Ruohonjuuri

The undersigned entities do not support the Omnibus proposal.

"On 26 February, the Commission published the Omnibus I proposal on EU sustainability regulation. The stated aim of the Omnibus proposal was to streamline and simplify the already agreed regulation while maintaining the original purpose of the legislation. We, the undersigned, fear that these objectives are not being achieved. International principles of corporate responsibility were established almost 15 years ago at the UN and OECD level. The original Corporate Responsibility Directive, adopted last year, sought to bring the above-mentioned principles to the level of legislation by imposing a risk-based human rights and environmental due diligence obligation on large companies. The Commission's Omnibus proposal no longer fully relies on risk-based approaches and therefore risks breaking the link between legislation and the above-mentioned principles."**Text translated, original language Finnish

The undersigned entities oppose the re-opening of the agreed and adopted legal texts of the CSRD and CSDDD. It indicates that this would lead to legal uncertainty and indicates necessary simplification should be done at level 2 of legislative process only.

"""The undersigned 28 Finnish companies and CSOs, are concerned about the uncertaintythat the Commission’s announcement of an upcoming Omnibus Simplification Package hascreated. We are calling on the Commission to ensure that the already agreed sustainabilitydue diligence rules are not opened for renegotiation.""""we continue to support the CSRD and CSDDD. What we need is certainty andtimely transposition of the CSDDD and guidance for smart implementation of both ofthese directives.""""The possibility of the CSRD and CSDDD being reopened creates political uncertainty andlegal unpredictability which are both detrimental to investment and competitiveness. Assuch, we are calling on you to clarify that this omnibus package, if embarked upon, will notlead to already agreed and adopted legal texts being opened for renegotiation. Any changesto the legislation should be at level 2 only."""

By endorsing this joint statement, the entity demonstrates unequivocal support for the establishment of mandatory due diligence legislation on human rights and environmental issues. The letter reinforces the urgency of adopting the legal text and the central role that regulation must play. The entity publicly supports the mandatory nature of the legislation and its alignment with international standards (UNGPs, OECD), which directly corresponds to the scope of indicator Q1.1. The language used reflects a proactive and affirmative stance.

Based on the document "EU Business Statement – February 2022," in which the entity is listed as a signatory, it states: “We... urge the European Commission to adopt a legislative proposal without further delay.” “We firmly believe that strong and ambitious EU legislation would make a tangible contribution to improving human rights and environmental conditions along global value chains...” “Our view has always been that the due diligence expectations set out in the UNGPs and in the OECD Guidelines should form the core requirements on business in HREDD legislation.”

The statement calls for preserving the core of the EU sustainable finance framework, including corporate due diligence, considering that regulatory simplification can be achieved without compromising the substance of the new rules.

Signatories ‘are issuing this joint statement to emphasise the importance of preserving the core of the EU sustainable finance framework. Rules on … corporate due diligence are a key foundation for achieving the EU’s economic and sustainability goals. … In the context of the Omnibus I simplification initiative, we call attention to the investors, banks, other financial institutions and companies across our economy that support preserving the core elements of the … Corporate Sustainability Due Diligence Directive (CSDDD). … CSRD/ESRS and CSDDD are essential for achieving the EU’s wider sustainability, growth and competitiveness ambitions. … The signatories of this statement consider that regulatory simplification can be achieved without compromising on the substance of sustainability rules or their significant benefits for businesses across the EU’.

The signed entities support the introduction of a mandatory human rights and environmental due diligence law at the EU level and call on their governments to vote in favour of the CSDDD.

"As Nordic businesses, we recognize that there is a critical need for business to play their part in addressing the urgent human rights and environmental challenges we face globally.""With the Corporate Sustainability Due Diligence Directive (CSDDD), the EU has a unique opportunity to harness the transformative power of the UN Guiding Principles on Business and Human Rights. This will further strengthen the relationship between business and society and the realization of sustainable development. A mandatory human rights and environmental due diligence law that is applicable throughout the EU would serve as an international benchmark for advancing responsible business conduct. It would also create a level playing field across the EU to drive much needed action""We call upon our governments to continue to play a leadership role by supporting the CSDD in the final stages of the legislative process, including by voting in favour of the initiative at the upcoming Council meeting."

Based on the document "EU Business Statement – February 2022," in which the entity is listed as a signatory, it states: “All businesses established in the EU and/or active on the internal market, including financial actors, and regardless of size, should be covered by mHREDD legislation.” “Many European SMEs... acknowledge that responsibility... is not a matter of company size...”

The document advocates for the legislation to apply to all companies, regardless of size or sector, expressly including SMEs and financial actors. This position represents clear support for the universal scope of the regulation. The entity explicitly supports the universal application of the legislation, recognizing the importance of a level regulatory playing field, including for SMEs.

Based on the document "EU Business Statement – February 2022," in which the entity is listed as a signatory, it states: “The requirement needs to be accompanied by legal consequences – encompassing administrative penalties and provisions for civil liability – that will be strong enough to ensure that businesses... carry out HREDD to a high standard...”

