For SOEs, which often operate in strategic sectors and deliver public services, responsible business conduct (RBC) is both a governance imperative and a practical tool to mitigate legal, reputational and operational risks. This chapter first outlines RBC-related expectations in the SOE Guidelines. It then focuses on two practical areas where RBC is particularly relevant for SOEs: stakeholder engagement and the development of strong anti-corruption and integrity systems. Together, these elements provide the behavioural foundation for sustainable and resilient SOEs.
State‑Owned Enterprises and Sustainability
Leading by Example
Abstract
The growing presence of SOEs in the global marketplace and value chains has brought increased attention to the importance of responsible business conduct (RBC). RBC refers to the expectation that enterprises avoid and address adverse impacts of their operations on people, the planet and society, and contribute positively to sustainable development (OECD, 2023[1]).
The state as an owner should set high expectations for SOEs’ observance of responsible business conduct standards together with effective mechanisms for their implementation, should fully recognise SOEs’ responsibilities towards stakeholders and should request that SOEs report on their relations with stakeholders. Such owner’s expectations should be publicly disclosed in a clear and transparent manner (Guideline VII.D).
As recommended by the SOE Guidelines, the state as an owner should set high expectations for SOEs’ observance of RBC standards, along with effective implementation mechanisms. RBC and sustainability are closely linked, and many enabling conditions for RBC (such as risk-based due diligence and transparency and disclosure) are addressed in earlier chapters. This chapter begins by outlining key RBC concepts and instruments and their link to the SOE Guidelines (Section 5.1), and then examines two key areas not previously covered, stakeholder engagement (Section 5.2) and anti-corruption and integrity (Section 5.3).
5.1.1. Concept of RBC and key instruments
RBC is increasingly central to enable corporate sustainability. The “RBC concept” has two core objectives:
Enterprises are expected to contribute positively to economic, environmental, and social progress in the countries where they operate, and advance sustainable development outcomes.
Enterprises are expected to avoid and address adverse impacts, whether caused by their own activities or linked to their operations, products, or services through business relationships.
The OECD has developed a framework of instruments aimed at promoting responsible business practices and helping governments create enabling environments for RBC. Key among these are:
The OECD Guidelines for Multinational Enterprises on Responsible Business Conduct (MNE Guidelines). The MNE Guidelines are the most comprehensive international standard on RBC. They are recommendations from governments to businesses on how to act responsibly across a wide range of areas: human rights, labour relations, the environment, anti-corruption, taxation, consumer interests, disclosure, and more. The Guidelines were updated in 2023 to reflect evolving priorities, including climate change and technological transformation. The MNE Guidelines are also aligned with and complement other leading international standards on RBC, including the UN Guiding Principles on Business and Human Rights and the ILO Tripartite Declaration of Principles concerning Multinational Enterprises and Social Policy.
Due Diligence Guidance on Responsible Business Conduct. At the heart of RBC is risk-based due diligence, a process through which enterprises can identify, prevent, mitigate, and account for how they address actual and potential adverse impacts. As further elaborated in Chapter 3, the OECD has developed a cross-sectoral due diligence instrument to support this process, as well as sector-specific guidance, focusing on minerals and extractives, agriculture, garment and footwear, and financial sectors, to help mitigate RBC-related risks in company operations, supply chains and business relationships.
National Contact Points (NCPs). To ensure their implementation, countries that adhere to the Guidelines are required to establish NCPs. These NCPs have two main functions: (i) to promote awareness and uptake of the MNE Guidelines; and (ii) to serve as a non-judicial grievance mechanism through the handling of “specific instances” of non-compliance. As of 2024, NCPs had handled more than 620 specific instances in over 105 countries, and continue to play a key role in promoting corporate accountability globally (OECD, 2024[2]).
Recognising the essential role of public policy in fostering responsible conduct, the OECD adopted in 2022 a Recommendation on the Role of Government in Promoting Responsible Business Conduct to guide governments in this regard. Broadly, it encourages governments to embed RBC expectations across areas, including legal and regulatory frameworks, trade agreements, public procurement, and co-operation frameworks. Importantly, it also includes provisions for the state to lead by example in terms of state ownership practices (Figure 5.1).
