Language selection

Government of Canada Government of Canada

Search

People’s University 4 Gaza and the University of British Columbia - Initial Assessment

September 2026

Summary

1. Substance of the specific instance

1.1 The Parties

Notifier

  1. People’s University 4 Gaza (“PU4G”) described itself as a “coalition of Palestinian, Jewish, and allied students, staff, and faculty at UBC-O and UBC-V campuses”. PU4G stated that its objective is to end what it claims to be UBC’s “complicity in the commission of international crimes in the Occupied Palestinian Territories”.

Respondent

  1. The University of British Columbia (UBC) is a public research university with campuses in Vancouver and the Okanagan. It is a corporation established in 1908 and continued under British Columbia’s University Act. UBC is also a registered charitable organization in Canada. UBC Investment Management Incorporated (UBCIM) is a wholly owned subsidiary of UBC. UBCIM was established in 2003 to provide “comprehensive portfolio management and advisory services” to the University of British Columbia. UBCIM is responsible for investing the university’s main endowment pool, staff pension plan, and working capital fund, as well as other portfolios. The Notifier’s request for review was focused on UBC’s Endowment Fund, which had a reported market value of $2.52 billion as of March 2025.

1.2 Perspectives of the Notifier

  1. The Notifier claimed that the Respondent maintained investments “via pooled funds” in nine companies identified by a group of UN experts in June 2024 as at risk of “being complicit in serious violations of international human rights and international humanitarian laws”, namely by virtue of “sending weapons, parts, components and ammunition to Israeli forces”.Footnote 1
  2. The Notifier also claimed that the Respondent maintained investments “via pooled funds” in companies “operating in and/or maintaining illegal Israeli settlements in the Occupied West Bank and East Jerusalem”. The Notifier referred to a list of business enterprises compiled by the UN Office of the High Commissioner for Human Rights (OHCHR) pursuant to a 2016 resolution of the UN Human Rights Council (31/36).Footnote 2 This list purports to identify business enterprises involved in ten types of activities related to settlements in the Occupied Palestinian Territory.
  3. The Notifier claimed that these investments represented “business relationships” directly linking UBC’s operations, products or services to adverse human rights impacts caused or contributed to by the investee companies, and that the Respondent had not “sought to prevent or mitigate adverse human rights impacts” in alignment with the Guidelines. The Notifier further claimed that “investment policy commitments” in UBC’s Statements on Responsible Investing (June 30, 2023) “make no mention of human rights” and that this raised questions around UBC’s approach to paragraph 4 of Chapter IV (having a publicly available policy commitment to respect human rights).
  4. The Notifier further alleged that certain “academic partnership agreements” between UBC and three Israeli universities represented business relationships directly linking UBC’s operations, products or services to adverse human rights impacts allegedly caused or contributed to by those Israeli universities. The Notifier claimed that all three Israeli universities “promote and facilitate the occupation and annexation of Palestine”. The Notifier also questioned whether these agreements were consistent with recommendations in paragraph 5 of Chapter IX (Science, Technology and Innovation).
  5. The Notifier said that its representatives had met on multiple occasions with the Respondent’s representatives regarding these issues throughout 2024 and had previously called on the Respondent to divest from the companies cited in its request for review.

