Chapman Taylor, a UK-based global architecture firm, has been reported to the UK National Contact Point (NCP) for alleged breaches of the OECD Guidelines for Multinational Enterprises due to a construction project in Azerbaijan. This little known rule opens the door to a potential litany of human rights complaints against UK businesses, with wide-ranging consequences for supply chains and international operations as geopolitical shifts open up new regions for development and investment.
The UK National Contact Point (NCP) is the government body responsible for handling complaints under the OECD Guidelines for Multinational Enterprises, a set of international standards on responsible business conduct. By accepting a complaint against Chapman Taylor, the NCP has signalled that a broad range of companies can face scrutiny under these global human rights and due diligence expectations.
While the NCP’s findings are non-binding, its assessments can carry significant weight, and potentially lead to further litigation. For UK companies, it’s important to note that the government has been stepping up its focus on corporate accountability and ESG governance. Any business working in conflict-affected or politically sensitive regions may face not only reputational fallout, but also heightened compliance and legal risks.
The Case: Chapman Taylor’s involvement in a sensitive redevelopment
The complaint was filed by Avan Shushi, a US-based investment partnership that acquired and developed a hotel in Nagorno-Karabakh, a region of Azerbaijan long affected by war. The case centres on the redevelopment of the historic town of Shushi in the conflict region. After the 2020 Nagorno-Karabakh war, tens of thousands of Armenians were displaced. Properties—including Avan Shushi’s hotel—were abandoned or seized. Chapman Taylor was later contracted to prepare a masterplan for the redevelopment of the city, reportedly including the redesign of the Avan Shushi Hotel and other properties tied to displaced Armenians. Avan Shushi is now claiming its property and cultural rights have been violated through Chapman Taylor’s redevelopment plans.
The allegations are stark:
- Erasure of Armenian cultural heritage through demolition or redesign of sites.
- Violation of property rights by incorporating displaced Armenians’ properties into redevelopment.
- Failure to use leverage to mitigate or prevent human rights abuses, despite close ties to the Azerbaijani government and state-linked contractors.
The UK NCP has not concluded that Chapman Taylor breached the OECD Guidelines, but its decision to accept the complaint confirms that the issues are “material and substantiated.” This means the firm will face mediation or further investigation. The reputational damage, however, is already unfolding.
Regulatory and legal frameworks to consider
The case sits at a difficult intersection of international human rights standards and corporate responsibility frameworks:
OECD Guidelines for Multinational Enterprises (2023):
The complaint focuses on Chapter II (General Policies) and Chapter IV (Human Rights), which require firms to:
- Conduct risk-based due diligence (II.11, IV.5).
- Avoid contributing to human rights harms (II.12, IV.2).
- Seek to prevent or mitigate impacts linked to business relationships, even without direct contribution (II.13, IV.3).
UN Guiding Principles on Business and Human Rights (UNGPs):
Widely seen as the “global standard,” the UNGPs expect businesses to respect human rights irrespective of host government compliance, with enhanced due diligence in conflict zones.
International human rights treaties:
The complaint references the International Covenant on Civil and Political Rights and the International Covenant on Economic, Social and Cultural Rights, particularly rights to property, culture, and freedom of movement.
Importantly, the OECD Guidelines apply to professional services just as much as extractives, manufacturing, or finance. Even firms offering “neutral” services like planning and design are expected to assess human rights risks linked to their projects.
The role of the UK NCP: Jurisdiction and sanctions
The UK National Contact Point exists to handle complaints under the OECD Guidelines for Multinational Enterprises, a government-backed but non-binding standard for responsible business conduct. Each OECD member state is required to maintain an NCP, which acts as a mediation and accountability mechanism rather than a court. In this case, although the alleged human rights violations occurred in Azerbaijan, the UK NCP has jurisdiction because Chapman Taylor is headquartered in the UK. The Guidelines explicitly state that enterprises are expected to respect human rights wherever they operate, regardless of whether the host state complies with international law.
Importantly, the NCP cannot impose fines, binding sanctions, or legal penalties. Instead, it offers mediation between the parties and, if that fails, issues a public determination on whether the company acted consistently with the Guidelines. While the outcomes are technically non-binding, they carry real weight: adverse findings can damage a firm’s reputation, undermine investor confidence, and trigger follow-on action by regulators, lenders, or clients who incorporate OECD standards into their contractual or ESG frameworks. In practice, the NCP’s “soft law” influence often proves more damaging than formal sanctions, as it directly impacts a company’s licence to operate in global markets.
The impact of geopolitical changes: More investment, more risk?