Source: OECD (2022[3]) Recommendation of the Council on the Role of Government in Promoting Responsible Business Conduct, https://legalinstruments.oecd.org/en/instruments/OECD-LEGAL-0486
5.1.2. RBC requirements and expectations for SOEs
Some economies explicitly reference RBC in their ownership policies (see Table 2.3). These expectations often incorporate stakeholder consultation practices (OECD, 2022[4]). For example, in the Netherlands, the state has set expectations for Dutch SOEs to develop RBC policies and to further strengthen them if necessary. This is translated by SOEs into concrete policies, such as the Dutch state’s entrepreneurial development bank, FMO, which revised its sustainability policy to describe how RBC is implemented within its operations as a financial institution (Box 5.1).
FMO is a Dutch development bank, majority-owned by the Dutch government (51%) but operating as a commercial company. It provides long-term capital to projects in developing countries where private investors are often reluctant to engage, with a strong focus on achieving both financial returns and positive environmental and social impact. FMO manages funds on behalf of the Ministries of Foreign Affairs and Economic Affairs and promotes responsible business conduct (RBC) through several policies:
FMO’s responsible finance approach: FMO’s responsible finance approach precludes the bank from engaging in certain consumer finance activities. It supports the adoption of Client Protection Principles (CPPs) which are embedded in the investment process. The CPPs aim at facilitating a risk-based assessment of financial institutions, non-banking financial institutions and corporations providing finance to natural persons. CPPs define the minimum standards that end-clients should expect to receive when doing business with a financial service provider.
Business integrity and anti-money laundering: FMO’s investee companies – including their owners, directors, managers and other key staff – need to comply with FMO’s policies on business integrity and anti-money laundering. FMO maintains a zero-tolerance policy regarding bribery and corruption. FMO’s Know Your Customer (KYC) Policy describes FMO’s participation in international efforts to fight money laundering and terrorist financing.
Human rights due diligence: the IFC Performance Standards guide FMO’s human rights due diligence with respect to customers. FMO requires customers to assess the likelihood and severity of adverse impacts on human rights as part of their assessment of social and environmental impact, and to implement mitigation measures in line with the IFC Performance Standards. In case environmental, social or human rights impacts are identified that the IFC Performance Standards do not sufficiently address, FMO will identify and agree on mitigants by referring to the other standards.
Source: FMO, 2024, Sustainability Policy, https://www.fmo.nl/l/library/download/urn:uuid:c4d8ec12-9257-464f-8154-bf111ea07ce6/2024.01_sustainability+policy.pdf
Expectations for companies – state-owned and private – can also be articulated within broader national strategies. For example, Canada launched in 2022 a national strategy called “Responsible Business Conduct Abroad: Canada’s Strategy for the Future” (2022-2027), which was developed in consultation with SOEs. The Strategy aims at supporting Canadian companies abroad adopt responsible business practices, gain a competitive edge, manage risks, and support inclusive economic recovery. One key enabler is ensuring policy coherence across federal departments, SOEs, subnational governments, and Indigenous peoples, who receive support from Canada’s Trade Commissioner Service on issues such as human rights, environmental risks, and due diligence (Government of Canada, 2022[5]).
Beyond national policies, RBC is increasingly embedded in legal and regulatory requirements. Many jurisdictions have begun translating due diligence expectations into legislation (e.g. France, Germany, Netherlands, Norway). At the EU level, the Corporate Sustainability Due Diligence Directive (CSDDD) was adopted in 2024.1 It requires large companies operating in the EU to implement risk-based due diligence procedures to address adverse human rights and environmental impacts across their global value chains. The EU has also introduced regulations on conflict minerals, batteries, deforestation and forced labour (EU Council, 2024[6])
Trade agreements can also serve as instruments to advance RBC. For example, the European Union’s agreements with partner countries include chapters specific to trade and sustainable development which may promote responsible business conduct beyond EU borders. Such agreements may also make explicit reference to their application to SOEs. For instance, the Association Agreement between the European Union and the European Atomic Energy Community and their Member States, on the one hand, and Ukraine, of the other, has a chapter specifically dealing with sustainable development and trade. It explicitly references SOEs and encourages adherence to standards such as the MNE Guidelines.
