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.
Although it doesn't take a position in relation to DD Duty definition, the Company is in favour of legislation following a minimum processes and definitions approach.
The Company agrees (question 2) that an EU legal framework is needed, but don't respond to question 14 on whether they agree with the definition of DD Duty. It declarers it in favour of option 3 in its response to question 15, which means it is in favour of a "minimum process and definitions approach" complemented with further requirements for environmental issues. According to this approach, the EU should define a minimum set of requirements with regard to the necessary processes, which should be applicable across all sectors (for example, the coverage of adverse impacts that should be the subject of due diligence obligation). It doesn't indicate that this should be complemented by specific sector guidance.
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.
In favour of applying requirements to all sectors and all companies, including SMEs, even if these are subject to lighter requirements.
As responded to question 15, the Company is in favour of, "minimum process and definitions approach ... with further requirements in particular for environmental issues". This includes SMEs, which, according to the response to question 16, "should be subject to lighter requirements".
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 Company is in favour of national supervision with an EU coordination mechanism.
In response to question 19a on enforcement mechanisms where companies fail to carry out DDD, the Company is in favour of "supervision by competent national authorities (option 2) with a mechanism of EU cooperation/ coordination to ensure consistency ...". The Company clarifies that this should be sufficient as long as the application remains harmonised across the EU.
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.
In favour to some extent of directors being required by law to manage risks but also disagrees to some extent in being similarly required to have procedures and, where relevant, measurable targets to identify, prevent and address those risks.
Although the consultation does not directly ask about an obligation for directors to avoid impacts or harms, it asks (question 6) about a legal requirement for them to manage the risks of the company in relation to stakeholders' interest, to which it agrees "to some extent". However, when asked if corporate directors should be required by law to have procedures and targets to identify, prevent and address risks, it disagrees "to some extent" indicating that it doesn't think that making it a legal requirement would significantly improve the current situation (voluntary commitments), while potentially representing a significant burden.
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.
This is not directly asked by the consultation and the questions and responses don't allow inference.
The company did not respond to question 14 about DD duty definition, nor to question 20c in relation to the complaint mechanisms as part of due diligence. It agrees to some extent that the EU should require directors to establish mechanisms for engaging with stakeholders, but doesn't elaborate on whether these should include grievance options.
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.
Question 19a directly asks about this option and the company didn't choose it.
Question 19a allows for multiple choice, 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 as a possible option.
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 Company doesn't indicate whether it agrees with the DD duty definition and doesn't refer to upstream chain. It is in favour of a due diligence process that follows a minimum process and definitions approach.
The Company doesn't indicate whether it agrees with DD duty defintion as presented before question 14, and doesn't refer to upstream chain. It is in favour of a due diligence process following a minimum process and definitions approach.
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 company is in favour "to some extent" of corporate directors being required to identify companies' stakeholders and their interests.
The company considers relevant the interests of stakeholders affected by the company and its supply chain, and agrees "to some extent", with question 6 regarding corporate directors being legally required to identify the Company's stakeholders and their 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.
Question 20a asks about requiring directors to establish and apply engagement mechanisms in this area (fulfilling DD duties more effectively) and the Company agrees "to some extent".
Question 20a asks about requiring directors to establish and apply engagement mechanisms in this area (fulfilling DD duties more effectively) and the company agrees "to some extent". No further details were found in relation to which parts it agrees with and what prevents the company giving a more favourable response.
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 Company agrees, "to some extent", when directly asked about this. No further comment.
The Company agrees, "to some extent", when directly asked about this. No further comment, including whether this should be a requirement for corporate directors.
| Legislation | Phase of Active Company Engagement | Position |
|---|
| Industry Association | Performance band |
|---|---|
| EuroCommerce | E+ |
