INGKA Group (An IKEA retailer)

The Company explicitly supports the CS3D directive in its sustainability report 2024

The sustainability report states that '‘We believe businesses have a responsibility to provide transparency on human rights through due diligence reporting. … we have supported the adoption of the proposal for a Corporate Sustainability Due Diligence Directive (CS3D) and Forced Labour Ban and we continue to engage with EU institutions and policy makers to support the implementation of CS3D, including through the development of practical implementation guidelines'.

The company confirms its commitment to the CSDDD

In just a few days, we will gain clarity on the content of the European Commission's Omnibus proposal. ... Our commitment has not changed. While we welcome simplification, we firmly oppose deregulation, emphasizing the big need for regulatory clarity, stability and consistency. This moment is critical for recognizing the global efforts by companies to enhance #transparency and #ESGdisclosures.

The Company agrees with the need for a legal framework and with the definition of due diligence duty proposed. It advocates for a Minimum process and definitions approach, building on the UNGPs

The entity agrees with the need of a legal framework (question 2). It explains: ‘The UNGPs provide an internationally-recognised and respected framework describing the business responsibility to respect human rights and the human rights due diligence framework to achieve this. The European Union has a unique opportunity to build off of these principles by developing a Mandatory Human Rights Due Diligence (MRDD) approach. This framework could create a level playing field in Europe, ... and more broadly, could serve as an international benchmark for advancing the implementation of the UNGPs’. It generally agrees with the due diligence duty definition proposed by the consultation (question 14) and advocates for a Minimum process and definitions approach complemented with further requirements in particular for environmental issues (question 15).

The Company explicitly supports mandatory, harmonised HRDD law covering full systems (from risk identification to disclosure)

The Company states that 'IKEA welcomes the proposal ... and urges for a harmonised legislation ... which is mandatory and proportionate across the entire value chain and relies on a risk based approach'; It points out that Companies should align their due diligence efforts with the UN Guiding Principles … taking appropriate action ... (including remediation) ... tracking the effectiveness of measures and meaningful stakeholder engagement (including communicating progress)'.

Signatories call the EU to not reopen the Directive for renegotiation.

‘The undersigned companies and industry associations continue to support the goals of the European Union’s sustainability due diligence … We write now to urge at this critical juncture that you focus on delivering the much-needed practical implementation of these rules. Investment and competitiveness are founded on policy certainty and legal predictability. The announcement that the European Commission will bring forward an “omnibus” initiative that could include revisiting existing legislation risks undermining both of these. … Therefore, we urge the European Commission to publicly clarify that this “omnibus approach,” if embarked upon, will not allow already agreed and adopted legal texts to be reopened for renegotiation. We are particularly concerned about the potential reopening of the Corporate Sustainability Due Diligence Directive (CSDDD), especially as the CSDDD does not introduce any overlapping reporting requirements’

The statement calls for preserving the core of the EU sustainable finance framework, including corporate due diligence, considering that regulatory simplification can be achieved without compromising the substance of the new rules.

Signatories ‘are issuing this joint statement to emphasise the importance of preserving the core of the EU sustainable finance framework. Rules on … corporate due diligence are a key foundation for achieving the EU’s economic and sustainability goals. … In the context of the Omnibus I simplification initiative, we call attention to the investors, banks, other financial institutions and companies across our economy that support preserving the core elements of the … Corporate Sustainability Due Diligence Directive (CSDDD). … CSRD/ESRS and CSDDD are essential for achieving the EU’s wider sustainability, growth and competitiveness ambitions. … The signatories of this statement consider that regulatory simplification can be achieved without compromising on the substance of sustainability rules or their significant benefits for businesses across the EU’.

The joint statement shows support for the legal framework on due diligence irrespective of diverging views on certain aspects.

The joint statement indicates that 'While we hold diverging views on certain aspects of the law, we are aligned in recognising the necessity of a common EU wide legal framework, as part of a smart and coherent mix of policy and legislative measures. We therefore urge the co-legislators to reach a political agreement in view of adopting the final version of the law ... We commend the co-legislators’ efforts in current negotiations toensure that the CS3D follows a risk-based approach and builds on existing globally recognised due diligence standards, such as the UN Guiding Principles on Business and Human Rights and the OECD Guidelines for Multinational Enterprises ... Key elements of this risk-based approach include the recognition of different modes of involvement with adverse impacts and allowing companies to prioritise the most severe and likely ones'.

