The Canadian National Contact Point (NCP) 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 Canadian technology company Genetec concerning the alleged sale of its comprehensive security platform through channel partners operating in the Islamic Republic of Iran.
The complaint alleged that Genetec failed to conduct adequate human rights due diligence to ensure that its products, distributed through local channel partners, did not contribute to serious human rights violations committed by Iranian authorities. According to JFI and JBB, this failure was inconsistent with the OECD Guidelines for Multinational Enterprises on Responsible Business Conduct, which require companies to identify, prevent and mitigate adverse human rights impacts linked to their business activities and commercial relationships.
In support of the complaint, JFI and JBB argued that the risks associated with supplying advanced surveillance technologies to Iran were well documented. They pointed to evidence that crimes against humanity have been committed during successive waves of repression, including the November 2019 Aban protests and the nationwide crackdown following the death of Mahsa Amini in 2022. Citing the findings of the Aban Tribunal, the organisations argued that companies operating in the surveillance technology sector have a responsibility to ensure that their products do not facilitate widespread or systematic human rights abuses.
The organisations maintained that companies cannot rely solely on indirect distribution models when operating in high-risk jurisdictions. Instead, they argued that meaningful human rights due diligence must extend throughout the value chain, including relationships with authorised distributors and channel partners.
Following its initial assessment, the Canadian NCP concluded that the issues relating to the alleged ongoing sale of Genetec products in Iran did not warrant further consideration under the OECD Guidelines and declined to offer mediation or facilitated dialogue between the parties.
Although the complaint did not proceed beyond the initial assessment stage, the case reflects a broader trend in the use of OECD National Contact Point mechanisms to examine the role of private companies in enabling digital repression. As governments increasingly rely on sophisticated surveillance technologies to monitor, identify and prosecute political opponents, human rights organisations have intensified efforts to scrutinise the responsibilities of technology companies whose products may be used in authoritarian contexts.
For NGOs, lawyers and business and human rights practitioners, the case underscores both the opportunities and the limitations of the OECD grievance mechanism. While the Canadian NCP declined to pursue the complaint further, the proceedings contribute to the growing international debate over corporate accountability for surveillance technologies and reinforce expectations that technology companies must conduct robust human rights due diligence before entering or maintaining business relationships in countries where there is a foreseeable risk that their products could facilitate serious human rights violations.
