promote and enable RBC.
Roadmap for Sustainable Investment Policy Reforms in Uzbekistan
7. Promoting responsible business conduct in Uzbekistan
Copy link to 7. Promoting responsible business conduct in UzbekistanAbstract
7.1. Summary and recommendations
Copy link to 7.1. Summary and recommendationsIntegration and promotion of responsible business conduct (RBC) principles and standards in the Uzbek economy can significantly support progress toward sustainable development. RBC sets out an expectation that all companies avoid and address the adverse impacts of their operations on people, planet and society, and contribute to the sustainable development of the countries in which they operate. At the same time, RBC enhances Uzbekistan’s access to global investments and markets: the country’s key economic partners and potential new markets are setting expectations in terms of observance of RBC principles and standards, including in important sectors for Uzbekistan’s economy such as mining, textiles and agriculture. Moreover, RBC presents a clear business case for individual companies, strengthening their competitiveness in global value chains and markets with high RBC expectations, enhancing their management of risks and resources, and improving their brand and employer reputation.
Uzbekistan has already made progress in promoting RBC. The government actively supports the management of environmental, social and governance risks by state-owned enterprises and has made their non-financial reporting mandatory. Both green procurement and sustainable finance are expanding, setting important incentives for better business behaviour. These actions complement progress in key policy areas, including efforts to eradicate systemic forced labour, efforts in the fight against corruption and increasing attention to and incentives for protecting natural resources and reducing climate emissions. There is a growing number of businesses that are interested in RBC and adapt their practices.
The government has underscored the importance of RBC to attract foreign investment. It is working on a National Action Plan on Business and Human Rights to enhance the realisation of human rights, raise awareness of RBC and improve access to remedy. The government is also including the promotion of RBC in a draft strategy for small- and medium-sized enterprises and considering strengthening the legal framework for RBC.
Government action will be essential to address remaining gaps in observance of international RBC principles and standards. Effective implementation and enforcement of standards are not systematic, meaning that more efforts are needed to translate better rules into better practice. Companies do not always respect labour rights and labour inspections require strengthening. The right to strike not guaranteed and independent operations of unions face challenges. Businesses are frequently not held to account when damaging the environment. Impact assessments of business operations do not systematically consider social and human rights impacts. The framework for transparency and anti-corruption of private businesses could be enhanced.
Greater efforts are needed to create an enabling environment for RBC, in particular meaningful stakeholder engagement. Restrictions to freedom of association and of expression impede the ability of citizens, media, and civil society to flag risks of poor business behaviour, advise on risk management and contribute to monitoring. While courts help resolve RBC-related issues, increased access to non-judicial and notably operational-level grievance mechanisms could enhance stakeholders’ access to remedy. As an economic actor, the government is not yet fully exploiting its potential to incentivise better business behaviour. Raising greater awareness of RBC is a key challenge, as is the common misperception of RBC as an obstacle to business activity, rather than an enhancement of business practice.
A clear institutional framework for RBC does not yet exist. While various public actors promote aspects of RBC as part of their wider mandates, no institution has a dedicated mandate to promote RBC and there is no mechanism to strengthen co-ordination and coherence of RBC-related activities across government. The Foreign Investors Council has established a working group on RBC and tripartite commissions discuss social and labour issues, but no national or sectoral platforms exist where all relevant stakeholders from government, business, unions and civil society could discuss RBC challenges and efforts to address them.
This chapter aims to inform the government and its dialogue with stakeholders. It helps explore options based on OECD instruments and practice for a well-designed policy mix to address existing gaps in the regulatory framework and promote observance of RBC principles and standards in practice.
Recommendations
Copy link to RecommendationsEnhance awareness of RBC and support businesses to implement RBC principles and standards. To maximise the opportunities for investment and trade, this should be aligned with international standards, such as the OECD Guidelines for Multinational Enterprises on RBC and due diligence guidances. RBC should be systematically integrated in policies to promote private sector development. Building on its efforts, and the government is exploring further opportunities to do so, including through dedicated regulation on responsible business conduct and plans to include promotion of RBC in its planned strategy for development of small- and medium-sized enterprises. Activities should involve key ministries, human rights institutions, the Business Ombudsman, business associations, trade unions and civil society organisations. Activities should include:
Informing all stakeholders about the rationale and benefits of RBC, building on the dynamic to promote environmental, social and governance (ESG) risk management and outlining the difference to corporate social responsibility as philanthropy;
Providing information, tools and advice to businesses operating in and from Uzbekistan on the integration of RBC and notably RBC due diligence in their business operations, including in supply chains. This should also be part of investment and trade promotion activities, as it will help businesses in Uzbekistan to meet RBC expectations of international trade and investment partners.
Adopt and implement a National Action Plan for Business and Human Rights in close collaboration with all stakeholders. The roadmap for implementing the UN Guiding Principles for Business and Human Rights led by the National Human Rights Centre provides an important opportunity to boost implementation of the recommendations presented here. Implementing the roadmap should facilitate co-ordination, monitoring and dialogue on progress and challenges.
Clarify the institutional responsibilities for promoting RBC and ensure cross-government co-ordination of RBC-related policies. Several ministries and public institutions already undertake activities related to RBC. As significant opportunities to expand efforts exist, the government should clarify how each institution will promote and enable RBC. An effective co‑ordination mechanism should bring together include key ministries and public institutions active in promoting, overseeing and contracting private sector activities, to align messages, expectations, requirements and incentives, and to promote exchange of information and learning.
Facilitate meaningful stakeholder engagement around RBC-related policies as well as the identification of risks of adverse impacts, response measures and monitoring at the operational level. This includes ensuring an enabling environment that allows all stakeholders to express their views and encouraging companies to consider the views of stakeholders and affected communities. The government should also ensure stakeholder engagement in consultations for, and follow-up to, environmental impact assessments.
Enhance the regulatory environment for responsible business conduct and ensure the effective application of standards. Better respect for existing standards would already make a substantial difference in due diligence risk assessments of potential investors and trade partners. If Uzbekistan develops dedicated legislation on RBC, it will be important to consult all stakeholders to ensure coherence across policy areas such as corporate governance, investment, procurement and sectoral policies. Uzbekistan could act in the following areas:
Enhance enforcement of RBC-related standards, by systematically applying requirements for licensing and permits, effective monitoring and follow-up to recommendations and injunctions to businesses. The government should closely monitor whether the new system of notification and risk classification strengthens the effectiveness of inspections, allows unannounced inspections, and does not impede inspections where they would be warranted, in line with international standards.
Implement fundamental ILO conventions Uzbekistan has adhered to. In addition to building on progress in the eradication of systemic forced and child labour, this relates notably to freedom of association of trade unions, the right to strike and the effectiveness of labour inspections.
Integrate consideration of social impacts in impact assessments of business activities. This could pertain to the effects of business operations notably on livelihoods, land rights and vulnerable groups to help consider impacts in addition to those on the environment and climate change.
Strengthen transparency and anti-corruption in private enterprises. Building on ongoing efforts, this should include clear responsibilities for risk management in corporate governance, which could strengthen businesses’ readiness for RBC due diligence. The recent OECD Monitoring of Anti-Corruption Reforms in Uzbekistan under the Istanbul Anti-Corruption Action Plan provides important steer in this regard.
Further promote RBC in economic activities of the government, notably by:
Reinforcing expectations for large SOEs to observe RBC standards, supporting implementation and monitoring progress. Building on the ongoing promotion of ESG risk management, this should include support to meaningful stakeholder engagement of SOEs and a gradual introduction of RBC due diligence in their business operations, to identify and respond to the range of relevant risks of adverse impacts, including in supply chains.
Fostering attention to RBC in public procurement. Building on efforts to promote green procurement, the government should support and guide procurement authorities in making full use of existing regulations to strengthen attention to both environmental and social impacts of procurement, including in supply chains. The planned introduction of a principle of sustainable procurement provides an opportunity to reinforce these efforts.
Strengthen access to remedy. The government should raise awareness of existing judicial and non-judicial mechanisms, assess to what extent these mechanisms are effective in remediation and ensure follow-up to relevant measures foreseen under the planned National Action Plan for Business and Human Rights. To strengthen access to judicial remedies, the government should promote training for judges and legal professionals on RBC and continue efforts to strengthen the independence of the judiciary. The government should also work with social partners to promote operational-level grievance mechanisms.
7.2. The relevance of responsible business conduct for Uzbekistan’s economy and sustainable development
Copy link to 7.2. The relevance of responsible business conduct for Uzbekistan’s economy and sustainable developmentResponsible business conduct (RBC) enhances business contribution to sustainable development in Uzbekistan. All sustainable development goals can be connected to RBC: businesses’ positive contribution is essential to make progress towards the SDGs, while business operations’ adverse impacts on people, planet and society need to be avoided and addressed (OECD, 2019[1]). RBC can directly support and lift businesses’ role (of both state-owned enterprises and private companies) in implementing Uzbekistan’s Development Strategy 2022-2026, the Strategy Uzbekistan 2030, and country’s transition to a green economy, for which a dedicated strategy was adopted in 2019 (Republic of Uzbekistan, 2019[2]; Republic of Uzbekistan, 2023[3]; Republic of Uzbekistan, 2022[4]). Examples of key objectives are reducing emissions and protecting natural resources, the delivery of services through private providers, the increase of local production and exports, boosting gender equality in the economy and attracting investments. Recent crises have underlined the importance of reliable and resilient supply chains; RBC, by enhancing the understanding of, and collaboration across, supply chains and enhancing risk management, can help minimise disruptions (OECD, 2021[5]).
RBC is an important factor in attracting foreign direct investment (FDI) to Uzbekistan. The President of Uzbekistan highlighted this in an address to the Foreign Investors Council of Uzbekistan (President of the Republic of Uzbekistan, 2024[6]). Uzbekistan aims to attract USD 70 billion in FDI under its 2022-2026 investment programme (Republic of Uzbekistan, 2021[7]). Integrating RBC expectations in these programmes can help ensure that these investments contribute to Uzbekistan’s overall sustainable development goals. As the OECD Policy Framework for Investment sets out: “[T]o the extent that governments provide an enabling environment for businesses to act responsibly and meet their duty to protect the public interest from potential negative impacts of business activities, they are more likely to keep and attract high quality and responsible investors, minimise the risks of potential adverse impacts of investments, and ensure broader value creation and sustainable development” (OECD, 2015[8]).
Promoting RBC will help Uzbekistan strengthen its integration in global value chains and can generate additional benefits. Multinational enterprises (MNEs) that conduct RBC due diligence would seek to identify risks for people, the environment and society their operations and supply chains in Uzbekistan might create, and then take action to address these risks and monitor and communicate on them (Figure 7.1). This would then translate in expectations vis-à-vis business partners in Uzbekistan. Dedicated OECD due diligence guidances and tools exist for key sectors of the Uzbek economy such as mining, garment and agri-food and can help create a shared understanding of RBC due diligence across the value chain.1 Additional factors strengthen the business case for RBC. These include an improved risk, resource and supply chain management, better access to green and sustainable finance and stronger brand and reputation among employees and customers (OECD, 2021[9]; OECD, 2023[10]; OECD/Columbia University, 2016[11]).