By endorsing this joint statement, the entity demonstrates unequivocal support for the establishment of mandatory due diligence legislation on human rights and environmental issues. The letter reinforces the urgency of adopting the legal text and the central role that regulation must play. The entity publicly supports the mandatory nature of the legislation and its alignment with international standards (UNGPs, OECD), which directly corresponds to the scope of indicator Q1.1. The language used reflects a proactive and affirmative stance.

Based on the document "EU Business Statement – February 2022," in which the entity is listed as a signatory, it states: “We... urge the European Commission to adopt a legislative proposal without further delay.” “We firmly believe that strong and ambitious EU legislation would make a tangible contribution to improving human rights and environmental conditions along global value chains...” “Our view has always been that the due diligence expectations set out in the UNGPs and in the OECD Guidelines should form the core requirements on business in HREDD legislation.”

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…”

The entity cautions against deregulation of sustainability legislation including the CSDDD

"… Additionally, new laws on corporate sustainability reporting and due diligence promote greater climate ambition and transparency on environmental action, and create a level playing field by also applying to foreign companies active in the EU. Implementing these laws requires time, resources and effort by businesses, as well as trust that investments undertaken to get ready for the application of these laws are not in vain. Deregulation, whether through lowering environmental or social standards, reneging on international commitments, or reducing the EU’s climate ambition, threatens the stable and predictable legal framework that we depend on. We urge the European Commission to support businesses in successfully implementing existing and upcoming environmental standards — by prioritising smart implementation ...

The entities welcome the directive and urge EU legislators to do support it

The statement includes that following '“The CSDDD is substantially aligned with the international standards on Responsible Business Conduct. This makes it credible and its implementation manageable.” “At the same time, it is ground-breaking as it makes due diligence mandatory for companies that are in scope across the EU.” “We support the CSDDD and call on European decision-makers to do so as well.'

In favour of applying requirements to all sectors and all companies, including SMEs, even if these are subject to lighter requirements, and elaborates on it.

In response to question 16, the Company states that ‘As the backbone of the European economy, SMEs can take decisions that have strong social and environmental impact. The framework should focus on minimum requirements for all, including SMEs, and foresee proportional obligations that protect the competitiveness of all European businesses. ... As laid out by the UNGPs (Principle 14), the responsibility of business enterprises to respect human rights applies to all enterprises regardless of their size, sector, operational context, ownership and structure. As such SMEs should not be excluded by the legislation, since they can have severe human rights impacts’.

The Company advocates for inclusive scope that covers SMEs and recommends extending it to financial institutions.

The Company indicates that 'Excluding any actors, specifically Small and Medium sized Enterprises (SMEs), from due diligence obligations would provide limited practical benefit since they may still need to meet those obligations … We call upon EU Institutions to adopt due diligence legislation under which all actors, including SMEs, are obligated as part of their shared responsibilities, and secure that any assistance provided to them should not be through carving out exceptions but by providing additional support (capacity building and/or financial support) in meeting those obligations. We also recommend that the scope of this legislation is extended to financial institutions, requiring them to factor in the implementation and outcomes of the due diligence process while considering investments in or extending financing to companies'.

Based on the document "EU Business Statement – February 2022," in which the entity is listed as a signatory, it states: “All businesses established in the EU and/or active on the internal market, including financial actors, and regardless of size, should be covered by mHREDD legislation.” “Many European SMEs... acknowledge that responsibility... is not a matter of company size...”

The document advocates for the legislation to apply to all companies, regardless of size or sector, expressly including SMEs and financial actors. This position represents clear support for the universal scope of the regulation. Undersigning entities explicitly support the universal application of the legislation, recognizing the importance of a level regulatory playing field, including for SMEs.

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…”

The entity cautions against exemptions from sustainability legislations such as the CSDDD based on sector and size

"Avoiding blanket exemptions of sectors or company sizes which can create unfair competition, harm consumer trust and further complicate supply chains. Given the proportionality principle, EU legislation often already provides longer timeframes and lighter processes for SMEs."