5.1.3. RBC scope in the SOE Guidelines
Earlier chapters have demonstrated intersections between RBC approaches as outlined in relevant OECD instruments. Within this framework, the SOE Guidelines recommend state owners to:
set high expectations for SOEs’ conduct, particularly with regard to integrity and stakeholder engagement
ensure that SOEs respect stakeholder rights and foster meaningful stakeholder dialogue
avoid the misuse of SOEs for political finance, patronage, or personal gain
require regular and transparent reporting on stakeholder relations and responsible conduct.
Beyond setting expectations, state owners should also support implementation. This includes measures such as:
supporting and participating in multistakeholder dialogue
ensuring adequate access to remedy (through judicial and non-judicial mechanisms). The mechanisms for reporting violations should be transparent and unbiased. They should offer legal protections for whistleblowers who report misconduct (e.g. related to social or environmental issues, corruption, or human rights violations).
The following sections of this chapter examine how countries are putting these expectations into practice, with a focus on stakeholder engagement and anti-corruption and integrity.
Stakeholder engagement is a key component of RBC and sound corporate governance. The MNE Guidelines recommend enterprises to “engage meaningfully with relevant stakeholders or their legitimate representatives as part of carrying out due diligence and in order to provide opportunities for their views to be taken into account with respect to activities that may significantly impact them (…)” (OECD, 2023[1]). 2
This is especially relevant for SOEs, which often operate in high-risk sectors and provide public goods and services (e.g. water, electricity, transport). As such, SOEs tend to have a broader and more diverse stakeholder base than privately-owned companies. In line with the SOE Guidelines (VII.D), SOEs should acknowledge the importance of stakeholder relations, including those with workers, creditors, customers, suppliers, and affected communities. Importantly, workers are a specific stakeholder group for which tailored engagement and consultation mechanisms may be necessitated reflecting their specific rights and interests (e.g. enshrined in labour law and/or governance arrangements). Their engagement requires tailored mechanisms and protections that go beyond typical stakeholder consultations. This includes, for example, collective bargaining rights, representation on boards or advisory bodies, and access to grievance mechanisms.
Stakeholder engagement can also contribute to SOEs’ resilience, as it supports them with the identification of their material sustainability-related risks and opportunities, as well as the impact of their activities on the environment and society more broadly. It can also be an effective response to the evolving trend of grievances and sustainability-related litigation against companies, which in some cases involve SOEs. An example includes the United Nations challenging a large SOE involved in the oil and gas sector over climate change concerns in 2023 (Box 5.2). As noted in Section 3, in some jurisdictions, directors’ duties also include the obligation to take into account stakeholders’ interests. Failing to adequately consider and communicate potential negative externalities to stakeholders may entail legal risks for the enterprise and its board. As demonstrated by a 2022 OECD survey, the corporate sector has witnessed a rise in sustainability-related litigation, partly due to stakeholder activism (OECD, 2022[7]).3 Engaging stakeholders early and transparently can reduce litigation risk and ensure stakeholders’ interests are taken into account effectively.
In June 2023, the United Nations (UN) Working Group on Business and Human Rights issued a public communication expressing concern about the climate-related human rights impact of the state-owned oil and gas company Saudi Aramco. The communication signals growing expectations that SOEs uphold international human rights standards – particularly in relation to climate change and environmental harm.*
According to UN experts, the continued crude oil production and further exploration of oil and gas of companies with an already important carbon footprint may threaten “the enjoyment of the right to a healthy environment” and contribute to undermining the Paris Agreement. Referring to the UN Guiding Principles on Business and Human Rights (UNGPs), which outlines the responsibilities of both states and businesses with respect to the impact of climate change on human rights, the communication underscored that SOEs may carry "increased responsibility" to act in line with international standards. It also stated that financial institutions supporting such companies may be expected to take “reasonable steps” to prevent or mitigate the adverse impacts, or risk being “viewed as enabling” them.
It is one of the first times that UN Working Group experts has taken action focused on an SOE’s human rights responsibilities in the context of climate change. Although not a court case, the process reflects how soft law instruments are increasingly used to interpret accountability under international norms, with implications for SOEs and their stakeholders.
Note: *U.N Communications are not legally binding but may influence how governments, courts and other actors interpret corporate responsibilities.
