The Korean National Contact Point (KNCP) for the OECD Guidelines for Multinational Enterprises has concluded its initial assessment of a complaint brought by Justice for Iran (JFI) and Justice Beyond Borders (JBB) against South Korean manufacturer Jino Motors over its past sales of water cannon vehicles to the Islamic Republic of Iran.
Although the KNCP decided not to accept the complaint for further examination, it nevertheless urged Jino Motors to “faithfully implement Responsible Business Conduct to minimise and address the adverse impacts of its business activities,” highlighting the continuing importance of corporate human rights due diligence in high-risk contexts.
The complaint, submitted in November 2024, alleged that Jino Motors failed to conduct adequate human rights due diligence before selling water cannon vehicles to Iran. According to JFI and JBB, the vehicles were subsequently used by Iranian security forces to suppress peaceful protests, contributing to serious human rights violations. The organisations argued that the company’s conduct was inconsistent with the OECD Guidelines, particularly the provisions relating to general policies, human rights and environmental responsibility.
In support of their submission, the organisations pointed to evidence of systematic repression in Iran, including findings of the Aban Tribunal concerning the November 2019 protests and the violent crackdown on the 2022 Woman, Life, Freedom movement following the death of Mahsa Amini. They argued that crimes against humanity have been committed during both waves of repression and that companies exporting crowd-control equipment to Iran have a responsibility to assess whether their products could facilitate such abuses.
Jino Motors responded that its last sale of water cannon vehicles to Iran took place in 2010. The company further stated that it has since strengthened its human rights due diligence procedures and has no intention of selling such vehicles to Iran in the future unless their legitimate use can be ensured and there is a change in the international consensus regarding such exports.
Following its initial assessment, the KNCP concluded that further examination of the complaint would not contribute to the purposes and effectiveness of the OECD Guidelines and therefore declined to proceed with the case. At the same time, however, it explicitly encouraged the company to continue implementing responsible business conduct measures to prevent or mitigate adverse human rights impacts arising from its operations.
While the decision brings the specific proceeding to a close, the complaint highlights a broader trend in business and human rights practice. Increasingly, civil society organisations are using the OECD National Contact Point mechanism to scrutinise companies whose products or services may be linked to repression, even where the alleged conduct occurred years earlier. The case also reflects the growing expectation under the OECD Guidelines that businesses identify, prevent and address human rights risks throughout their operations and business relationships, particularly when operating in conflict-affected or authoritarian environments.
For NGOs, lawyers and corporate accountability advocates, the case illustrates both the opportunities and limitations of the OECD grievance mechanism. Although the complaint was not accepted for further examination, the proceedings secured a public response from the company, prompted commitments regarding future exports and reinforced the expectation that manufacturers of law enforcement equipment must conduct meaningful human rights due diligence before entering high-risk markets.