1.3 Perspectives of the Respondent

  1. According to the Respondent, the endowment funds managed by UBCIM are invested to “provide an income stream to support teaching, learning, and research at UBC in perpetuity”. The Respondent stated that UBC’s investment practices were fully aligned with recommendations in Responsible business conduct for institutional investors, a 2017 OECD publication aimed at helping institutional investors implement the due diligence recommendations of the OECD Guidelines.
  2. The Respondent noted that UBCIM has been a signatory (on behalf of UBC) to the Principles for Responsible Investment (PRI) since 2020, and that UBC is “committed to responsible investing in a manner that is consistent with its fiduciary duties and legal obligations: taking ESG factors into consideration as part of a financial decision that considers all relevant information through a risk and reward lens”.
  3. According to the Respondent, UBC adopted a “Responsible Investment Policy” in 2014. The UBC Board of Governors subsequently replaced that policy with an updated set of “Statements on Responsible Investing” in 2023. The 2023 Statements recognize that ESG factors “may present material and evolving impacts on the risk and return of a given investment and/or investment portfolio” and contain the following statement regarding human rights:
    • UBC believes that business practices are an important criterion for considering investments. The key areas of focus for UBC are: human rights, labour standards, workplace health and safety, and diversity, equity, and inclusion. UBC continues to explore and conduct due diligence with respect to best practices for implementation of this belief in a manner consistent with UBC’s Investment Obligations.
  4. The Respondent referred the NCP to a UBCIM “Responsible Investing Update” presented to the UBC Finance Committee in November 2024. The presentation outlined the development of UBCIM’s “Responsible Investing Strategy”, noting that UBCIM was “tracking along the original plan, including the establishment of Social factors – like Human Rights risk – as a core component of our work”. Subsequent public updates indicate that UBCIM has continued to develop its “Responsible Investing Strategy”, including by strengthening its approach to assessing and managing social risks, including human rights, developing a Social Risk (including Human Rights) Framework, and continuing stakeholder engagement, including meetings with interested faculty and student groups in 2025.Footnote 3
  5. The Respondent told the NCP that UBC had established metrics to track ESG factors across a range of social areas, including “human rights controversies and policies” and that UBC was “actively reviewing and updating its practices”, noting that its approach would continue to evolve in the area of social and governance factors “as improvements in industry practices are made”.
  6. The Respondent also told the NCP that UBC’s investments are “overwhelmingly in pooled funds” and that UBC would only be an “indirect investor” in the enterprises cited in the Notifier’s submission. According to the Respondent, this meant that UBC would not be able to selectively divest from any of the individual companies cited by the Notifier without making large changes to its investment pools “out of proportion to the 0.57%” of the portfolio implicated in the Notifier’s request for review.
  7. The Respondent noted that senior representatives of UBC had met on multiple occasions with individuals from PU4G over the course of 2024, representing at least 20 hours of meeting time. The Respondent took the position that the NCP should only become engaged where an enterprise is “making a material and substantial contribution to adverse impacts on human rights” and that this threshold had not been met in this instance.

2. Initial Assessment

  1. The NCP’s initial assessment was based on the information provided by the Notifier and the Respondent, as well as publicly available information. The assessment considers whether the issues raised are bona fide and relevant to the implementation of the Guidelines, taking into account the following:
    • the identity of the party concerned and its interest in the matter
    • whether the issue(s) are material and substantiated
    • whether there seems to be a link between the enterprise’s activities and the issue(s) raised in the specific instance
    • the relevance of applicable law and procedures, including court rulings
    • how similar issues have been, or are being, treated in other domestic or international proceedings
    • whether the consideration of the specific issue(s) would contribute to the purposes and effectiveness of the Guidelines
  2. The NCP has also taken note of the Government of Canada’s August 2026 Advisory to CanadianFootnote 4 businesses (“the Advisory”) concerning economic and financial activities associated with Israeli settlements in the West Bank and East Jerusalem. As the Advisory was issued after the Initial Assessment was completed and shared with the parties in September 2025, it did not form part of the record on which the Initial Assessment was originally prepared. The NCP has nevertheless considered the Advisory prior to publication, including its relevance to settlement-related risks and the due diligence expected in relation to such risks.
  3. This assessment does not represent a determination as to whether the Respondent has acted consistently with the Guidelines. It should not be seen as validating to any degree – one way or the other – claims made by either the Notifier or Respondent.

2.1 Identity of the party concerned

  1. To the extent that it is an organized group of UBC students, staff, and faculty with a mandate and expressed interest in promoting respect for human rights in the Respondent’s activities, the Notifier appears to have a sufficient interest in the matter of the Respondent’s observance of the Guidelines’ recommendations on human rights due diligence.

2.2 Materiality and Substantiation

  1. In assessing whether the issues raised are “material”, the question is whether the issues raised have clear and meaningful relevance to the Guidelines.
  2. The Guidelines state that an enterprise’s “commercial form, purpose, or activities” are main factors to consider in understanding whether an entity is a “multinational enterprise” to which the Guidelines are addressed (Chapter I, paragraph 4). The NCP recognizes that some entities or groups of entities may be engaged in a mix of both commercial and non-commercial activities. The former activities may be material to the Guidelines while the latter may not. It may therefore be necessary to consider some entities or groups of entities only as “multinational enterprises” in respect of some of their activities and not others. While commercial activities in certain cases may be aimed at generating revenues to support non-commercial activities or purposes, the NCP does not see this as a reason for those commercial activities to fall beyond the scope of the Guidelines. The application of the Guidelines to institutional investors is further addressed in the OECD’s Responsible business conduct for institutional investors.
  3. In assessing substantiation, the overarching question is whether there is sufficient and credible information to provide a basis for further consideration.

