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.
In its response to phase 3, the entity discloses: “TIC Council welcomes the European Commission’s proposal for a Directive on Corporate Sustainability Due Diligence.”“We expect it to act as a cornerstone in implementing and enforcing human rights and environmental protection.” “Due diligence services by the TIC sector include... audits... periodic assessment... effectiveness of their own due diligence policies.”
The TIC Council explicitly supports the proposed Directive, describing it as fundamental for the implementation and enforcement of human rights and environmental protection. The organization also outlines concrete instruments for its application, such as periodic audits and independent verification. However, since this statement was made within the context of an official consultation response (phase 3) rather than proactively or spontaneously, it should be interpreted as a prompted response, in accordance with the methodological criteria.
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 response to questions 2, 3, 5, 15 and 17, the entity discloses: “TIC Council welcomes the European Commission’s proposal for a Directive on Corporate Sustainability Due Diligence.”“We expect it to act as a cornerstone in implementing and enforcing human rights and environmental protection.”“Due diligence services by the TIC sector include... audits... periodic assessment... effectiveness of their own due diligence policies.”“Yes, an EU legal framework is needed.”“We expect it to act as a cornerstone in implementing and enforcing human rights and environmental protection.”“...require third-party verification... to guarantee compliance and consistency.”“Option 3: Minimum process and definitions approach… complemented with further requirements in particular for environmental issues.”“All companies should be obliged to verify their claims with conformity assessment bodies.”
The TIC Council clearly expresses support for the creation of a mandatory legal framework for due diligence, recognizing the European Commission's proposal as essential for promoting environmental and human rights protection. The entity provides practical suggestions, such as third-party verification and the implementation of regular audits, to ensure the effectiveness of the directive. However, since the statements were given in response to direct questions in a questionnaire (rather than spontaneously or proactively), this support is considered to be motivated by external consultation rather than an independent or anticipatory public statement. According to the scoring criteria, this justifies a positive evaluation, but not the highest rating. The TIC Council supports the legal obligation of due diligence, including measures to ensure its enforcement, such as audits and third-party verification.
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.
Question 15 – TIC Council selects Option 3, which is a horizontal approach (applicable to all sectors) with environmental complements: "Option 3: Minimum process and definitions approach as presented in Option 2 complemented with further requirements in particular for environmental issues. This approach would largely encompass what is included in option 2 but would complement it as regards, in particular, environmental issues." Question 15a reinforces that the horizontal application should be adapted by sector but based on voluntary consensus: "We consider that the approach should be based on voluntary consensus by multi-stakeholders, which would specify how it can be applied for each sector." Question 16 – TIC Council does not request exemptions for SMEs. Instead, it suggests proportional support without exclusion: "Capacity building support, including funding; Detailed non-binding guidelines catering for the needs of SMEs in particular."
The choice of Option 3 and the subsequent comments show that the TIC Council supports a due diligence model applicable to all sectors, with specific adjustments according to thematic or sectoral contexts—exactly as outlined in the scope of indicator Q1.2. Additionally, when addressing the application to companies of different sizes, the TIC Council does not advocate for the exclusion of SMEs but rather the adoption of support measures to reduce the burden, aligning with the principle of proportionality without compromising the scope of the legislation. The TIC Council clearly supports the universal application of the directive, both in terms of sector and company size, without requesting exceptions—only proposing proportional adaptation and support for SMEs.
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.
In its response to phase 3, the entity states that: “Improper verification could also cause unfair competition among companies subject to the Directive...”...“...supervisory authorities to use accredited companies for independent third-party verification...”...“...increase the number of compliance controls... ensure a better implementation rate...”
The TIC Council directly supports the strengthening of enforcement mechanisms, suggesting the use of independent bodies to enhance the effectiveness of the directive's implementation. Proactive support for enforcement mechanisms through independent oversight, with specific recommendations to expand regulatory capacity and prevent competitive loopholes.
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 response to questions, 2, 5, 9, 17b and 19a, the entity discloses: “...require third-party verification through qualified conformity assessment bodies...”“...could ensure the truthfulness and accuracy of companies' claims.”“...to guarantee compliance and consistency.”“Judicial and market surveillance enforcement… are inadequate without a system of verification…”“TIC Council members can verify compliance…”
The TIC Council actively supports the implementation of third-party verification through qualified conformity assessment bodies to ensure truthfulness, accuracy, and compliance with due diligence obligations. This proposal strengthens enforcement mechanisms, preventing false claims and enhancing regulatory consistency. Additionally, the organization argues that judicial and market surveillance enforcement alone is inadequate without a system of independent verification, emphasizing that TIC Council members could play a role in ensuring compliance. This direct endorsement of independent oversight further reinforces the need for technical-operational enforcement measures beyond state-controlled mechanisms. The TIC Council explicitly advocates for independent audits and certifications, reinforcing regulatory efficiency and closing enforcement gaps.
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 response to questions 8 and 13, the entity states :“Giving stakeholders such rights would influence the company’s management to an excessive extent.” “Such broad responsibility is creating a very vague responsibility.”
The TIC Council explicitly rejects the proposal for directors to have additional legal duties concerning stakeholders, including obligations for impact prevention. Instead, it advocates for voluntary and more technical approaches. Clear opposition to expanding directors' responsibilities, with criticisms regarding both implementation and the viability of the concept
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.
In response to questions 2, 3 and 14, the entity discloses: “...including in their value chain.”“...ensuring that the company is aware of its adverse... impacts... to mitigate these risks...”“Direct suppliers remain the same focus... but their suppliers should also be included in the assessment.”“...tier 3 within the supply chain...”
The TIC Council clearly supports the application of due diligence throughout the supply chain (upstream), advocating that companies should assess and mitigate risks at different levels, including beyond direct suppliers (up to the third tier). However, there is no explicit or comprehensive mention of the downstream value chain (such as distributors, resellers, or end users), which is also an essential part of the scope of indicator Q3.1. The entity supports due diligence in relevant parts of the value chain, particularly within the supply chain, and proposes the inclusion of indirect suppliers up to tier 3. However, the absence of a clear reference to the downstream chain limits the scope of support.
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.
In its response to phase, the entity discloses: "we recommend amending the definition of “independent third-party verification” (article 3) to ensure that only accredited bodies, which are established as legal persons, would be allowed to conduct verification regarding the implementation of the contractual assurances to prevent and mitigate identified adverse effects (articles 7 and 8). "
The response advocates for the verification of contractual clauses by independent third parties, recognizing their importance as tools to mitigate impacts within the value chain. Direct support for the use of contractual clauses with business partners, accompanied by a concrete proposal to ensure their verification and effectiveness.
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.
In response to question 6, the entity says: “Do not take position. We consider that identifying long-term stakeholders' interests might not be possible to measure and verify.”
The organization refrains from supporting the mandatory systematic identification of stakeholders, arguing that such interests are difficult to measure. By declining to endorse the formal identification of stakeholders, the organization implicitly opposes incorporating this practice as a legal obligation, thereby reducing the ambition of the indicator.
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.
In question 20a, the entity marked: “I do not take position.”
No clear support or opposition—neutral stance without a practical recommendation.
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.
In response to question 8, the entity disagree with the item.
Clear and direct opposition to the formal accountability of directors for risk management concerning stakeholders.
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