"Decision on Interlocutory Appeal Concerning Personal Jurisdiction in Contempt Proceedings", 2 Oct 2014

[T]he Appeals Panel finds that the ordinary meaning of the word "person" in a legal context can include both natural human beings and legal entities...[T]he Appeals Panel has examined evolving international standards on human rights and corporate accountability as well as trends in national laws. Current international standards on human rights support an interpretation that is consonant with imposing criminal liability on legal persons...With respect to the Lebanese Code of Criminal Procedure, the Appeals Panel considers it relevant that legal persons can be criminally liable under Lebanese criminal law. Accordingly, it considers that it is foreseeable under Lebanese law that legal entities could besubject to criminal proceedings...[The UN Guiding Principles on Business and Human Rights represent] a concrete movement on an international level backed by the United Nations for, inter alia, corporate accountability. Although we are wary that such instruments are non-binding, in light of the fact that corporations have been considered subjects of international law, the possibility of proceeding against a corporation through criminal prosecution cannot discarded but rather criminal regimes are regarded as an available remedy. The Appeals Panel considers these factors to be evidence of an emerging international consensus regarding what is expected in business activity, where legal persons feature predominantly, in relation to the respect for human rights.