Academic partnership agreements

  1. The Notifier claimed that the Respondent had “academic partnership” agreements with three Israeli universities allegedly causing or contributing to adverse human rights impacts by “[promoting and facilitating] the occupation and annexation of Palestine”. According to the Notifier, the academic partnerships constituted “business relationships” under the Guidelines which directly linked the Respondent’s operations, products or services to the alleged adverse human rights impacts. The specific agreements cited by the Notifier were “Student Mobility Agreements” and a “faculty exchange program”.
  2. It is difficult to see the issue raised being material to the Guidelines. Regarding whether an entity is considered a “multinational enterprise”, the NCP notes again that the “commercial form, purpose, or activities” of an entity or group of entities are main factors to consider in determining the applicability of the Guidelines to a particular context (Chapter I, paragraph 4). The OECD Investment Committee has affirmed in recent clarifications the relevance of these factors in assessing whether particular entities and/or activities are material to the Guidelines and therefore potentially subject to an NCP specific instance procedure.
  3. With regard to this instance, the NCP takes note of section 47(2) of British Columbia’s University Act, and the list of duties and functions which UBC must undertake “so far as and to the full extent that that its resources from time to time permit”. These include providing “instruction in all branches of knowledge” and establishing “facilities for the pursuit of original research in all branches of knowledge”. The NCP also takes note of UBC’s status as a registered charitable organization for the “advancement of education”.Footnote 5 UBC itself has cited “teaching, research, scholarly pursuits and community service” as charitable purposes of the organization.Footnote 6
  4. Based on the information available to the NCP, the agreements cited by the Notifier (“Student Mobility Agreements” and one “faculty exchange program”) appeared focused on advancing the Respondent’s non-commercial purposes and activities, namely those related to the advancement of education and scholarship. Accordingly, the NCP did not see the operation of these agreements being material to the Guidelines.
  5. In relation to this issue, the Notifier also cited paragraph 5 of Chapter IX (Science, Technology and Innovation):
    • Where relevant to commercial objectives, [enterprises should] develop ties with local higher education institutions, public research institutions and participate in co-operative research projects with local industry or industry associations, including small- and medium-sized enterprises and civil society organizations. Such co-operation should take into account effective risk management, ethical considerations, national security concerns, applicable laws and considerations of stakeholders. It should also recognise the value of open science and respect safeguards to preserve academic freedom, as well as research and scientific autonomy.
    The Notifier indicated that the academic partnership agreements are “ties with local higher education institutions” and questioned whether UBC had taken into account appropriate ethical and other considerations, as called for in paragraph 5.
  6. The NCP notes that the recommendations of paragraph 5 are qualified with “where relevant to commercial objectives”. Again, the agreements cited by the Notifier did not appear relevant to “commercial objectives” or commercial activities of UBC. The NCP therefore did not consider the issue material to the recommendations in paragraph 5 of Chapter IX.

