Tchibo

The Company opposes any postponement of the implementation of the CSDDD.

"We strongly oppose the proposed delay of the CSDDD until 2028. Immediate enactment is essential to create a fair and reliable competitive environment and to promptly address potential human rights violations."" ""Reviewing due diligence processes and measures every five years is not sufficient. A review interval of two years allows for responding to changes and ensuring the effectiveness of measures."

The entity expresses concern regarding the Omnibus proposal

Johanna von Stechow, Director of Corporate Responsibility at Tchibo: "As a company with 20 years of experience in human rights work, we appreciate clear political guidelines such as the LkSG and CSDDD. They put human rights on the global agenda and promote impact-oriented cooperation. We are critical of the EU's current omnibus proposals, as they could mean more bureaucracy with less effect.

The entity expresses concern regarding the Omnibus proposal

As a company that already implements the German Supply Act (LkSG) and has 20 years of experience in human rights work within our supply chains, we view the EU Commission's proposals for adjusting the CSDDD with skepticism. We fear:- More bureaucracy- Less impact

The entity expresses concern regarding the Omnibus proposal

As a company that already implements the German Supply Act (LkSG) and has 20 years of experience in human rights work within our supply chains, we view the EU Commission's proposals for adjusting the CSDDD with skepticism. We fear:- More bureaucracy- Less impact

The letter expresses direct and repeated support for the approval of the CSDDD, praising the balance achieved in the political agreement and its alignment with international standards. The signatories also express concern about the risk of the directive being rejected at this final stage.

The statement indicates: “The political compromise on the CSDDD from December last year is based on the UN and OECD standards and thus builds on guidelines that responsible companies have been using as a reference for years. In our view, the requirements of the CSDDD are appropriate and feasible.” “We are very concerned that German support for the CSDDD could still be withdrawn in the final approval process.” “We expect Chancellor Olaf Scholz to secure this democratically achieved compromise and thereby provide companies with legal certainty and fair competitive conditions.”

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’.

Based on the joint letter “Support for EU framework on mandatory human rights and environmental due diligence,” signed by this entity: “We... welcome the announcement by the European Commissioner for Justice... that the European Commission will launch a legislative initiative on mandatory human rights and environmental due diligence.” “Mandatory human rights and environmental due diligence is key to ensure that efforts by companies that respect people and the planet... are not undercut by the lack of a uniform standard...” “Legislation introducing an obligation to conduct due diligence as defined by the UNGPs... is critical to bring all companies to the same standard...”

The statement, demonstrates clear and direct support for the creation of mandatory legislation on human rights and environmental due diligence, recognizing the importance of standardizing business conduct. The statement actively supports the creation of a binding directive on due diligence, advocating for it as essential to establishing a uniform and competitive standard.

Based on the joint letter “Support for EU framework on mandatory human rights and environmental due diligence,” signed by this entity: “...legislation introducing an obligation to conduct due diligence as defined by the UNGPs and covering all business actors is critical to bring all companies to the same standard…”“EU-wide cross-sectoral legislation... should harmonise these expectations…”

The letter explicitly advocates that all companies, regardless of sector or size, should be subject to the legislation, reinforcing the idea of a "level playing field." The statement supports the universal application of the regulation, without sectoral or business-size exceptions, fully meeting the indicator.

Based on the joint letter “Support for EU framework on mandatory human rights and environmental due diligence,” signed by this entity: "Mandatory legislation can... clarify legal consequences for when responsibilities are not met...”

The statement advocates that the legislation should establish clear legal consequences for non-compliance with due diligence obligations. Implicit support for enforcement mechanisms. Although it lacks detailed specifications (such as civil or administrative sanctions), the acknowledgment of the importance of legal consequences justifies a positive score

The Company supports a risk-based due diligence process.

The Company states that ‘Focusing on Tier-1 suppliers leads to more bureaucracy and less impact. Instead, we advocate for a risk-based approach that prioritizes risks in the supply chain based on severity, likelihood, and influence, and implements corresponding measures. ... We support the BAFA's clarification that LkSG obligations should not be passed on to supply chain partners, especially SMEs. A risk inquiry for SMEs must remain possible, as human rights can also be violated here. In risk mitigation, SMEs should be supported by their larger business partners and policymakers.'

The entity calls for a risk based approach to due diligence it is unclear if they support applying this to the downstream value chain

One of our points of critism is limiting the scope to direct business partners. It doesn’t make sense to send out questionnaires to our neighbour-hood caterer when the real human rights problems lie elsewhere. Therefore, we call for a risk-based approach, prioritizing our own activities based on severity, probability, and one’s own influence.

The entity calls for a risk based approach to due diligence it is unclear if they support applying this to the downstream value chain

One of our points of critism is limiting the scope to direct business partners. It doesn’t make sense to send out questionnaires to our neighbour-hood caterer when the real human rights problems lie elsewhere. Therefore, we call for a risk-based approach, prioritizing our own activities based on severity, probability, and one’s own influence.

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'.

The entity supports the inclusion of stakeholder dialogue in the drafting of HRDD legislation

The distance between brands and production facilities is no excuse for inaction—it's precisely why we need approaches that center worker voices rather than external assessments. Transformative change happens when we stop treating workers as data points in risk assessments and start recognizing them as the experts of their own experience. This needs to be reflected when drafting HRDD legislation.

The entity supports the inclusion of stakeholder dialogue in the drafting of HRDD legislation

The distance between brands and production facilities is no excuse for inaction—it's precisely why we need approaches that center worker voices rather than external assessments. Transformative change happens when we stop treating workers as data points in risk assessments and start recognizing them as the experts of their own experience. This needs to be reflected when drafting HRDD legislation.