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.
The entity states that they "welcome" the EU's due diligence initiative, but then calls on the EU to rely on voluntary schemes, as they are "credible and efficient enough" to prevent human rights abuses. They also state that placing obligations on solely the private sector in inherently problematic and unlikely to function.
"The European Precious Metals Federation (EPMF) welcomes the European Commission’s upcoming initiative on due diligence and sustainable corporate governance. The EPMF supports the Commission’s objective to respect both human and labour rights, and corporate social responsibility throughout the value chains of European companies. Should the Commission develop mandatory EU legislation on due diligence, the EPMF suggests the following key recommendations:" "Rely on voluntary due diligence schemes: voluntary supply chain due diligence schemes (e.g. LBMA Responsible Gold Guidance and RJC Chain-of-Custody Certification Program) are based on anti-money laundering principles and the 5-step framework for risk-based due diligence from the OECD Due Diligence Guidance. Voluntary schemes are credible and efficient enough to help carry out due diligence and fight against serious abuses of human rights, money laundering and any contribution to conflicts." "due diligence is only successful if deployed hand in conjunction with projects led by local governments (both in the EU and non-EU countries). Placing the responsibilities on the private sector (companies and their directors) as the primary leverage to improve human rights, environmental protection and climate change is inherently problematic and unlikely to function successfully."
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 support mandatory due diligence obligations at the EU level, and states that enhancing and following voluntary standards is sufficient.
In response to Q2: "No, it should be enough to focus on asking companies to follow existing guidelines and standards."
Q3: "If the EU wants to become a standard setter on human rights, sustainability and responsibility, it should engage into diplomatic efforts (coordinated with the EU industry) to reach an international due diligence standards and make those initiatives actually measurable and efficient."
Q3a: "Any EU initiative should consider the concerned market, the outcome of the competitiveness analysis and impact assessment, and in full consultation with the relevant industry. There is no universal definition or reference criteria for social and environmental due diligence requirements and obligations."
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 calls for proportionate responsibilities for SMEs, but states that number of employees is not an adequate threshold for determining scope. They also support the inclusion of all business sectors.
Q 14: "If the upcoming due diligence initiative proposes to limit due diligence companies’ obligations, EPMF suggests looking for thresholds that limit the due-diligence obligations to companies with a real impact on the ground, e.g. big manufacturers could have less impact on the ground than a small trading company. Hence, for the precious metals sector thresholds of number of employees is not the best approach. Purchasing power could be a better threshold. " Q 16: "All business sectors have a potential to contribute to environmental and social, including human rights, impacts, and the responsibility to respect human rights in particular under the UN Guiding Principles on Business and Human Rights, however efforts should be proportionate to their size and impact."
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 supports supervision at the national and EU level.
Q 19: For enforcement of the CSDDD, the entity calls for "Supervision by competent national authorities, with a mechanism of EU cooperation/coordination to ensure consistency throughout the EU."
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 does not support the inclusion of civil liability provisions in the CSDDD.
Q 19: For enforcement of the CSDDD, the entity calls for "Supervision by competent national authorities, with a mechanism of EU cooperation/coordination to ensure consistency throughout the EU" but does not support the inclusion of sanctions or civil liability provisions.
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.
The entity calls for full coverage of the value chain within the scope of due diligence obligations.
"Due diligence should be applicable throughout the entire value chain: all companies and business sectors can contribute to environmental, social, human and economic impacts. As an example, the EU Conflict Minerals Regulation which only covers smelters and refiners. Due diligence should not end at the smelting and refining stages but cover all production stages and be applied throughout the value chain. Additionally, producers of parts and finished products originating from third-countries have no due diligence obligations. Importers of the final device are also not obliged to conduct full due diligence. These omissions create loopholes and, hence, due diligence cannot be fully implemented."
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 calls for clarity and stronger definitions of the scope of supply chain responsibilities and propose to limit obligations based on purchasing power.
Q 14: "The concept of 'supply chain' needs to be clarified, both in terms of clear definition/meaning (supply chain vs. value chain) and in terms of an approach and scope of due diligence. The OECD guidance for responsible supply chains from conflict-affected and high-risk areas (CAHRAs) provides a holistic definition of ‘due diligence for supply chain’s including the whole supply chain, back to the source of primary material not just suppliers, subsidiaries and subcontractors.
If the upcoming due diligence initiative proposes to limit due diligence companies’ obligations, EPMF suggests looking for thresholds that limit the due-diligence obligations to companies with a real impact on the ground, e.g. big manufacturers could have less impact on the ground than a small trading company. Hence, for the precious metals sector thresholds of number of employees is not the best approach. Purchasing power could be a better threshold."
| Legislation | Phase of Active Company Engagement | Position |
|---|
| Member | Performance band |
|---|---|
| BASF | E+ |
| Anglo American | F |
| Glencore | F |