The entity picks Supervision by competent national authorities based on complaints about non-compliance with setting up and implementing due diligence measures, etc. with a mechanism of EU cooperation/coordination.

As per its response to question 19a on enforcement mechanisms, the entity selects '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) with a mechanism of EU cooperation/coordination to ensure consistency throughout the EU’. It notes: ‘we urge the Commission to place emphasis on enforcement of the process rather than the results. ... If penalties fall to companies based on results, there is a big risk that this level of transparency and self-checking will be diminished. Proportionate penalties could serve as an important enforcement mechanism’.

The Company backs monitoring and sanctions, calling for uniform EU-wide enforcement.

The Company states that ‘We urge the Commission to provide clear, pragmatic guidelines to companies and Member States, including legal obligations and reporting requirements. We also call upon the Commission to specify monitoring requirements for competent authorities and sanctions regime for violations, which need to be uniform across the EU to secure effective enforcement. Competent authorities in Member States should rely upon clearly developed and uniform guidelines for implementation and compliance verification’.

The joint statement shows support both for administrative enforcement and civil liability

The joint statement indicates that 'This common standard should be effectively enforced, recognising the need for a balanced combination of administrative enforcement and civil liability, as well as access to justice measures'.

Based on the document "EU Business Statement – February 2022," in which the entity is listed as a signatory, it states: “The requirement needs to be accompanied by legal consequences – encompassing administrative penalties and provisions for civil liability – that will be strong enough to ensure that businesses... carry out HREDD to a high standard...”

The entity advocates for the existence of legal accountability mechanisms, including administrative sanctions and civil liability, as a means to ensure the effectiveness of the legislation. There is clear support for the implementation of robust enforcement mechanisms, covering both administrative penalties and civil liability, fully aligning with the scope of the indicator.

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…”

Although the entity agrees to some extent to both questions on requiring directors to establish procedures to ensure that possible impacts are identified, prevented, and addressed; and on whether directors should be required by law to manage the risks for the company in relation to stakeholders and their interests, including in the long run, it considers that responsibility should not sit on individuals, and advocates for an UNGPs based approach to stakeholder engagement.

In its response to question 7, it agrees 'to some extent' and points out that: ‘we agree that there should be accountability to set up adequate procedures and where relevant, targets to mitigate risks. However, this obligation should sit at the company level, not tied to individuals, and describes its reasons. In response to question 6 it agrees to some extent to a legal requirement for directors to manage the risks for the company in relation to stakeholders and their interests, although offers the same explanation regarding directors' responsibility, and advocates for a UNGPs based approach to stakeholder engagement, indicating that ''Excessive stakeholder engagement requirements would be very time-consuming, hampering the agility and competitiveness of European businesses without effectively securing a positive impact on society'.

The Company requests clarity on scope of director obligations; favours company-level over individual liability. No explicit position on adding a human rights duty to directors.

It indicates that ‘We also request more clarity on the definition of ‘director.’ Would this legislation cover person(s) with management responsibility and/or only include those with authority? Further, would requirements on ‘directors’ extend to the Board of Directors (who take strategic decisions), or would they be restricted to company management? It points out that ‘Liability should be imposed on companies and not on individuals, as individuals act on behalf of companies and face internal responsibilities for non-performance’.

Based on the document "EU Business Statement – February 2022," in which the entity is listed as a signatory, it states: “HREDD should also be embedded in appropriate governance and accountability structures, including at board level.”

The letter argues that governance structures, including boards of directors, should integrate due diligence, implying an active role for directors in risk prevention and mitigation. Although the text does not explicitly propose a formal legal obligation for directors, it advocates for their incorporation into governance, justifying a positive score.

The Company supports accountability measures that considers whether a company has provided access to remedy.

The Company states that 'We support the inclusion of accountability measures at the company level to bolster the implementation of due diligence efforts, emphasizing that the legislation should take a holistic view and incorporate a range of measures extending from liability to positive incentives. Such measures should provide sufficient legal clarity and be designed with due consideration given to whether a company has taken reasonable steps to conduct human rights due diligence and provide access to remedy'.

The Company endorses remediation and requests for EU to specifiy requirements and timelines.