Figure 7.1. The MNE Guidelines are operationalised through risk-based due diligence
Copy link to Figure 7.1. The MNE Guidelines are operationalised through risk-based due diligenceA six-step framework provides companies with a process to embed RBC practices within the core of company operations
Uzbekistan’s key trade partners2 are actively promoting RBC. For example, Kazakhstan, Korea, Switzerland, Türkiye, and European Union member states, as well as other OECD high-income markets, are all adherents to the OECD Guidelines for Multinational Enterprises on Responsible Business Conduct (OECD MNE Guidelines)3 (OECD, 2023[10]). These countries are also adherents to the OECD Recommendation on the Role of Government in Promoting Responsible Business Conduct [OECD/LEG/0486]. Their governments actively promote RBC, including through regulatory and policy measures, and a network of National Contact Points for RBC (NCPs), which provide a non-judicial grievance mechanism when corporate conduct raises issues with regard to the OECD MNE Guidelines. France’s law on the duty of vigilance4 is an example of a regulatory measure. large companies (more than 5 000 employees) are required to develop a due diligence action plan (Business & Human Rights Resource Centre, n.d.[13]). In discussion with stakeholders, this plan needs to identify risks the company create for human rights and the environment, including in supply chains, and propose suitable response measures. A number of lawsuits have been filed against companies under the law.
The European Union – a market of growing relevance for Uzbekistan – has put in place a range of regulatory and policy measures to promote RBC. These cover due diligence by companies (the Corporate Sustainable Due Diligence Directive), corporate and financial sector disclosure (Corporate Sustainable Reporting Directive and Sustainable Finance Disclosure Regulation)5, as well as specific issues and sectors of relevance to Uzbekistan, notably on deforestation, forced labour, minerals, and batteries. Moreover, Uzbekistan has access to the EU’s General Scheme of Preferences+ (GSP+) since 2021,6 which provides preferential access to the EU market under the condition of implementing key international instruments, many of which are closely related to RBC, notably on labour rights and anti-corruption. The Economic Cooperation and Partnerships Agreement that the EU and Uzbekistan aim to adopt will also include a section on sustainable trade and RBC (see below). Finally, the EU and Uzbekistan have entered a strategic partnership on critical raw materials that includes co-operation on sustainable and responsible production and sourcing (European Commission, 2024[14]).
The People’s Republic of China (hereafter ‘China’), as one of Uzbekistan’s largest trade partners and foreign investors,7 is also stepping up attention to RBC. In 2021, the government issued “Green Development Guidelines for Overseas Investment and Co-operation”, recommending Chinese businesses to scale up integration of green development through the overseas investment process including based on international standards (Nedopil, De Boer and Fan, 2022[15]). Following the adoption of Green Finance Guidelines in 2022, Chinese banks are required to establish accountability mechanisms for their foreign investments, and the Responsible Critical Mineral Initiative, where many Chinese mining companies are a member, also aims to introduce an accountability mechanism to respond to violations of environmental and social standards (Day and Liang, 2023[16]). In 2024, three major stock exchanges introduced mandatory rules to report on sustainability related risks and impacts, including climate transition plans, and at the end of 2024, the government issued Basic Guidelines for Corporate Sustainability Disclosure (UN Environment Programme Finance Initiative, 2025[17])
Promoting responsible business conduct principles and standards is also relevant in the context of maximising the benefits of the anticipated Uzbek accession to the WTO. The plurilateral Investment Facilitation for Development Agreement put forward by over 120 WTO members includes a section on sustainable investment with a clause on measures against corruption and a dedicated clause on responsible business conduct that calls upon members to encourage investors and enterprises to “voluntarily incorporate into their business practices […] internationally recognised principles, standards and guidelines of responsible business conduct” (WTO, n.d.[18]).
RBC is also an important factor in projects financed through official development assistance (ODA), a key source of external finance in Uzbekistan. From 2019-2023, official development assistance to Uzbekistan amounted to USD 6.6 billion.8 Multilateral development banks and OECD Members are the most important donors, with significant investments in infrastructure and economic development. These institutions generally require environmental and social impact assessments for their loans, which can lead to RBC-related expectations of suppliers. Ensuring local suppliers demonstrate responsible business conduct can therefore be a relevant factor in attracting development financing and ensuring both timely and high-quality project preparation and implementation. The collaboration with international partners also provides an opportunity for Uzbek officials to gain insights into their standards for identifying and managing adverse impacts, and to adapt good practices for investments financed without ODA.
7.3. International instruments and national policies supporting RBC
Copy link to 7.3. International instruments and national policies supporting RBCMain international instruments on RBC are applicable in the Uzbek context. The UN Guiding Principles on Business and Human Rights, the International Labour Organization Tripartite Declaration of Principles concerning Multinational Enterprises and Social Policy and the OECD MNE Guidelines all “establish that all companies have the responsibility to avoid and address adverse impacts with which they are involved, including in their supply chains, while making a positive contribution to the economic, environmental and social progress of the countries in which they operate” (ILO/OECD/OHCHR, 2023[19]). Uzbekistan is a party to the main international instruments in areas relevant for RBC such as human rights, labour rights, the protection of the environment, and the fight against corruption (Table 7.1).
Table 7.1. Uzbekistan’s adherence and ratification of key international instruments
Copy link to Table 7.1. Uzbekistan’s adherence and ratification of key international instruments|
Instrument |
Ratification or Adherence |
|---|---|
|
7/91 |
|
|
10/10 |
|
|
Yes |
|
|
Yes |
|
|
Yes |
|
|
Yes |
1. Uzbekistan has not ratified the International Convention on the Protection of the Rights of All Migrant Workers and Members of their Families and the Convention for the Protection of All Persons from Enforced Disappearance. It has not agreed to most individual communications procedures or visit or inquiry procedures that exist under UN human rights instruments.
Private sector development is a national policy priority, and the relevance of RBC is increasingly recognised. Both the Development Strategy 2022-2026 and the Strategy Uzbekistan 2030 set out objectives for stimulating the private sector for economic growth. The strategies some objectives to address adverse effects of business operations, in particular environmental impacts such as pollution, water usage and greenhouse gas emissions, with objectives on the fight against corruption and the promotion of gender equality also being relevant for private sector activities. The National Human Rights Strategy aims at “protecting the economic rights and legitimate interests of individuals and legal entities, especially entrepreneurs; as well as improving legislation to further enhance the involvement of business in the field of human rights” (Government of Uzbekistan, 2017[26]). Moreover, the government is developing a strategy for SMEs. Based on a draft shared with the OECD in the context of this review, one of the strategy’s goals would be to support SMEs in adopting RBC-related practices to strengthen their competitiveness in global value chains and attractiveness for investors (Government of Uzbekistan, 2025[27]). The draft strategy also foresees the development of national RBC standards and the inclusion of RBC in educational curricula.
While distinct from RBC, corporate social responsibility as philanthropy has long been recognised in the legal framework. It builds on a tradition of state-owned enterprises (SOEs) and private companies to finance philanthropic activities, for instance, related to community development. This is for instance reflected in the Code of Entrepreneurs, which was recently approved by the Senate (Kun.uz, 2024[28]). The Code brings together many existing regulations on entrepreneurship. It also confirms that the state encourages social responsibility, as a voluntary addition to the regular business, typically in the form of sponsorship for social or environmental activities (Government of Uzbekistan, 2022[29]). This is distinct from RBC which requires that businesses consider risks of adverse impacts “as part of their core business considerations and not as an add-on” (ILO/OECD/OHCHR, 2023[19]).
Businesses see a positive trajectory, but also room for further improvement in terms of government support to RBC. In a 2022 survey of international businesses operating in Uzbekistan, around half of responding companies indicated some or major progress on “corporate social responsibility and ethics of business” (OECD, 2023[30]). While considerable, this is less than the progress they perceived in other policy areas (up to 20% percentage points). Specifically for the green transition, a majority of firms report that policy support remains insufficient and call for greater investment in sustainable infrastructure, better environmental standards, and stronger financial incentives for the adoption of greener practices.
Recent initiatives have put RBC higher on the policy agenda. The government is taking action to improve the management of environmental, social and governance (ESG) risks in SOEs (see below). In its Voluntary National Review on the SDGs, Uzbekistan also put forward the possibility of “creating a rating of companies that comply with ESG principles” (Government of Uzbekistan, 2023[31])”. The growing ESG dynamic in Uzbekistan can be a springboard to enhance and complement RBC, as ESG risk management can help companies manage and report on the risks they may create for people, planet and society (Box 7.1). Specifically on RBC, in 2024, the President of Uzbekistan requested the Foreign Investors Council of Uzbekistan to create a working group on RBC (President of the Republic of Uzbekistan, 2024[6]), while the Ministry for Investments, Industry and Trade is considering developing dedicated legislation on RBC.
Box 7.1. Understanding linkages, overlap and differences between RBC and managing environment, social and governance risks (ESG)
Copy link to Box 7.1. Understanding linkages, overlap and differences between RBC and managing environment, social and governance risks (ESG)RBC and ESG are closely linked concepts, with significant overlap, complementarity, and differences. Under the OECD MNE Guidelines, RBC means that business should: i) make a positive contribution to economic, environmental, and social progress with a view to achieving sustainable development; and ii) avoid and address adverse impacts through their own activities and seek to prevent or mitigate adverse impacts directly linked to their operations, products, or services by a business relationship. ESG criteria is the term normally used by financial institutions to describe the set of criteria they use when assessing the sustainability performance of a company.
While both RBC and ESG relate to social, environmental and governance considerations, RBC is specific to the standards and recommendations set out in the MNE Guidelines. Furthermore, in some instances ESG criteria may be used primarily to identify financial risks to a business, while RBC is concerned with adverse impacts on people and planet. In practice, many of these considerations will also have financial implications and be therefore material (negatively or positively) for the company concerned. RBC means a business tries to positively influence the situation by engaging with stakeholders, adjusting business processes and actively using leverage, thereby reducing risks for people and environment.
Source: OECD (2019[32]), Due Diligence for Responsible Corporate Lending and Securities Underwriting, https://mneguidelines.oecd.org/due-diligence-for-responsible-corporate-lending-and-securities-underwriting.pdf.
An effective implementation of regulation and policies will be essential for promoting RBC. This chapter highlights many significant improvements in the legal framework and ongoing reform efforts. This sends an important signal to potential investors. However, the chapter also points to continuing challenges in applying these standards, be they related to impact assessments, licensing, monitoring and enforcement. This underlines the importance of effective implementation.
