Corporate Sustainability Due Diligence

Fairtrade Finland welcomes the opportunity to give feedback on the proposed CSDD Directive. The proposal is an important milestone in corporate accountability. It sets an ambitious goal of transforming corporate behaviour and encouraging a sustainable future.

The release of the CSDD proposal is a crucial first step towards mandating respect for people & planet for EU-operating businesses. While we highlight some ‘good practices’, our benchmarks and allegations data show that progress is glacial.

Companies, as well as society and the wider economy, can in the long-term benefit from responsible business conduct and a global level-playing field that requires and rewards sustainable production and consumption, including by respecting human rights.

RP Legal & Tax was among the first Italian law firms to provide legal services on sustainability and impact investing, with a dedicated “ESG & Legal Impact” team. The ESG & Legal Impact team of RP Legal & Tax welcomes the proposal for a Directive on Corporate Sustainability Due Diligence and thanks for the opportunity to provide written inputs.

The Responsible Business Alliance welcomes this important step towards creating a level playing field and harmonizing requirements in the area of sustainability due diligence, across the EU. Our support for this framework is based on the RBA Roadmap for EU Due Diligence (attached).

Fair Labor Association (FLA) commends the European Commission on the publication of the proposed Company Sustainability Due Diligence Directive (CSDDD). It is a significant milestone in the evolution of business and human rights.

Departamento de Disciplinas Comerciales Dirección de Política Comercial Viceministerio de Comercio Exterior Mayo 2022 Ref. Ares(2022)3886596 - 23/05/2022 Comentarios sobre la propuesta de una Directiva del Parlamento y el Consejo Europeo sobre Debida Diligencia de Sostenibilidad Corporativa y enmienda a la Directiva (EU) 2019/1937 La República Dominicana saluda los esfuerzos realizados por la Unión Europea para…

Filed in Spanish · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Mazars comments on the European Commission’s Corporate Sustainability Due Diligence Directive proposal Mazars welcomes the proposal for a Corporate Sustainability Due Diligence Directive (CS3D), which usefully completes the Governance pillar of the Corporate Sustainability Reporting Directive (CSRD) proposal.

Forest Peoples Programme (FPP), welcomes the publication of the European Commission’s proposal of a directive on Corporate Sustainability Due Diligence (CSDD). This legislative initiative is a crucial step in the European Union’s effort to tackle environmental and human rights violations affecting indigenous and forest peoples linked to corporate activities.

AstraZeneca welcomes the Commission proposal and intent to ensure a level-playing field. As a global business we are playing our part in tackling the biggest challenges, from climate change to access to healthcare and disease prevention. We take bold action for a sustainable future. AstraZeneca was one of the first companies with net zero targets verified by the SBTi.

AmCham EU supports an EU wide approach to create a level playing field, with the introduction of mandatory human rights and environmental due diligence that is in line with the political and strategic ambition of the Union. The European Commission’s proposal for a Directive on corporate sustainability due diligence aims to foster sustainable and responsible corporate behaviour throughout global value chains.

23 May 2022 Positioning on the Proposal for a Directive of the European Parliament and of the Council on Corporate Sustainability Due Diligence and amending Directive (EU) 2019/1937 Kesko Corporation, being the biggest trading sector operator in Finland and one of the biggest in Northern Europe, appreciates the opportunity to share its view on the Commission’s proposal on Corporate Sustainability Due Diligence…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

MedTech Europe’s response to the Public Consultation on the European Commission’s proposal for a Directive on Corporate Sustainability Due Diligence 23 May 2022 Introduction We welcome the European Commission’s proposal addressing human rights and environmental due diligence in global supply chains.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

In principle, the VDA welcomes the fact that the proposal for a “Directive on Corporate Sustainability Due Diligence" has laid the foundations for a uniform implementation of sustainability requirements in the member states of the EU.

The European Commission has published its proposal for a “Corporate Sustainability Due Diligence and amending Directive” to promote fairer globalisation by ensuring respect for human rights, labour and environmental standards along companies’ global value chains. We recognise the efforts made in this draft to improve upon the European Parliament resolution published in March.

Thank you for the opportunity to comment on this draft Directive. This opinion is based on the comments of the CCIs, companies and the economic policy positions of the DIHK, received by the DIHK up to the date of the opinion. Should the DIHK receive any other relevant comments not yet taken into account in this opinion, this opinion will be supplemented accordingly.

Filed in German · English published by the European Commission

The attached note presents Sherpa’s analysis and recommendations on six key issues: the material scope, the concept of established business relationships, the definition of duty of care, civil liability, administrative control, and the protection of persons who may act on the basis of the duty of care.

Filed in French · English published by the European Commission

Bitkom e.V. welcomes the European Commission’s objective to strengthen human rights through corporate sustainability due diligence and thus contribute to the global economy’s resilience and long-term prospects. Nevertheless, recognising the complexities and limits of statutory measures as well as the capacity for companies to exert influence, is crucial. Please find attached our feedback on the proposal.

