Making human rights due diligence a legal requirement for companies including systems to identify, assess, mitigate or manage human rights risks and impacts to improve that process over time and to disclose the risks and impacts, the steps taken and the results.
Direct Consultation with Governments
Comments from the entity submitted through official regulatory and legislative consultation processes, or via meetings and other direct engagements with policymakers. Includes evidence obtained by InfluenceMap through Freedom of Information requests.
The Company agrees that an EU legal framework is needed, agrees with due diligence duty defintion proposed and advocates for a principles-based approach.
The Company agrees thtat an EU legal framework is needed (question 2), agrees with due diligence duty defintion proposed by the consultation (question 14) and advocates for a principles-based approach (question 15).
Direct Consultation with Governments
Comments from the entity submitted through official regulatory and legislative consultation processes, or via meetings and other direct engagements with policymakers. Includes evidence obtained by InfluenceMap through Freedom of Information requests.
Although the Companies does not explicitly shows support for the Directive as a whole, it calls for strenghtening requirements presented in the proposal
Although it does not explicitly shows support for the Directive as a whole, calls for strenghtening requirements presented in the proposal, which can be inferred as a tacit support for an EU legal framework on due diligence.
Media Reports
Here we search in a consistent manner (the organization name and relevant query search terms) a set of web sites of representing reputable news or data aggregations. Supported by targeted searches of proprietary databases.
Based on the document "Investor Statement in Support of Mandated Human Rights and Environmental Due Diligence in the European Union," signed by this entity. It states: “We... support mandated human rights and environmental due diligence.” “The process of continuously conducting robust human rights and environmental due diligence is a core requirement for businesses...” “Governments have a duty to protect against human rights abuses... through effective regulatory measures, particularly where voluntary corporate measures continue to leave significant gaps.” "In line with the requirements detailed in the UN Guiding Principles and the OECD Guidelines, businesses should have an obligation to identify, prevent, mitigate, and account for how they address their potential and actual human rights and environmental impacts through an ongoing human rights and environmental due diligence process"
The statement clearly expresses support for the legal mandatory nature of due diligence, considering it essential for the protection of human rights and the environment, as well as for closing gaps left by voluntary approaches. The organization publicly endorses the mandatory implementation of due diligence including the obligation to identify, prevent, mitigate, and account for how they address their potential and actual human rights impacts and the ongoing nature of due diligence based on international standards and the inefficacy of voluntary solutions, fully aligning with the indicator.
Media Reports
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The signatory organizations express clear support for the mandatory nature of due diligence, highlighting its importance for tangible outcomes in human rights, environmental protection, and climate action, as well as its role in establishing mandatory standards beyond sustainability disclosure.
“The CSDDD holds huge promise for leveling the playing field... as well as driving better outcomes for people and planet through global value chains.” “We support the CSDDD and the process to adopt an ambitious final law.” “The Directive should complement mandatory sustainability disclosure with substantive due diligence duties on human rights and environmental impacts…”
Requiring Human rights due diligence of all companies, regardless of sector and size, while still reflecting their individual circumstances.
Direct Consultation with Governments
Comments from the entity submitted through official regulatory and legislative consultation processes, or via meetings and other direct engagements with policymakers. Includes evidence obtained by InfluenceMap through Freedom of Information requests.
The Company advocates for an horizontal approach (all sectors), the inclusion of SMEs and 'comply or explain' for small and micro-enterprsises
It advocates for a horizonal approach (covering all sectors) in question 15, and in its response to question 16, the Company states that 'Mandatory for large and SME, comply or explain for small and micro'.
Direct Consultation with Governments
Comments from the entity submitted through official regulatory and legislative consultation processes, or via meetings and other direct engagements with policymakers. Includes evidence obtained by InfluenceMap through Freedom of Information requests.
The Company asks for the inclusion of SMEs and complete coverage of the financial sector.