Source: UNFCCC (UNFCCC, 2023[8]), COP28 Agreement Signals “Beginning of the End” of the Fossil Fuel Era, https://unfccc.int/news/cop28-agreement-signals-beginning-of-the-end-of-the-fossil-fuel-era
5.2.1. Operationalising stakeholder engagement
International conventions generally recognise the rights of stakeholders to information, consultation and negotiation. In certain contexts, stakeholders may also be granted such rights by way of law (e.g. labour, environmental protection, tax, human rights, etc.) or through mutual agreements or contracts. For example, the French national railway company, SNCF, has established partnerships with regional authorities and local communities that outline specific rights regarding environmental assessments and community input on infrastructure projects (SNCF, 2019[9]).4
In practice, SOEs should develop an active policy of stakeholder dialogue and consultation which can include practices such as (see also Table 5.1).
formal or informal consultation
whistleblower protections
access to efficient redress mechanisms
representation on advisory bodies or boards.
Note: *Independent offices that investigate complaints against public authorities or organisations, often providing recommendations for resolution.
** Such schemes can be sometimes part of a compensation/privatisation programme that makes employees shareholders, thereby empowering them to elect representatives to the board.
Stakeholder Analysis
An effective stakeholder engagement process should start with a stakeholder analysis or mapping to identify and prioritise key groups and their needs and concerns, based on what is material for the company. Trade unions and workers are considered a key stakeholder group to prioritise. Several methods exist for stakeholder mapping, the most widespread is based on the Mendelow Framework (Box 5.3).
The Mendelow framework helps identify key stakeholders by mapping their individual power (i.e. ability to influence an organisation’s objectives) and interest (i.e. how interested they are in the organisation or project succeeding).
The stakeholders with the highest combination of power and interest are likely to be those with the most influence over an organisation’s objectives. Therefore, they should be fully engaged, while others may be given less attention according to this model.
The matrix must be regularly updated to reflect changing circumstances. For example, individual stakeholders with high interest but low power can increase their overall influence by forming coalitions with other stakeholders to exert greater pressure and thereby increase their power. Conversely, stakeholders with high power but low interest can also be tapped into by simply “awakening” their interest for a specific issue. While useful as a starting base, this framework is generally considered too static and simple to account for relevant stakeholders in more complex organisations. It is generally complemented with richer tools. Alternative frameworks such as the stakeholder salience model (Mitchell, Agle and Wood, 1997) or the AA1000 Stakeholder Engagement Standard (SES) and GRI standards may be more adapted in such circumstances.
After identifying key stakeholders of the enterprise, it is important for a firm to determine a stakeholder engagement policy/strategy, including the appropriate form of stakeholder participation. Several stakeholder engagement methods may be leveraged depending on the stakeholder group and the purpose of the enterprise. A significant body of OECD work on RBC, including the MNE Guidelines, establishes that stakeholder engagement has moved from one-way communication (e.g. informing/reporting) towards interactive two-way dialogue through, for example, meetings, hearings or consultation proceedings. This ensures a more “meaningful” stakeholder engagement (see Box 5.4).
“Meaningful” stakeholder engagement refers to ongoing engagement with stakeholders that is two-way, conducted in good faith and responsive. The elements below are the constituents of meaningful stakeholder dialogue.
Two-way engagement means that parties freely express opinions, share perspectives and listen to alternative viewpoints to reach mutual understanding. Some sharing of decision making power through moving away from the enterprise as a primary decision maker to a more mutual process of decision making between the interested and affected parties is important. It also means that stakeholders are actively involved in driving engagement activities themselves.
“Good faith” engagement depends on the participants of both sides of the engagement. It means that the parties engage with the genuine intention to understand how stakeholder interests are affected by enterprise activities. It means that the enterprise is prepared to address its adverse impacts and that stakeholders honestly represent their interests, intentions and concerns.
Responsive engagement means that there is follow-up on outcomes of stakeholder engagement activities through implementation of commitments agreed on by the parties, ensuring that adverse impacts to stakeholders are appropriately addressed including through provision of remedies when enterprises have caused or contributed to the impact(s), and that stakeholder views are taken into account in project decisions.
Ongoing engagement means that stakeholder engagement activities continue throughout the lifecycle of an operation and are not a one-off endeavour.
