Mirova
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 for supply chain due diligence to address adverse impacts on human rights. It agrees with the definition of due diligence duty provided by the consultation and advocates for a minimum process and definitions approach.
The Company agrees that an EU legal framework is needed for supply chain due diligence to address adverse impacts on human rights (question 2). It agrees with the definition of due diligence duty provided by the consultation. It states that, 'we agree because we believe that a company's responsibility is to be understood on its entire supply-chain, although the level (1, 2 or 3) of suppliers and subcontractors should be more precisely specified to understand the limits of the company's responsibility.' Finally, it advocates for a minimum process and definitions approach.
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 considers that SMEs should be excluded with some exceptions, and considers that due diligence duty should follow a minimum process and definitions approach applicable to sensitive sectors.
In response to the question on how the burden on companies, particularly smaller ones, could be reduced (question 16), it picks different options, including the exclusion of SMEs with some exceptions (e.g. most risky sectors or other), and having lighter reporting requirements for them. It also advocates for a minimum process and definitions approach to due diligence duty, but clarifies that: 'the horizontal approach of minimum processes and definitions should be implemented for human rights for sensitive sectors (such as textile, IT...) and climate-related issues for almost all sectors in order to limit EU importation of carbon.'
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 advocates for judicial enforcement with liability and compensation in case of harm caused by not fulfilling the due diligence obligations.
The Company advocates for judicial enforcement with liability and compensation in case of harm caused by not fulfilling the due diligence obligations.
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 Company strongly agrees that corporate directors should be required by law to manage the risks in relation to stakeholders and set up procedures, and, where relevant, targets, to identify, prevent and address human rights risks in relation to stakeholders.
The Company strongly agrees that corporate directors should be required by law to manage the risks in relation to stakeholders (question 6) and set up procedures, and, where relevant, targets, to identify, prevent and address human rights risks in relation to stakeholders. (question 7)
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.
Although it does not explicitly refer to impact remediation, it picks as an enforcement mechanism judicial enforcement with liability and compensation in case of harm caused by not fulfilling the due diligence obligations.
Although it does not explicitly refer to impact remediation, it picks as an enforcement mechanism judicial enforcement with liability and compensation in case of harm caused by not fulfilling the due diligence obligations. (question 19a)
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 chains 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 chains 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).
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 company strongly agrees that directors should be required to establish mechanisms for engaging with stakeholders as part of their due diligence duty, it is unclear whether it supports the inclusion of grievance mechanisms within due diligence, as it believes these should not be promoted at the EU level but rather considered a best practice.
Although the company strongly agrees that directors should be required to establish mechanisms for engaging with stakeholders as part of their due diligence duty (question 20a), it is unclear whether it supports the inclusion of grievance mechanisms within due diligence, as it believes these should not be promoted at the EU level but rather considered a best practice (question 20c).
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 picks as an enforcement mechanism judicial enforcement with liability and compensation in case of harm caused by not fulfilling the due diligence obligations.
The Company picks as an enforcement mechanism judicial enforcement with liability and compensation in case of harm caused by not fulfilling the due diligence obligations (question 19a).
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 agrees with the definition of due diligence duty, and advocates for a: 'minimum process and definitions approach in terms of content for the due diligence duty.' Although it does not explicitly refers to remediation, it advocates for: 'judicial enforcement with liability and compensation in case of harm caused by not fulfilling the due diligence obligations'.
The company agrees with the definition of due diligence duty presented in the consultation stating that: 'we agree, because we believe that company's responsibility is to be understood on its entire supply-chain, although the level (1, 2 or 3) of suppliers and subcontractors should be more precisely specified to understand the limits of the company's responsibility.' In relation to due diligence duty content, it advocates for a minimum process and definitions approach. Finally, although it does not explicitly refer to remediation, it advocates for judicial enforcement with liability and compensation in case of harm caused by not fulfilling the due diligence obligations.
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 strongly agrees with the requirement for companies to identify stakeholders and their interests, including communities affected by both operations and supply chains.
The Company strongly agrees to requirement for companies to identify stakeholders and their interests (question 6), including communities affected by both operations and supply chain. (question 5, relevancy of different stakeholder groups).
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 strongly agrees that the EU should require companies to establish consultation channels for engaging with stakeholders.
The entity strongly agrees that the EU should require companies to establish consultation channels for engaging with stakeholders (question 20a). It does not elaborate further.
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 strongly agrees that directors should be required by law to manage risks for the company in relation to stakeholders and their interests.
The company strongly agrees that directors should be required by law to manage risks for the company in relation to stakeholders and their interests (question 6).
| Legislation | Phase of Active Company Engagement | Position |
|---|
| Industry Association | Performance band |
|---|---|
| France Invest | E- |
| Mouvement Impact France | B |