The forthcoming National Action Plan on Business and Human Rights is an opportunity to advance RBC in practice and engage all stakeholders. Both the UN Committee on the Rights of the Child and the Human Rights Council Universal Periodic Review recommended that Uzbekistan establish a human rights framework for private sector activities such as a National Action Plan on Business and Human Rights (UN Committee on the Rights of the Child, 2022[33]; UN Human Rights Council, 2023[34]). In 2023, the government pledged that it would develop an action plan (Government of Uzbekistan, 2023[35]). To do so, the National Centre for Human Rights, a government agency, has led consultations with public bodies, some companies and civil society actors and developed a draft roadmap for implementation of the UN Guiding Principles on Business and Human Rights. Efforts to finalise this roadmap are ongoing. While a broad range of national and international stakeholders can contribute to advancing RBC in Uzbekistan, not all have been systematically associated in its development. It will therefore be important to ensure their active participation in its implementation and monitoring, as well as the development of a successor action plan, – in line with international standards (UN Working Group on Business and Human Rights, 2016[36]). As an example from the region,9 Mongolia has adopted its first National Action Plan in 2023, based on wide consultations that informed a baseline assessment and the action plan itself (Danish Institute for Human Rights, 2024[37]).
The government is increasingly raising awareness on RBC issues. The government has pledged to “raise awareness among public and private sector representatives of the UN Guiding Principles to ensure a permanent, inclusive and transparent process of respect for human rights in business” (Government of Uzbekistan, 2023[35]). For example, in concert with other institutions, the Human Rights Ombudsman held information sessions on the new labour code and labour rights. The National Center for Human Rights conducted trainings on business and human rights. The Office of the Business Ombudsman is also promoting RBC under its mandate is to protect the rights and interests of businesses. For instance, it has also developed a business anti-corruption charter and conducted trainings for entrepreneurs and farmers on anti-corruption and business and human rights (Business Ombudsman, 2021[38]). As an important interlocutor between the state and businesses, the Business Ombudsman would also be well-placed to explain how meeting RBC expectations can be in companies’ interest and that a growing number of businesses in Uzbekistan are already adjusting their practices.
Greater co-ordination could strengthen efforts to promote and enable RBC. Across government, there is a limited exchange on how different institutions promote RBC. The full range of stakeholders are not systematically consulted and there are no platforms that allow all relevant stakeholders to exchange on the promotion of RBC. Establishing a co-ordination mechanism and clearly assigning roles and responsibilities across government in promoting and enabling RBC could help co-ordinate efforts and support coherence across policy areas.
7.4. Stakeholders’ awareness of RBC
Copy link to 7.4. Stakeholders’ awareness of RBCBusinesses in Uzbekistan with international exposure are increasingly aware of and responsive to RBC. For example, the UN Global Compact’s membership in Uzbekistan now numbers 16 businesses, since its foundation in 2021 (United Nations Global Compact, n.d.[39]). This also includes business umbrella bodies, notably the Chamber of Commerce and Industry, the Textile and Garment Sector Association and the Food Industry Association, as well as banks that influence private sector actors through their loan policies. The textile sector signed up to a Sustainability Pledge in 2022, promoting principles of a circular economy while also promoting transparency and accountability (UNECE, 2022[40]). More and more firms are aware of investor and business partners expectations on ESG risk management and reporting and RBC-related requirements to access higher-income markets, though overall awareness seems to be lower than in other countries in the region (PwC, 2024[41]). International firms in Uzbekistan are aware of the opportunities and challenges of the sustainability transition and adjust their business practices, for instance by reducing their carbon footprint (OECD, 2023[30]). Consumers’ awareness of RBC appears to be increasing: a study shows that consumers in Uzbekistan would be willing to pay higher prices for responsibly produced products, further strengthening the business case for RBC (Ataniyazova, Friedman and Kiran, 2022[42]).
A range of stakeholders collaborate to raise awareness of sustainability and RBC. For example, the UN and Westminster International University jointly organise an annual Forum on Championing Business Sustainability in Uzbekistan (United Nations Uzbekistan, 2023[43]), the OSCE integrates RBC in its human rights work, and the ILO organises events on labour rights and the role of trade unions. Business-led initiatives share information on recent policy developments and international practice, such as through a workshop series on ESG, co-organised by the American Chamber of Commerce (AmCham Uzbekistan, 2024[44]), and an ESG working group in the Europe-Uzbekistan Association for Economic Cooperation (EUROUZ, n.d.[45]).
Bilateral and multilateral development partners also actively promote RBC in collaboration with the government. International engagement and support was of great importance in the fight against systemic forced labour (see below). Ongoing initiatives include programmes supporting better environmental and social business practices in the cotton and agriculture sectors, ILO’s programme on decent work (ILO, 2021[46]), and enhanced environmental protection, for instance regarding industrial waste from mining (UNECE, 2024[47]). Development finance institutions provide loans to financial institutions and companies with specific expectations on managing adverse impacts. A range of partners support business integrity and the fight against corruption. Trade and development partners, including the European Union (Delegation of the EU to Uzbekistan, 2023[48]) and the United States (US Embassy in Uzbekistan, 2024[49]), also raise the importance of RBC in their policy dialogue.
Strengthening awareness will be critical for making progress on RBC, a point highlighted by many stakeholders (Ataniyazova et al., 2024[50]). Implementation of the draft SME Strategy 2025-2030 provides an excellent opportunity to do so. From interviews with the OECD, three aspects emerge as important: i) Informing about the benefits and business case of RBC, as many stakeholders perceive RBC as an impediment to Uzbekistan’s priority of facilitating private sector activities; ii) Co-ordination and involvement of all stakeholders to create synergies; and iii) Supporting small and medium-sized enterprises (SMEs), as stakeholders expressed concern at their capacity to meet expectations.10 Engaging with suppliers and business relationships, including through support and training for SMEs, can be an important element in this regard.
7.5. Policies and laws in the areas covered by the OECD Guidelines on RBC
Copy link to 7.5. Policies and laws in the areas covered by the OECD Guidelines on RBCThis assessment focuses on the main areas covered by the Guidelines, i.e., human rights, employment and industrial relations, environment, and combating bribery and other forms of corruption. Due to length limitation, it does not delve into the following areas that are also covered by the Guidelines: consumer interests; science, technology and innovation; competition; and taxation.
An enabling legal and policy framework is essential to enable RBC in key areas such as human rights, labour rights, environmental protection and anti-corruption. This also requires attention to implementation and effective enforcement of standards, including identifying and addressing unnecessary barriers that impede their implementation.
7.5.1. Human rights
The new constitution adopted in 2023 expanded domestic guarantees for human rights. With particular relevance to RBC, human rights guarantees under the constitution include a set of labour rights, notably the right to form unions and to decent work and a ban of forced labour and dangerous child labour (Republic of Uzbekistan, 2023[51]). Moreover, the constitution guarantees the right to a favourable environment and a state obligation to “implement measures to improve, restore and protect the environment”. With regard to economic activities, the constitution highlights that “[t]he use of any property must not be harmful to the environment or violate the rights and legitimate interests of other persons, society and the state”.
Uzbekistan can further strengthen the institutional framework for the protection of human rights. The creation of a Human Rights Ombudsman (the Authorized Person of the Oliy Majlis [the Parliament] of the Republic of Uzbekistan), the establishment of the National Centre for Human Rights and the adoption of a National Human Rights Strategy and Uzbekistan’s first membership in the Human Rights Council were important steps to promote human rights in policy making. The Ombudsman is Uzbekistan’s National Human Rights Institution. It promotes RBC by resolving individual case submissions, raising awareness, in particular of labour rights, and submitting advice on policies and legislation. As the Ombudsman is not yet fully compliant with the Paris principles for National Human Rights Institutions, strengthening its institutional effectiveness – as recommended by the Universal Periodic Review – could also enhance its role in promoting business and human rights and RBC (GANHRI, 2020[52]; UN Human Rights Council, 2023[34]). New legislation allows the Ombudsman also to issue special reports on human rights to the president and parliament and submit legislative proposals (Republic of Uzbekistan, 2024[53]).
RBC considerations are also relevant for the respect of human rights of individuals belonging to specific groups or populations that require particular attention. In 2019, the Law on Guarantees with Respect to Equal Rights and Opportunities for Women and Men underlined women’s and men’s equality in terms of rights and opportunities, tasked government institutions with promoting equality and created a parliamentary commission; this was followed by a gender equality strategy (Republic of Uzbekistan, 2019[54]) (Government of Uzbekistan, 2021[55]). The government has further enshrined non-discrimination in legislation such as the labour code and made efforts to promote equal rights of the country’s diverse ethnic groups (Government of Uzbekistan, 2022[56]). Uzbekistan granted citizenship to over 80 000 stateless persons and is considering accession to international instruments on the protection of refugees and stateless persons (UNHCR Central Asia, 2023[57]). Improvements in gender equality are reflected in higher than regional average scores in the World Bank’s 2024 edition of the Women, Business and Law Index (World Bank, 2024[58]). The government recognises that further progress is needed, including on discrimination in the workplace and the gender pay gap11 (Government of Uzbekistan, 2023[31]; UN Committee on the Elimination of Discrimination against Women, 2022[59]). The ratification of the Convention on the Rights of Persons with Disabilities and the Labour Code has improved the legal framework for persons with disabilities in the labour market, also foreseeing incentives for employers. A comprehensive baseline assessment aims to inform a national action plan to implement the convention (World Bank, 2023[60]). Gaps remain, however, such as weak enforcement of the system for employment quota, lack of quality data and low awareness of regulation and incentives (World Bank, 2023[60]). The autonomous region of Karakalpakstan is an area heavily affected by the Aral Sea disaster but also has significant potential for renewable energy. The government actively promotes investments in Karakalpakstan, for example in windfarms. As the region had witnessed tensions in 2022 (OHCHR, 2022[61]), attention to an enabling environment for meaningful engagement with all local stakeholders will further help promote the region as a destination for investment in sectors that are essential for Uzbekistan’s green transition.
The guarantee of individual land rights vis-à-vis business interest is a concern. The Land Code and related regulations protect land holders against involuntary expropriation and provide for compensation in case of expropriation for public needs (Republic of Uzbekistan, 2022[62]) (for more information, see Chapter 2 on Strengthening Uzbekistan’s Legal and Policy Framework for Sustainable Investment). However, in practice tenure is not always secure, and access to compensation challenging (World Bank, 2022[63]) (Special Rapporteur on the right to adequate housing, 2024[64]). A particularity in Uzbekistan is that farmland is not privately owned but rather leased to farmers. Alleged infringements concern in particular undue pressure to “voluntarily” cede their rights to make land available for larger investments (Uzbek Forum For Human Rights and Tashkent-SNOS, 2023[65]). For project investments, the regulatory framework does not require a resettlement plan and could be clearer on compensation for loss of livelihoods and for affected persons, who do not hold formal land titles (MIIT/ADB, 2023[66]). In the case of urban development, concerns around expropriation and compensation were also raised (Special Rapporteur on the right to adequate housing, 2024[64]; University of Ulster Centre for Public Administration, 2024[67]) (European External Action Service, 2024[68]). In 2024, the government amended the Housing Code to strengthen the rights of homeowners against expropriation (Republic of Uzbekistan, 1999[69]).