Source: Direct quote from OECD (2017[11]), OECD Due Diligence Guidance for Meaningful Stakeholder Engagement in the Extractive Sector, https://www.oecd.org/en/publications/2017/02/oecd-due-diligence-guidance-for-meaningful-stakeholder-engagement-in-the-extractive-sector_g1g65995.html
The use of social media platforms and other new communication technologies is increasingly gaining traction as an effective tool to promote stakeholder engagement. These tools allow enterprises to disseminate information broadly and engage in real-time, two-way dialogue with a wide range of stakeholders, including employees, customers, communities and interest groups. Several studies have shown that social media facilitates cost-effective, inclusive, and interactive communication that helps enterprises both gather feedback and adjust to stakeholder expectations (Paredi et al., 2021[12]). Stakeholder engagement through social media can be initiated directly by SOEs – for instance, through online consultations sessions. Stakeholders, such as workers’ unions or civil society organisations, also use digital platforms to mobilise stakeholder input, raise awareness about specific issues or organise campaigns. An example of a co-ordinated stakeholder dialogue is provided in (see Box 5.5)
Systembolaget is Sweden’s government-owned alcohol retailer. Its mission is to sell alcohol beverages responsibly, focusing on consumer satisfaction and health rather than profit. It is a retail monopoly and Sweden’s only chain liquor shop. The company follows a strict mandate to implement Sweden’s alcohol policy, which is based on public health considerations and focuses on three pillars which the World Health Organization (WHO) has established as best practice: 1) the price of alcohol; 2) limited access; and 3) restrictive regulation of marketing.
Systembolaget organises its stakeholder engagement process by first identifying relevant stakeholder groups and by scoping important key issues that will have to be discussed with them. The company’s stakeholders include civil society, customers, employees, suppliers, and stakeholder organisation groups.
Selected example: protection of children and secondary harm of alcohol
In 2023, Systembolaget initiated a collaboration with the organisations Bris, Maskrobarn, Trygga Barnen and the World Childhood Foundation as part of their stakeholder dialogue process. The aim of the collaboration was to raise awareness of the impact of adult’s drinking habits on children. The outcome of the project was an educational campaign to inform the public on what individuals can do if they see a child being subject to secondary alcohol abuse. It involved the distribution of a pamphlet labelled “Decisive Moments” in Systembolaget’s stores and its partner organisations, for example during seminars and by sending it out to sports clubs, community programmes and all schools in Sweden.
Source: Systembolaget, 2023, Systembolaget Responsibility Report 2023, https://www.omsystembolaget.se/globalassets/pdf/ansvarsredovisning/systembolaget-responsibility-report-2023.pdf.
Finally, stakeholder engagement activities, outcomes and impact should be part of the overall sustainability performance monitoring and evaluation process and should be publicly reported in the enterprise’s annual report, sustainability report, or website content. Effectively reporting on stakeholder issues can support SOEs with demonstrating their willingness to operate transparently and their commitment to co-operation with stakeholders. Such reporting may include progress reports for project-affected stakeholders, reports on stakeholder engagement activities and outcomes to stakeholder participants, amongst other aspects.
Anti-corruption and integrity are fundamental components of sustainability and are often embedded in enterprise-level corporate compliance and risk management systems. They also form a core pillar of the sustainability chapter in the SOE Guidelines. This section explores these components, recognising that anti-corruption merits a focused approach not only due to its prominence the SOE Guidelines, but also because of the availability of complementary instruments, namely the OECD Guidelines on Anti-Corruption and Integrity in State-Owned Enterprises (ACI Guidelines). These tools can support the development of more robust integrity frameworks within the state-owned sector.
In certain countries, state ownership is concentrated in high-risk and carbon-intensive sectors such as the extractive industries and infrastructure, where public and private sectors intersect via valuable concessions and large public procurement projects. Such configurations present heightened corruption risks and integrity challenges for SOEs (OECD, 2018[13]).5
Sustainability in the SOE sector also depends on the ability of state owners and SOEs to effectively prevent, detect and address corruption or other forms of abuse or exploitation. This is not only costly for the public purse, but also harms SOEs’ reputation, trust in government institutions and citizens’ wellbeing particularly where SOEs are involved in the delivery of key public services. It can also distort competition and create conflicts with sustainability goals.
State ownership entities and SOEs should take action to ensure high standards of integrity in the state-owned sector and to avoid the use of SOEs as conduits for political finance, patronage or personal or related-party enrichment (Guideline VII.D.4).
