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.
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 ‘it should be enough to focus on asking companies to follow existing guidelines and standards’ and generally agrees with the definition of due diligence.
In response to question 2, the entity thinks that ‘the most important target currently should be to encourage companies to follow existing guidelines’ and ‘there is no necessity to provide new EU regulations’.
In response to question 14, the entity considers that the definition is too complex to be legally applied and instead, a collection of lessons learned on due diligence would be more helpful.
In response to question 15, the entity picks up option 1 ‘Principles-based approach’.
In response to question 17, the entity states that due diligence rules should be applied to certain third-country companies.
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 picks up option 1 ‘Principles-based approach’. It seems the entity does not support full exclusion of the SMEs.
In response to question 15, the entity picks up option 1 ‘Principles-based approach’, stating that ‘A general due diligence duty based on key process requirements should be defined at EU level regarding identification, prevention and mitigation of relevant human right…risks. These should be applicable across all sectors’.
In response to question 16, the entity chooses ‘Capacity building support, including funding; Detailed non-binding guidelines catering for the needs of SMEs in particular; Toolbox/dedicated national helpdesk for companies to translate due diligence criteria into business practices’. The entity does not support full exclusion of the SMEs and considers that ‘Detailed but non-binding guidelines suitable for SMEs could prove helpful, as well as special support organized at the national level.’
In response to question 17, the entity thinks due diligence rules should also be applied to certain third-country companies.
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 is not in favour of mandatory requirements for enforcement mechanism and considers that it should be guidance.
In response to question 19, the entity picks ‘Supervision by competent national authorities (option 2) with a mechanism of EU cooperation/coordination to ensure consistency throughout the EU; Other, please specify’ and considers that it should ‘be guidance- not mandatory requirements.’ The entity also indicates that ‘If however it is decided otherwise, the best solution would be the supervision of competent authorities.’
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 entity agrees to some extent on director’s legal duty to identify the company’s stakeholders and their interests, however, disagrees to some extent on director’s legal duty to ensure human rights impacts are identified, prevented and addressed.
In response to question 6, the entity states that ‘Board members must be obliged to identify their stakeholders, because otherwise they will not be able to pursue their interests.’
In response to question 7, regarding identifying, preventing, and addressing human rights, social, health and environmental impacts, the entity considers that ‘Companies have legal obligations of this sort and it seems excessive to impose these legal obligations on directors.’
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.
The entity seems to be not supportive for legal requirements for directors to establish and apply mechanisms for engaging with stakeholders.
In response to question 20a, the entity implies that it is not familiar with such requirements, however, it believes that ‘EU should not add legal requirements.’
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 is not in favour of mandatory requirements for enforcement mechanism and considers that it should be guidance.
In response to question 19, the entity picks ‘Supervision by competent national authorities (option 2) with a mechanism of EU cooperation/coordination to ensure consistency throughout the EU; Other, please specify’ and considers that it should ‘be guidance- not mandatory requirements.’ The entity also indicates that ‘If however it is decided otherwise, the best solution would be the supervision of competent authorities.’
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.
The entity considers that ‘it should be enough to focus on asking companies to follow existing guidelines and standards’, however, it seems that the entity agrees with risk management related to supply chains.
In response to question 2, the entity believes that ‘there is no necessity to provide new EU regulations as this solution may not be effective. The most important target currently should be to encourage companies to follow existing guidelines and to encourage them to engage in the process of risk management related to supply chains. We realize that the biggest problems with measuring the harmful influence on the environment refer to the supply chains. Maybe imposing new reporting obligations especially on unlisted SMEs would be the solution.’
In response to question 14, the entity picks option 1 ‘Principles-based approach’, stating that ‘A general due diligence duty based on key process requirements (such as for example identification and assessment of risks….and of the supply chain, risk and impact mitigation actions…etc.) should be defined at EU level regarding identification, prevention and mitigation of relevant human rights, social and environmental risks and negative impact. These should be applicable across all sectors.’
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 agrees to some extent on director’s legal duty to identify the company’s stakeholders and their interests.
In response to question 6, the entity states that ‘Board members must be obliged to identify their stakeholders, because otherwise they will not be able to pursue their interests.’ It seems the entity is supportive to require companies to identify their stakeholders and interests.
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 seems to be not supportive for legal requirements for directors to establish and apply mechanisms for engaging with stakeholders.
In response to question 20a, the entity implies that it is not familiar with such requirements, however, it believes that ‘EU should not add legal requirements.’
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 agrees to some extent on director’s legal duty to identify the company’s stakeholders and their interests. However, the entity disagrees to some extent on directors’ legal duty to identify, prevent and address human rights, social, health and environmental risks.
In response to question 6, the entity states that ‘Board members must be obliged to identify their stakeholders, because otherwise they will not be able to pursue their interests.’
In response to question 7, the entity states that ‘Companies have legal obligations of this sort and it seems excessive to impose these legal obligations on directors.’
| Legislation | Phase of Active Company Engagement | Position |
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| Industry Association | Performance band |
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