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 all SMEs should be excluded from the scope of the legal framework and receive support.
In response to question 16, it would exclude SMEs. The entity states: 'Many small businesses, including the majority of FSB members, do not have the structure of shareholders and boards of directors. ... they often lack the resources or capacity necessary to fulfil complex sustainability technical or reporting requirements. SMEs cannot easily absorb the costs of such requirements in comparison to larger companies with greater resources. Policymakers must therefore consider the impact of such requirements on small businesses and put in place carefully considered thresholds beneath which businesses are exempt, as well as providing dedicated support to help those within scope adapt to the requirements'. Although it is not explicit about supporting any of the proposed approaches, it advocates for a principles-based approach (this option is proposed by the consultation as an horizontal approach): 'If new requirements were to be introduced, a principles-based approach would be the most appropriate solution for European businesses to ensure robust measures are in place while allowing SMEs to take the most appropriate approach for their business'.
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 does not directly address grievance mechanisms, it disagrees with a legal requirement to establish consultation channels for engaging with stakeholders as part of the due diligence duty.
The entity does not respond in relation to whether grievance mechanisms as part of due diligence should be promoted at the EU level (question 20c). However, it disagrees with a legal requirement to establish consultation channels as part of due diligence: ‘such requirements would not be appropriate for small businesses, which cannot easily absorb the costs of complex or burdensome obligations in comparison to larger companies with greater resources. The impact of any such requirements on SMEs must therefore be taken into consideration by the EU, and any new rules must be carefully designed to avoid bringing the smallest businesses into scope.’
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 entity does not clarify to what extent it agrees with the due diligence duty definition, nor whether it considers that a legal framework on due diligence is needed. On the other hand, it does not show opposition to any specifics of the definition; although it advocates for a principles-based approach.
The entity does not respond to question 2 on whether it considers that a legal framework for due diligence is needed (companies being required to conduct due diligence). In relation to whether it agrees with due diligence duty definition (question 14), it states: 'The definition given broadly reflects national law and best practice in the UK. It is essential however to ensure that the implementation of any such EU measures resulting from this exercise are risk-based, proportionate and context specific, particularly with regards to small and medium-sized businesses. In particular requirements should include thresholds beneath which SMEs are exempt to avoid placing disproportionate administrative and fiscal burdens on small businesses.' In relation to due diligence approach, it points out that: 'If new requirements were to be introduced, a principles-based approach would be the most appropriate solution for European businesses to ensure robust measures are in place while allowing SMEs to take the most appropriate approach for their business.' It does not refer to remedy.
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