Alsetex, Etienne Lacroix Group and Americans for Democracy and Human Rights in Bahrain (ADHRB)
Lead NCPFrance
Supporting NCP(s)None Selected
DescriptionSpecific instance notified by the NGO “Americans for Democracy and Human Rights in Bahrain” (ADHRB) regarding the activities of Alsetex, a subsidiary of the French multinational enterprise Etienne Lacroix Group trading with Bahrain, in the Gulf region.
Theme(s)Human rights, General policies
Date19 Aug 2015
Host country(ies)Bahrain
Industry sectorPublic administration and defence

Read the initial assessment  issued by the French NCP – 16 November 2015 français

Read the final statement issued by the French NCP – 4 July 2016 | français


In August 2015, the French NCP received a submission from the American NGO Americans for Democracy and Human Rights in Bahrain (ADHRD), regarding the sale of security product (tear gas) by Alsetex, a subsidiary of the Etienne Lacroix Group, to the government of Bahrain. The NGO asked whether human rights had been respected and whether due diligence was applied in the sale of these security products  to Bahrain which could have been used in 2011 and more recently to potentially violate human rights. These tear gas  products fall under a specific export regulation in France.

In November 2015, the NCP published its initial assessment which noted that the submission was precise, detailed and well documented and that questions raised by the NGO merited further consideration. The NCP offered its general good offices and both parties accepted. Given the confidential nature of the sector in question, the NCP asked ADHRBC to sign a non-disclosure agreement. After this contact with the parties, the NCP offered mediation to discuss the enterprise's due diligence, which Alsetex refused.

The NCP had a constructive dialogue with both parties which led to an agreement. On 4 July 2016, the NCP released a Report (final statement). The NCP notes that specific European and French regulations on the tear gas export control take into consideration human rights and the potential risks caused by the final use of such products. The NCP notes that the enterprise conducted due diligence as recommended by the Guidelines through this legal export control system. It noted that the enterprise strictly complied with French regulations and respected the export ban decided by the French government in 2011 after it was determined  that tear gas had been misused in Bahrein in February 2011. By respecting these decisions and regulations, the enterprise complied with the Guidelines and did not contribute to human rights violations in Bahrain. The NCP also noted that the enterprise has developed risk-based due diligence measures and recommends that the company formalise its risk management system. The NCP also notes that Alsetex is developing a policy for responsible business conduct, and comments this initiative. The NCP invites Alsetex to use the OECD Guidelines and to take into account comments provided by ADHRD during this process and release its policy afterwards.