Oslo, 23 May 2022 The Norwegian National Contact Point (Norwegian NCP) for the OECD Guidelines for Multinational Enterprises (the OECD Guidelines) appreciates the opportunity to give input to the public consultation regarding the proposal from the European Commission for a Directive on Corporate Sustainability Due Diligence.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

PwC International Ltd (PwC), on behalf of the PwC network, welcomes the European Commission’s proposal for a Directive on Corporate Sustainability Due Diligence (CSDDD) as a much needed step to accelerate the transition towards more sustainable business. Please find attached our feedback on the proposal.

Swedwatch welcoming the Commission’s proposal on corporate sustainability due diligence. However, it is of utter import that the directive provided for appropriate rules for the due diligence process, in line with the UNGPs, since the directive will set, or in best case existing, HREDD standards for companies operating within the EU.

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The Forum Disuguaglianze Diversità (Forum DD) welcomes the Proposal for a Directive of the European Parliament and of the Council on Corporate Sustainability Due Diligence and APPRECIATES in particular: 1. the adoption of binding rules imposing specific duties extended along the entire value chain; 2.

The EU Chocolate, Biscuits and Confectionery Industries are committed to ensuring that their products are manufactured responsibly and to the highest standards, minimising environmental impacts and respecting the human rights of those in their value chains.

Corporate Accountability Lab (“CAL”) is a non-governmental human rights organization based in the United States (“US”). CAL unleashes the creative potential of the law to protect people and the planet from corporate abuse. CAL focuses on human rights and environmental issues that are cross-jurisdictional and are not confined within state or regional boundaries.

_ EUROPEAN CENTER FOR CONSTITUTIONAL AND HUMAN RIGHTS e.V. _ ZOSSENER STR. 55-58 AUFGANG D 10961 BERLIN, GERMANY _ ECCHR Commentary on the EU Corporate Sustainability Due Diligence Directive Proposal The long-awaited proposal by the European Commission for a Corporate Sustainability Due aims to establish an EU-wide Human Rights and environmental due diligence framework.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

NVB feedback CSDD 23 May 2022 Introduction The NVB underlines the importance of corporate social responsibility and, against that background, the introduction of the directive on Corporate Sustainability Due Diligence ("CSDD"). The Dutch financial industry, in accordance with current regulations and soft law, already established practices for due diligence on business relationships and risk management processes.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

You will find attached the feedback from FEBIS, the Federation of Business Information Services, the specialized and recognized industry body of providers of global B2B business intelligence services for managing trade risks.

European Commission’s public consultation on the legislative proposal on Corporate Sustainability Due Diligence The proposal is a milestone in corporate accountability. HREDD framework is a rightsholder centric instrument which should be clear in the directive on Corporate Sustainability Due Diligence (CSDD) while ensuring that all rightsholders’ interests are considered.

Position Paper 1 (5) 23.5.2022 FFE comments on the European Commission’s proposal for a Directive on Corporate Sustainability Due Diligence European Commission published on 23th February proposal for a Directive on Corporate Sustainability Due Diligence.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

23 May 2022 Response on the Proposal for a directive on corporate sustainability due diligence. The European Chamber of Commerce Thailand (EABC) is the leading voice of European business in Thailand. EABC’s main mission is to advocate member interests, to support European business in Thailand, and to promote Thailand as an attractive partner for trade and investment.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

23 May 2022 Response on the Proposal for a directive on corporate sustainability due diligence. The European Chamber of Commerce Thailand (EABC) is the leading voice of European business in Thailand. EABC’s main mission is to advocate member interests, to support European business in Thailand, and to promote Thailand as an attractive partner for trade and investment.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Unipol Group S.p.A. (Unipol Group) has examined the Commission proposal of 23 February 2022 for a directive on Company Sustainability Due Diligence (CSDD) and welcomes the opportunity to provide input for the upcoming discussions between the European institutions.

The International Cocoa Initiative (ICI) welcomes the opportunity to give feedback on the proposed Corporate Sustainability Due Diligence Directive. Our experience over the past decade has allowed us to learn from what is working, where barriers to scale are and under what conditions effective approaches can make a difference.

Dear Sir or Madam: I write on behalf of United Nations University’s Initiative for Finance Against Slavery and Trafficking (FAST). Please find attached FAST’s feedback on the European Commission’s proposed Directive on Corporate Sustainability Due Diligence. FAST welcomes the development of the Directive and we appreciate the opportunity to provide feedback.

I. Preliminary remark In recent years, responsible conduct in line with ethical, ecological and social criteria has become increasingly important when it comes to entrepreneurial activity. The EU would like to assume its international responsibility in this regard. The intention of the European Commission is to protect human and children's rights along global supply chains and to strengthen environmental protection.

Change The Law Limited Submission to the EU on the Corporate Sustainability Due Diligence Directive The EU Commission’s Proposal for a Corporate Sustainability Due Diligence Directive is welcomed. The legislation is a good way to begin to create a level playing field and will help create legal certainty for companies.

The Office of the United Nations High Commissioner for Human Rights (OHCHR) welcomes the opportunity to submit feedback on the proposed directive on Corporate Sustainability Due Diligence. The attached feedback highlights five areas where OHCHR believes further attention and discussion are needed in order to improve alignment with the UN Guiding Principles on Business and Human Rights.

