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.
Main Web Site
The main organizational Web site of the company and its direct links to major affiliates and attached documents.
Cascale clearly supports the legal establishment of human rights and environmental due diligence obligations through the CSDDD.
In the statement, Elisabeth Reitzenstein, Senior Director of Policy and Public Affairs, states:“The CSDDD marks a huge leap toward transformative change, setting strong due diligence obligations for large companies in or who sell in the European Union. It will hold large companies accountable regarding actual and potential adverse impacts on human rights and the environment, ‘with respect to their own operations, those of their subsidiaries, and those carried out by their business partners.” Furthermore, the organization affirms its broader regulatory stance: “We believe regulation is essential to drive meaningful change and the agreement reached on CSDDD is a major step forward.” The statement also underscores the organization’s long-term commitment to helping members align with due diligence regulations and provides tools like the Higg Index to meet regulatory demands. Cascale explicitly recognises the directive as a, “major step forward”, and a ,“huge leap toward transformative change”, not only in principle but in operational terms — highlighting accountability for actual and potential adverse impacts across the value chain. Justification: Cascale publicly endorses the mandatory nature of the CSDDD, emphasizing its alignment with principles of accountability and systemic change. The statement frames regulation as essential, not optional, and welcomes the introduction of due diligence obligations across company operations and partnerships.
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 a legal framework is needed and agrees with the definition of due diligence duty provided by the consultation.
The association considers that 'an EU legal framework is needed' for supply chain due diligence: 'An EU legal framework would ensure accountability of businesses by creating a necessary level playing field. Such legal framework should follow the UN Guiding Principles and the OECD Guidelines for MNEs.' It also agrees with the definition of due diligence duty provided by the consultation arguing that it aligns with both initiatives (OECD and UNGPs).
Requiring Human rights due diligence of all companies, regardless of sector and size, while still reflecting their individual circumstances.
Main Web Site
The main organizational Web site of the company and its direct links to major affiliates and attached documents.
Cascale does not advocate for the universal applicability of the directive across all companies, nor does it call for further expansion to SMEs or all sectors.
The statement explains that the directive will apply to, “companies with over 500 employees and a net worldwide turnover of over €150 million,” and that, “it will not apply to micro companies and SMEs.” No objections are raised regarding this scope; however, there is no direct call for extending obligations to companies regardless of size or sector.
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 is in favour of a 'minimum process and definitions approach' to the due diligence duty, with sector specific legislation for apparel and footwear industry which includes SMEs.
The entity is in favour of a 'minimum process and definitions approach' in relation to the DDD, with sector specific legislation for the apparel and footwear industry: 'in this regard, an alignment with the OECD Guidance for Responsible Supply Chains in the Garment and Footwear sector should be ensured'. It also states that: 'we do not consider that the SMEs should be excluded. However, a proper guidance/support should be available'. 'SMEs should be subject to lighter requirements'.
Implementing an enforcement mechanism where companies fail to carry out due diligence as described.
Main Web Site
The main organizational Web site of the company and its direct links to major affiliates and attached documents.
Cascale acknowledges the directive’s enforcement provisions: “Penalties for non-compliance entail fines of five percent of a company’s net turnover.” There is no critique or support expressed about the existence or proportionality of these penalties.
The company acknowledges penalty provisions in the directive.
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 is in favour of enforcement mechanisms.
The entity supports, 'supervision by competent national authorities based on complaints ... with a mechanism of EU cooperation/coordination to ensure consistency throughout the EU'. It also adds that, 'any enforcement mechanism should ensure consistent application across the EU to prevent situations where companies operating in different countries would be subjected to different expectations or reporting obligations. Any rule should be transparent, clear and avoid unreasonable administrative burden.'
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.
Although not directly asked, the entity disagrees, 'to some extent', that directors should be required to, 'manage risks for the company in relation to stakeholders and their interests', and to establish procedures to ensure that risks and impacts are identified, prevented and addressed.