The Company states that ‘We strongly recommend that the financial sector should be covered completely and consistently with the UNGPs without the specific limitations to due diligence on companies at the precontractual phase and to operations of large corporate clients’. It also points out that ‘Whilst recognising the need for proportionate phase in of requirements, we recommend that the proposals are unduly limited to large companies and those in the high-risk sectors. It does not make sense to set a lower standard nor to limit it to a smaller group of companies in the proposed Directive, although we recognise the need for proportionate implementation for SMEs. For SME’s we would recommend matching the approach in the proposed CSRD to phase in the rules for SMEs and also set appropriate and proportionate requirements via delegated act’.
Media Reports
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The statement indicates: “Mandated human rights and environmental due diligence should be cross-sectoral, covering all business enterprises and financial institutions, public and private, domiciled or based in, operating, or offering a product or service within the EU.” “Critically, it should cover small as well as large businesses, recognizing that they are part of the same value chain.”
The document explicitly advocates that the legislation should include all companies, regardless of size or sector, including financial institutions. The statement supports the universal application of the regulation, including SMEs and financial actors, justifying the maximum score.
Media Reports
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The text asserts that the requirements should apply to all companies and sectors, including the financial sector.
“The due diligence requirements should be risk-based and apply to the entire spectrum of risks and impacts across the full value chains of companies in all sectors, including financial institutions…”
Implementing an enforcement mechanism where companies fail to carry out due diligence as described.
Direct Consultation with Governments
Comments from the entity submitted through official regulatory and legislative consultation processes, or via meetings and other direct engagements with policymakers. Includes evidence obtained by InfluenceMap through Freedom of Information requests.
The Company picks all three options as enforcement mechanism, from a multiple choice question.
In response to question 19a on enforcement mechanisms, the Company picekd all three options: 'Judicial enforcement with liability and compensation in case of harm caused by not fulfilling the due diligence obligations; Supervision by competent national authorities based on complaints (and/or reporting, where relevant) about non-compliance with setting up and implementing due diligence measures, etc. with effective sanctions (such as for example fines);Supervision by competent national authorities (option 2) with a mechanism of EU cooperation/coordination to ensure consistency throughout the EU'.
Direct Consultation with Governments
Comments from the entity submitted through official regulatory and legislative consultation processes, or via meetings and other direct engagements with policymakers. Includes evidence obtained by InfluenceMap through Freedom of Information requests.
The Company recommends that, in addition to remedies and fines against companies for breaching obligations, directors who oversee serious should face the potential to be disqualified.
The Company states that ‘in addition to the remedy of damages or fines levies against the company in breach of its obligations, we strongly recommend that the Commission add a provision that directors who oversee serious breaches of the due diligence requirements additionally face the potential to be disqualified from holding the role of a corporate director for a specified period (such period to be commensurate with the scale of the breach)’.
Media Reports
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“Legislation can... clarify legal consequences for when those standards are not met...” “EU Member States should ensure robust enforcement of all obligations and provide the right to an effective remedy.”
The organization advocates for effective regulatory mechanisms with clear legal consequences, indicating support for mandatory enforcement. There is explicit support for the existence of robust legal enforcement to ensure the effective implementation of the legislation.
Media Reports
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The organizations demand that the directive include administrative oversight and civil liability, demonstrating explicit support for effective enforcement mechanisms.
“The Directive will not be effective without meaningful enforcement… This includes both administrative supervision and civil liability…”
Including in the duties of directors and company law obligations to avoid human rights impacts or “harms”.
Direct Consultation with Governments
Comments from the entity submitted through official regulatory and legislative consultation processes, or via meetings and other direct engagements with policymakers. Includes evidence obtained by InfluenceMap through Freedom of Information requests.
The entity agrees to some extent that corporate directors should be required to manage the risks for the company in relation to stakeholders and that directors should set up procedures to ensure risks and impacts on stakeholders are identified, prevented and addressed.
