Teneo Should Terminate its Misleading Public Relations Work for Saudi Arabia's Public Investment Fund and NEOM
(Washington, D.C. – November 13, 2024) – U.S. consulting firm Teneo has contributed to, and benefited from, human rights abuses by whitewashing human rights abuses by the Saudi government and providing the public with misleading and incomplete information about its Saudi government-owned clients, the Saudi Public Investment Fund (PIF) and NEOM, said DAWN today.
Teneo has also defied the U.S. Congress and undermined Congressional oversight by failing to comply with a November 2023 Senate subpoena investigating the PIF's attempted takeover of PGA Tour, instead choosing to shield its Saudi government clients by citing a Saudi court injunction threatening criminal penalties—an unprecedented challenge to Congress's investigative authority. DAWN urged Teneo to drop its contracts with PIF and NEOM to avoid further contributing to human rights abuses.
"Teneo's work for Saudi government-owned entities, the Public Investment Fund and NEOM, has not only contributed to human rights abuses in the country, but misled the public regarding an accurate and complete understanding about the role these entities play in violating the rights of people in Saudi Arabia," said Sarah Leah Whitson, DAWN's executive director. "Teneo's CEO Paul Keary has defied congressional oversight by failing to address the national security risks posed by its Saudi clients, failing to comply with a Senate subpoena because of the absurd excuse that the Saudi government will prosecute him if they do."
As described in DAWN's new profile of the company, Teneo has multiple, lucrative contracts with Saudi government-owned entities, including a $275,000 monthly contract with NEOM since August 2021, and contracts with the PIF valued at $2.19 million for June 2023 to January 2024 and $4.305 million for strategic consulting services through December 2024. These contracts involve Teneo promoting NEOM and the PIF's public relations and enhancing their image, while omitting crucial information about Saudi Arabia's unlawful, dangerous, and destabilizing abuses, helping to whitewash Saudi Arabia's human rights record.
DAWN reached out to Teneo for comment but did not receive a response by the time of publication.
Teneo's client NEOM is a $500 billion Saudi government-owned infrastructure agency, whose project to build a megacity in northwest Saudi Arabia has been rife with human rights abuses. Teneo is responsible for producing NEOM's communications to attract investors but has failed to disclose the abuses and risks associated with the project, including the forcible displacement of the indigenous population residing there and abuses of migrant worker rights.
Teneo is also registered as a foreign agent for Saudi Arabia's PIF and has submitted copies of its contracts with the PIF to the Justice Department's Foreign Agents Registration Act unit. Teneo's contract with the PIF requires Teneo to secure investor confidence and promote a positive image to the public. DAWN's research has uncovered how Teneo has misled the public and investors by omitting material facts about serious human rights violations in which the PIF has been implicated, including the murder of Jamal Khashoggi and illegal seizure of assets from Saudi citizens, and failed to disclose the human rights risks and national security concerns raised by PIF's influence campaign and acquisitions in the U.S. By failing to disclose these abuses and presenting the PIF as a legitimate global investment partner, Teneo has effectively provided an inaccurate, misleading and sanitized narrative that obscures the risks of engaging with the PIF.
In its work for the PIF and NEOM, Teneo appears to have breached its business human rights obligations by contributing to and benefiting from Saudi Arabia's human rights abuses. Under the United Nations Guiding Principles on Business and Human Rights (the "UN Guiding Principles"), businesses have a responsibility to "avoid causing or contributing to adverse human rights impacts through their own activities" as well as "to prevent or mitigate adverse human rights impacts that are directly linked to their operations, products or services by their business relationships, even if they have not contributed to those impacts." Working to promote a positive image of governments, agencies, government investment funds, or officials like those in Saudi Arabia responsible for grave crimes, including murder, torture, arbitrary arrests, and extrajudicial killings, effectively contributes to such abuses.
Teneo has also undermined U.S. Congressional oversight by failing to comply with a subpoena from the Senate Permanent Subcommittee on Investigations issued in November 2023. The subpoena sought details about Teneo's role in the PIF's attempted takeover of PGA Tour and its consultant Stephen Cohen's meetings with PIF and PGA Tour officials. While Teneo claims it intends to comply with the subpoena, it has yet to provide the requested information, citing a Saudi court injunction that supposedly threatens its staff with criminal liability under Saudi law.
This unprecedented situation highlights how Teneo has prioritized its lucrative relationship with the Saudi government over its obligations to comply with U.S. Congressional oversight. When faced with a choice between cooperating with a legitimate Senate investigation or protecting its Saudi government clients, Teneo effectively chose to shield the Saudi government from scrutiny, citing threats of legal action from Saudi courts as justification for withholding information from Congress.
"Allowing Teneo to use threats from a Saudi court to shield itself from congressional oversight sets a very dangerous precedent," said Raed Jarrar, DAWN's advocacy director. "Teneo's obligations to Saudi Arabia do not supersede its duties to comply with U.S. law, and no foreign court should be able to shield U.S. firms from Congressional investigation."
DAWN calls on Teneo to drop its contracts with NEOM and the PIF, conduct a thorough review of all of its clients, and cease representation of abusive clients such as the PIF and NEOM. Teneo should comply with the UN Guiding Principles to avoid causing or contributing to adverse human rights impacts through its own activities and to prevent or mitigate adverse human rights impacts that are directly linked to its operations or relationships.
DAWN, along with its partners—ALQST for Human Rights, Freedom Forward, and ReThinking Foreign Policy—has also submitted a coalition letter to Teneo. This letter, sent on November 13, 2024 and signed by these organizations, reiterates our demand for Teneo to terminate its contracts with Saudi Arabia's PIF and NEOM. The letter highlights the grave human rights abuses associated with these entities and urges Teneo to align its practices with international human rights standards. You can read the full letter here.
DAWN also urges Congress to cosponsor legislation that advances vital U.S. interests to protect our country from malign foreign influence, including the Fighting Foreign Influence Act and the Anti-Corruption and Public Integrity Act. DAWN urges members of Congress to refuse to meet with consultants and public relations firms working for abusive governments and their affiliates, and to pledge not to work for foreign governments or their agents on leaving office.
DAWN's Lobbyist Hall of Shame will continue to expose American consultants and PR firms—including strategic advisors, political operatives, former elected representatives and government officials—who are working as agents for abusive governments in the Middle East and North Africa to garner U.S. government support, including military aid, weapons sales, and diplomatic protection. DAWN's complete set of recommendations to consultants and the U.S. Congress are available here.
