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.
Social Media
We search other media and sites funded or controlled by the organization, such as social media (Twitter, Facebook) and direct advertising campaigns of the organization.
EUROBAT clearly expresses public support for the adoption of the CSDDD as a mechanism imposing legal obligations on human rights and environmental impacts.
The use of the term "exciting news" and the acknowledgment of its mandatory nature reflect a positive stance. EUROBAT demonstrates affirmative support for the legal obligation of due diligence, albeit briefly.
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 doesn't consider that a legal framework on supply chain is needed and advocates for asking companies to follow existing guidelines and standards.
The entity responds to question 2 that a legal framework is not needed, 'it should be enough to focus on asking companies to follow existing guidelines and standards'. It states: 'Main part of a general framework should be in any case self-regulation initiatives'.
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 explicitly welcomes the proposal for a directive.
The entity states that: 'EUROBAT welcomes the European Commission’s proposal for a Corporate Sustainable Due Diligence Directive and confirms its full support for the harmonisation of human rights and environmental due diligence obligations in the EU and abroad'. Although the rest of the response consists in discussing different aspects of the directive, it shows general support for the legal requirement of due diligence.
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 legislation should apply only to companies with more than 5.000 employees. It does not refer to a horizontal approach, emphasising that it prefers a tailored approach for each industry.
In response to question 16 the entity states that 'If at all, only companies with more than 5.000 employees might be included only due to the high level of administrative burden, that smaller companies would not be able to handle'. In relation to sectorial approach, the entity does not refer to a horizontal approach nor chooses any of the proposed approaches. It states that 'we prefer a more tailored approach for each industry, which is based on self-regulation and not on legislation. A one fits-all legislation will be difficult to implement due to the different haracteristics of each industry'.
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 avocates for a specific approach to due diligence for its sector.
The entity states that 'For the battery sector, the main legislation that should apply is the soon-to-be-approved Batteries Regulation. This is product legislation covering the whole battery life-cycle, from mining to recycling. Developing new horizontal legislation -lex generalis- that will introduce different requirements and initiatives in regard to activities or risks that might not be covered in the Batteries Regulation leaves the industry in a vulnerable situation. In this sense, two different pieces of legislation will be covering the due diligence activities of battery manufacturers: first, under the product-specific Batteries Regulation (Art. 39 of the EC proposal) and then under the CSDD, which will create complementary requirements at a company level. Moreover, we would like to express our support for the industry schemes as we previously did with the Batteries Regulation. … In order to avoid overlaps or inconsistencies, the development of industry schemes must refrain from formulating any new additional standards to address the new requirements of the CSDD proposal. Otherwise, a scenario with overlapping pieces of legislation would create inconsistencies that might hinder the growth of the battery market and, therefore, endanger the competitiveness of the EU industry and the electrification of the transport, energy, and industrial sectors’.
Implementing an enforcement mechanism where companies fail to carry out due diligence as described.
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 advocates for 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.
The entity chooses theses pre-defined options in response to question 19a. It doesn't elaborate.
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.
The Company disagrees 'to some extent' with a legal requirement for directors to establish procedures to ensure that possible risks and advese impacts on stakeholders are identified, prevented and addressed.
In its response to question 7, it disagrees 'to some extent' and points out that: ‘Although as an association, we cannot enforce individual member companies to comply with certain initiatives or legislations, they have agreed to be a part of a global material stewardship project for lead and lead batteries. … The member companies of these 4 associations have aligned on a number of Guiding principles. Proof points and measurable Kpis are currently being discussed and decided up on. Include safe harbor option for these kind of initiatives, e.g.: Proven and functioning industry initiatives should be considered as a safe harbor option as an alternative to any newly created regulatory measurements and KPIs’. The entity does not take position in relation to a requriement for directors to manage risks for the company in relation to stakeholders.
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 considers that complaint mechanism as part of due diligence would be a best practice, it disagrees with a formal, legal requirement for stakeholder consultation.
Although the entity indicates that 'a company specific complaint mechanism as part of the due diligence would cover the requests of the OECD Guidelines in the most effective way', it disagrees to some extent (question 20a) with a mandatory requirement to establish mechanisms for engaging in stakeholder consultation, arguing that 'In our view companies should from a business-perspective proactively reach out to their key internal stakeholders and depending on each industry as well to external stakeholders, but it should be part of the audits within the self-regulated initiatives'.
Enabling judicial enforcement with liability and compensation in case of harm caused by not fulfilling the due diligence obligations.
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 doesn't consider this a suitable option as enforcement mechanism.
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.
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.
Although the entity agrees with due diligence duty definition proposed by the consultation, it does not consider that the EU should implement a due diligence legal framework. The entity prefers a tailored approach for each industry.
The entity agrees with the due diligence duty definition proposed in question 14: 'agree, as that definition is already well embedded in a global material stewardship project. This project, initiated in 2019 by 4 Associations ... A business-specific due diligence is the most effective process to identify industry and company-specific risks and their possible remediation actions'. However, it opposes a legal requirement for due diligence, advocating instead for the use of existing guidelines and standards. It does not refer to remedy or improvement over time, nor to whether due diligence should include the whole value chain (the consultation definition only refers to the downstream supply 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.
The entity opposes to the consideration of the whole value chain.
It states that 'a possible expansion of scope from “supply chain” to “value chain” is far too early to be considered in specific even more so if we consider that the Batteries Regulation is currently under the final stage of negotiations between the EU institutions and different positions on this matter are being discussed. Furthermore, a very broad expansion of the scope of the due diligence obligations for identification and mitigation of social and environmental risks associated with raw materials going into battery manufacturing could put the battery industry at a competitive disadvantage vis-à-vis international competitors because of disproportionate additional administrative burdens. The economic and administrative pressure on the battery industry will skyrocket if this possibility is considered in the final text'.
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 does not take a position on whether there should be a legal requirement for directors to identify stakeholders and their interests.
It chooses the option of not taking a position in response to question 6, arguing that 'EUROBAT is a trade association, we cannot reply to this question, which is directly aimed at our individual members'.
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 disagrees to some extent that the EU should require directors to establish mechanisms for engaging with stakeholders as part of due diligence duty.
It disagrees to some extent (question 20a) with a mandatory requirement to establish mechanisms for engaging in stakeholder consultation, arguing that 'In our view companies should from a business-perspective proactively reach out to their key internal stakeholders and depending on each industry as well to external stakeholders, but it should be part of the audits within the self-regulated initiatives'.
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 does not take a position on whether there should be a legal requirement for directors to manage the risks for the company in relation to stakeholders and their interests.
It chooses the option of not taking a position in response to question 6, arguing that 'EUROBAT is a trade association, we cannot reply to this question, which is directly aimed at our individual members'.
| Legislation | Phase of Active Company Engagement | Position |
|---|
| Member | Performance band |
|---|---|
| EUROBAT | E+ |