Uzbekistan could benefit from greater attention to social and human rights impacts of private sector activities. RBC-related requirements in Uzbekistan for private sector actors are generally limited to environmental and anti-corruption objectives, such as in regulations on public procurement, PPP, and investment (see the respective sections below). Regulation on the protection of land rights considers some but not all relevant social factors. Environmental impact assessments require a public consultation but not an assessment of social or human rights impacts. Better understanding risks of adverse human rights impacts would enable prevention and mitigation of risks by enterprises, and also support the government in its efforts to ensure the effective implementation of RBC-related standards. , For example, in 2023, Mongolia adopted a regulation on environmental impact assessments to include social impacts, such as on employment, land rights and gender equality (OECD, 2025[70]; PwC Mongolia, 2024[71]). Experiences from Mongolia could thus be valuable for Uzbekistan in strengthening the attention of human rights impacts of private sector projects. This could also enhance the consideration for vulnerable groups, who might be impacted differently or more severely by business behaviour.
7.5.2. Labour rights
In recent years, Uzbekistan has significantly enhanced its legal framework for labour rights. This includes ratification of all fundamental ILO Conventions. Since 2019, Uzbekistan has ratified eleven ILO Conventions.12 Moreover, Uzbekistan has revised its Law on Trade Unions (entered into force in 2020) (Republic of Uzbekistan, 2020[72]) and its Labour Code (entered into force in 2023) (Republic of Uzbekistan, 2023[73]). Both have significantly enhanced the alignment of Uzbekistan’s legal framework with international standards. A crucial next step will be full application of these new standards in practice.
Social partners are increasingly engaged in labour regulation. The revised Law on Trade Unions gave unions the right to be consulted on legislation. Moreover, in 2019, Uzbekistan created a “Republican tripartite commission on social and labour questions”, where unions are represented by the Federation of Trade Unions of Uzbekistan (FTUU) and union representatives, such as of employees of Navoi Mining and Metallurgical Company (Republic of Uzbekistan, 2019[74]). The Commission meets regularly to consider progress against a General Collective Agreement between the Government, FTUU and the Confederation of Employers of Uzbekistan and discuss current issues, such as the prevention of forced labour and the promotion of decent work. These mechanisms have strengthened the role of social partners, allowing them to share views and propose amendments to numerous regulations, including those implementing relevant ILO recommendations. FTUU also indicated its collaboration in developing methodological recommendations for the practical application of the new Labour Code (FTUU, 2024[75]).
Unions’ role in enhancing and overseeing labour standards is increasing. Collective agreements exist at national, regional and enterprise level, covering a large number of employees. Moreover, the revised Law on Trade Unions gave Unions the right to independently control workplaces. Around 100 FTUU inspectors assess business compliance, providing advice for preventive and remedial action. Businesses must respond within 10 days; if issues remain unresolved, unions can forward the complaint to the national labour inspection and, where needed, the judicial system without incurring court fees. Unions frequently follow up to complaints by workers, having contributed to providing remedies to more than 3 000 persons in 2023 (frequently recovery of wage payments), through agreements between employers and workers and submitting a small number of cases to courts (FTUU, 2024[75]). From 2020 to early 2024, FTUU estimates to have supported around 250 000 people and obtained payments and damages of around UZS 217 billion (around USD 17 million).
The right to create independent unions and the right to strike remain areas of concern. With the revised law, creation of a union was simplified. This has led to an expansion of unions and union membership (FTUU, 2024[75]). However, creating independent unions outside the Federation of Trade Unions remains a challenge, and stakeholders have i raised the issue of a high minimum threshold of 3 000 workers. Attempts to form a union in the cotton sector in 2021 have met with significant challenges, and the union was ultimately absorbed into FTUU. The ILO Committee of Experts expressed strong concerns regarding the independent creation and functioning of trade unions (ILO, 2025[76]). In 2024, a legal amendment simplified the registration of unions that are not legal entities (UzDaily, 2024[77]). A proposal to lower the threshold of workers to 1 000 is under discussion, but meeting this requirement would still be challenging (ILO, 2025[76]). Moreover, while also under discussion, the right to strike is still not explicitly recognised and can be subject to administrative or criminal sanctions (Khajbakhteev, 2020[78]). Both the ILO’s Committee of Experts and the Human Rights Council’s Universal Periodic Review therefore recommended to Uzbekistan to “facilitate the freedom of trade unions and labour organisations and allow independence in their activities” (ILO, 2025[76]; UN Human Rights Council, 2023[34]).
Most worker complaints concern irregular wage payment and terminations of contracts. This is apparent from the issues identified through state and trade union labour inspections, complaints brought to the Human Rights Ombudsman and cases brought to courts. Minimum wage regulation exists but is not systematically respected by employers. Outside the public sector, weak enforcement allows employers to pay insufficient wages, especially in the informal sector (ILO, 2021[46]). Minimum wage does not apply to seasonal and daily work. Moreover, minimum wage rates are not at living wage levels (ILO, 2021[46]).
Occupational health and safety of workers remains a concern, notably in the informal economy and the construction sector. Construction workers face significantly higher risks than in other sectors, including due to reports of insufficient controls (ILO/Ministry of Employment and Labor Relations, 2023[79]). Informal labour is an important factor that can increase work-related risks– a share of 58% in the construction sector gives an indication of the relevance of the phenomenon in Uzbekistan. The government provides tax incentives to reduce the part of the shadow economy (Republic of Uzbekistan, 2020[80]). FDI can also promote higher levels of formal employment (OECD, 2022[81]). In 2024, Uzbekistan ratified ILO Convention No. 155 on Occupational Safety and Health and seeks to address challenges, including through better monitoring and training of employees and employers.
Uzbekistan has made important progress in the fight against systemic forced labour and child labour. Thanks to changes to legislation, a decrease of the state’s role in cotton production and independent monitoring, Uzbekistan succeeded in eliminating systemic forced labour in the cotton sector (ILO, 2022[82]). However, instances of violations persist (ILO, 2025[76]; Cotton Campaign, 2023[83]; Uzbek Forum for Human Rights, 2024[84]), and impede efforts to successfully attract more international businesses (see Box 7.2). Uzbekistan has also achieved considerable progress in eliminating child labour (US Department of Labour, 2023[85]). With the entry into force of a revised Labour Code in 2023, it further reduced the scope for permissible child labour. Some incidents of child labour persist, requiring continued attention (UN Committee on the Rights of the Child, 2022[33]; ILO, 2025[76]).
Box 7.2. The arduous road to re-attract international businesses in the cotton sector
Copy link to Box 7.2. The arduous road to re-attract international businesses in the cotton sectorUzbekistan’s political reform and international pressure helped address severe human rights violations in the cotton sector. State-organised forced labour and child labour used to be systemic in Uzbekistan. In response, a multi-stakeholder coalition of civil society and businesses started the Cotton Campaign in 2007. The campaign called for urgent reforms and a large group of 331 brands and retailers signed the Campaign’s pledge not to source cotton from Uzbekistan. Following the 2016 presidential elections, Uzbekistan launched a series of key reforms to outlaw forced labour and eliminate it in practice, with success, as independent monitoring by civil society confirmed. In March 2022, the Cotton Campaign officially lifted its pledge.
Some incidents of human rights violations persist. More than one hundred vertically integrated private sector cotton clusters now manage production. However, public production targets create incentives for local authorities to resort to coercion where cotton or silk workers are not readily available, and some incidents are reported. In response, civil society monitoring recommends strict controls and sensitisation to prevent forced labour. It also highlighted the need to decrease the role of government in production, while strengthening inspections. Restrictions for the creation of independent unions and reports of land right violations are further challenges.
These dynamics have made retaining and attracting international business partners challenging. Some multinational enterprises are active in textile production, including with financial support from international financial institutions. However, alleged human rights violations have led to formal complaints and to a suspension of the Better Cotton Initiative’s licensing partnership in 2023, although the initiative had only resumed operations in Uzbekistan in 2022. In a public call on authorities, a representative of the American Apparel and Footwear Association stated: “Protection and respect of workers' and farmers' rights to freedom of association and collective bargaining are essential to encourage brands to source cotton products from Uzbekistan. Not only is this the right thing to do and built into brands’ vendor contracts, but growing regulations worldwide require brands to ensure the protection and respect of workers’ rights.”
Development co-operation actors provide active support. ILO and IFC through the Better Work Programme, Germany’s GIZ and others work with the government and stakeholders to enhance respect for environmental and social standards in cotton production. For example, the Solidarity Centre (funded by the United States and affiliated with US trade unions) and the Center for Private Enterprise (affiliated with US employers) collaborate with workers and management in select cotton clusters. To help attract international investment, the project raises awareness of labour standards, supply chain compliance, and transparency and supports social dialogue and grievance mechanisms at enterprise level.
Source: Abdulla (2023[86]), Better Cotton probes alleged human rights violations at Indorama Agro, https://www.just-style.com/news/better-cotton-probes-alleged-human-rights-violations-at-indorama-agro/; American Apparel and Footwear Association (2024[87]), Uzbekistan Should Emphasize Workers’ Rights to Maintain Momentum for Responsible Sourcing, https://www.aafaglobal.org/AAFA/AAFA_News/2024_Press_Releases/Uzbekistan_Worker_Rights_Responsible_Sourcing.aspx; Better Cotton (2023[88]), Better Cotton Launches Sustainability Roadmap in Uzbekistan, https://bettercotton.org/better-cotton-roadmap-to-strengthen-uzbekistan-programme/; Cotton Campaign (n.d.[89]), The Uzbek Cotton Pledge for Companies, https://www.cottoncampaign.org/uzbek-cotton-pledge; Independent civil society activists (2024[90]), Independent monitoring of working conditions, including child and forced labour, during the 2023 cotton harvest in Uzbekistan (unpublished); ILO (2025[76]), Report of the Committee of Experts on the Application of Conventions and Recommendations, https://www.ilo.org/resource/conference-paper/application-international-labour-standards-2025; Solidarity Centre (2024[91]), Groundbreaking Uzbekistan Cotton Agreement, Project, https://www.solidaritycenter.org/groundbreaking-uzbekistan-cotton-agreement-project/; Uzbek Forum for Human Rights (2024[84]), Risk of Forced Labor Remains High: Government Officials Use Coercion to Address Shortage of Pickers, https://media.business-humanrights.org/media/documents/UZBEK-FORUM_harvest_report_2023_FINAL_LR-1.pdf.
