The Complainants submit that Glencore UK, either directly or through its local subsidiary PetroChad (Mangara) Limited (“PCM”), has breached the OECD Guidelines for Multinational Enterprises (the “OECD Guidelines”) by failing: - to conduct appropriate environmental and human rights due diligence at its Badila oil concession in Chad...; - to respect the internationally recognised human rights of the local communities living near the concession...; - to provide remediation for the harm caused (Chapter IV, par. 6); - to disclose material information on human rights and environmental risks and issues affecting stakeholder communities (Chapter III); - to ensure meaningful stakeholder engagement...; - and to contribute to the communities’ sustainable development... In addition to general neglect towards its stakeholders and local communities, major events have occurred at the Badila oilfield that demonstrates the acute failure of Glencore UK to respect the OECD Guidelines...

On 10 September 2018, the earth bank supporting a wastewater basin containing the equivalent of 34 Olympic size pools collapsed and a wave of destruction swept across the surrounding landscape until the wastewater poured, unchecked, into the local Nya Pende River. The river is crucial for daily life...

The Complainants acknowledge that the UK NCP’s approach to resolving complaints is in the first instance to facilitate conciliation or mediation and respectfully request that the NCP offers its good offices to resolve the OECD Guidelines breaches outlined below...

the Complainants seek the following outcomes: 6 1) That Glencore UK commissions independent experts to investigate the September 2018 wastewater spill and the oil leak reported by the customary chief and local residents and all subsequent injuries and loss of livelihoods reported by residents...