To address these risks, the state owner should adopt clear policies aimed at combating corruption and bribery in SOEs. In practice, many OECD countries have set expectations for SOEs to implement anti-corruption compliance programmes, including whistleblower mechanisms, establish internal audit functions, and adopt transparent procurement processes (e.g. Croatia, Romania, Lithuania).
The OECD recommends that both state owners and SOEs implement the ACI Guidelines to the fullest extent possible, to ensure high standards of integrity in the state-owned sector and to avoid the use of SOEs as conduits for political finance, patronage or personal or related-party enrichment.6
The OECD Guidelines on Anti-Corruption and Integrity in SOEs have four pillars which are designed to work in tandem to address all stages and actors involved in the corporate governance of SOEs.
Source: OECD, (n.d.[14]) Anti-corruption and integrity in state-owned enterprises, https://www.oecd.org/en/topics/sub-issues/corporate-governance-of-state-owned-enterprises/anti-corruption-and-integrity-in-state-owned-enterprises.html.
The ACI Guidelines set out a comprehensive framework built on the following four “pillars” (Figure 5.3):
1. Integrity of the state owner: a culture of ethics and integrity should start at the top. This entails a strong rule of law as its absence may translate in increased risks of interference in SOE decision making and appointments of board members and CEOs, and in favouritism through its varied forms (e.g. nepotism, cronyism, patronage). The state ownership entity in particular – being the main contact point between the state and SOEs – should exemplify high standards of conduct. Integrity in the SOE sector also depends largely on the ownership arrangements in place which should ensure a sufficient level of transparency and independence of the state ownership function as established in the SOE Guidelines.
2. Active and informed ownership: the state should, as an active and informed owner, hold SOEs to high standards of performance and integrity, while also refraining from unduly intervening in the operations of SOEs or directly controlling their management. The different ways the state can be an active and informed owner are elaborated in Chapter 2.
3. Integrity at the enterprise level: develop integrated risk management and internal control systems, as discussed under Section 3.2, that address high-risk areas such as the procurement of goods and services.
4. Accountability and enforcement: ensure proper detection, investigation and enforcement of corruption or related irregularities, and that key processes are entrusted to institutions that are insulated from influence or suppression of said processes or dissemination of public information regarding their conduct.
To ensure SOEs operate in line with high levels of integrity, state owners should set and communicate clear expectations regarding anti-corruption and integrity, notably by identifying and expressing their expectations related to high-risk areas that could include among others: board and senior/top management composition and remuneration, conflicts of interest, hospitality and entertainment, charitable donations and sponsorships, gifts, favouritism, nepotism or cronyism, facilitation payments, solicitation, extortion and lobbying.
To support implementation of responsible business conduct by SOEs, state owners and SOE boards may consider the following practices.
Embed RBC expectations in the state ownership policy. Define clear expectations for SOEs to behave responsibility and avoid adverse impacts across operations and value chains, including by conducting risk-based due diligence. This includes promoting the use of the OECD MNE Guidelines, UN Guiding Principles, and ILO instruments as guiding frameworks for SOE conduct.
Encourage stakeholder engagement at both state and SOE levels. Some countries have supported SOEs in recognising and respecting stakeholders’ rights and interests by adopting structured approaches to stakeholder dialogue. Relevant stakeholders can be identified through stakeholder mapping, analysis of priority groups, and tailored consultation formats (e.g. employee engagement mechanisms that reflect their specific rights). A common aim is to promote meaningful two-way dialogue with relevant stakeholders throughout SOE operations.
Set clear expectations on anti-corruption and integrity. To mitigate corruption risks, many countries have established anti-corruption and integrity safeguards to reduce the risk of conflicts of interest, self-dealing or undue influence in SOE operations. This includes expectations for SOEs to adopt compliance programmes, whistleblower protections and transparent procurement processes, in line with the OECD Guidelines on Anti-Corruption and Integrity in State-Owned Enterprises.
References
[10] ACCA (n.d.), All about stakeholders, https://www.accaglobal.com/gb/en/student/exam-support-resources/professional-exams-study-resources/strategic-business-leader/technical-articles/all-about-stakeholders-part-1.html.
