Oatly!

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 uncertaintythat the Commission’s announcement of an upcoming Omnibus Simplification Package hascreated. We are calling on the Commission to ensure that the already agreed sustainabilitydue diligence rules are not opened for renegotiation.""""we continue to support the CSRD and CSDDD. What we need is certainty andtimely transposition of the CSDDD and guidance for smart implementation of both ofthese directives.""""The possibility of the CSRD and CSDDD being reopened creates political uncertainty andlegal unpredictability which are both detrimental to investment and competitiveness. Assuch, we are calling on you to clarify that this omnibus package, if embarked upon, will notlead to already agreed and adopted legal texts being opened for renegotiation. Any changesto the legislation should be at level 2 only."""

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 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 entity supports mandatory human rights due diligence legislation at the EU level.

"As the European Commission begins the new mandate, we urge you to uphold and strengthen the EU’s ambitions in supporting responsible businesses and achieving our collective environmental and social targets.""Specifically, we advocate for: ... Strengthening corporate due diligence and addressing forced labour: We support the CSDDD as a key step toward responsible global value chains and urge its rapid and effective adoption.

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 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

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'.