Although not directly asked about directors' obligation to avoid impacts or harms, the entity disagrees, 'to some extent', that directors should be required to, 'manage risks for the company in relation to stakeholders and their interests', and to establish procedures to ensure that risks and impacts are identified, prevented and addressed. It adds that 'we are concerned that a mandatory legal framework directors will not be able to properly capture this complexity, and it will fail to be practical'. It also states that 'we agree with the idea that adequate procedures and measure targets identify, prevent and address risks and impacts should be set at a company level .... However, it may not be the duty of corporate directors to set up such adequate procedures. Corporate directors may oversee the procedure but may not set up targets as such'.
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.
The entity is in favour of enforcement through 'supervision by competent national authorities based on complaints ... with a mechanism of EU cooperation/coordination to ensure consistency throughout the EU'. However, it does not refer to remedying harm caused or to which it has contributed.
The entity is in favour of enforcement through: 'supervision by competent national authorities based on complaints ... with a mechanism of EU cooperation/coordination to ensure consistency throughout the EU.' The entity's explanation reinforces the importance of consistent application and adds that 'any rule should be transparent, clear and avoid unreasonable administrative burden.' However, it does not refer to remedying harm caused or to which it has contributed.
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).
Main Web Site
The main organizational Web site of the company and its direct links to major affiliates and attached documents.
The statement says: “In collaboration with partners and stakeholders, the SAC actively engages in pioneering projects, including the development and support of an OECD-aligned Human Rights and Environmental Due Diligence (HREDD) framework. Collaborating with Worldly and Fair Wear, the SAC is working to deliver resources for effective human rights due diligence.”
Analysis: The entity presents its own efforts to provide tools, frameworks, and collaborative resources to enable companies, including supply chain partners, to meet due diligence expectations. This suggests a recognition of the need to support business partners in implementing and improving due diligence, including remediation. Score: +1 Justification: The organization promotes collaborative implementation mechanisms and resource-sharing in line with OECD-aligned HREDD principles. This meets the threshold for a supportive stance, albeit not directly framed as a formal obligation.
Require companies to provide grievance mechanisms for all stakeholders including those in the value chain.
Main Web Site
The main organizational Web site of the company and its direct links to major affiliates and attached documents.
In the statement, Cascale discloses: “The Directive also makes a stand for ‘meaningful engagement,’ as in dialogue and consultation with affected stakeholders as part of the due diligence process.”
Analysis: Cascale explicitly highlights stakeholder engagement as a key element of the due diligence process. The language suggests a normative endorsement of consultative practices with affected rightsholders in remediation and impact mitigation. Score: +1 Justification: By naming, “dialogue and consultation with affected stakeholders”, as a strength of the directive, the organization demonstrates clear alignment with the expectation of participatory remediation.
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 seems in favour of having stakeholder consultation mechanisms as part of the risk management mechanisms, and that complaint mechanisms should be promoted at the EU levels.
The entity indicates that complaint mechanisms as part of due diligence, 'should be promoted to EU level', and considers all stakeholders presented by the consultation as, 'relevant'. The entity states that: 'It is in the interest of the company and its director to have a sound and comprehensive risk management system in place, including stakeholder consultation channels. However, this is a company-specific task as the number and geographical distribution of stakeholders may vary significantly from sector to sector and company to company and change over time. Thus, different consultation channels would have to be applied to specific situations. We are concerned that it would be difficult for the legislators to properly address this complexity and any mandatory legislation would risk to be impractical.'
Enabling judicial enforcement with liability and compensation in case of harm caused by not fulfilling the due diligence obligations.
Main Web Site
The main organizational Web site of the company and its direct links to major affiliates and attached documents.
Cascale mentions the inclusion of joint liability, which forms part of the judicial enforcement mechanisms foreseen in the directive without indicating support or opposition.
The statement indicates “This EU Directive builds in joint liability to ensure wider supply chain accountability.”
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.
Question 19a allows for multiple choice, one of them being, 'judicial enforcement with liability and compensation in case of harm caused by not fulfilling the due diligence obligations'. The Company didn't pick this as a possible option.