The Company claims that ‘To be truly effective, due diligence mechanisms need to proactively identify and manage risks, … focusing on identifying and assessing actual or potential risks and impacts, taking appropriate action to avoid/mitigate these (including remediation of impacts when risk mitigation is not possible)’. It also calls for the EU to elaborate on this issue: ‘We call upon EU Institutions to shed light on certain topics currently outside the CSDDD scope to secure a future looking EU framework on due diligence: The requirements for remediation of actual human rights or environmental adverse impacts (e.g., specific timelines), as a precondition for companies to continue doing business’.

Based on the document "EU Business Statement – February 2022," in which the entity is listed as a signatory, the company states: "To level and harmonise the playing field in practice, the requirement needs to be accompanied by legal consequences – encompassing administrative penalties and provisions for civil liability – that will be strong enough to ensure that businesses falling within the personal scope of the legislation carry out HREDD to a high standard and that those that are harmed have access to remedy."

The text reinforces the importance of corporate accountability and the guarantee of access to remediation for victims of negative impacts, in line with the spirit of the indicator. Despite being brief, the direct mention of the need for remediation justifies a positive score, as it aligns with the principle of repairing damages caused or contributed to

Based on the document "EU Business Statement – February 2022," in which the entity is listed as a signatory, it states: "The legislation should reflect the wide spectrum of avenues, including adjustments to own purchasing practices, to effectively influence and enable business partners as well as increase leverage if needed, rather than honing in narrowly on the extent to which a company can deploy contractual or commercial leverage."

The letter explicitly advocates that companies should adopt measures to influence and support their business partners, including adjusting their own purchasing practices, which aligns with the use of leverage for remediation purposes. There is clear and active support for the use of leverage to influence business partners, as outlined in the indicator.

The Company supports grievance mechanisms with broad scope and process guidelines

It states that '‘The complaints procedure should be more robust. … We recommend that the complaints procedure is open for two types of stakeholders: Affected stakeholders ...; Interested stakeholders – those who may not be directly affected and/or impacted, but who have an interest in the … human rights impacts of a company’s activities in the region .... We also request the European Commission to adopt guidelines specifying the various steps to be included in an efficient complaint handling mechanism including at least :a) Receipt of the complaint and acknowledgment’ b) Internal review and assessment of complaint, c) Informing the complainant of the next steps …, d) If complaint is processed, then the outcome of the complaint, e) Compliance with EU acquis'.

Based on the document "EU Business Statement – February 2022," in which the entity is listed as a signatory, it states: "A key component of qualitative HREDD is meaningful engagement with affected stakeholders – those people that are at risk of negative impacts from business activity. Listening to the voices of workers, community members and others is vital to a company’s understanding of risks to people and planet and strengthens its due diligence. To ensure that the EU legislation encourages people-centric HREDD, robust engagement with affected groups, workers and other relevant stakeholders including unions and human rights and environmental defenders should inform all stages of the required due diligence process. Engagement must also be safe, so that those speaking out can do so without suffering or fearing retaliation."

The entity explicitly supports engagement with affected rights holders as a central part of the due diligence process, including during critical stages such as remediation. The document emphasizes the centrality of meaningful stakeholder engagement and their security, demonstrating full alignment with the indicator.

Although the entity doesn't consider this a suitable option as enforcement mechanism, it does not oppose to measures that include liability

Question 19a asks about enforcement mechanisms through a multiple-choice format, one of which is 'judicial enforcement with liability and compensation in case of harm caused by not fulfilling the due diligence obligations'. The company did not select this as one of its preferred measures. On the other hand, it also indicates that 'We agree that companies should be held accountable for balancing the interests of all stakeholders. Any such legislation describing such obligations should provide legal clarity, incorporate a range of measures (extending from liability to positive incentives) and give due consideration for whether a company has taken reasonable steps to conduct human rights due diligence and offer access to a remedy, as needed.

The Company supports liability for due diligence failures, calling for proportionality and clarity.

