The UK National Contact Point’s (NCP) Initial Assessment process is a decision on whether the issues raised in the complaint warrant further examination. It does not determine whether the respondent has acted consistently with the OECD Guidelines for Multinational Enterprises on Responsible Business Conduct (the ‘guidelines’).

In November 2023, Possible submitted complaints to the UK National Contact Point (“NCP”) concerning statements by Virgin Atlantic and British Airways. The NCP is part of the Department for Business and Trade. It is responsible for promoting the OECD guidelines for multinational enterprises on responsible business conduct and for operating the complaints mechanism in the guidelines.
Both airlines are said to have made a significant number of misleading claims about reducing emissions, efficiency and alternative fuels. Additionally Virgin is said to have made misleading claims about net zero, and British Airways about offsets. These claims, individually and collectively, are said to downplay the current and likely future impact of each airline’s operations on the climate. This is on the basis that the statements misleadingly suggest that the airlines are in the process of eliminating the environmental impact of their flights, which tells consumers that they can continue to fly frequently without worrying unduly about their carbon footprint, and policymakers that they do not need to take steps to moderate the growth in demand for flying. Possible’s position is that, if the world hopes to achieve the goals of the Paris Agreement and avoid the worst impacts of climate change, both of these messages are false. On 16 March 2026, the UK NCP decided that elements of this complaint warrant further consideration under the 2011 and 2023 OECD guidelines, Chapter VI, paragraphs 2(a) and 6(c) ‘Environment’ (2011); and Chapter VIII, paragraphs 2 and 4 ‘Consumer Interests’ (2011 and 2023 guidelines). In accordance with the UK NCP’s procedures, it offered mediation to the parties – the scope of which would cover only those elements of the complaint warranting further consideration. If any party declines mediation, the UK NCP will conduct a further examination of the complaint, and determine whether the company has acted consistently with the OECD guidelines. Should it determine that the company has not adhered to the OECD guidelines, the UK NCP may provide non-binding recommendations for improving the company’s adherence to the OECD guidelines.

Complaint against Virgin Atlantic and British Airways under the OECD Guidelines brought by Possible

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Complaint against Virgin Atlantic and British Airways under the OECD Guidelines brought by Possible - decision

Filed

International

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An aim to achieve a quantifiable outcome within a given time-frame, set by an institution such as a national government.

Policy instruments are techniques or tools used by governing authorities to promote certain policies in order to achieve predetermined goals. Put simply, instruments are how a government tries to achieve its goals, with this taxonomy being focused on national policy instruments.

Risk is the potential for adverse consequences resulting from the dynamic interplay between (climate-related) hazards, exposure, and vulnerability of affected human or ecological systems.

Groups  of people who are adversely affected by climate change or the response to it

A set of principles, processes, and practices that build economic and political power to shift from an extractive economy to a regenerative economy.

Justice is the ethical and political framework that addresses fairness, including issues of responsibility, rights, and structural inequity.

Renewable energy means all forms of energy produced from renewable sources in a sustainable manner.

Fossil fuel is a generic term for non-renewable energy sources such as coal, fossil gas, and oil (including crude oil, and petroleum products), that can be used for electricity and heat generation. Fossil fuels are hydrocarbons formed from pressurised and heated organic material buried over millions of years.

Molecules in the atmosphere that play a key role in the greenhouse effect by trapping heat radiating from Earth’s surface.

Area of the economy in which actors engage in identical or related activities.

In human systems, the process of adjustment to actual or expected climate change and its effects, in order to moderate harm, increase resilience or exploit beneficial opportunities. In natural systems, the process of adjustment to actual climate change and its effects; human intervention may facilitate adjustment to expected climate change and its effects.

The management and allocation of funds, assets and investments to meet various objectives

Tradable permits are market-based tools that grant permission for specific activities, frequently used to regulate emissions. These permits can be issued within a trading system to manage environmental impacts.

The processes through which enterprises can identify, prevent, mitigate and account for how they address their actual and potential adverse impacts. Due diligence is the idea that reasonable precautions should be taken to avoid causing harm to people, the environment, or society. It also involves identifying and mitigating risks before they occur.

An agency providing government-backed financing, guarantees, and insurance to support domestic companies' international exports, that can play a role in financing climate-related projects.

A target to reduce the prevalence of a greenhouse gas over a specific time frame

A commitment to balance GHG emissions with removal by a certain point in time, effectively reducing the net emissions to zero

Either money or something of monetary value is transferred between two or more organisations, people or countries.

The release of heat-trapping gases, primarily from human activities such as burning fossil fuels, agriculture and industry.

A long-lived, colourless gas, chiefly emitted from fossil fuel combustion, deforestation and cement production.

Actions to reduce emissions in energy generation and supply.

Terrestrial means "of the earth" and relates to the risks to ecological system that includes all living organisms and their interactions within land-based environments, such as forests, grasslands, and deserts.

Energy derived from biological compounds that are renewable due to their short life cycle within the carbon dioxide cycle.

People whose health, both mental and physical, makes them more vulnerable to the effects of climate change

This sector involves the wholesale and retail selling of goods.

This sector involves activities to move goods and people, alongside the storage of products.

This sector creates and distributes information and entertainment through television, radio, print, and digital platforms.

This sector involves activities that impart knowledge and skills to individuals, including formal schooling, vocational training and educational support.

Climate change can have a range of impacts on technological system. Extreme weather events can cause infrastructure failures like power outages or damage to roads and bridges, as well as the impacts from waste following natural disasters. Human activities also cause technological impacts, such as the risks posed by oil spillage and leaks.

Climate change impacts our society by disrupting the natural, economic and social systems we depend on. Physical hazards and underlying vulnerabilities can lead to increased resource competition for food and water, which can heighten the risk of conflict.

Slow onset events evolve gradually from incremental changes over many years or from increased frequency or intensity of recurring events. As defined in the Cancun Adaptation Framework (2010), slow onset events include risks and impacts from rising temperatures, desertification, biodiversity loss, land and forest degradation, glacial retreat, ocean acidification, sea level rise, and salinization.

Complaint against Virgin Atlantic and British Airways under the OECD Guidelines brought by Possible - decision

Target

Policy instrument

Risk

Impacted group

Renewable energy

Greenhouse gas

Economic sector

Finance