In March 2022, Greenpeace and development NGO ASTM published a briefing criticising Luxembourg’s pension fund Fonds de compensation commun au régime général de pension (FDC) for weak and unambitious investment criteria on environmental and human rights risks. The briefing is based on an analysis by Nextra Consulting, an environmental consulting group, of FDC's 2020 investments.

The fund say it "welcomes any exchange of view and critical discussions with actors like Greenpeace Luxembourg and ASTM" but that it "will continue to evolve its responsible investor policy step by step, at its own pace and independently of any external pressure." The FDC is due to review its investment strategy for a five-year period starting 2023.