Via submission: Sustainable corporate governance (europa.eu) 23rd May 2022 Dear President von der Leyen, Re: Proposal for a DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on Corporate Sustainability Due Diligence and amending Directive (EU) 2019/1937 and Annex to the Proposal The International Corporate Governance Network (ICGN) appreciates the opportunity to comment on the Proposal for a Directive on…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

B lab Europe is the not for profit that is responsible for the B Corp movement in Europe. It is also the coordinator of The Interdependence Coalition (IC). It represents over 100 Certified B Corporations, systems change and impact driven organisations.

Global Reporting Initiative (GRI) very much welcomes the opportunity to provide our feedback to this crucial initiative, particularly given that the 2021 revision of the GRI Standards ensured that they reflect due diligence expectations for organizations to manage their sustainability impacts, including on human rights, as set forth in intergovernmental instruments by the United Nations and OECD.

Register ID: 8754829960-32 Re: POSITION on the Proposal for a DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on Corporate Sustainability Due Diligence and amending Directive (EU) 2019/1937 Committee on Economic and Monetary Affairs EAPB position, 25.05.2022 The EAPB Secretariat would like to take the opportunity to comment on the Proposal for a Directive of the European Parliament and of the Council on…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

econsense is the German Business Network for Sustainability. Our members are 45 large, internationally operating companies from various sectors committed to sustainable development. They have long engaged with human rights due diligence based on the UN Guiding Principles on Business & Human Rights.

FRUCOM appreciates this opportunity to provide feedback on the Proposal for a Directive of the European Parliament and of the Council on Corporate Sustainability Due Diligence and amending Directive (EU) 2019/1937, published on 23 February 2022.

The Chancery Lane Project (https://chancerylaneproject.org/about/) welcomes the Directive. The Chancery Lane Project has 25 model supply chain clauses and due diligence questions free on its website that relate to climate, biodiversity and environment. See https://chancerylaneproject.org/climate-clauses/.

The signatories in the attached joint letter - all active in the garment and textile industry - support the commitment of the European Commission to implement a regulatory approach to due diligence, in order to ensure companies are taking their responsibility to respect human rights and the environment throughout their value chains.

Sonae is a multinational company managing a diversified portfolio of businesses in retail, financial services, technology, real estate and telecommunications. We welcome the opportunity to share feedback about the Corporate Sustainability Due Diligence Directive. Please find our feedback in the attached document.

GegenStroemung – CounterCurrent is an initiative in Germany which is hosted by the non-profit Institute for Ecology and Action Anthropology (INFOE). GegenStroemung is member of the ECA Watch network which advocates for strong human rights and environmental standards of export credit agencies. We very much welcome the proposal of the CSDDD.

For the National Federation of Public Works (FNTP), provision should be made for the possibility of centralising vigilance policies at group level rather than entity by entity. Indeed, the current approach is at odds with the organisation of most international groups that have policies and procedures that apply to all their subsidiaries worldwide.

Filed in French · English published by the European Commission

Corporate Sustainability Due Diligence Public consultation 23.05.2022 Founded in 1973, the Fédération de la Haute Couture et de la Mode (“the Federation”) represents over a hundred French and international brands and is the voice of the creative and luxury fashion industry.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

BlackRock is pleased to have the opportunity to respond to the Proposal for a Directive on Corporate Sustainability Due Diligence. As an asset manager, we would like to share some observations in the attached comment letter from the perspective of investing in companies on behalf of institutional and individual asset owners with long-term investment horizons.

TCS believes that the CSDD will be a major opportunity for companies trading in the EU region to set a global norm for securing ESG targets and unleash improved sustainability value for actors in the value chain.

E3G welcomes the Commission’s proposal for the Corporate Sustainability Due Diligence Directive (CSDDD) as an important step to incorporate sustainability considerations in corporate due diligence practices and directors’ accountability to stakeholders.

For the BGA human rights are non-negotiable and must be respected everywhere and at all times. Apart from human rights the protection of our environment and climate is also a top priority for us. Nevertheless, we believe that the proposal for the Corporate Sustainability Due Diligence Directive is too far-reaching in several aspects and threatens to massively overburden European companies.

As a business association whose mission is to support its members with improving the social and environmental performance of their supply chains through common tools and collaborative approaches, amfori has been a long-standing advocate of the benefits of well-designed EU-wide due diligence legislation.

The China Chamber of Commerce to the EU (CCCEU) is a business organisation that gathers Chinese-invested corporations in Europe. As such, the CCCEU speaks on behalf of about 1,000 Chinese enterprises in the EU. Its mission is to promote China-EU economic cooperation, to increase the mutual understanding and dialogue between China and the EU, and to bridge the existing gaps and explore ways to enhance collaboration…

May 2022 LO, TCO and Saco's initial comments on the European Commission's proposal for a new directive on Corporate Sustainability Due Diligence (CSDD), COM (2022) 71. General comments    LO, TCO and Saco welcome the European Commission's proposal for a new Corporate Sustainability Due Diligence directive (CSDD), COM (2022) 71.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The European Recycling Industries’ Confederation (EuRIC) represents the recycling industry at a European level. Gathering the vast majority of national recycling federations from EU/EEA Member States, the Confederation represents about 5.500+ recycling companies – from market leaders to SMEs – generating an aggregated annual turnover of about 95 billion € by treating various waste streams such as household or…

BASF is committed to respect internationally recognized human rights and protect the environment in its own operations. We embrace the responsibility to foster respect for human rights and environment in relationships with our business partners along the value chain. We are open to participate in the discussions on that topic.

