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 is supportive for the proposal of CS3D.
The entity states that ‘Mazars welcomes the proposal for a Corporate Sustainability Due Diligence Directive (CS3D). There is a need of coordination between both proposals on definitions and subsidiarity principles, for the consistency and practicality. ...We believe that the obligation for companies to carry out periodic assessments of their operations and processes (article 10) is not sufficient to ensure compliance. Instead, we suggest that companies should establish appropriate internal controls, which ensure allocation of duties, completeness, and the necessary safeguards.’
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 seems to support due diligence would covers more than first tiers of supply chain and third countries companies.
The entity states that ‘Due diligence should not be limited to the first tier of supply chain but encompass those posing major risks. We also support the inclusion of third countries corporations (around 1% of European companies). An in substance progressing extension in scope should be considered - via level 2 standards and/or level 3 guidance, encouraging the main contractors and banks to embed recommendation of application in the supply chain tendering/financing processes, as it is the case in the OECD and UN guidelines.’
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 is supportive for directors’ duty of care.
The entity states that ‘while we support the provisions included in Articles 25 and 26, the ‘board’s collective responsibility’ needs to be further clarified. To help transposition and secure proper implementation, special attention should be paid to the different existing national regimes on board responsibility (collective and individual).’
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 seems to support due diligence would covers more than first tiers of supply chain.
The entity states that ‘Due diligence should not be limited to the first tier of supply chain but encompass those posing major risks. We also support the inclusion of third countries corporations (around 1% of European companies). An in substance progressing extension in scope should be considered - via level 2 standards and/or level 3 guidance, encouraging the main contractors and banks to embed recommendation of application in the supply chain tendering/financing processes, as it is the case in the OECD and UN guidelines.’
Require that companies implement contract clauses and Code of Conduct with business partners clarifying obligations to avoid and to address human rights 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 seems to support implementing codes of conduct with business partners on human rights due diligence, especially with SMEs while highlighting the importance to not offload the due diligence duty onto business partners.
The entity states that ‘Due Diligence process is the cornerstone of CS3D: large companies should aim at identifying potential adverse impacts within their supply chain and not offload the risk via contracts, especially with SMEs that may lack resources to comply. In conjunction with accompanying measures, we support the use of contractual provisions as additional comfort, but not as the main solution.The business partner should comply with the company’s code of conduct, provided it follows a transparent procedure as well.’
| Legislation | Phase of Active Company Engagement | Position |
|---|
| Industry Association | Performance band |
|---|---|
| Assirevi | D+ |
| France Invest | E- |
