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.
Although the entity agrees with the definition of due diligence, the entity thinks that: ‘No, it should be enough to focus on asking companies to follow existing guidelines and standards.’
In response to question 2, the entity believes, ‘there is no need to consider introducing regulatory requirements on due diligence in supply chain.’ The entity thinks that, ‘sectoral legislation in the EU already includes requirements on due diligence’, and supply chain due diligence should avoid duplication with the sectoral legislation.
The entity agrees with the definition of due diligence (question 14) and picks option 1, ‘Principles-based approach’ (question 15).
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 entity agrees with the definition of due diligence, ‘Principles-based approach’, and considers SMEs should be excluded with some exceptions.
The entity agrees on the definition in question 14. In response to question 15, the entity picks option 1 ‘Principles-based approach’. In response to question 16, the entity considers ‘SMEs should be excluded with some exceptions (e.g. most risky sectors or other)’.
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 has not taken a position on directors’ legal duty to identify companies’ stakeholders and interests, and disagrees to some extent on directors’ legal duty to set up procedures in risk identification, prevention, and remedy. The entity strongly disagrees on directors’ responsibilities to balance the interests of all stakeholders.
In response to question 6, the entity has not taken a position on director’s legal duty, instead indicates that, ‘the assessment of factors relevant to stakeholders should be guided by materiality’.
In response to question 7, the entity thinks there are important constraints for setting measurable targets regarding assessing the procedures; however, clear agreement and data base is absent.
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.
The entity disagrees to some extent on directors’ responsibility to establish and apply consultation channels for engaging with stakeholders.
In response to question 20a, the entity emphasizes that there are many existing channels for engaging with stakeholders already and suggests companies to make better use of existing channels rather than setting up new competing bodies.
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.
Although the entity agrees with the definition of due diligence, the entity thinks that, ‘it should be enough to focus on asking companies to follow existing guidelines and standards.’
In response to question 2, the entity believes, ‘there is no need to consider introducing regulatory requirements on due diligence in supply chain.’ The entity thinks that, ‘sectoral legislation in the EU already includes requirements on due diligence’ and supply chain due diligence should avoid duplication with the sectoral legislation.' The entity agrees with the definition of due diligence (question 14) and picks option 1 ‘Principles-based approach’ (question 15).
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 entity has not taken a position on directors’ legal duty to identify companies’ stakeholders and their interests.
In response to question 6, the entity has not taken a position on director’s legal duty, instead indicates that ‘the assessment of factors relevant to stakeholders should be guided by materiality’.
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 entity disagrees to some extent on directors’ responsibility to establish and apply consultation channels for engaging with stakeholders.
In response to question 20a, the entity emphasises that there are many existing channels for engaging with stakeholders already and suggests companies to better make use of existing channels rather than setting up new competing bodies.
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 entity has not taken a position on directors’ legal duty to identify companies’ stakeholders and interests and disagrees to some extent on directors’ legal duty to set up procedures in risk identification, prevention, and addressment.
In response to question 6, the entity indicates that, ‘the assessment of factors relevant to stakeholders should be guided by materiality’.
In response to question 7, the entity thinks there are important constraints for setting measurable targets regarding assessing procedures; however, clear agreement and data base is absent.
| Legislation | Phase of Active Company Engagement | Position |
|---|
| Industry Association | Performance band |
|---|---|
| Assogestioni | E- |