The Company agrees to some extent with both questions 7 and 6. In relation to the first (7h), it states that 'The principle is sound but in practice it will depend on the issue, the availability of data and the ability of directors to influence. A principles or risk-based approach would therefore be appropriate – part of sound risk management practices more generally. Where risks cannot be prevented, then any duty should include a requirement to mitigate those risks to the extent possible in line with OECD Guidance for Responsible Business Conduct'. In response to question 6, it sates that 'Certain stakeholders, risks and interests will be more proximate/ relevant and so a one size fits all approach to all stakeholders and interests would not be appropriate. Where interests conflict, or have the potential to conflict, then directors should have the duty to balance those interests as according to how they in good faith believe will best promote the long-term interests of the company. Companies will need to understand the stakeholder interests in order to identify and manage risks'.
Direct Consultation with Governments
Comments from the entity submitted through official regulatory and legislative consultation processes, or via meetings and other direct engagements with policymakers. Includes evidence obtained by InfluenceMap through Freedom of Information requests.
The Company recommends that article 26 (setting up and overseeing due diligence) should be strengthened, adding more concrete requirements that taking steps, and directors should face potential for disqualification.
The Company states that ‘in respect of Article 26, we suggest that more concrete requirements that “taking steps” to adapt strategy are incorporated into the requirements of directors’. It points out that ‘Too often, directors, as the controlling mind of the company, consider the risk of fines for failure to carry out environmental or human rights due diligence or the failure to identify, prevent, mitigate, end and remedy adverse impacts as “the cost of doing business”. It finally states that ‘The potential for disqualification for either deliberate due diligence failures, or turning a blind eye to them, would change the incentives and behaviours and complement the other directors’ duties provisions in the proposed Directive. Article 26 should therefore be strengthened, with the potential for disqualification for directors not fulfilling their personal responsibility for due diligence’.
Media Reports
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“Corporate boards should oversee and be accountable for the implementation of rigorous human rights and environmental due diligence processes; monitor, discuss, and report on their development...”
The statement advocates for the inclusion of formal responsibilities in boards of directors, reinforcing their role in the governance of due diligence.
Require companies to provide remedy for human rights impacts they have caused or contributed to.
Direct Consultation with Governments
Comments from the entity submitted through official regulatory and legislative consultation processes, or via meetings and other direct engagements with policymakers. Includes evidence obtained by InfluenceMap through Freedom of Information requests.
The Company advocates for enforcement mechanisms that include liability and compensation, at least, in case of harm caused by not fulfilling due diligence duty.
In its response to question 19a the Company chooses, among other enforcement mechanisms, judicial enforcement with liability in case of harm caused by not fulfilling the due diligence duty. Although the entity does not refer to remedy in other contexts, it is not directly asked about it either.
Direct Consultation with Governments
Comments from the entity submitted through official regulatory and legislative consultation processes, or via meetings and other direct engagements with policymakers. Includes evidence obtained by InfluenceMap through Freedom of Information requests.
The Company recommends ‘that the provisions regarding remedy be enhanced to provide for penalties in respect of directors as individuals in certain circumstances’.
The Company states that ‘With regard to the remedies provisions of Article 20 (Sanctions) and 22 (Civil Liability), in addition to the remedy of damages or fines levies against the company in breach of its obligations, we strongly recommend that the Commission add a provision that directors who oversee serious breaches of the due diligence requirements additionally face the potential to be disqualified from holding the role of a corporate director for a specified period (such period to be commensurate with the scale of the breach). Too often, directors, as the controlling mind of the company, consider the risk of fines for failure to carry out environmental or human rights due diligence or the failure to identify, prevent, mitigate, end and remedy adverse impacts as “the cost of doing business”. … This market failure requires regulatory intervention to correct it. Fines, and particularly substantial fines linked to turnover as well as the scale of the breach, are an important part of the range of appropriate remedies for due diligence failures’.
Media Reports
Here we search in a consistent manner (the organization name and relevant query search terms) a set of web sites of representing reputable news or data aggregations. Supported by targeted searches of proprietary databases.
“Due diligence legislation should ensure accountability for harms which businesses cause or contribute to and should enable and support the provision of adequate and effective remedy.”