[6] EU Council (2024), Proposal for a Directive of the European Council and of the Council on Corporate Sustainability Due Diligence and amending Directive (EU) 2019/1937, https://data.consilium.europa.eu/doc/document/ST-6145-2024-INIT/en/pdf.
[5] Government of Canada (2022), Responsible Business Conduct Abroad: Canada’s Strategy for the Future, https://www.international.gc.ca/trade-commerce/assets/pdfs/rbc-cre/strategy-2021-strategie-1-eng.pdf.
[2] OECD (2024), Ownership and Governance of State-Owned Enterprises: 2024.
[1] OECD (2023), OECD Guidelines for Multinational Enterprises on Responsible Business Conduct, OECD Publishing, Paris.
[7] OECD (2022), Climate Change and Corporate Governance, Corporate Governance, OECD Publishing, Paris, https://doi.org/10.1787/272d85c3-en.
[3] OECD (2022), Recommendation of the Council on the Role of Government in Promoting Responsible Business Conduct, https://legalinstruments.oecd.org/en/instruments/OECD-LEGAL-0486.
[15] OECD (2020), Implementation Guide: OECD Guidelines on Anti-Corruption and Integrity for State-Owned Enterprises, https://www.oecd.org/content/dam/oecd/en/publications/reports/2019/05/oecd-guidelines-on-anti-corruption-and-integrity-in-state-owned-enterprises_960c4d25/7f7f9fb4-en.pdf.
[13] OECD (2018), State-Owned Enterprises and Corruption: What Are the Risks and What Can Be Done?, https://www.oecd.org/corruption-integrity/reports/state-owned-enterprises-and-corruption-9789264303058-en.html.
[11] OECD (2017), OECD Due Diligence Guidance for Meaningful Stakeholder Engagement in the Extractive Sector, OECD Publishing, Paris, https://www.oecd.org/en/publications/2017/02/oecd-due-diligence-guidance-for-meaningful-stakeholder-engagement-in-the-extractive-sector_g1g65995.html.
[14] OECD (n.d.), Anti-corruption and integrity in state-owned enterprises, https://www.oecd.org/en/topics/sub-issues/corporate-governance-of-state-owned-enterprises/anti-corruption-and-integrity-in-state-owned-enterprises.html.
[4] Papers, O. (ed.) (2022), Climate Change and Low-carbon Transition Policies in State-owned Enterprises, OECD Publishing, https://doi.org/10.1787/e3f7346c-en.
[12] Paredi, D. et al. (2021), “How to Meet Stakeholders’ Expectations on Environmental Issues? An Analysis of Environmental Disclosure in State-Owned Enterprises via Facebook.”, Global Media Journal, https://www.globalmediajournal.com/open-access/how-to-meet-stakeholders-expectations-on-environmental-issues-an-analysis-ofenvironmental-disclosure-in-stateowned-enterprises-via.php?aid=89268&view=mobile.
[9] SNCF (2019), Rapport d’Engagement Societal d’Entreprise 2019, https://medias.sncf.com/sncfcom/ese/SNCF_Rapport_ESE_2019.pdf.
[8] UNFCCC (2023), COP28 Agreement Signals “Beginning of the End” of the Fossil Fuel Era, https://unfccc.int/news/cop28-agreement-signals-beginning-of-the-end-of-the-fossil-fuel-era.
← 1. A proposal for simplification was issued in 2025 and is currently under consideration.
← 2. In the SOE Guidelines the term stakeholder generally refers to non-shareholder stakeholders and includes, among others, the workforce, creditors, customers, suppliers and affected communities.
← 3. In certain OECD countries, SOEs have faced litigation with regard to environmental degradation (such as pollution and water discharge), timelines for coal plant closures and investments by state-owned companies in fossil fuels, among other areas (OECD, 2022[4]).
← 4. Stakeholder engagement may also be required under specific contexts such as within the framework of large (infrastructure) projects that may raise potential environmental and social concerns.
← 5. The 2018 SOE survey demonstrated that SOE leaders in oil and gas, as well as in mining, were more likely to have witnessed corruption or related irregularities transpire in their companies in the years prior (OECD, 2018[13]).
← 6. State owners and SOEs may also resort to the implementation guide of the OECD Guidelines on Anti-Corruption and Integrity in State-Owned Enterprises issued in 2020 to identify concrete ways in which they can implement OECD recommendations in this area (OECD, 2020[15]).