Question 19a allows for multiple choice, one of them being 'judicial enforcement with liability and compensation in case of harm caused by not fulfilling the due diligence obligations'. The Company didn't pick this as a possible option.
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.
Main Web Site
The main organizational Web site of the company and its direct links to major affiliates and attached documents.
Cascale appears to supports the application of due diligence obligations throughout the supply chain, including both upstream (suppliers) and partial downstream (distribution, recycling).
The statement indicates 'This EU Directive builds in joint liability to ensure wider supply chain accountability. Importantly, it covers upstream and partial downstream activities, such as distribution or recycling.” By highlighting that the directive applies to the companies’ own operations, subsidiaries, and business partners, and by naming upstream and downstream activities, it demonstrates explicit support for comprehensive value chain due diligence.'
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 consultation does not cover all the aspects of this indicator and the entity's response does not clarify its definition of value chain, and whether it is in favour of remedy provision and supporting the whole value chain.
The entity agrees with the definition of DDD: 'we agree with the definition as it is aligned with the OECD Guidance on Responsible Business Conduct and the UNGPs, particularly the due diligence should be a risk-based, proportionate and context specific'. However, the definition does not include both upstream and downstream, and remedy, and the entity doesn't refer to them.
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 entity is against a mandatory legal framework on this matter.
The entity considers all stakeholders presented in question 5 as relevant, however, it disagrees, 'to some extent', that directors should be required by law to identify stakeholders and their interests. It indicates the following: 'We agree that it is the ultimate interest of every director to have a sound and comprehensive risk management system in place, including an assessment of stakeholder interests and the corresponding stakeholder engagement. ... However, this is a company-specific task as the number and geographical distribution of stakeholders may vary significantly from sector to sector and company to company and change over time. Thus, we are concerned that a mandatory legal framework will not be able to properly capture this complexity, and it will fail to be practical. We would also like to point out that managing stakeholders’ interests requires flexibility as the specifics of these interests may change based on any number of variables ... Therefore, we do not see how such complexity of managing different stakeholder interests could be operationally implemented by mandatory legislation. The flexibility and room for the director's decision-making need to be ensured.'
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 is against a mandatory legal framework on this matter.
In response to question 20a of the consultation, the entity disagrees, 'to some extent', adding the following explanation: "It is in the interest of the company and its director to have a sound and comprehensive risk management system in place, including stakeholder consultation channels. However, this is a company-specific task as the number and geographical distribution of stakeholders may vary significantly from sector to sector and company to company and change over time. Thus, different consultation channels would have to be applied to specific situations. We are concerned that it would be difficult for the legislators to properly address this complexity and any mandatory legislation would risk to be impractical."
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 entity is against a mandatory legal framework on this matter.
In response to this question in the consultation, the entity disagrees, 'to some extent', and points out the following: 'We agree that it is the ultimate interest of every director to have a sound and comprehensive risk management system in place. ... However, this is a company-specific task as the number and geographical distribution of stakeholders may vary significantly from sector to sector and company to company and change over time. Thus, we are concerned that a mandatory legal framework will not be able to properly capture this complexity, and it will fail to be practical. We would also like to point out that managing stakeholders’ interests requires flexibility as the specifics of these interests may change based on any number of variables ... Therefore, we do not see how such complexity of managing different stakeholder interests could be operationally implemented by mandatory legislation. The flexibility and room for the director's decision-making need to be ensured. Also, it is not clear how such legislation would address conflicting interests of different stakeholders, ... And how would that affect a further decision-making of a company. Thus, when it comes to the managing of stakeholder interests, a voluntary approach would be preferred. Lastly, we would also like to flag that some of the suggested requirements are already addressed by the financial reporting directive and national corporate governance codes. Therefore, any of the upcoming legislation on corporate governance should be aligned with already existing EU legislation to not create additional administrative burden.'
Legislation | Phase of Active Company Engagement | Position |
---|
Member | Performance band |
---|---|
C&A | D |
H&M Group | C- |
Zalando SE | D- |