The Company states that ‘The proposal needs to clearly specify the legal liability regime applicable to companies. Clarifying … will be essential to secure the homogeneous transposition of its provisions across the EU, …, and set up a consistent liability framework’ … We would like to emphasise that liability of companies should be proportional and should result from a breach of clearly described, attainable and reasonable obligations. We would welcome clarification on whether lapses in Directors’ duty of care would result in a civil or a criminal liability, as Member States address this point differently. Liability should be imposed on companies and not on individuals’.

Based on the document "EU Business Statement – February 2022," in which the entity is listed as a signatory, it states: "To level and harmonise the playing field in practice, the requirement needs to be accompanied by legal consequences – encompassing administrative penalties and provisions for civil liability"

Support for civil liability as an essential component of the legislation shows direct alignment with the requirement for judicial enforcement. The entity explicitly endorses civil liability with provisions for compensation, justifying the maximum score.

The Company advocates for a minimum process with definitions approach to due diligence duty. It agrees with the definition and argues that any measure should cover the entire value chain.

The Company advocates for a minimum process with definitions approach to due diligence duty, as per its response to question 15 (horizontal approach). It generally agrees with the definition provided in question 14 and it argues that ‘Any measures should apply to the entire company value chain not only supply chains as human rights impacts could be linked to all operations, products or services or through any business relationships (not just suppliers, but also partners connected to products) as defined in the UNGP Principle 13’. It does not explicitly refer to remedy nor improvement in this context, although acknowledges that should be held accountable through measures that consider due diligence steps and access to remedy.

Explicit support for full value-chain due diligence beyond tier-1 limits.

The Company states that 'Since impact on people and planet can occur both up and downstream, regardless of size, sector or ownership structure, it is important for due diligence process requirements to cover the entire value chain'. It also states that 'To be truly effective, due diligence mechanisms need to proactively identify and manage risks, moving beyond simply avoiding adverse impacts. That means ..., focusing on identifying and assessing actual or potential risks and impacts, taking appropriate action to avoid/mitigate these (including remediation of impacts when risk mitigation is not possible), tracking the effectiveness of measures and meaningful stakeholder engagement (including communicating progress on measures to stakeholders)'.

The statement calls for not limiting due diligence to tier-1 suppliers.

It states that 'the most salient ... risks and impacts often lie deeper in supply chains. A risk-based approach to due diligence is helpful to companies as this allows them to focus on where the real risks are, building on their knowledge of their own supply chains. By limiting due diligence to tier 1 suppliers, the Omnibus proposal may unintentionally promote the kind of “box ticking” compliance exercises that it intends to reduce'.

The statement advocates for enforcing due diligence in own operations and 'value chains'.

The statements shows support for the Directive in general, and also states that: 'The Directive aims to harmonise requirements for companies to carry out due diligence in their own operations, subsidiaries and value chains, thereby ensuring an EU-wide level playing field and avoiding market fragmentation. This common standard should be effectively enforced, recognising the need for a balanced combination of administrative enforcement and civil liability, as well as access to justice measures'.

Based on the document "EU Business Statement – February 2022," in which the entity is listed as a signatory, it states: “The legislation should oblige businesses to carry out ongoing due diligence proactively and across all their operations and the full value chain.” “The UNGPs set out that a company’s responsibility... extends throughout its business relationships across its full value chain...”

The entity fully supports the application of due diligence throughout the entire value chain, as reflected in UN and OECD principles. The statement proposes that the legislation require a continuous and proactive approach, covering direct operations and business relationships. There is clear and normative support for the application of due diligence across the entire chain (upstream and downstream), justifying the maximum score for this indicator.

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"

The Company shows support for stepping up efforts in high-risk areas, advocating additional measures and capacity building to address severe risks.

The Company states that 'the CSDDD should not result in adverse effects on people employed in or dependent on value chains, should companies be discouraged from being fully transparent or divest their upstream value chains from high-risk sources due to fear of penalties and/or litigation. We urge the European Commission to put more focus on additional measures to provide support (financial, training, capacity building, etc.) in high-risk areas and sectors for companies to be able to tackle these environmental and human rights risks.