The statement acknowledges the obligation to remedy damages caused or contributed to, advocating for appropriate compensation mechanisms. Direct support for the principle of remediation, with strong and specific normative language.
Require companies to exert leverage on and/or provide support to their counterparties in the remediation of human rights impacts that are linked to company activities through their business relationships (e.g their value chains).
Direct Consultation with Governments
Comments from the entity submitted through official regulatory and legislative consultation processes, or via meetings and other direct engagements with policymakers. Includes evidence obtained by InfluenceMap through Freedom of Information requests.
Although this is not directly asked, the Company agrees with the definition of due diligence duty, which includes accounting for human rights in the supply chain linked to the Company and is in favour of judicial enforcement with liability and compensation in case of harm caused by not fulfilling the due diligence obligations.
Although this not directly asked, the Company agrees with the definition of due diligence duty, which includes accounting for human rights in the supply chain linked to the Company (question 14) and is in favour of judicial enforcement with liability and compensation in case of harm caused by not fulfilling the due diligence obligations (question 19a).
Direct Consultation with Governments
Comments from the entity submitted through official regulatory and legislative consultation processes, or via meetings and other direct engagements with policymakers. Includes evidence obtained by InfluenceMap through Freedom of Information requests.
The Company recommends mandating responsible disengagement and ongoing responsibility for unremediated adverse impacts.
The Company states that ‘In terms of alignment, in particular we recommend that the proposal to limit due diligence to “established business relationships” should be extended across the value chain in a risk-based and proportionate manner and the provisions relating to the need to cease a business relationship should be strengthened to mandate responsible disengagement and ongoing responsibility for unremediated adverse impacts’.
Media Reports
Here we search in a consistent manner (the organization name and relevant query search terms) a set of web sites of representing reputable news or data aggregations. Supported by targeted searches of proprietary databases.
"Dependent upon their connection to a harm, businesses should provide for, cooperate in, or use leverage to ensure remediation of adverse impacts in their global value chains and within their operations."
The statement explicitly supports the use of leverage to ensure remediation within its global value chains.
Require companies to provide grievance mechanisms for all stakeholders including those in the value chain.
Direct Consultation with Governments
Comments from the entity submitted through official regulatory and legislative consultation processes, or via meetings and other direct engagements with policymakers. Includes evidence obtained by InfluenceMap through Freedom of Information requests.
Although the entity is in favour of requirements for consultation channels for engaging with stakeholders, it is not clear if it considers it complaint mechanisms should be included.
The Company agrees 'to some extent' with a requirement (for directors) to establish mechanisms for engaging in stakeholder consultation as part of due diligence duty (question 20a). It then states that 'Companies should be able to identify through their due diligence process the stakeholders most at risk of severe impacts. They should ensure they engage constructively and meaningfully with the relevant stakeholders, either via existing mechanism or through the establishment of new ones, to ensure different groups interests are accounted for'. It does not respond to the specific quesiton on grievance mechanisms. it considers employees and communities at both own operations and supply chain as relevant.
Require companies to actively engage, consult and involve rights-holders at all stages of the remediation process.
Direct Consultation with Governments
Comments from the entity submitted through official regulatory and legislative consultation processes, or via meetings and other direct engagements with policymakers. Includes evidence obtained by InfluenceMap through Freedom of Information requests.
The Company encourages the Directive to ‘strengthen its emphasis on stakeholder engagement throughout (e.g. Article 6-11) and particularly in relation to the role of companies in providing remedy’.
It states that ‘In our experience, companies that conduct meaningful engagement with affected stakeholders often … tend to be better at implementing strategies to mitigate and remedy their impacts. We encourage the proposal to strengthen its emphasis on stakeholder engagement throughout (e.g. Article 6-11) and particularly in relation to the role of companies in providing remedy’.
Enabling judicial enforcement with liability and compensation in case of harm caused by not fulfilling the due diligence obligations.