Edison’s response to the public consultation on the European Commission’s proposal for a Corporate Sustainability Due Diligence and amending Directive (EU) 2019/1937 Edison recognizes the need to tackle the issue of due diligence to strengthen sustainable corporate practices. Our company is already deeply committed to sustainability and strives to guarantee the highest standards.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Sustaiable Corporate Governance 23 May 2022 Reply on the EU Commission’s proposed directive on Corporate Sustainability Due Diligence from the Danish Agriculture and Food Council The Danish Agriculture and Food Council (DAFC) welcomes the Commission’s initiative to improve the regulatory framework for EU companies to manage sustainability matters in regards of human rights and climate change.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The DAV is fighting for the rule of law, democracy and human rights. The DAV therefore takes the view that the Member States of the European Union and their businesses are fighting for the rule of law, democracy and human rights in view of the great international interdependence of their economies and their extensive involvement in global procurement and abaThe DAV.

Filed in German · English published by the European Commission

This document is sent electronically Your ref. Our ref. Case nr: 22/3097 Executive Officer: Nadia Ullah Dir.tlf: 457 29 435 Date: 23.05.2022 The Norwegian Consumer Authority's response to the European Commission's proposal for a Directive on corporate sustainability due diligence and amendments to directive (EU) 2019/19371 1 INTRODUCTION The Norwegian Consumer Authority refers to the consultation from the Commission…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

FSB supports the European Commission’s objectives of achieving economic, social and environmental sustainability in corporate governance. However small businesses, many of which do not have shareholders or boards of directors, must not be overburdened with regulatory requirements.

Global Witness believes that the SCDDD presents an unprecedented opportunity to help protect people and the environment. The Directive could be the first regional framework compelling companies to act sustainably, and to sanction and hold them liable in court if they fail to do so.

The State Fair Trade Coordinator appreciated the opportunity to give feedback to the European Commission’s proposal on the Corporate Due Diligence Directive on Sustainability. We recognise that the Commission’s proposal is a turning point in the fight to end corporate impunity, but we consider that it suffers from significant shortcomings and exceptions that can undermine its purpose: Scope of application: The…

Filed in Spanish · English published by the European Commission

ShareAction welcomes the opportunity to comment on the proposal for a Directive on Corporate Sustainability Due Diligence. The newly proposed rules on due diligence and directors’ duties contribute to setting a new standard to lead companies in the EU on a path to climate neutrality and sustainable development. Unfortunately, important provisions in the proposal have been watered down.

BMW Group already started in 2010 by implementing due diligence activities with focus on human rights, environmental and social sustainability standards in the supply chain. By setting up a cross-sectoral harmonized sustainability questionnaire in close cooperation with the Drive Sustainability Initiative in 2014 BMW Group took an important step for conducting risk management in its supply chain.

The Federation of the Dutch Pension Funds welcomes the initiative to introduce due diligence obligations in order to strengthen human rights and environmental objectives. The OECD Guidelines and UN Guiding Principles should serve as the basis for this initiative and the Corporate Sustainability Due Diligence Directive (CSDDD) should be drafted in consistency with these international standards.

SolarPower Europe welcomes the European Commission's efforts to make supply chains more sustainable. We believe that ensuring respect for human rights and the environment and advancing the clean energy transition go hand in hand.

Reprisals against human rights defenders, related to business, are sadly very common. In 2021, Front Line Defenders recorded the killings of 358 human rights defenders, and the Business and human rights resource centre recorded over 600 attacks against human rights defenders working on business-related human rights issues – ranging from judicial harassment to death threats and violent attacks.

CFA Institute feedback on the European Commission proposal for a Directive on Corporate Sustainability Due Diligence CFA Institute welcomes the opportunity to provide its views on the European Commission proposal for a Directive on Corporate Sustainability Due Diligence.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

DIGITALEUROPE welcomes the opportunity to comment on the Commission Proposal, is supportive of a common approach and level playing field at EU level on mandatory human rights and environmental due diligence. Companies within the digital technology sector recognise their significant responsibility regarding sustainable corporate behaviour, and thus welcome the European Commission’s efforts to foster a resilient…

Response to the EU Commission's draft Directive on corporate sustainability due diligence UN Special Rapporteur on the situation of human rights defenders - May 2022 The nexus between corporate activity and human rights defenders has been a priority area for me since I took up the mandate of Special Rapporteur in May 2020.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Minderoo Foundation’s No Plastic Waste Initiative seeks to increase transparency across global supply chains, in particular for single-use plastics (SUP), a key driver of global plastic pollution. Today, we have limited visibility on plastic material flows, from production to end-of-life. The lack of data makes it difficult to evaluate industry’s progress to their circularity and zero pollution targets.

CFA Institute feedback on the European Commission proposal for a Directive on Corporate Sustainability Due Diligence CFA Institute welcomes the opportunity to provide its views on the European Commission proposal for a Directive on Corporate Sustainability Due Diligence.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Addressing the substantial sustainability challenges in the areas of climate change, pollution, loss of biodiversity but also social sustainability and human rights, whilst facing energy and supply insecurities, will be a challenging task for all the organisations present in global supply chains in the next years and decades to come.

The Policy Hub welcomes the European Commission’s (EC) Proposal on the Corporate Sustainability Due Diligence Directive (CSDD). We recognize the importance for companies to take responsibility to respect human rights and protect the environment. Thus, having a harmonized legislative framework on due diligence (DD) is critical.

The ONGD Coordinator appreciated the opportunity to participate in the consultation on the Corporate Due Diligence Directive on Sustainability. We recognise that the Commission’s proposal is a turning point in the fight against corporate impunity, but we consider that it suffers from significant shortcomings: Scope of application: The proposal legitimately targets both EU and non-EU companies operating in the EU…

Filed in Spanish · English published by the European Commission

The World Benchmarking Alliance (WBA) is an international non-profit organisation that publishes free and publicly available benchmarks on how the world’s most influential companies contribute to tackling the biggest sustainability challenges of our time, in line with the Sustainable Development Goals.

23 May 2022 Ref. Ares(2022)3882171 - 23/05/2022 Ensuring the Contribution of the Corporate Sustainability Due Diligence Directive to Sustainable Investments in Low- and Middle-Income Countries EDFI’s Comments on the Corporate Sustainability Due Diligence (CSDD) Proposal Promoting Corporate Sustainability As long-standing impact investors and ESG pioneers, European Development Finance Institutions (DFIs) very much…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Position of ESFAM AISBL on CSSD DIRECTIVE ESFAM is an international non-profit association whose members are leading European manufacturers of hunting and sport shooting weapons. The association, which is governed by the Belgian law of June 27, 1921, was created in 2009. Its main mission is to represent its members towards the European and international authorities. https://www.esfam.eu/

German textile & fashion industry companies, most of them SMEs, are committed to fair soc. & env. standards along supply chains, undertaking major efforts to expand knowledge & control. Their economic commitment & know-how transfer contribute much to sustainable growth & jobs in developing & emerging countries.

International Federation of the Economy for the Common Good Internationaler Verband der Gemeinwohl-Ökonomie e.V. [address removed] https://www.ecogood.org/ Transparency Register: 339093641078-19 Position paper on the Corporate Sustainability Due Diligence Directive May 2022 The Economy for the Common Good (ECG) is a social movement advocating for a future-fit economic model which is beneficial to all stakeholders of…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The EACB supports the EC objectives: respect for human rights and the environment in line with the UN Agenda 2030 for Sustainable Development and the Paris Agreement on Climate Change. It is important to harmonize corporate sustainability due diligence at the EU level to ensure a level playing field and the spread of EU values. Including non-EU companies in the scope is vital.

The Trade Union for the Public and Welfare Sectors JHL is the largest trade union for the welfare sector in Finland. JHL has about 165 000 members, and it unites the professionals working in municipalities, for the Finnish state and in private welfare services. JHL welcomes the Commission proposal for a directive that sets for the first time an EU framework on Corporate Sustainability Due Diligence.

Access to land and water is essential for people. Over the last two decades, more and more people around the world have accessed withdrawn from these resources. For example, agricultural commodities, such as soya and palm oil, are increasingly being cultivated. large quantities of water, the appropriation of which is often in conflict with the rights of the local population.

Filed in German · English published by the European Commission

PensionsEurope welcomes the opportunity to comment on the proposal of the European Commission for a Corporate Sustainability Due Diligence Directive. PensionsEurope supports the objectives of the OECD Guidelines on Responsible Business Conduct, to which a large number of pension funds have already voluntarily committed.

PRIORITIES AND COMMENTS TO THE CORPORATE SUSTAINABILITY DUE DILIGENCE PROPOSAL ArcelorMittal supports the EU Green Deal and the Sustainable Finance agenda. In this context, Arcelormittal has reviewed the Corporate Sustainability Due Diligence Proposal released by the European Commission and wishes to give its contribution to the public consultation.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Legal Affairs and Administration Hannu Ylänen 23.5.2022 1 (4) Proposal for a DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on Corporate Sustainability Due Diligence and amending Directive (EU) 2019/1937 – Comments by the Confederation of Finnish Industries EK General remarks Confederation of Finnish Industries considers the protection and development of human and environmental rights being of utmost…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Consultation response to the proposal for a new Directive on Corporate Sustainability Due Diligence UN Working Group on the issue of human rights and transnational corporations and other business enterprises 23 May 2022 1 The UN Working Group on Business and Human Rights is glad to see that the European Commission’s proposal for a new Directive on Corporate Sustainability Due Diligence has been published and looks…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The European Copper Institute (ECI) welcomes the Commission’s ambition to set up rules for sustainable corporate due diligence (CSDD). ECI always supports policies and schemes that ensure responsible copper mining and production and contribute to establishing a level playing field across all relevant global supply chains and regions.

Dear Sir or Madam, The French Banking Federation supports the objectives of the European Commission’s proposal on the due diligence to enhance respect for human rights and environmental protection, create a level playing field and avoid fragmentation amongst Member States and non-EU companies in Europe.

The German Association of Energy and Water Industries (BDEW) represents over 1,900 companies along the entire value chain of electricity and heat production and transmission, as well as drinking water extraction and wastewater disposal. We and our members are committed to enabling the successful implementation of the European Green Deal and the achievement of the EU climate targets for 2030 and 2050.

Filed in German · English published by the European Commission

Stellungnahme Europäische Sorgfaltspflichten in Sachen Nachhaltigkeit müssen verhältnismäßig sein! 1. Ausgangssituation Der Vorschlag der EU-Kommission für eine EU-Richtlinie zu nachhaltigkeitsbezogenen Sorgfaltspflichten für Unternehmen (Corporate Sustainability Due Diligence Directive, CSDDD) trifft die Familienunternehmen in einer Zeit, die geprägt ist durch eine Fülle von gewichtigen und teilweise existenziellen…

Filed in German · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Responsible supply and value chains and sustainability are important issues for the German confectionery industry. German producers of confectionery, branded ice-cream and snacks are active in this regard both nationally and internationally, and thus contribute to higher social and environmental standards, better education and thus growth and prosperity abroad. Enjoyment and responsibility are not excluded.

Filed in German · English published by the European Commission

The Commission’s proposed draft directive aims to ensure compliance with human rights and environmental and climate-related obligations throughout the value chain. The aim is to have uniform EU-wide rules, which the DRV generally welcomes in the interests of fair competition and the creation of a level playing fields.

Filed in German · English published by the European Commission

Brussels, 23 May 2022 Feedback Ref. Ares(2022)3881017 - 23/05/2022 Eurochambres feedback on the Proposal for a Corporate Sustainability Due Diligence Directive Eurochambres believes that sustainability is at the heart of businesses activities and is key to ensuring long-term economic growth.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

WVMetalle welcomes the intention of the proposal and its contribution to fulfilling our shared goal of ensuring the ethically and responsible sourcing of metals needed for Europe´s twin transition while considering the social and environmental risks in certain areas of global metals and minerals supply.

The Corporate Sustainability Due Diligence Directive (CSDDD) is an important cornerstone of the EU regulatory framework on company law and corporate governance. CDP Europe welcomes the Commission’s initiative to establish a coherent framework of due diligence rules to make companies accountable for human rights and environmental harm as well as require them to develop plans to mitigate these risks and impacts.

Eramet, a European mining and metallurgical group, is a key player in the extraction and refining of base metals necessary for the overall growth of our economy (manganese, titanium mineral sands) and those critical for the transition to a climate neutral economy (nickel, lithium, cobalt).

CPME takes note of the European Commission’s desire to encourage companies to take better account of the interests of their stakeholders (employees, suppliers, customers, etc.) and to be aware of the negative impacts of their activities on human and social rights, the environment and climate change in corporate decision-making.

Filed in French · English published by the European Commission

Dear Sir or Madam, please find enclosed the comments from bvse e.V. (Bundesverband Sekundärrohstoffe und Entsorgung e.V.), BDSV (DER steel scrap association) and VDM (Verband Deutscher Metallhändler e.V.) Yours sincerely, [name removed] Lawyer bvse e.V. Franconian road 2 53229 Bonn

Filed in German · English published by the European Commission

The Federation of German Industries (BDI) is the leading organization of German industries and related service providers. She represents 40 inter-trade organizations and more than 100.000 companies with their approximately 8 million employees.

23 May 2022 Input of the SER on the Commission’s Proposal for a Directive on corporate sustainability due diligence The Social and Economic Council of the Netherlands (SER) has followed the development of the Commission’s proposal with great interest. In October 2021 the SER published its advisory report ‘Effective European Due Diligence legislation for Sustainable Supply Chains’.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

ANIA, the Italian Insurance Association, fully support the aim of promoting sustainable governance which represents a key issue for the sustainable transformation of the European economy. Interventions should however focus on limited principles set in hard law (with a principle-based approach) to be combined with an extensive soft law regime, thus allowing each company to exploit its sustainable potential in the…

IOGP Position on the Corporate Sustainability Due Diligence Directive (CSDDD) IOGP, the International Association of Oil and Gas Producers whose member companies account for approximately 90% of oil and gas produced in Europe, supports the goals of the Paris Agreement and the EU’s ambition to reach climate neutrality by 2050.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

QJ(22)1960:3 – JE/na Copa and Cogeca feedback to Commission consultation on the proposed Corporate Sustainability Due Diligence directive (2022/0051(COD)) In response to the current legislative proposal on Corporate Sustainability Due Diligence we would like to reiterate our general position that due diligence needs to be reasonable, inherent-risk based and proportionate.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

I. Basic approach of business - Problems related to ESG occurring in supply chains need to be addressed. Building on the experience with the UN Guiding Principles and the OECD MNE Guidelines, an additional substantial step forward in the field of due diligence should be taken.

The Confederation of Swedish Enterprise is the main business association in Sweden representing 60,000 companies and 50 national industry and employer organisations. Please find our feedback to the proposal in the enclosed document. We would be happy to furnish more detailed information on the points raised, if this would be of interest.

SOK (S Group) welcomes the European Commission’s aim to introduce sustainability due diligence legislation – nevertheless proposal still includes problems to be solved SOK welcomes EU-level sustainability due diligence legislation that would create level playing field and foster environmental and human rights due diligence.

The German industry association SPECTARIS is thankful for the opportunity to provide feedback and generally welcomes the initiative by the EU Commission to tackle and address human rights and environmental due diligence within supply chains and the effort to create a harmonized regulatory approach.

The German Institute for Human Rights (GIHR) welcomes the European Commission‘s proposal on Corporate Sustainability Due Diligence (EU CSDD). Europe-wide regulation will help to improve respect for human rights along supply chains.

IOM welcomes this initiative and is pleased to have the opportunity to provide feedback on the proposed Directive in the form of an attached paper. This paper outlines IOM’s recommendations to strengthen corporate sustainability due diligence mechanisms and supply chain protections.

Please see the attached file for full feedback from the Saami Council. Re. explanatory memorandum Saami Council welcomes the EU Commission's proposal for a directive on Corporate Sustainability Due Diligence as it combines human rights, including rights of Indigenous Peoples, and the environment. This approach is in alignment with the holistic worldview of the Sámi people.

European Semiconductor Industry Association ESIA Position Paper on the CS3D Input to the Commission Proposal for a Directive on Corporate Sustainability Due Diligence Brussels, 23 May 2022 ESIA represents the European semiconductor sector which is operating and competing in Europe and globally.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The European Cocoa Association would like to thank the European Commission for being able to provide its feedback on the proposed Directive on Corporate Sustainability Due Diligence and would like to refer to the European Cocoa Association position paper that is attached.

The Social & Labor Convergence Program (SLCP) welcomes the European Union’s proposed Corporate Sustainability Due Diligence Directive (CSDD). The proposal mandates that companies are responsible for respecting human rights in their supply chain. This is a significant step in addressing the root causes of adverse human rights impacts globally.

Civil liability and access to justice: The proposal includes a fault-based liability regime allowing people affected by corporate abuse to obtain judicial remedy. But major barriers to justice still remain as tort law in Member States puts the burden of proof on the claimants. Victims will need to provide evidence of the company’s breach of its duties which normally requires access to internal company information.

May 23rd, 2022 To the attention of the European Commission, We welcome the opportunity to make recommendations on increasing the effectiveness of the initial Corporate Sustainability Due Diligence Directive’s draft, drawing on EcoVadis’ 15 years of real life experience supporting our customers in their due diligence strategies.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

NomoGaia Comments on EU Directive on Corporate Sustainability Due Diligence Nomogaia submits the following comments on the Proposal for a Directive of the European Parliament and the Council on Corporate Sustainability Due Diligence and amending Directive (EU) 2019/1937, dated 23 February 2022 (the “Draft Directive”). Nomogaia is a non-profit research organization devoted to business and human rights.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The Norwegian National Human Rights Institution (NIM) welcomes and supports the draft Directive. NIM does submit a comprehensive analysis of the entire draft proposal, but we will make some observations and recommendations on the provisions pertaining to human rights and environmental impacts, especially Article 2, 3 (b) and (c) and 15.

From the FAIRTRADE point of view, the proposal is an Important milestone in corporate accountability. At its core, the HREDD framework is a rightsholder centric instrument and this should be clearer in the final directive. Within that it must be ensured that all rightsholders’ interests are considered.

Ericsson welcomes the EU Commission’s proposal as a crucial step in ensuring a level playing field and harmonization. The Directive however needs to be more firmly grounded in the key existing international standards on sustainability due diligence adopted by the UN and the OECD.

AIM high-level preliminary comments on CSDD proposal: AIM – the European Brands Association – is supportive of an EU harmonised legislative framework for human rights and environmental due diligence. We welcome the fact that the European Commission finally released its proposal for a Directive on Corporate Sustainability Due Diligence in late February 2022 but have a number of concerns on key aspects of the…

EU Corporate Sustainability Due Diligence Directive A balanced and proportionate EU law is needed Position paper on the Proposal for a Directive on Corporate Sustainability Due Diligence, 23 May 2022 EU CORPORATE SUSTAINABILITY DUE DILIGENCE DIRECTIVE Table of Contents Table of Contents .......................................................................................................

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Consultation response to the Commission’s proposal on Corporate Sustainability Due Diligence and amending Directive (EU) 2019/1937 The Danish Association of Managers and Executives (DAME) welcomes the Commission’s intentions to encourage companies to make corporate decisions that fosters sustainable development. DAME thanks the Commission for omitting several of the previous ideas of the assessment analysis by EY.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

As the voice of cooperatives enterprises in Europe, Cooperatives Europe welcomes this proposal, which aims at promoting a more democratic and sustainable business model in Europe. This proposal is aligned with our objective of putting people before profit and with cooperatives’ core values of human dignity, collective ownership and democratic governance.

Finance Finland welcomes the Commission’s proposal on Corporate Sustainability Due Diligence Directive that sets a concrete legal obligation for companies to respect human rights and to protect the environment. We support the objectives of the proposal to advance respect for human rights and environmental protection, as well as to create a level playing field and to avoid fragmentation amongst Member States.

JBCE welcomes the opportunity to share our position on the Corporate Sustainability Due Diligence Directive, following the proposal published by the European Commission on 23 February, 2022. JBCE support the Commission’s ambition to enhance due diligence in corporate management processes and hence prevent adverse impacts related to environmental and human rights factors.

Feedback on the proposal Scope: - The scope of the proposal captures different sectors and entities. While it is clear that a common set of rules should apply to the commercial sector, it should be kept in mind that for financial institutions and in particular asset managers (AMs) the supply - and investor chain are not on equal terms. Reg.

