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.
Policy hub highlights the value of the CSDDD as a legislation adopted through a democratic process and stresses the need for timely implementation
"The Policy Hub – Circularity for Apparel & Footwear, remains committed to supporting the climate, environmental, and human rights goals that form the basis of the Corporate Sustainability Due Diligence Directive (CSDDD) and the Corporate Sustainability Reporting Directive (CSRD). We also support efforts to maintain the competitiveness of the EU single market ... We strongly encourage policymakers working on the upcoming Omnibus Simplification Packages to uphold the integrity and ambition of these legislative measures. It is important to recognise the commitment and significant investments businesses have already made to meet the current requirements. Therefore, the focus should remain on providing clarity and predictability as we move forward and not on lowering the ambition of the different legislative pieces. ... Preserve legal clarity for CSDDD transposition. The CSDDD was adopted through a democratic process after over two years of intensive negotiations, with a consensus reached in April 2024. We urge the Commission to uphold the integrity of this legislation to ensure legal certainty for businesses and member states. We welcome a timely implementation of the CSDDD, as a delay on the will create legal uncertainty for businesses and set a concerning precedent for the implementation of other key legislative instruments and the EU legislative process itself."
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 welcomes the proposal that establishes due diligence as a legal requirement, providing a harmonised framework.
The entity states that: 'The Policy Hub welcomes the European Commission’s (EC) Proposal on the Corporate Sustainability Due Diligence Directive (CSDD). ... having a harmonized legislative framework on due diligence (DD) is critical. We support the EC’s attempt to level the playing field in the current Proposal by including non-EU businesses in the scope, and to provide companies with an obligation of means rather than results. ...'
Requiring Human rights due diligence of all companies, regardless of sector and size, while still reflecting their individual circumstances.
Main Web Site
The main organizational Web site of the company and its direct links to major affiliates and attached documents.
The entity indicates the need to a level playingfield is ensured between EU-based on third-country companies with high value sales in the EU. It does not think that the Omnibus is sufficiently ensuring equal due diligence obligations
"Ensuring a level playing field between companies with significant operations in the EU and those without but with significant sales volumes on the EU market. It is crucial that reporting and due diligence obligations are designed in a way that ensures a level playing field between EU and non-EU companies. While we support the European Commission’s intention to simplify reporting requirements, we want to ensure that the competitiveness of EU businesses is not undermined through the Omnibus Package, especially in comparison to companies without significant operations in the EU but with significant sales. "
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 recommends to extend the scope of the Directive to cover SMEs.
It states that: 'As recognised in international standards, a due diligence process is relevant for all companies, regardless of the size and sector. From the scope defined in Art. 2, the Directive covers only a significantly limited part of companies operating in EU markets, casting doubts on the legislation’s effectiveness to create the intended level playing field and meaningful impact. We recommend the extension of the scope of the Directive to also cover small and medium-sized companies. With the right guidance and design allowing for the prioritization of risks and proportionality applied to SMEs, due diligence can be conducted by all.'
Implementing an enforcement mechanism where companies fail to carry out due diligence as described.
Main Web Site
The main organizational Web site of the company and its direct links to major affiliates and attached documents.
The entity highlights the need for alignment of enforcement mechanisms
"Ensure uniform enforcement of CS3D through the creation of a single supervisory authority at the EU level. Without this, multiple authorities may independently investigate subsidiaries of the same company for the same issue, resulting in duplicated efforts, inconsistencies, and increased administrative burdens for businesses"
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 considers that companies should not be liable if they acted with due care in line with the DD regulation.
The entity states that: 'As foreseen in international standards, the responsibility of business enterprises to conduct due diligence should be distinct from issues of legal liability. We recommend separating the scope of due diligence requirements from the one where civil liability applies. Furthermore, companies shall not be held liable if they acted with due care in line with the due diligence obligations of means.'
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 there's a lack of clear risk prioritisation and proportionality of actions, and considers that the broad concept of "value chain", contributes to that.
The entity states that: 'There is a lack of clear risk prioritization and proportionality of actions. International standards foresee that where business enterprises have large numbers of entities in their value chains, it may be unreasonably difficult to conduct DD for adverse impacts across them all. If so, business enterprises should identify general areas where the risk of adverse impacts is most significant and prioritize these for due diligence. This is a key point for a company’s due diligence activities and needs to be further strengthened in the CSDD. ... The lack of clear risk prioritisation is further reinforced by the broad concept of “value chain”, encompassing both upstream and downstream activities. Such a broad definition dilutes the focus on those activities and operations where risks have higher potential impact.'
| Legislation | Phase of Active Company Engagement | Position |
|---|
| Member | Performance band |
|---|---|
| Primark | B+ |
| Zalando SE | D- |