Direct Consultation with Governments
Comments from the entity submitted through official regulatory and legislative consultation processes, or via meetings and other direct engagements with policymakers. Includes evidence obtained by InfluenceMap through Freedom of Information requests.
The Company is in favor of judicial enforcement with liability and compensation in case of harm caused by not fulfilling due diligence duty
To question 19.a regarding the enforcement of obligations, the Company's choice includes all 3 options: 1) "Judicial enforcement with liability in case of harm caused by not fulfilling the due diligence obligations" (which include remedy). 2) "Supervision by competent national authorities based on complaints (and/or reporting, where relevant) about non-compliance with setting up and implementing due diligence measures, etc. with effective sanctions (such as for example fines)". 3) "Supervision by competent national authorities (option 2) with a mechanism of EU cooperation/coordination to ensure consistency throughout the EU".
Direct Consultation with Governments
Comments from the entity submitted through official regulatory and legislative consultation processes, or via meetings and other direct engagements with policymakers. Includes evidence obtained by InfluenceMap through Freedom of Information requests.
The Company is supportive of greater efforts to address legal and practical barriers to accessing judicial remedy.
It states that ‘We also support calls by NGOs and trade unions for greater efforts to be made to address legal and practical barriers to accessing judicial remedy’
Media Reports
Here we search in a consistent manner (the organization name and relevant query search terms) a set of web sites of representing reputable news or data aggregations. Supported by targeted searches of proprietary databases.
"Businesses should be held accountable through appropriate administrative and civil liability legislative provisions for human rights and environmental adverse impacts within their operations and throughout their global value chains"
The statement explicitly advocates for civil and administrative liability, aligning with the judicial enforcement framework at an early stage in the legislative process.
Require companies to implement a due diligence process covering their value chain to identify, prevent, mitigate and remediate human rights impacts and improve that practice over time.
Direct Consultation with Governments
Comments from the entity submitted through official regulatory and legislative consultation processes, or via meetings and other direct engagements with policymakers. Includes evidence obtained by InfluenceMap through Freedom of Information requests.
The Company considers that en EU legal framework on due diligence is needed agrees with due diligence duty definition provided by the consultation, advocates for a horizontal principles-based approach. It however, does not refer to the rest of the elements of the indicator.
The Company considers that en EU legal framework on due diligence is needed (question 2) agrees with due diligence duty definition provided by the consultation (question 14), advocates for a horizontal principles-based approach (15). It however, does not refer to the scope of value chain (including both upstream and downstream relationships), remedy, or improving practice over time.
Direct Consultation with Governments
Comments from the entity submitted through official regulatory and legislative consultation processes, or via meetings and other direct engagements with policymakers. Includes evidence obtained by InfluenceMap through Freedom of Information requests.
The Company calls for mandatory due diligence, considers that business relationships definition should cover the whole value chain, and is in favour of strengthening requirements regarding remedy.
It states that ‘The proposal limits the scope of this due diligence to “established business relationships” and unhelpfully reverses the logic of the UNGPs, and risks creating perverse incentives whereby companies may adapt their business structures to avoid the requirement to carry out human rights due diligence and/or fail to identify the most severe risks and impacts that often further upstream’. It also recommends enhancinig the provisions regarding remedy.
Media Reports
Here we search in a consistent manner (the organization name and relevant query search terms) a set of web sites of representing reputable news or data aggregations. Supported by targeted searches of proprietary databases.
“Businesses having an obligation to respect human rights and the environment in their own operations and in their global value chains should use their leverage to ensure that human rights and the environment are respected in those global value chains.” “...should ensure remediation of adverse impacts in their global value chains and within their operations.” “...businesses should be held accountable... throughout their global value chains.”
The statement supports the application of due diligence across the value chain. However, no more detail is provided on the extent of global value chains.
Media Reports
Here we search in a consistent manner (the organization name and relevant query search terms) a set of web sites of representing reputable news or data aggregations. Supported by targeted searches of proprietary databases.
The text clearly states that due diligence should apply to the entire value chain, including both upstream and downstream operations.