In August 2025, Donald Trump brokered a major peace deal between Azerbaijan and Armenia, ending decades of war and creating a new transit and trade corridor linking Azerbaijan to its Nakhchivan exclave through Armenian territory. Branded the “Trump Corridor,” the agreement gives the US long-term development rights and is designed to reduce reliance on Russian and Iranian routes, opening the region to Western-backed infrastructure and investment. While it promises economic integration and reconstruction and is expected to unlock major infrastructure projects, the corridor also paves the way for large-scale redevelopment in contested areas.
This surge in development also increases the risk of disputes like the Chapman Taylor case: as new projects reshape towns and heritage sites in areas scarred by conflict and displacement, professional services firms, investors, and contractors will face heightened scrutiny over human rights, property rights, and cultural preservation. The deal may therefore open the door to more complaints under the OECD Guidelines and similar frameworks, as development and investment expand into territories where legal, ethical, and political sensitivities remain unresolved.
It’s not only the South Caucasus that could see more human rights complaints. Western governments have begun easing sanctions on Syria to encourage reconstruction and regional trade, despite the country’s continuing internal conflict, including clashes with Druze communities and other factions. This creates new opportunities for investment and infrastructure, but also heightened risks of complicity in human rights abuses, expropriation, and cultural erasure in volatile political environments.
Why geopolitical risk matters
Geopolitical shifts, whether peace deals, sanctions relief, or regime change, often open the door to new markets, investment opportunities, and redevelopment projects. But for businesses, especially those in professional services, infrastructure, and finance, these opportunities come with sharp edges: unresolved conflicts, contested ownership, and human rights concerns can quickly turn commercial ventures into reputational or compliance crises. Risks need to be fully understood, analysed and mitigated.
Reputational risk
A firm’s brand can be damaged overnight by association with state-led projects tied to human rights abuses. In Chapman Taylor’s case, its involvement is now linked in public discourse with accusations of cultural erasure and displacement, regardless of the eventual NCP outcome.
Legal and regulatory risk
While OECD NCP decisions are non-binding, they can trigger scrutiny from regulators, investors, and courts. In the EU, for example, the Corporate Sustainability Due Diligence Directive (CSDDD) will soon impose binding human rights due diligence obligations across global value chains. Similar proposals are emerging in the UK.
Contractual and investor risk
Investors, insurers, and clients increasingly include ESG and human rights clauses in contracts. Failure to meet these expectations could lead to exclusion from tenders or project cancellations.
Operational and security risk
Operating in conflict zones or politically sensitive areas exposes firms to unpredictable government behaviour, corruption, and security concerns. A lack of due diligence can create liabilities that extend beyond reputational damage.
Geopolitical Risk
Rapid geopolitical shifts such as peace deals, sanctions relief, or regime change can transform conflict zones into investment hubs almost overnight. But unresolved human rights issues, contested property claims, and cultural heritage disputes mean that today’s opportunity can quickly become tomorrow’s compliance crisis.
What other companies have been caught up in conflict zones?
The Chapman Taylor case echoes other high-profile examples of businesses being involved in conflict-related or geopolitically risky zones.
- Danish bank Danske Bank faced reputational collapse for failing to control money laundering through its Estonian branch, despite not directly perpetrating the crime.
- ENRC (Eurasian Natural Resources Corporation) was linked to corruption and human rights abuses in its overseas mining operations, triggering SFO investigations in the UK and a secret deal with the regulator.
- Architecture and engineering firms have been criticised for involvement in Gulf states, including during the 2022 World Cup in Qatar, where migrant labour exploitation is widespread, raising questions about complicity through supply chains and project partnerships.
How compliance teams can manage geopolitical risk
For compliance officers, the Chapman Taylor case is a reminder that geopolitical shifts can rapidly turn commercial opportunities into reputational and legal minefields. Managing these risks requires going beyond box-ticking exercises and embedding resilience into every stage of operations:
Enhanced supplier onboarding
Carry out rigorous human rights and ESG assessments of state clients, contractors, and local partners. Use screening tools to identify exposure to corruption, sanctions, or links to political regimes implicated in human rights abuses.
Ongoing geopolitical due diligence
Monitor not just business partners but also the broader political context; conflict developments, sanctions changes, and international rulings. Establish escalation protocols for when risks spike, ensuring projects can adapt or be suspended quickly.
Embedding human rights policies
Align company policies with the OECD Guidelines and UN Guiding Principles on Business and Human Rights, and make them visible to stakeholders. Equip staff with the training to spot red flags in high-risk environments, from cultural heritage issues to forced displacement.
Using leverage and knowing when to exit
Deploy contractual and reputational leverage to press clients or partners towards compliance. Where influence is limited, firms must be prepared to withdraw rather than risk complicity in violations.