Human Rights Due Diligence Regarding Endowment Fund Investments

  1. The Respondent appears to be engaged in commercial activities in its capacity as an institutional investor. According to the 2023 Annual UBC Endowment Report, UBCIM manages the UBC Endowment’s assets with the “goal of maximizing net real returns in accordance with Fund’s objectives, spending requirements and risk parameters”. This activity also appears to have an international dimension, with UBCIM managing an endowment fund that includes investments in a wide range of global and emerging equities, among other types of assets. UBCIM’s publicly available disclosure of holdings indicate investments in thousands of enterprises around the world.
  2. The issue of whether an institutional investor is undertaking human rights due diligence regarding business relationships with investee companies appears material to the Guidelines. Paragraph 17 of the commentary notes that the term “business relationship” includes relationships with “investee companies”. The relevance of the OECD Guidelines to institutional investors and their business relationships has been recognized in the OECD’s publication Responsible business conduct for institutional investors (2017).Footnote 7
  3. In this instance, the Notifier claimed that the Respondent “maintained investments via pooled funds in the companies that manufacture, design, or sell the components or primary systems for weapons” and that, by supplying the Israeli military, at least nine of these companies were “contributing to international and human rights law violations” allegedly caused by that military. The Notifier also claimed that the Respondent lacked a publicly available policy commitment to respect human rights and had not carried out human rights due diligence with regard to investments in its endowment portfolio, including by “[not using] its leverage to mitigate the severe adverse human rights impacts associated with these investments”.
  4. While the Respondent's June 30, 2023 Statements on Responsible Investing identify human rights as one of the social considerations informing its responsible investing approach, they do not contain a specific commitment under the "Responsible Investment Commitments" section relating to human rights due diligence. However, subsequent public updates describe additional measures relating to the management of social risks, including human rights.Footnote 8 The NCP notes that many of these initiatives were developed or further elaborated after UBC was notified of the complaint, including after the IA was completed and shared with the parties in September 2025. The Respondent has noted that these measures show continuous improvement in respect of its evolving responsible investing approach. The NCP has not assessed these measures as part of this Initial Assessment.
  5. Based on the information available to the NCP, there appears to be a sufficiently substantiated basis to accept for further consideration the Respondent’s overall approach to carrying out human rights due diligence regarding business relationships potentially arising from its endowment portfolio. While the Respondent does appear to have a general policy commitment to respect human rights in relation to its investment activities, it was unclear to the NCP how the Respondent’s current policies and approaches operate to identify, address, and communicate about human rights risks, in alignment with the Guidelines. The Respondent itself appeared to characterize this as an area for further development in its approach to responsible investing.
  6. It is important to emphasize that this is not a finding as to whether the Respondent has acted consistently with the Guidelines or whether it or other enterprises are involved with adverse human rights impacts. Rather, it simply means that the information available suggests there is a reasonable basis for further consideration of the issue as part of the specific instance procedure.
  7. The Notifier also alleged that the Respondent was invested in companies “operating in and/or maintaining illegal Israeli settlements in the Occupied West Bank and East Jerusalem”Footnote 9 and that its operations, services, or products were thereby linked to adverse human rights impacts being caused or contributed to by those companies.
  8. The NCP recognizes that this is a context presenting heightened human rights risks. The Government of Canada’s August 2026 Advisory to Canadian businesses states that given the risks associated with economic and financial activities in Israeli settlements, the Advisory strongly advises against economic and financial activities associated with Israeli settlements, expressly including investments and financial transactions, and calls on businesses to undertake enhanced due diligence, consistent with the Guidelines, including by assessing business relationships and direct or indirect linkages. More generally, the OECD Due Diligence Guidance for Responsible Business Conduct recognizes that systemic issues — defined as “problems or challenges that are prevalent within a context and are driven by root causes outside of the enterprise’s immediate control” — may be relevant to the nature and extent of an enterprise’s due diligence, as they may increase the risk of adverse impacts within an enterprise’s own operations.
  9. However, the fact that an enterprise is operating in a high-risk area or context where systemic issues exist does not by definition mean that it is contributing to adverse impacts. As noted in the NCP’s procedures, a specific instance process “cannot be founded on assumptions”. In this case, while the information provided identifies the investee companies and the settlement-related risks associated with their activities, it does not establish how the Respondent, through those investment relationships, was directly linked to particular adverse human rights impacts. The NCP therefore does not consider this specific allegation sufficiently substantiated to warrant dedicated further consideration.
  10. The NCP’s assessment of this issue does not represent a finding or determination as to whether the Respondent is directly linked to adverse impacts through a business relationship, or whether entities with which it may have business relationships are themselves causing or contributing to adverse human rights impacts.

2.3 Whether there seems to be a link between the enterprise’s activities and the issue(s) raised in the specific instance

  1. The Respondent took the position that NCPs should engage only in cases where enterprises are making a “material and substantial contribution to adverse impacts on human rights” and that this threshold had not been met. In this case, the issue which the NCP considers material and substantiated relates to the Respondent’s approach and system for conducting human rights due diligence. There appears to be a link between the Respondent’s activities as an institutional investor and the issue raised regarding its human right due diligence.