"The due diligence requirements should be risk-based and apply to the entire spectrum of risks and impacts across the full value chains of companies in all sectors, including financial institutions, in line with the international standards. The same concepts in those standards that make due diligence feasible in an upstream context – including prioritisation on the basis of severity and the need to look at how a company’s own activities can heighten or reduce risks across value chains – also make it feasible in a downstream context"
Require that companies implement contract clauses and Code of Conduct with business partners clarifying obligations to avoid and to address human rights harms.
Direct Consultation with Governments
Comments from the entity submitted through official regulatory and legislative consultation processes, or via meetings and other direct engagements with policymakers. Includes evidence obtained by InfluenceMap through Freedom of Information requests.
The company opposes relying on contractual clauses as a justification for fulfilling due diligence obligations, warning that this could lead companies to consider such clauses sufficient in themselves.
The Company states that 'The proposal risks entrenching a widely held misconception among companies that a reliance on compliance-based mechanisms e.g. contractual obligations and auditing are sufficient to comply with the due diligence requirement. In our experience this misconception is one of the biggest barriers we face when engaging with companies on their due diligence processes. This is despite extensive evidence that suggests otherwise'.
Media Reports
Here we search in a consistent manner (the organization name and relevant query search terms) a set of web sites of representing reputable news or data aggregations. Supported by targeted searches of proprietary databases.
The statement warns against excessive reliance on contractual clauses, favoring collaboration-based approaches instead
“...rather than top-down policing through an overreliance on contracts and audits. Such an approach simply shifts responsibility...”
Require that companies identify their stakeholders and their interests.
Direct Consultation with Governments
Comments from the entity submitted through official regulatory and legislative consultation processes, or via meetings and other direct engagements with policymakers. Includes evidence obtained by InfluenceMap through Freedom of Information requests.
The Company indicates that it agrees to some extent to the requirement of mandatory identification of stakeholders and their interests.
In response to question 6, the Company states that 'Certain stakeholders, risks and interests will be more proximate/ relevant and so a one size fits all approach to all stakeholders and interests would not be appropriate. Where interests conflict, or have the potential to conflict, then directors should have the duty to balance those interests as according to how they in good faith believe will best promote the long-term interests of the company. Companies will need to understand the stakeholder interests in order to identify and manage risks'.
Require directors to establish and apply mechanisms or, where they already exist for employees for example, use existing information and consultation channels for engaging with stakeholders.
Direct Consultation with Governments
Comments from the entity submitted through official regulatory and legislative consultation processes, or via meetings and other direct engagements with policymakers. Includes evidence obtained by InfluenceMap through Freedom of Information requests.
The Company responds that agrees to some extent to directors being required to establish consultation channels for engaging with stakeholders.
The Company agrees 'to some extent' with a requirement (for directors) to establish mechanisms for engaging in stakeholder consultation as part of due diligence duty (question 20a). It then states that 'Companies should be able to identify through their due diligence process the stakeholders most at risk of severe impacts. They should ensure they engage constructively and meaningfully with the relevant stakeholders, either via existing mechanism or through the establishment of new ones, to ensure different groups interests are accounted for'.
Direct Consultation with Governments
Comments from the entity submitted through official regulatory and legislative consultation processes, or via meetings and other direct engagements with policymakers. Includes evidence obtained by InfluenceMap through Freedom of Information requests.
The Company encourages the proposal to strengthen emphasis on stakeholder engagement.
The Company states that ‘Another dimension companies often fail to understand or appreciate … is meaningful stakeholder engagement …. In our experience, companies that conduct meaningful engagement with affected stakeholders often display a better and more informed understanding of their actual and potential adverse impacts, are better at communicating these in the public domain – including to stakeholders themselves - and tend to be better at implementing strategies to mitigate and remedy their impacts. We encourage the proposal to strengthen its emphasis on stakeholder engagement throughout (e.g. Article 6-11) and particularly in relation to the role of companies in providing remedy’.