The Company supports codes and contracts although warns against over-reliance on contracts alone

The Company indicates that 'An effective due diligence mechanism requires going beyond … and should focus on proactively identifying and managing risks. There is a risk that companies will rely only on contracts, reducing the meaning of due diligence. If the contract clauses are used as a limitation for companies to perform and engage in due diligence, this would be in direct contradiction to the UNGPs. Contracts will provide a level of control, but should the risks extend outside of contractual relationships, so do businesses’ responsibilities and actions as well. We recommend modifying the subject matter of this proposal to require companies to focus their due diligence efforts on risk identification … assessment, risk avoidance and/or risk mitigation and remediation of adverse impacts'.

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...”

The Company agrees to some extent to extent with the requirement of having to identify their stakeholders. It considers that all stakeholder groups presented in the consultation are relevant.

It considers that all stakeholders presented in the consultation are relevant (question 5). It elaborates on it: ‘We see it engagement as a responsibility and an opportunity to listen to different stakeholder groups, as listed above, but emphasize that there are different avenues for such engagement. ... An EU framework that requires companies to undertake stakeholder engagement activities provides value’. The entity agrees to some extent with the requirement of companies having to identify their stakeholders and their interests, as per question 6 and states that: ‘For Ingka Group, the identification of stakeholders is already built into the ways of working both for the IKEA brand and for our other businesses. ... Still, from a regulatory perspective, we see value in a sharpened proposal to achieve the most effective results. Excessive stakeholder engagement requirements would be very time-consuming, hampering the agility and competitiveness of European businesses without effectively securing a positive impact on society’.

The entity shows general support for broad identification and engagement, albeit calls for clarity.

The Company indicates that 'We urge EU Institutions to secure more clarity on the terms … ‘stakeholders’ … are all stakeholders considered to be part of the value chain, or are they also limited by ‘established business relationships?' It refers in several places of its response to the need of information gathering including stakeholder engagement as part of due diligence risk identification: ‘We recommend the subject matter of this to proposal is modified to require companies to focus their due diligence efforts on risk identification (including information gathering and stakeholder engagement)’.

The Company agrees 'to some extent' to this question, which is directly asked. Although it does not refer to directors in this response, it has established that does not agree with individual directors' responsibility.

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 ‘We believe companies should be provided the flexibility to decide on priority and pursue various avenues for engaging different stakeholders, such as our own mechanisms for co-worker input, stakeholder forums with NGOs and partners, etc. These mechanisms should be clearly defined based on the United Nations Guiding Principles (UNGPs)’. Although the explanation does not clarify its view on directors' responsibility on the matter, in a response to a different question it calls for more clarity on corporate directors definition and states that 'we di bit bekueve tge responsibility should sit with individuals. Rather, it should sit with the corporation'.

Although it does it explicitly call for stakeholder-driven impact assessments, it shows general support for stakeholder involvement in early due diligence phases.

The Company states that 'We recommend the subject matter of this to proposal is modified to require companies to focus their due diligence efforts on risk identification (including information gathering and stakeholder engagement), risk assessment …'.

There's a support for stakeholder engagement throughout due diligence.

The joint statement indicates that: 'It is important that the Directive integrates stakeholder engagement as a critical component of effective due diligence, recognises the role of trade unions and worker representatives, and promotes effective collaboration between companies, including in the context of industry and multistakeholder initiatives'.

Based on the document "EU Business Statement – February 2022," in which the entity is listed as a signatory, it states: “Listening to the voices of workers, community members and others is vital to a company’s understanding of risks to people and planet and strengthens its due diligence.”

The letter advocates that risk assessment should take place through active listening and dialogue with affected stakeholders, which aligns with the spirit of the indicator. The statement explicitly supports the use of dialogue as a risk assessment tool, justifying the maximum score.

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."

There's a support for stakeholder engagement throuhgout due diligence.

The joint statement indicates that: 'It is important that the Directive integrates stakeholder engagement as a critical component of effective due diligence, recognises the role of trade unions and worker representatives, and promotes effective collaboration between companies, including in the context of industry and multistakeholder initiatives'.

The entity agrees 'to some extent' with this requirement, although it advocates for the responsibility to sit with the corporation.

In response to question 6 on requiring directors to manage the risks in relation to stakeholders and their interests, the entity agrees 'to some extent' and states that ‘While we agree with the importance of accountability, we do not believe the responsibility should sit with individuals. Rather, it should sit with the corporation.’