2.4 The relevance of applicable law and procedures, including court rulings

  1. The Notifier’s submission referred to a 2024 advisory opinion of the International Court of Justice (Legal Consequences arising from the Policies and Practices of Israel in the Occupied Palestinian Territory, including East Jerusalem). The Notifier alleged that the Respondent was “failing to respect” certain “provisions” of that opinion. The relevance of this advisory opinion – which responded to a request from the UN General Assembly and speaks to legal considerations for States and the United Nations – was not clear to the NCP.
  2. The Notifier’s submission also referred to Nevsun Resources Ltd. v. Araya, a 2020 decision of the Supreme Court of Canada. This decision did not involve the parties to the specific instance. The NCP notes that it is called upon to conduct initial assessments and carry out its non-judicial specific instance process with reference to the recommendations and expectations for multinational enterprises set out in the Guidelines, not domestic legal principles concerning civil liability. The relevance of this court decision was therefore not clear to the NCP.
  3. The Respondent emphasized in its response to the NCP its legal obligations, including in relation to fiduciary duties. The NCP recognizes that fiduciary duties of institutional investors inform and provide parameters for investment decisions and portfolio management. The NCP also notes the steps taken by the Respondent to integrate human rights considerations into its responsible investment approach. Given the evolving nature of practice in this area, the NCP considers that further dialogue could usefully explore how the Respondent applies human rights due diligence in practice, including in the context of the issues raised in this specific instance.

2.5 How similar issues have been, or are being treated in other domestic or international proceedings

  1. Neither of the parties cited parallel proceedings that would preclude further consideration of the issue or an offer of good offices from making a positive contribution to resolution of the material and substantiated issue, or that would create serious prejudice for either of the parties in other proceedings.

2.6 Whether the consideration of the specific issue(s) would contribute to the purposes and effectiveness of the Guidelines

  1. The NCP takes note of the Respondent’s stated commitment to further integrate human rights considerations into its responsible investing practices, as reaffirmed in its published April 4, 2025 “Update on UBC and UBCIM Responsible Investing Commitments”. The IA is based on the record before the NCP when the assessment was completed and shared with the parties in September 2025. The NCP has nevertheless taken note of subsequent public updates describing further developments in the Respondent's approach to managing social and human rights risks in its investment activities, including the completion of a Social Risk (including Human Rights) Framework and an Educational Primer on Social Risk, engagement with interested faculty and student groups, and the planned integration of these measures into UBCIM's Responsible Investing Strategy in 2026.Footnote 10 These developments indicate that the Respondent's approach continues to evolve and do not alter the NCP's view that further consideration of its approach in light of paragraphs 4 and 5 of Chapter IV (Human Rights) has the potential to contribute to the purposes and effectiveness of the Guidelines.
  2. As noted earlier, the NCP has also taken into consideration the Government of Canada’s August 2026 Advisory to Canadian businesses concerning economic and financial activities associated with Israeli settlements in the West Bank and East Jerusalem. The Advisory post-dates completion of the Initial Assessment but is relevant to the risk context in which investment-related human rights due diligence may operate, including its call for enhanced due diligence in relation to settlement-associated activities. The Advisory reinforces the potential value of further consideration of the Respondent’s overall approach under Chapter IV, paragraphs 4 and 5.
  3. The NCP recognizes that the parties have already had multiple discussions outside of the specific instance procedure. This may raise questions about whether further consideration and an accompanying offer of good offices by the NCP would be constructive. However, the NCP is mindful of the 2022 Response by the Investment Committee to the substantiated submission by OECD Watch regarding the Canadian National Contact Point for Responsible Business Conduct, and the committee’s position that a determination to accept an issue for further consideration should not be based on the likelihood of good offices being accepted or leading to a resolution. The fact that the parties have previously engaged in dialogue will therefore not preclude the NCP from accepting the issue for further consideration and offering good offices.

