MAIF

The company agrees that a legal framework is needed; agrees with the definition of Due Diligence Duty provided by the consultation, advocating for a, ‘principles-based approach.’ It also considers that impact evaluation should be available for all citizens.

The Company agrees that, 'an EU legal framework is needed,' (question 2) without adding further details. It also agrees with the definition of Due Diligence Duty (question 14) and adds that: 'it gives a wide vision of the liability of companies, integrating all aspects of the due diligence duty, both upstream and downstream.' It considers that the legislation should follow a, 'principles-based approach.' (question 15) In addition to this, they also state that: 'companies should be compelled to assess their impacts. In that respect, there should be a common and harmonized criteria, for all member states. The evaluation of these impacts should also be available for all citizens ...'.

The Company advocates for a horizontal approach (all sectors) and that SMEs should be subject to lighter requirements, including reporting.

The entity advocates for a horizontal approach (question 15) based on principles. It adds (question 15a) that: 'neither any sector nor theme should be excluded. The principles based approach should be the same for all, with slight adaptations according to the sector where it applies.' Regarding size, it indicates (question 16) that SMEs should be subject to lighter requirements and lighter reporting requirements, including also toolbox/dedicated national helpdesk.

The Company advocates for supervision by national authorities with a mechanism for EU cooperation/coordination.

In response to question 19a the Company advocates for: 'supervision by competent national authorities (option 2) with a mechanism of EU cooperation/coordination to ensure consistency throughout the EU.' It adds that: 'This solution is the only one that can not only ensure an efficient European harmonization but also answer to transborder litigations.'

Although this is not directly asked, the Company is in favour of mandatory management of risks in relation to stakeholders and their interests to identify, prevent and address impacts.

The entity, 'strongly agrees,' to requiring by law that corporate directors both manage the risks for the company in relation to stakeholders and their interests (question 6), and have procedures and targets to identify, prevent and address risks and impacts on stakeholders.

Although the entity is in favour of requirements for consultation channels for engaging with stakeholders, it is not clear if it considers whether its complaint mechanisms should be included.

The Company strongly agrees with requiring directors to establish mechanisms for engaging with stakeholders in this area (due diligence duty) (question 20a). It considers that employees and suppliers (among others) should be included, although it does not refer to employees in the supply chain and doesn't explicitly consider them relevant as stakeholder group (question 5). It states that: 'dialogue and concertation with employees and, more generally, all stakeholders, increase the requirements concerning the impacts of the companies.' When asked whether, 'complaint mechanism,' should be part of due diligence and if it should be promoted to the EU level or consider it a best practice, the company doesn't respond (question 20c).

The Company had the opportunity to pick this option and it didn't.

Question 19a asks about enforcement mechanisms with a multiple choice-type response, 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 among its possible measures.

The Company agrees with the consultation definition of due diligence duty including both upstream and downstream, using a horizontal approach based on principles.

The Company agrees with the due diligence duty definition (question 14), adding that: 'It gives a vision of the liability of companies, integrating all aspects of the due diligence duty, both upstream and downstream.' It is in favour of a, 'principles-based approach,' adding that, 'neither any sector nor theme should be excluded.' It, however, does not refer to remediation.

The company 'strongly agrees' with requiring corporates to identify stakeholders and their interests

In response to question 6 on whether directors should be legally required to identify stakeholders and their interests, the company, 'strongly agrees.' The question also asks other stakeholder-related questions. In relation to all of them, it states that: 'we deeply think that the previous assertions are core elements so a company can define its strategy according to the positive impacts it has on stakeholders. We also agree with the fact that the above proposals should become mandatory to a European scale.'

The Company strongly agrees that directors should be required to establish consutlation channels for engaging with stakeholders.

The Company strongly agrees with requiring directors to establish mechanisms for engaging with stakeholders in this area (due diligence duty) (question 20a). It adds that: 'dialogue and concertation with employees and, more generally, all stakeholders, increase the requirements concerning the impacts of the companies.' It then indicates that employees, customers, associations or NGOs related to the main social impacts, academics, and suppliers, should be included.

The company, 'strongly agrees,' with requiring directors to manage human rights risks in relation to stakeholders and their interests.

In response to question 6 on whether directors should be legally required to manage risks in relation to stakeholders and their interests, the company responds that it, 'strongly agrees.' The question also asks other stakeholder-related questions. In relation to all of them it states that, 'we deeply think that the previous assertions are core elements so a company can define its strategy according to the positive impacts it has on stakeholders. We also agree with the fact that the above proposals should become mandatory to a European scale'.