Reinforcing labour inspections will be critical to ensure effective implementation of legal standards. In 2023, the State Labour Inspectorate identified more than 21 000 violations and conducted around 5 000 awareness raising and public engagement activities (figures provided by the Ministry of Employment and Labour Relations). However, ILO reports that labour inspections are insufficiently resourced to conduct sufficiently regular visits, and do not cover the informal economy (ILO, 2021[46]). Labour inspection reports are not published. The ILO Committee of Experts on the Application of Conventions and Recommendations had expressed deep concern at limitations to labour inspections, including the ability to conduct unscheduled labour inspections (ILO, 2025[76]). International bodies have urged Uzbekistan to adequately resource and strengthen the State Labour Inspectorate and enable unannounced inspections in line with ILO standards (UN Committee on Economic, Social and Cultural Rights, 2022[92]; ILO, 2025[76]).
A recent change to the inspection system could lead to improvements. Starting in 2025, a decree foresees that inspections can be conducted and only subsequently notify the Business Ombudsman, where inspections serve to prevent harm (Republic of Uzbekistan, 2024[93]). This includes inspections related to forced labour, child labour and accidents. Moreover, the new system foresees a digitalisation of a risk analysis framework to target activities for prevention and inspections at businesses that present medium and high risks. It will be essential to monitor whether this new system enables inspections to fulfil their role in practice, including through unannounced inspections, and whether the new risk assessment does not impede inspections where they would be warranted.
7.5.3. Environmental issues
Environmental impacts of business operations are significant in Uzbekistan (see also Chapter 6 on Promoting Green Investment in Uzbekistan). Economic activities have caused and are still causing severe negative environmental impacts in Uzbekistan, such as water scarcity, land degradation and pollution (Ministry of Ecology, Environmental Protection and Climate Change, 2023[94]). This directly affects the well-being, health, and livelihoods of the population. While foreign investments in the renewable energy sector have increased, supporting Uzbekistan’s green transition, the high share of fossil fuels and levels of energy consumption relative to GDP (one of the highest in the world) contribute to air pollution and climate emissions and underline the need to invest in renewable energy and energy efficiency (IEA, 2022[95]).
Managing the environmental impacts of business activities is increasingly a policy priority (see also Chapter 6 on Promoting Green Investment in Uzbekistan). Adopted in 2019, the Concept on Environmental Protection until 2030, foresaw in particular strengthening of environmental impact assessments (including through public participation), state inspections and increased penalties in case of non-compliance and better monitoring of pollution (Republic of Uzbekistan, 2019[96]). The concept also planned that businesses, whose activities are defined under Uzbek legislation as high-risk, need to have an environmental service and provide mandatory regular training. Strategy Uzbekistan 2030 has set new and reaffirmed important environmental policy objectives related to business activities. These include reducing greenhouse gas emissions by 30% from 2010 to 2030, improving monitoring, increasing energy efficiency and introducing green labels, enhancing water efficiency in agriculture and industry, modernising emissions management and monitoring, preventing air pollution, and reforestation and rehabilitation of land degraded from agriculture and mining (Republic of Uzbekistan, 2023[3]).
Regulation and policy action aims to reduce the environmental impacts of businesses. A suite of laws and regulations set standards for managing pollution, waste management, energy efficiency and environmental protection. They are accompanied by support programmes to introduce air and water filters, water efficient techniques such as drip water irrigation, and certification of environmental standards and energy management (Ministry of Ecology, Environmental Protection and Climate Change, 2023[94]).13 Environmental impact assessments (EIAs) are a critical tool for assessing risks prior to a new project. The government strengthened their use, while a 2021 Law on Environmental Audits requires annual verifications for high-risk activities (Republic of Uzbekistan, 2021[97]; Republic of Uzbekistan, 2021[98]). In 2021, a new cabinet resolution clarified the obligations of businesses that cause environmental damage, with the amount of damages proportionate to the extent of the pollution (Republic of Uzbekistan, 2021[99]). The experience from Kazakhstan could also be of interest to Uzbekistan: in 2021, Kazakhstan adopted a new Environmental Codex that promotes the continuous adoption of best available techniques (BAT) to enhance companies’ environmental performance (IEA, 2022[100]; OECD, 2025[70]).
The full implementation of environmental standards remains a work in progress. Environmental inspections identify violations and apply fines to companies. However, the government recognised that monitoring has not been sufficiently effective and fines not sufficiently dissuasive, highlighting illegal logging, groundwater use and pollution as key issues (Republic of Uzbekistan, 2023[101]). Examples such as the operation of a cement production near a nature protected reserve indicate indeed that even for businesses identified as high risk, controls are not fully effective (Government of Uzbekistan, 2022[102]). In response, the government decided to strengthen environmental monitoring, including automated monitoring at industry sites, and severely increase administrative and criminal sanctions (Republic of Uzbekistan, 2023[101]; OECD, 2025[70]). It is also introducing “green certifications”, an audit to confirm a company’s respect for environmental standards. The planned introduction of climate monitoring, reporting and verification, including databases for a greenhouse gas registry, would further enhance controls in the sphere of climate change (Government of Uzbekistan, 2024[103]).
The government is taking action to enhance the relevance of EIAs and strengthen accountability. The government’s conclusions on EIAs are published online,14 as are ratings of services providers that conduct assessments on behalf of companies.15 A recent decision allows withholding financial support for facilities that cannot demonstrate a positive environmental impact assessment (Republic of Uzbekistan, 2023[104]). The law on EIAs is currently being revised: this provides an opportunity to enhance space for public consultation (see stakeholder engagement) and to connect environmental with social impact assessments that could consider for example the effects on land rights, livelihoods, and vulnerable groups.
7.5.4. Bribery, corruption and business integrity
Uzbekistan has enhanced its legislation to fight corruption and enhance business integrity. It enacted its first comprehensive “Law on Combating Corruption” in 2017, which introduced a broad set of measures aimed at preventing corruption, including strengthened parliamentary and public oversight of state bodies, whistleblower protection, and the promotion of ethical conduct among public sector employees (OECD, 2024[105]; OECD, 2024[106]). Complementing these efforts, Uzbekistan adopted a Law on Conflict of Interest in June 2024, providing detailed guidance and tools for conflict-of-interest management (OECD, 2024[105]). Anti-corruption measures have also been included in legislation on procurement and public-private partnerships.
The institutional framework for the fight against corruption has also been strengthened. A dedicated anti-corruption agency was created in 202016 to guide and co‑ordinate anti-corruption efforts and compliance with international anti-corruption instruments, including the UN Convention against Corruption and the Istanbul Anti-Corruption Action Plan of the OECD Anti-Corruption Network for Eastern Europe and Central Asia (ACN)17. The Business Ombudsman supports businesses facing challenges in their dealings with other public institutions (including on corruption) and provides access to remedy. Uzbekistan has also invested in greater transparency, through information registers and publicity for all procurements through an online platform and reinforced obligations for financial reporting; in addition, increased digitisation reduces opportunities for corruption from manual management (Anti-Corruption Agency, 2023[107]).
While progress on anticorruption is visible, challenges persist. Uzbekistan stands out by having improved its ranking in Transparency International’s Perception of Corruption Index (TI) in the region (Transparency International, 2024[108]). However, businesses report frequently facing corruption in their dealings with the authorities regarding licences and land issues or when accessing loans: surveying nearly 2 500 businesses in 2023, 8% of respondents indicated they always encounter corruption and 34% sometimes (Anti-Corruption Agency, 2023[107]). Moreover, businesses may refrain from reporting cases of corruption out of fear of retaliation by public agents (OECD, 2024[106]). This raises concerns, as corruption enables adverse impacts of business activity such as environmental violations or abuses of human and labour rights (OECD, 2023[10]). Positively, it can be noted that around two-thirds of respondents considered that corruption had decreased, a perception confirmed in regular surveys of the World Justice Project Rule of Law Index that show a significant improvement since 2021 (World Justice Project, n.d.[109]).
Corporate governance frameworks on anti-corruption present important gaps. The recent ACN monitoring exercise of the OECD highlighted concerns regarding anti-corruption regulations and their application. These relate to the voluntary nature of anti-corruption standards for private businesses, the lack of an oversight mandate for boards, insufficient monitoring of compliance with corporate governance, information on beneficial ownership and application of sanctions (OECD, 2024[106]). Boards play an important role in overseeing the risk management function of companies, including as related to RBC (OECD, 2018[12]), thus the recommendations related to oversight mandate for boards can be of particularly importance for promoting better risk management also when it comes to environmental and social impacts.
The anti-corruption framework for SOEs has considerably improved but gaps remain. In 2023, the government updated the Rules of Corporate Governance to align them with international standards of financial management and reporting (Republic of Uzbekistan, 2023[110]). The corporate governance framework for SOEs contains compulsory rules on managing risks of corruption, through risk identification, dedicated risk management and oversight services, as well as rules on conflict of interest and whistleblowing. It is complemented by a model code of ethics and these documents were shared with 62 SOEs for integration into their management procedures (Daryo.uz, 2023[111]). The State Asset Management Agency UzSAMA supports SOEs on anti-corruption, as part of wider work on managing ESG risks. The IMF encouraged these reform efforts to continue, to achieve comprehensive and transparent reporting of SOEs (IMF, 2024[112]; Government of Uzbekistan, 2024[113]; Government of Uzbekistan, 2020[114]). Many key policies and procedures are in place, including for risk management, compliance, and the due diligence of business partners. SOEs make key information publicly available. Moreover, a dedicated Openness Index18 by the Anti-Corruption Agency assesses the performance of public institutions including SOEs. Gaps in SOE practice concern notably the transparent and merit-based nomination of supervisory boards and company leadership (OECD, 2024[106]). Uzbekistan reports that competitive selections for executive positions were conducted in several cases in 2024.
Voluntary measures aim to reinforce business integrity, but uptake could improve. The Anti-Corruption Agency and Business Ombudsman organise a regular business integrity forum to raise awareness. An Anti-Corruption Business Charter was adopted in 2021 (Anti-Corruption Agency, 2023[107]; Business Ombudsman, 2021[38]).19 The Charter encourages businesses to adopt measures aimed at preventing corruption in procurement and contracts, including through internal oversight, compliance, and training. The Charter is accompanied by procedures to govern adhesion, possible exclusion and publication in a registry. Some five hundred companies have adhered to the Charter and the government is making efforts to encourage greater participation. It should also be noted that Uzbekistan is not member of the Extractive Industries Transparency Initiative (EITI), contrary to, for example, Kazakhstan and Mongolia,20 although the mining sector is highly relevant for its economy.
7.6. Trade and investment policies to encourage RBC
Copy link to 7.6. Trade and investment policies to encourage RBCGovernments can encourage RBC in investment and trade policies and agreements, including through an expectation that businesses under the scope of these policies and agreements implement RBC standards (OECD Recommendation on the Role of Government in Promoting RBC [OECD/LEG/0486]).
7.6.1. Trade and investment promotion and facilitation
The review of the legal framework for investments is an opportunity to set out stronger expectations for RBC. The 2019 Law on Investments and Investment Activity stresses the obligation of investors to comply with legal requirements, such as on anti-corruption and environmental protection (Republic of Uzbekistan, 2019[115]). The ongoing revision seeks to further integrate concepts related to responsible business conduct: the draft text as shared with the OECD states that the purpose of the law is, inter alia, to promote investments that contribute to the Sustainable Development Goals, developing a green economy, as well as ensuring human rights (see Chapter 4 on the Legal Framework for Investment for further details). The draft law defines promotion of RBC as one of the basic principles of working with investors and investments. It will be important to define measures to achieve these objectives. For instance, the draft law allows additional investment incentives for projects that contribute to Sustainable Development Objectives. This could be connected with a commitment of investors to observe RBC principles and standards, and disclosure about how they are identifying, preventing, addressing and accounting for adverse environmental and social impacts of their project.
There is no particular reflection of RBC in special economic zones (SEZs). Regulations requires compliance with environmental and labour regulations and excludes some activities with adverse impacts such as arms and tobacco production from the incentives of SEZs (Republic of Uzbekistan, 2020[116]). However, at the practical implementation level, business plans only need to provide information on emissions, and not on environmental and social impacts more broadly (Investment Promotion Agency, n.d.[117]).
Investment promotion could better include and explicitly reflect and promote RBC objectives. The current investment guide lacks references to sustainable development or RBC principles and standards (Ministry of Investments and Foreign Trade of the Republic of Uzbekistan, 2022[118]). Potential investors could be interested in the progress achieved in promoting RBC, and ongoing efforts to address gaps in Uzbekistan. Conversely, when engaging with domestic companies, the investment promotion agency could highlight the relevance of RBC to attract investment, potentially drawing inspiration from the efforts of the agency UzAssets in working with SOEs on ESG risk management (UzAssets, 2024[119])(see below). As an example, Brazil has taken steps to integrate RBC in investment promotion (see Box 7.3). New draft legislation on special free zones proposes the creation of “eco-industrial zones” and “green zones”. In line with this approach, the government could explore attracting investors with strong performance in minimising adverse environmental impacts, or – to go beyond green issues – at businesses that have a put in place RBC due diligence.
Export promotion can play a role in promoting RBC among Uzbek exporters. For example, the Standard and Certification Agency organises seminars for exporters to inform on EU product standards, while the newly established Trade Development Company (Uzbekistan’s export promotion agency) can cover the cost of introducing international standards (Azizov & Partners, 2024[120]). Of around 6 000 exporters, more than 800 have received certifications, including on environmental practices such as organic production in the agri-food sector. To further incentivise RBC, Uzbekistan could offer export promotion services at preferential terms or specific support for companies that invest in observing RBC principles and standards and have risk-based due diligence processes in place, or for products that meet specific environmental or social standards, as a recent programme Türkiye does for example (Box 7.3).
Box 7.3. Brazil and Türkiye integrate RBC in their trade and investment promotion
Copy link to Box 7.3. Brazil and Türkiye integrate RBC in their trade and investment promotionBrazil’s Investment Promotion Strategy foresees the promotion of RBC in Brazil, a collaboration with the Brazilian private sector to study and promote due diligence in FDI and the ESG certification of strategic sectors. Brazil also developed a Model Cooperation and Facilitation Investment Agreement that requires investors to “comply with [..] voluntary principles and standards for a responsible business conduct” and to encourage their business relations to do the same. It has used this model in bilateral investment agreement negotiations.
In 2024, Türkiye’s Ministry of Trade set up a programme to support exporting companies in meeting sustainability expectations of European markets. Companies with a demonstrated commitment to improve are eligible to receive co-financing for consultancy services helping them to develop and implement sustainability strategies. If monitoring shows that a company exceeds certain sustainability parameters, it can use the public “Responsible” label vis-à-vis customers and business partners.
Source: OECD (2024[121]), Promoting responsible business conduct in trade and investment: Latin America and the Caribbean, https://doi.org/10.1787/bf84ff64-en; Government of Brazil, Model Cooperation and Facilitation Investment Agreement, https://investmentpolicy.unctad.org/international-investment-agreements/treaty-files/4786/download; Government of Brazil, Resolução CONINV No. 1 - Aprova o Programa Nacional para Melhoria do Ambiente de Investimentos (Resolution approving the National Programme for Improving the Investment Environment), https://in.gov.br/web/dou/-/resolucao-coninv-n-1-de-6-de-julho-de-2023-494849478; Ministry of Trade of Türkiye (n.d.[122]), Responsible, https://responsible.ticaret.gov.tr/.
7.6.2. Trade and investment agreements
Few Uzbek bilateral trade and investment agreements contain specific references to the protection of human rights, labour standards, or the environment (for more information, please see Chapter 2 on Strengthening Uzbekistan’s Legal and Policy Framework for Sustainable Investment). The Central Asia Trade and Investment Framework Agreement with the United States recognises the importance of providing adequate and effective protection and enforcement of worker rights. As a result, the United States and Uzbekistan have discussed worker rights under their regular policy dialogue under the agreement (Office of the United States Trade Representative, 2024[123]). Uzbekistan could also consider the example of Brazil, where a model agreement integrates RBC (Box 7.3). An analysis of international investment agreements concluded by the G20+ shows that from 2019-2023, 71% of agreements include provisions “intended to promote RBC” (UNCTAD, 2024[124]).
A new EU-Uzbekistan Enhanced Partnership and Cooperation Agreement is expected to reference RBC explicitly. The existing co-operation agreement already foresees co-operation on avoiding and mitigating negative environmental impacts of corporate activities. Negotiations for a new agreement were concluded in mid-2022 (European External Action Service, 2022[125]) and both parties intend to sign the agreement in the near future (Dunyo Information Agency, 2024[126]). Based on the initial draft, the chapter on Trade and Sustainable Development foresees that both parties commit to the promotion of RBC and the implementation of environmental and labour agreements they adhered to, as well as to measures to ensure occupational health and safety and effective labour inspections (European Commission, n.d.[127]). Collaboration on these areas under the agreement could contribute to Uzbekistan’s preferential access to the EU market under the GSP+.
7.7. Exemplifying RBC via the government’s economic role and commercial activities
Copy link to 7.7. Exemplifying RBC via the government’s economic role and commercial activitiesGovernments can promote and exemplify RBC in their role as economic actors and in their commercial activities. By integrating RBC into procurement policies as well as promoting due diligence in public procurement, into frameworks for sustainable finance and non-financial disclosure, as well as in expectations for State-Owned Enterprises, governments can lead by example and incentivise better business practices.
7.7.1. Sustainable finance and non-financial disclosure
Uzbekistan has taken significant steps to mobilise sustainable public finance. As one of the frontrunners in the region, Uzbekistan has successfully issued thematic sovereign bonds, an SDG bond in 2021 and a green bond in 2023, the latter for UZS 4.25 trillion (over USD 300 million) (OECD, 2023[128]). Uzbekistan also introduced a green taxonomy (Republic of Uzbekistan, 2023[129]). Significant potential for further attracting investments in sustainable finance exists (OECD, 2023[128]). Experiences from Kazakhstan and Mongolia in promoting sustainable finance and introducing requirements for non-financial disclosure could inform Uzbekistan’s reflections on further actions (OECD, 2025[70]). For example, Kazakhstan’s sovereign wealth fund Samruk-Kazyna is making efforts to integrate RBC in its activities. Uzbekistan could consider opportunities to promote RBC as institutional investor, a role which might grow further through public offerings of state-owned enterprises (OECD, 2017[130]).
State-owned and private banks are increasingly engaged in sustainable finance. In 2023, state-owned bank SanoatQurilishBank (SQB) (Uzbek Industrial and Construction Bank) issued a corporate green bond and has developed dedicated ESG policies, such as for managing environmental and social risks, with the aim to follow standards of international financial institutions.21 It also adhered to the UN Global Compact in the same year, followed in 2024 by the Business Development Bank; both banks now offer green finance products.
Requirements for non-financial disclosure and reporting of private companies are weak. The corporate governance framework contains no non-financial reporting requirements related to sustainability. A voluntary corporate governance code for joint stock companies introduced in 2015 sets expectations in terms of transparency and establishing a corporate development plan but does not contain expectations about disclosure of non-financial information. Voluntary non-financial reporting is limited (EBRD, 2020[131]). A recent policy change requires ESG-related reporting of SOEs (see State-owned enterprises), and more businesses are interested in sustainability reporting. Promoting sustainability reporting could help avoid diverging reporting practices that would lower their added value, especially when not compatible with internationally recognised standards.
7.7.2. Public Procurement
The state can incentivise RBC of suppliers through public procurement. Public procurement, including by SOEs, is governed by the Law on Public Procurement (Republic of Uzbekistan, 2021[132]). The Ministry of Economy and Finance (MEF) determines the overall procurement policy, regulation, and procedures, while the responsibility for conducting tenders lies with the respective public authorities.
Measures against corruption in procurement have proven useful. The Law on Public Procurement sets out key principles such as inadmissibility of corruption, openness, and transparency. These have translated into obligations to disclose conflicts of interest and sanctions against companies in violation of anti-corruption principles. Since 2018, more than 70 companies were listed in the Unified Register of Unfair Performers and excluded from procurement for two years. However, no case was registered in 2023 (OECD, 2024[106]). Uzbekistan has also expanded digitisation in public procurement procedures, which has enhanced transparency and reduced opportunities for corruption (IMF, 2022[133]).
Green procurement practice is a work in progress. As a principle under the Uzbek legislation, procurement authorities should consider environmental policy priorities. The requirement to consider the full cost of the operating cycle is useful, as it can help reflect the cost of repairs, energy, and resource efficiency of operations (OECD, 2020[134]). Aspects such as energy efficiency or the use of environmentally friendly materials can also be considered on a voluntary basis. However, recent research indicates that Uzbek procurement authorities apply environmental considerations only rarely (Nemec et al., 2023[135]). The MEF sees a positive trend, however, with 16% of “green” procurement procedures in the first quarter of 2024, which can include environmentally friendly technology, sustainable materials and adherence to energy efficiency standards. The ministry is providing trainings and awareness-raising activities and has issued instructions on green procurement that select public institutions are piloting (MEF, 2024[136]). It will be important to continue and step up these efforts so that procurement authorities make full use of opportunities to promote RBC-related considerations in procurement. As an example, Germany has developed the Sustainability Compass22 tool that helps public authorities in identifying where and how they can integrate sustainability considerations in their procurement, drawing on best practices and providing information on specific product groups and labels (OECD, 2020[134]).
Opportunities for stronger integration of RBC-related considerations in procurement exist. In November 2024, an amendment to the Law on Public Procurement introduced the principle of sustainability, requiring consideration of social impacts in addition to environmental considerations (Republic of Uzbekistan, 2024[137]). This is an opportunity to strengthen expectations related to RBC. Existing databases and ratings the government has developed, such as for the performance of suppliers or for tax compliance (“sustainability rating”) could inform the consideration of how such expectations could be applied in practice (Government of Uzbekistan, 2024[138]). In addition to guidelines, training, and support to staff, raising awareness among the business community and in particular SMEs will be essential to ensure that green and sustainable procurement provides an incentive for better performance across the board rather than reduce access to tenders.
7.7.3. Public-private partnerships
Public-private partnerships (PPPs) in Uzbekistan could benefit from active promotion of RBC. Since the introduction of PPPs in 2018 and the adoption of dedicated legislation in 2019, the number and volume of PPPs has grown massively to projects worth around USD 29.6 billion (figure provided by the government). This includes USD 3.2 billion specifically under PPP-legislation (figure provided by the government), while many PPP-projects are concluded under the Law on Investments. As in other countries, many PPPs in Uzbekistan focus on large infrastructure investments such as in energy generation and transmission, transport, heating, and wastewater treatment. Through their potential impacts on people and the environment, infrastructures raise important RBC considerations throughout their life-cycle (OECD, 2025[70]).
RBC considerations can be strengthened in the overall PPP regulatory framework. The Law on PPP (Republic of Uzbekistan, 2019[139]) sets out that corruption is inadmissible, which is particularly important for large-scale and long-term operation models of PPPs. The law does not contain requirements regarding the management of impacts on people or the environment, for instance through relevant criteria in tenders or due diligence in the selection process. A recent regulation requires an analysis of economic and social impacts for large-scale projects (above USD 10 million) (Government of Uzbekistan, 2024[140]). Experience from other countries can inform Uzbekistan’s considerations on how to make the most of PPPs for long-term development. For example, Indonesia’s Ministry of Finance’s developed an ESG Framework for Government Support and Facility for Infrastructure Financing, with standards on environmental protection, climate change, employment and governance issues (Ministry of Finance of Indonesia, 2022[141]; OECD, 2024[142]). Moreover, OECD good practice suggests that Uzbekistan raise public awareness and consult affected populations and stakeholders on the benefits and risks of projects and associate them in monitoring; these would be important mechanisms to avoid or mitigate any negative impacts of PPP (Recommendation on the Principles for Public Governance of Public-Private Partnerships [OECD/LEG/0392]). Partners also see rising interest in high environmental and social standards of PPPs but consider this will need capacity building (Schloemer, 2024[143]).
7.7.4. State-owned enterprises
SOEs are subject to RBC expectations and are expected to lead by example. While Uzbekistan aims to reduce the number of SOEs, they remain major economic actors in 2022: “SOEs still account for more than half of total output […] and dominate key sectors” (IMF, 2022[133]). International instruments on RBC such as the OECD MNE Guidelines and the UN Guiding Principles on Business and Human Rights23 explicitly state that they apply to SOEs. OECD good practice is that “the state as an owner should set high expectations for SOEs’ observance of responsible business conduct standards together with effective mechanisms for their implementation”, as set out in the OECD Guidelines on Corporate Governance of State-Owned Enterprises [OECD/LEG/0414] (OECD SOE Guidelines)24 ([see also the Recommendation on the Role of Government in Promoting Responsible Business Conduct [OECD/LEG/0486]).
Uzbekistan has started integrating expectations on environmental and social issues in the policy and regulatory framework for SOEs. The 2021 “Strategy for managing and reforming state-run enterprises in 2021-2025” contained clear expectations in terms of financial corporate governance and reporting on not-for-profit social engagement by SOEs (Government of Uzbekistan, 2021[144]). The government has also taken a range of actions to enhance corruption risk management (see above). In 2022, the government adopted an action plan to improve the business environment, including measures to “green” SOEs by “promoting greening and ESG systems”. (Republic of Uzbekistan, 2022[145]; Government of Uzbekistan, 2024[113]). The new corporate governance rules require SOEs to adopt environmental, health and safety standards and address labour issues (UzAssets, 2024[146]).
The government actively promotes the management of ESG risks in SOEs. As part of the continued agenda to scale back the state’s role in the economy, the government is expected to gradually decrease its financial engagement in SOEs and privatise SOEs. UzAssets has therefore developed a dedicated roadmap to promote ESG risk management in SOEs from 2024 to 2026 to enhance SOE performance and attract international investors (UzAssets, 2024[119]). This encompasses gap analyses in all three dimensions E, S and G, support for the development of relevant company policies and integration into management systems, audits, and reporting. Key performance indicators include carbon intensity, water usage, emission of pollutants, waste generation, work-related accidents, and financial disclosure in line with international standards. Moving forward, the government could also support SOEs in introducing RBC due diligence, including in identify and address adverse impacts in their supply chains, and also consider the situation of smaller SOEs. This could be based on integrating RBC in a State Ownership Policy, informed by experience from OECD members. For example, Finland’s State Ownership Policy states that SOEs “must ensure that their risk management strategies comply with human rights due diligence. They must integrate human rights’ aspects into their activities and value chains…” (Government of Finland, 2024[147]).
The introduction of mandatory non-financial disclosure of SOEs is an important step forward. As of July 2024, SOEs need to report annually on ESG and corporate social responsibility, the latter being understood as philanthropy in Uzbekistan (Republic of Uzbekistan, 2024[148]). This builds on an earlier requirement of non-financial disclosure for mining companies (Republic of Uzbekistan, 2019[149]). The obligation to report provides a major opportunity to strengthen SOEs’ observance of RBC principles and standards. Methodological guidelines developed by UzSAMA clarify that reporting should encompass risks business operations create for people, planet (incl. biodiversity) and society, illustrated by sample indicators (UzSAMA, 2024[150]).
Promoting meaningful stakeholder engagement would further strengthen Uzbekistan’s efforts. Dialogue with stakeholders is essential to identify risks, design responses and monitor implementation. This enhances the quality of reporting, which in turn enables stakeholders to better engage with the company. ESG reporting guidelines for SOEs accordingly stress the need for information on stakeholder engagement (UzSAMA, 2024[150]). Uzbekneftegaz provides a useful illustration of this approach: stakeholder feedback enabled the firm to identify the issues considered most relevant for its reporting (“material” in the terminology of reporting), with occupational health and safety considered most relevant from both a stakeholder and company perspective (Uzbekneftegaz, 2023[151]). As stakeholder engagement is not yet explicitly covered by UzAssets’ ESG promotion roadmap, the agency could include this aspect to ensure that SOEs engage in dialogue with stakeholders at all stages of ESG risk management.
The promotion of ESG risk management and reporting can build on an existing dynamic. For example, Navoi Mining and Metallurgical Company and gas company Uzbekneftegaz have issued sustainability reports since 2019 and 2021, respectively, and align with the Global Reporting Initiative standards (Uzbekneftegaz, 2023[151]; Navoi Mining and Metallurgical Company, 2023[152]), while others like Almalyk Mining25 and chemical enterprise Uzkimyosanoat26 publish policies on select ESG issues. Certain SOEs have also been rated from an ESG financial risk perspective, as part of their broader corporate rating. All three state-owned mining companies have action plans to achieve an ESG rating and have obtained certifications for practices in environmental, energy and health and safety management (Ministry of Geology Industry and Mining, 2024[153]).
7.8. Promoting stakeholder participation and access to remedy
Copy link to 7.8. Promoting stakeholder participation and access to remedyGovernments can enable RBC by promoting stakeholder participation and ensuring that access to remedy is available. Meaningful stakeholder engagement, i.e. two-way communication in good faith, is one of the basic tenets of RBC (OECD, 2018[12]). The OECD Council Recommendation on the Role of Government in Promoting Responsible Business Conduct [OECD/LEG/0486] recommends that governments promote stakeholder engagement by “[c]reating a conducive environment to enable stakeholders to engage in effectively implementing, monitoring, and promoting RBC, including by providing transparent channels for meaningful consultation and engagement to define challenges or opportunities related to RBC and a safe space for dialogue without undue pressure”. To support persons affected by adverse impacts, governments can enable access to judicial and non-judicial remedies.
7.8.1. Stakeholder engagement
Reforms have created opportunities for stakeholders to engage in public affairs. An online platform27 created in 2016 allows citizens to share feedback on any issue with the government and has become popular (Freedom House, 2024[154]). Specifically for legislation, draft laws are systematically published online for consultation28 and stakeholders use the opportunity to provide comments, though with some challenges (see Chapter 4 on Strengthening Uzbekistan’s legal and policy framework for sustainable investment), including for underrepresented groups (OSCE, 2023[155]). In 2021, the government adopted a decree on access to information and transparency within the system of public administration (Republic of Uzbekistan, 2021[156]); Uzbekistan also hosted a 2022 UNESCO conference that led to the adoption of the Tashkent Declaration on Universal Access to Information (UNESCO, 2022[157]). The 2021 Urban Planning Code stresses the importance of public participation (Republic of Uzbekistan, 2021[158]) and the city of Samarkand held broad consultations with the EBRD’s support when developing its Green City Action Plan (EBRD, 2023[159]). Specifically for the private sector, the government regularly organises sessions of “open dialogue” to allow businesses to express concerns and grievances.
Public consultation linked to environmental impact assessments could be further strengthened (see also Chapter 6 on Promoting Green Investment in Uzbekistan). Positively, early consultations are mandatory for higher-risk category 1 and 2 projects; companies must document in their submissions to the Ministry of Ecology how public feedback was incorporated into their proposals. Timelines for public review are tight, however (see Chapter 6 on Promoting green investment in Uzbekistan). Allowing the public and civil society organisations (CSOs) to provide feedback at later stages of the process could help ensure that project design and implementation effectively consider their concerns (World Bank, 2023[160]). Civil society feedback also suggests that consultation practice does not always meet expectations by limiting consultation interviews to authorities rather than directly affected communities (Lesikhina and Kožmínová, 2022[161]). Uzbekistan is considering acceding to the UNECE Convention on Access to Information, Public Participation in Decision-making and Access to Justice in Environmental Matters (Aarhus Convention), which could strengthen public consultation processes (UNECE, 2023[162]).
Civil society’s capacity to hold businesses to account would benefit from fewer restrictions to freedom of association. The opening of the country since 2017 has led to a significant increase in the number of CSOs. However, the UN Human Rights Committee expressed its concern at legal restrictions (UN Human Rights Committee, 2020[163]) leading to a high number of rejected requests of registration, affecting also organisations focusing on human rights. Partnering with and obtaining funding from international civil society organisations is challenging, as the 2022 Law on Non-Governmental Organisations regulates procedures for implementing projects of NGOs receiving funding, obliging them to involve “national partners” or employees of state agencies recommended by the Ministry of Justice (Republic of Uzbekistan, 2022[164]). Related procedures were then simplified (International Centre for Not-for-Profit Law, 2023[165]). In the Universal Periodic Review, several UN member states recommended that Uzbekistan lift restrictions and facilitate freedom of association (UN Human Rights Council, 2023[34]). This would be important for civil society organisations that monitor business activity, including state-owned enterprises, and flag concerns to the authorities and the public.