3. Conclusion

3.1 Issue accepted for further consideration

  1. The NCP has accepted for further consideration the Respondent’s overall approach to implementing the Recommendations in Chapter IV paragraphs 4 and 5 in relation to business relationships arising from its endowment portfolio investments.
  2. The Implementation Procedures of the Guidelines call on NCPs to offer good offices where, based on an initial assessment, the NCP is of the view that further consideration of an issue is warranted. The NCP’s own procedures note that good offices “will” be offered in such circumstances (section 4.18). The NCP is therefore offering its good offices to the parties. The NCP proposes a single, one-hour session of facilitated dialogue to provide a forum for constructive and targeted exchange on the Respondent’s approach to responsible investment and human rights, and to explore the relevance of the Guidelines to human rights due diligence in the context of its future investment activities. The NCP will work with both parties in advance to agree on appropriate parameters for the discussion, including participation, format, and scope, with the objective of ensuring a focused and forward-looking exchange.
  3. It is important to recall that the Guidelines call on enterprises to carry out human rights due diligence “as appropriate to their size, the nature and context of operations and the severity of the risks of adverse human rights impacts” (Chapter IV, paragraph 5). In this case, the Respondent’s status as an institutional investor is an important part of that context. As noted in Responsible business conduct for institutional investors, the relationship between an investor and an investee company is qualitatively different from other kinds of business relationship (e.g., between purchaser and supplier companies). Due diligence might entail a variety of approaches and responses and what is appropriate “will vary according to the characteristic of an investor, the investment strategy (e.g. active vs. passive investments) and relevant regulatory obligations”. The Government of Canada’s Advisory is also relevant to this context. The NCP would encourage the parties to approach any facilitated dialogue with this in mind.
  4. It is also important to recall that the Guidelines recognize that “obeying domestic laws is the first obligation of enterprises” and that the Guidelines are “not intended to place an enterprise in situations where it faces conflicting requirements” (Chapter I, paragraph 2). The NCP is not in a position to facilitate a dialogue focused on the legal obligations of an enterprise, or to advise or opine on the nature or extent of these obligations. However, the NCP can facilitate a dialogue aimed at exploring how the due diligence recommendations of the Guidelines might still be fulfilled to the greatest extent possible within the parameters of an enterprise’s approach to legal compliance.

3.2 Issues not accepted for further consideration

  1. The NCP has not accepted for further consideration the issue of the Respondent allegedly being directly linked to adverse human rights impacts by virtue of the academic partnership agreements cited by the Notifier.
  2. The NCP has not accepted for further consideration the issue of the Respondent allegedly being directly linked – via business relationships arising from its endowment portfolio – to adverse human rights impacts allegedly caused by the Israeli military.
  3. The NCP has not accepted for further consideration the issue of the Respondent allegedly being directly linked to adverse human rights impacts by virtue of having investments involving enterprises that may have operations involving settlements in the occupied territories.

Timeline

December 5, 2024 - NCP receives the Notifiers’ request for review.

December 19, 2024 - NCP holds a call with the Notifiers to discuss the request for review.

December 19, 2024 - Notifiers provide the NCP with additional information and supporting documentation.

January 9, 2025 - NCP shares the Notifiers’ request for review with the Respondent.

January 24, 2025 - NCP holds a call with the Respondent to discuss the issues raised in the request for review.

February 26, 2025 - Respondent provides the NCP with its reply to the request for review.

September 9, 2025 - NCP shares the draft Initial Assessment with the parties.

September 22, 2025 - Respondent acknowledges receipt of the draft Initial Assessment and requests an extension until the end of November 2025 to provide comments.

September 30, 2025 - Notifiers provide feedback on the draft Initial Assessment.

October 7, 2025 - NCP shares the Respondent’s reply to the request for review with the Notifiers.

November 7, 2025 - Respondent requests a call with the NCP Secretariat to discuss the draft Initial Assessment.

November 28, 2025 - Notifiers provide a response to the Respondent’s reply, along with amended feedback on the draft Initial Assessment.

November 29, 2025 - The Respondent provides comments on the draft Initial Assessment and identifies issues for discussion during the call with NCP Secretariat.

February 9, 2026 - NCP Secretariat holds a call with the Respondent to discuss the draft Initial Assessment.

April 8, 2026 - Respondent provides comments on the draft Initial Assessment for disclosure with Notifier.

April 8, 2026 - NCP shares Respondent’s feedback on the draft Initial Assessment with the Notifier.

May 5, 2026 - NCP informs the parties that the Initial Assessment shared on September 9, 2025, will proceed to publication.

May 5, 2026 - Respondent informs the NCP that it wishes to submit additional comments on the Initial Assessment.

May 28, 2026 - Second call with the Respondent

June 3, 2026 - Parties updated on the status of the Initial Assessment, including willingness to participate in good offices

July 11, 2026 - At the Respondent's request, the Chief Trade Commissioner holds a call with the Respondent.

July 27, 2026 - The Respondent submits a further set of comments on the draft Initial Assessment originally shared with the parties on September 9, 2025. The NCP reviewed these comments for factual accuracy.

Date modified: