Enact

The undersigned entities do not support the Omnibus proposal.

"On 26 February, the Commission published the Omnibus I proposal on EU sustainability regulation. The stated aim of the Omnibus proposal was to streamline and simplify the already agreed regulation while maintaining the original purpose of the legislation. We, the undersigned, fear that these objectives are not being achieved. International principles of corporate responsibility were established almost 15 years ago at the UN and OECD level. The original Corporate Responsibility Directive, adopted last year, sought to bring the above-mentioned principles to the level of legislation by imposing a risk-based human rights and environmental due diligence obligation on large companies. The Commission's Omnibus proposal no longer fully relies on risk-based approaches and therefore risks breaking the link between legislation and the above-mentioned principles."**Text translated, original language Finnish

The undersigned entities oppose the re-opening of the agreed and adopted legal texts of the CSRD and CSDDD. It indicates that this would lead to legal uncertainty and indicates necessary simplification should be done at level 2 of legislative process only.

"The undersigned 28 Finnish companies and CSOs, are concerned about the uncertainty that the Commission’s announcement of an upcoming Omnibus Simplification Package has created. We are calling on the Commission to ensure that the already agreed sustainability due diligence rules are not opened for renegotiation." "we continue to support the CSRD and CSDDD. What we need is certainty and timely transposition of the CSDDD and guidance for smart implementation of both of these directives." "The possibility of the CSRD and CSDDD being reopened creates political uncertainty and legal unpredictability which are both detrimental to investment and competitiveness. As such, we are calling on you to clarify that this omnibus package, if embarked upon, will not lead to already agreed and adopted legal texts being opened for renegotiation. Any changes to the legislation should be at level 2 only."

The signed entities support the introduction of a mandatory human rights and environmental due diligence law at the EU level and call on their governments to vote in favour of the CSDDD.

"As Nordic businesses, we recognize that there is a critical need for business to play their part in addressing the urgent human rights and environmental challenges we face globally." "With the Corporate Sustainability Due Diligence Directive (CSDDD), the EU has a unique opportunity to harness the transformative power of the UN Guiding Principles on Business and Human Rights. This will further strengthen the relationship between business and society and the realization of sustainable development. A mandatory human rights and environmental due diligence law that is applicable throughout the EU would serve as an international benchmark for advancing responsible business conduct. It would also create a level playing field across the EU to drive much needed action" "We call upon our governments to continue to play a leadership role by supporting the CSDD in the final stages of the legislative process, including by voting in favour of the initiative at the upcoming Council meeting."

The Company states that it considers it as problematic in the omnibus proposal to limit the due diligence obligation to companies’ own operations, subsidiary operations, and direct business partners (so-called tier 1 level).

"A particularly problematic aspect of the Commission's omnibus proposal is the general limitation of the due diligence obligation to companies' own activities, the activities of subsidiaries and direct business partners (the so-called tier 1 level). This limitation may mechanically direct companies' responsibility work and the resources allocated to it to places where environmental and human rights risks are generally not the greatest. Limiting the obligation to the first stage of the production chain will not help to address the problems for which the CSR Directive was enacted. It makes it more difficult for companies carrying out responsibility work and increases the administrative burden. At the same time, it allows irresponsible business practices to continue"*Text translated, original language Finnish