The U.S. Chamber of Commerce (“Chamber”) writes to express our deep concerns regarding the recently proposed changes to the OECD Guidelines for Multinational Enterprises (“Proposed Guidelines”). If embraced by the United States as currently drafted, the Proposed Guidelines could conflict with settled U.S. securities and corporate governance laws, impose enormous costs for U.S.-based businesses and investors, undermine principles of free speech, contradict U.S. labor law, and weaken the United States’ competitive edge in global markets. U.S. businesses, their suppliers and their shareholders could also become the targets of internationally coordinated campaigns by activists and international organizations seeking to “enforce” the guidelines.
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