Promoting freedom of expression increases the ability of stakeholders to provide feedback on and oversight of business performance related to RBC. The legal framework still contains a broad range of provisions that are used to restrict freedom of expression (Article 19, 2022[166]) (Human Rights Watch, 2024[167]). In 2023, a public appeal by journalists, bloggers, political scientists and civil society activists to the President of Uzbekistan called for better protection against obstacles, pressure and intimidation (Gazeta.uz, 2023[168]). In Freedom House’s Global Freedom assessment, Uzbekistan is ranked as not free, at a significant distance from countries considered partly free29 (Freedom House, 2024[154]). Such restrictions make meaningful stakeholder engagement challenging. There are also reports of harassment, intimidation and retaliation against human rights defenders (OHCHR, 2023[169]; Special Rapporteur on the right to adequate housing, 2024[64]). Numerous member states of the United Nations Human Rights Council therefore recommended that Uzbekistan take measures to guarantee freedom of expression and to protect human rights defenders (UN Human Rights Council, 2023[34]). This would be important to ensure citizens, media and civil society organisations can flag possible human rights impacts of businesses, including state-owned enterprises (SOEs), and encourage public debate.
7.8.2. Access to remedy
Courts play an important role in providing access to remedy, which needs to be further strengthened. Interviews indicated that workers frequently bring labour-related disputes to the courts, which are often decided in their favour. Pre-trial mediation is available based on the Law on Mediation. The revised constitution and legislation have affirmed the independence of the judiciary, while further progress may be needed in practice (UN Human Rights Committee, 2020[163]; Special Rapporteur on the right to adequate housing, 2024[64]) (see also Chapter 4 on Strengthening Uzbekistan’s legal and policy framework for sustainable investment). Since 2017, the government has been promoting reforms of the judicial system (The Permanent Mission of the Republic of Uzbekistan to the United Nations, 2022[170]). Judicial staff also receive training on human rights (Government of Uzbekistan, 2023[171]). UN Member States have welcomed these efforts and encouraged Uzbekistan to further enhance the independence of the judiciary (UN Human Rights Council, 2023[34]).
Non-judicial mechanisms provide an important complement and enhance access to the court system. In particular, the Human Rights Ombudsman receives numerous applications from citizens. Many of those relate to RBC issues, such as alleged infringements of labour rights, property rights or environmental violations of businesses. The Ombudsman intercedes on behalf of citizens with the authorities and supports their access to the courts (see Box 7.4). Specifically for labour rights, trade unions support access to remedy by providing a legal clinic and advice to members and referring cases to labour inspections or the court system. In countries that have adhered to the OECD MNE Guidelines, National Contact Points provide an additional non-judicial grievance mechanism (see Box 7.5).
Box 7.4. The Human Rights Ombudsman provides access to remedy
Copy link to Box 7.4. The Human Rights Ombudsman provides access to remedyResolving labour rights issues
In 2022 and 2023, the Ombudsman examined almost 900 appeals per year related to labour issues, corresponding to 27% of all applications in 2023. In 2023, the Ombudsman helped recover UZS 911 million (around USD 70 000) in wage payments and helped ensure administrative responsibility of nine employers. As an example of the Ombudsman’s support in 2022, the office supported the claim of a citizen whose contract was terminated during childcare leave. In addition to the citizen’s lawsuit against the company, the Ombudsman filed a claim for moral damages, which the court granted. In 2022, the Ombudsman and the Federation of Trade Unions of Uzbekistan signed a memorandum to strengthen their collaboration.
Flagging alleged business violations of the environment to the authorities
In 2022, citizens informed the Ombudsman about water pollution from industrial waste in a district in Tashkent province that was affecting their and their children’s health, impacting their livestock and creating risks for the environment, including possible waste inflow into the Syr Darya river. The Ombudsman interceded on their behalf with the State Committee of Ecology and Environmental Protection. The subsequent investigation led to sealing the equipment, administrative measures against company management as well as an instruction to the authorities to prevent future pollution.
Analysing a number of citizens’ appeals in the area of environment, the Ombudsman identified the need for measures and shared its conclusions with the local authorities in Tashkent and Syr Darya. In response, the administration took legal action and suspended the activities that damaged the environment.
Source: Submission of the Government to the OECD and reporting by the Human Rights Ombudsman (Authorized Person of the Oliy Majlis of the Republic of Uzbekistan for Human Rights, 2023[172])
Grievance mechanisms of development finance institutions bring to light RBC-related concerns in private sector investment projects. For instance, the EBRD mechanism is examining a complaint regarding a wind farm and possible effects on biodiversity (financed by EBRD together with IFC and ADB) (EBRD, 2024[173]) and human rights violations related to cotton production (financed by EBRD together with IFC) (EBRD, 2023[174]). These grievance mechanisms can also promote continued engagement and dialogue between affected populations, businesses, and other stakeholders. For example, IFC’s Compliance Advisor Ombudsman has been facilitating dialogue around labour rights in cotton production around a case brought to the Ombudsman in 2016 (IFC Compliance Advisor Ombudsman, 2023[175]).
The government indicates that enhancing dispute resolution is a priority under the draft action plan for business and human rights. Simpler cases that might not require a judicial remedy and could be resolved easier and quicker through other mechanisms, an approach the draft action plan could support. State-owned enterprises already have a legal obligation to provide for a complaints procedure, under a law that applies to all public institutions (Republic of Uzbekistan, 2017[176]). Some SOEs provide detailed information about the procedure in their sustainability reporting. As a positive example for private enterprises, where operational level grievance mechanisms seem much less frequent, Korzinka (a supermarket company) sets out rules for complaints on its website (Korzinka, n.d.[177]). Promoting operational-level grievance mechanisms in the private sector could be an important complement to strengthen access to remedy at a wider scale. For both SOEs and private enterprises, it could also be useful to explore to what extent the complaints procedures are used to their full potential. For example, effectiveness criteria under the UN Guiding Principles on Business and Human Rights also stress the importance of transparency, dialogue and engagement with stakeholders and continuous learning (OHCHR, 2024[178]).
Box 7.5. National Contact Points for Responsible Business Conduct
Copy link to Box 7.5. National Contact Points for Responsible Business ConductNational Contact Points for Responsible Business Conduct (NCPs) have a mandate to promote awareness and uptake of the OECD MNE Guidelines and to provide a non-judicial grievance mechanism for cases (called specific instances) put before them. They may also provide support to government policies and efforts to promote RBC.
A set of criteria for NCPs helps ensure quality and effective case handling.1 By the end of 2024, NCPs had received more than 700 specific instances, accessible in a public database. Eight of these cases concerned business operations in Uzbekistan, the latest of which was submitted in 2014 to the NCP of Korea. Most cases concerned allegations of forced labour and child labour, linked to Uzbekistan’s past challenges in this regard.
In countries who have adhered to the OECD Declaration on International Investment and Multinational Enterprises and the OECD MNE Guidelines annexed to the Declaration, National Human Rights Institutions and National Contact Points complement one another. The specificity of the NCPs is their expertise on RBC, the role of stakeholders in their institutional set-up and functioning, and their access to the network of other NCPs and support from the OECD.
In Central Asia, Kazakhstan provides a valuable example of an NCP that has gradually expanded its promotional work, has already managed a number of cases and was peer reviewed in 2023/2024. Kazakhstan’s experience could therefore prove valuable to Uzbekistan, should the country opt to establish a lead institution for RBC with a responsibility to provide a non-judicial access to remedy.
1. These are: Visibility; Accessibility; Transparency; Accountability; Impartiality and equitability; Predictability; and Compatibility with the Guidelines.
Source: OECD (2023[10]), OECD Guidelines for Multinational Enterprises on Responsible Business Conduct, https://doi.org/10.1787/81f92357-en; OECD (2024[179]), National Contact Point for Responsible Business Conduct Peer Reviews: Kazakhstan 2024, https://doi.org/10.1787/9090c11f-en; OECD (2018[180]), Global Forum on Responsible Business Conduct: The role of National Contact Points and National Human Rights Institutions in RBC policy making, https://mneguidelines.oecd.org/global-forum/2018-GFRBC-Session-Note-The-Role-of-NCPs-NHRIs-in-RBC-policy-making.pdf; OECD Database of Specific Instances: https://mneguidelines.oecd.org/database/.
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Notes
Copy link to Notes← 1. See: https://mneguidelines.oecd.org/due-diligence-guidance-for-responsible-business-conduct.htm.
← 2. Top 5 export destinations in 2024 were Switzerland, Russia, China, Türkiye and Kazakhstan, top 5 origins of imports China, Russia, Kazakhstan, Korea and Türkiye (Observatory of Economic Complexity (OEC), n.d.[181]).
← 3. The guidelines are an annex to the OECD Declaration on International Investment and Multinational Enterprises.
← 5. The regulation and highlights that impact materiality is determined through a due diligence process, such as in the OECD MNE Guidelines.
← 7. In 2023, exports to China from Uzbekistan amounted to USD 2.46 billion, and imports from China to USD 11.26 billion (figures provided by MIIT). Since 2009, China is the most important source of China of FDI inflows, with a share of 25.6% in 2023 (see Chapter 2 on Trends and impacts of FDI in Uzbekistan).
← 8. Disbursements, USD current, OECD Data Explorer,DAC2A: Aid (ODA) disbursements to countries and regions, https://data-explorer.oecd.org/.
← 9. In Asia, Indonesia, Japan and Thailand have all adopted National Action Plans on Business and Human Rights.
← 10. Particularly relevant for SMEs, due diligence expectations should be “proportionate to the size of the enterprise, its involvement with an adverse impact and the severity of adverse impacts” (OECD, 2023[10]).
← 11. The shares of women in management (between 4% and 14% by sector) and boards of SOEs (9%) remains very low (Republic of Uzbekistan, 2024[182]).
← 12. These are Conventions: No. 81 and No. 129 on labour inspections (ratified in 2019), No. 144 on Tripartite Consultation (2019); No. 187 on Promotional Framework for Occupational Safety and Health (2021), No. 167 on Safety and Health in Construction (2022); No. 148 on Working Environment (2023); No. 155 on Occupational Safety and Health (2024); No. 95 on Protection of Wages (2024), No. 156 on Workers with Families (2024); No. 132 Holidays with Pay (2025) and No. 175 on Part-Time Work (2025) (ILO, 2025[184]).
← 13. A recent addition to this framework includes a programme to improve the air quality in Tashkent (Republic of Uzbekistan, 2024[183]).
← 17. See https://www.oecd.org/en/networks/anti-corruption-network-for-eastern-europe-and-central-asia.html.
← 19. The authorities and the Chamber of Commerce and Industry also developed a draft Code of Ethics for Doing Business of Uzbekistan in 2021, but this was not adopted.
← 23. Principle 4: “States should take additional steps to protect against human rights abuses by business enterprises that are owned or controlled by the State”.
← 24. The Recommendation of the Council on Guidelines on Corporate Governance of State-Owned Enterprises was updated in 2024.
← 29. Uzbekistan is reported with a score of 12/100, with the first country ranked partly free has a score of 32/100.