Require that human rights risks and impacts should be assessed through dialogue with stakeholder or with their legitimate representatives.
Direct Consultation with Governments
Comments from the entity submitted through official regulatory and legislative consultation processes, or via meetings and other direct engagements with policymakers. Includes evidence obtained by InfluenceMap through Freedom of Information requests.
The Company encourages the proposal to strengthen emphasis on stakeholder engagement, including in impact assessment process.
The Company states that ‘Another dimension companies often fail to understand or appreciate … is meaningful stakeholder engagement …. In our experience, companies that conduct meaningful engagement with affected stakeholders often display a better and more informed understanding of their actual and potential adverse impacts, are better at communicating these in the public domain – including to stakeholders themselves - and tend to be better at implementing strategies to mitigate and remedy their impacts. We encourage the proposal to strengthen its emphasis on stakeholder engagement throughout (e.g. Article 6-11) and particularly in relation to the role of companies in providing remedy’.
Media Reports
Here we search in a consistent manner (the organization name and relevant query search terms) a set of web sites of representing reputable news or data aggregations. Supported by targeted searches of proprietary databases.
“Throughout the human rights and environmental due diligence process, businesses should meaningfully engage with actually and potentially affected stakeholders or their appointed representatives.”
The statement explicitly supports dialogue with stakeholders as part of the due diligence process, including the identification and assessment of risks. Direct and clear support for the dialogic approach to risk assessment, as defined by the indicator at an early stage in the legislative process.
Media Reports
Here we search in a consistent manner (the organization name and relevant query search terms) a set of web sites of representing reputable news or data aggregations. Supported by targeted searches of proprietary databases.
The letter links stakeholder engagement to risk assessment and the effectiveness of the company’s efforts.
"The distinguishing feature of sustainability due diligence is that it depends for its effectiveness and credibility on the perspectives of affected stakeholders. ... Meaningful and safe engagement with affected stakeholders –with special attention to people in vulnerable situations – is central to due diligence."
Require that action plans are developed in consultation with affected stakeholders.
Direct Consultation with Governments
Comments from the entity submitted through official regulatory and legislative consultation processes, or via meetings and other direct engagements with policymakers. Includes evidence obtained by InfluenceMap through Freedom of Information requests.
The Company encourages the proposal to strengthen emphasis on stakeholder engagement, including action plans.
The Company states that ‘Another dimension companies often fail to understand or appreciate … is meaningful stakeholder engagement …. In our experience, companies that conduct meaningful engagement with affected stakeholders often display a better and more informed understanding of their actual and potential adverse impacts, are better at communicating these in the public domain – including to stakeholders themselves - and tend to be better at implementing strategies to mitigate and remedy their impacts. We encourage the proposal to strengthen its emphasis on stakeholder engagement throughout (e.g. Article 6-11) and particularly in relation to the role of companies in providing remedy’. Articles 7 and 8 refer to impract prevention and bringing impacts to an end.
Require that corporate directors should manage the human rights risks for the company in relation to stakeholders and their interest including on the long run.
Direct Consultation with Governments
Comments from the entity submitted through official regulatory and legislative consultation processes, or via meetings and other direct engagements with policymakers. Includes evidence obtained by InfluenceMap through Freedom of Information requests.
The Company agrees 'to some extent' to requiring directors to manage the risks in relation to stakeholders and their interests, including in the long run.
In response to question 6, the Company states that 'Certain stakeholders, risks and interests will be more proximate/ relevant and so a one size fits all approach to all stakeholders and interests would not be appropriate. Where interests conflict, or have the potential to conflict, then directors should have the duty to balance those interests as according to how they in good faith believe will best promote the long-term interests of the company. Companies will need to understand the stakeholder interests in order to identify and manage risks'.
| Legislation | Phase of Active Company Engagement | Position |
|---|
| Industry Association | Performance band |
|---|---|
| Associazione Nazionale fra le Imprese Assicuratrici (ANIA) | E- |
| France Assureurs (Fédération Française de l'Assurance) | D+ |