The entity advocates for the existence of legal accountability mechanisms, including administrative sanctions and civil liability, as a means to ensure the effectiveness of the legislation. There is clear support for the implementation of robust enforcement mechanisms, covering both administrative penalties and civil liability, fully aligning with the scope of the indicator.

Based on the document "EU Business Statement – February 2022," in which the entity is listed as a signatory, it states: “HREDD should also be embedded in appropriate governance and accountability structures, including at board level.”

The letter argues that governance structures, including boards of directors, should integrate due diligence, implying an active role for directors in risk prevention and mitigation. Although the text does not explicitly propose a formal legal obligation for directors, it advocates for their incorporation into governance, justifying a positive score.

Based on the document "EU Business Statement – February 2022," in which the entity is listed as a signatory, the company states: "To level and harmonise the playing field in practice, the requirement needs to be accompanied by legal consequences – encompassing administrative penalties and provisions for civil liability – that will be strong enough to ensure that businesses falling within the personal scope of the legislation carry out HREDD to a high standard and that those that are harmed have access to remedy."

Analysis: The text reinforces the importance of corporate accountability and the guarantee of access to remediation for victims of negative impacts, in line with the spirit of the indicator. Score: +1 Justification: Despite being brief, the direct mention of the need for remediation justifies a positive score, as it aligns with the principle of repairing damages caused or contributed to

Based on the document "EU Business Statement – February 2022," in which the entity is listed as a signatory, it states: "The legislation should reflect the wide spectrum of avenues, including adjustments to own purchasing practices, to effectively influence and enable business partners as well as increase leverage if needed, rather than honing in narrowly on the extent to which a company can deploy contractual or commercial leverage."

The letter explicitly advocates that companies should adopt measures to influence and support their business partners, including adjusting their own purchasing practices, which aligns with the use of leverage for remediation purposes. There is clear and active support for the use of leverage to influence business partners, as outlined in the indicator.

Based on the document "EU Business Statement – February 2022," in which the entity is listed as a signatory, it states: "A key component of qualitative HREDD is meaningful engagement with affected stakeholders – those people that are at risk of negative impacts from business activity. Listening to the voices of workers, community members and others is vital to a company’s understanding of risks to people and planet and strengthens its due diligence. To ensure that the EU legislation encourages people-centric HREDD, robust engagement with affected groups, workers and other relevant stakeholders including unions and human rights and environmental defenders should inform all stages of the required due diligence process. Engagement must also be safe, so that those speaking out can do so without suffering or fearing retaliation."

The entity explicitly supports engagement with affected rights holders as a central part of the due diligence process, including during critical stages such as remediation. The document emphasizes the centrality of meaningful stakeholder engagement and their security, demonstrating full alignment with the indicator.

Based on the document "EU Business Statement – February 2022," in which the entity is listed as a signatory, it states: "To level and harmonise the playing field in practice, the requirement needs to be accompanied by legal consequences – encompassing administrative penalties and provisions for civil liability"

Support for civil liability as an essential component of the legislation shows direct alignment with the requirement for judicial enforcement. The entity explicitly endorses civil liability with provisions for compensation, justifying the maximum score.

The Company states that it considers it as problematic in the omnibus proposal to limit the due diligence obligation to companies’ own operations, subsidiary operations, and direct business partners (so-called tier 1 level).

"A particularly problematic aspect of the Commission's omnibus proposal is the general limitation of the due diligence obligation to companies' own activities, the activities of subsidiaries and direct business partners (the so-called tier 1 level). This limitation may mechanically direct companies' responsibility work and the resources allocated to it to places where environmental and human rights risks are generally not the greatest. Limiting the obligation to the first stage of the production chain will not help to address the problems for which the CSR Directive was enacted. It makes it more difficult for companies carrying out responsibility work and increases the administrative burden. At the same time, it allows irresponsible business practices to continue"*Text translated, original language Finnish

Based on the document "EU Business Statement – February 2022," in which the entity is listed as a signatory, it states: “The legislation should oblige businesses to carry out ongoing due diligence proactively and across all their operations and the full value chain.” “The UNGPs set out that a company’s responsibility... extends throughout its business relationships across its full value chain...”

The entity fully supports the application of due diligence throughout the entire value chain, as reflected in UN and OECD principles. The statement proposes that the legislation require a continuous and proactive approach, covering direct operations and business relationships. There is clear and normative support for the application of due diligence across the entire chain (upstream and downstream), justifying the maximum score for this indicator.

The statement calls for not limiting due diligence to tier-1 suppliers.

It states that 'the most salient ... risks and impacts often lie deeper in supply chains. A risk-based approach to due diligence is helpful to companies as this allows them to focus on where the real risks are, building on their knowledge of their own supply chains. By limiting due diligence to tier 1 suppliers, the Omnibus proposal may unintentionally promote the kind of “box ticking” compliance exercises that it intends to reduce'.

Based on the document "EU Business Statement – February 2022," in which the entity is listed as a signatory, it states: “Listening to the voices of workers, community members and others is vital to a company’s understanding of risks to people and planet and strengthens its due diligence.”

The letter advocates that risk assessment should take place through active listening and dialogue with affected stakeholders, which aligns with the spirit of the indicator. The statement explicitly supports the use of dialogue as a risk assessment tool, justifying the maximum score.