The proposed EU Corporate Sustainability Due Diligence Directive: more clarity needed to avoid excessive legal disputes ecoDa - Position Paper May 2022 ecoDa - Contribution to the stakeholders' consultation PAGE 2 Introductory remarks ecoDa welcomes the European leadership in promoting sustainable supply chains in Europe and beyond.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

STATEMENT Ref. Ares(2022)3876204 - 23/05/2022 FoodDrinkEurope views on the European Commission Proposal for a Directive on Corporate Sustainability Due Diligence Today, we are faced with growing global challenges such as climate change, environmental degradation, biodiversity loss and malnutrition.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Avocats Sans Frontières (ASF) is an NGO whose mission is to contribute to the establishment of independent and impartial access to justice and to guarantee the protection of Human rights. The EC’s CSDD proposal is an important step toward meaningful legislative actions to address the threat of corporate activities to human rights and the environment, ensuring sustainable growth.

The CSDDD proposal paves the way for a more crisis-resilient global business. - Companies report that due diligence leads to better risk management, better business relationships and stable supply chains and ultimately to better performance and resilience to crises.

As International Justice Mission Germany (IJM) e.V., we welcome the European Commission’s draft Directive on Corporate Due Diligence for Sustainability (CSDDD). We believe that this is an important step towards corporate accountability, responsible business and access to justice. These three measures are essential to protect not only the climate but also people.

Filed in German · English published by the European Commission

To: Mrs. Salla SAASTAMOINEN DG Justice (Salla SAASTAMOINEN, Director, Just A) Mrs. Outi SLOTBOOM DG Growth (Outi SLOTBOOM, Director, Grow A). The 23th of May 2022 Subject: EC Due Diligence proposal: more clarity needed to avoid excessive legal disputes Dear Mrs. Saastamoinen & Mrs.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

With reference to the accessibility to submit feedback in relation to the European Commission’s proposal for a new Directive on Corporate Sustainability Due Diligence (the “Proposal”), the Swedish Corporate Governance Board (the “Board”) would like to submit the comments. The Board advises against the inclusion of Articles 15, 25 and 26 in the Proposal, i.e. against all proposed corporate governance rules.

Filed in Swedish · English published by the European Commission

As the SÜDWIND Institute for Economics and Ecumens, we have been working for over 30 years on issues of fair global economy, in particular labour rights and social standards in global value chains and social sustainability in the financial sector. We very much welcome the Commission’s proposal for a directive on sustainable corporate due diligence.

Filed in German · English published by the European Commission

Intesa Sanpaolo is aware of the responsibilities that are connected from its position and of having a significant impact on the social and environmental space in which it carries out its business. Thus, it has chosen not to seek only profits, but also to create long-term value for the Bank, its employees, customers, community and the environment.

POSITION PAPER Comments on Sustainable corporate governance directive Answer to the public consultation - 23/05/2022 GENERAL COMMENTS EDF is fully aware of the importance of acting in favour of the environment and people and has long been committed to integrating human rights and environmental issues into its governance and in the frame of the implementation of its activities.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

MVO Nederland (CSR Netherlands) represents about 2000 affiliated frontrunning companies, particularly in agrifood, chemicals, textile, leather, tourism and coffee sectors in the Netherlands. All of them share the joint ambition: realisation of a New, Circular, Inclusive Economy in 2025, including fair and transparent international supply chains.

The United Nations welcomes the opportunity to give feedback to the European Commission’s proposal on the Corporate Due Diligence Directive on Sustainability. We recognise that the Commission’s proposal is a turning point in the fight to end corporate impunity, but we consider that it suffers from significant shortcomings and exceptions that can undermine its purpose: Scope of application: The proposal legitimately…

Filed in Spanish · English published by the European Commission

France Assureurs welcomes the proposal for a Directive on Corporate Sustainability Due Diligence aiming to prevent human rights & environmental abuses throughout the value chain. The proposal comes as a natural next step in the development of a sound legal framework which will help in delivering the goals of the Green Deal which we fully support as an industry.

23 May 2022 1/5 POSITION PAPER Corporate Sustainability Due Diligence Requires Cooperation, not Litigation Since many years, Directors’ Institute Finland (DIF) promotes sustainability and today, approximately one third of our events and materials are related to sustainability. Even our annual seminar this spring focused on sustainability in supply chains.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Pro Ethical Trade Finland is a non-profit organisation that promotes trade justice, sustainable value chains and ethical consumption. Pro Ethical Trade Finland welcomes the proposal for the Corporate Sustainability Due Diligence Directive.

The Fédération de la Maille, de la Lingerie et du Bach wishes to alert the European Commission to various points relating to the implementation of this proposal for a directive for textile companies. In addition, the lingerie and beach mesh Federation expresses its support for the positions adopted by EURATEX.

Filed in French · English published by the European Commission

TRAFFIC International Global Office [name removed] Pembroke Street, Cambridge CB2 3QZ, UK [phone removed] [email removed] traffic.org TRAFFIC Public Statement on the EU Corporate Sustainability Due Diligence On 23 February 2022, the European Union (EU) demonstrated its commitment to implementing its Green Deal by publishing a proposal for a Directive on Corporate Sustainability Due Diligence.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

OACPS response to EU consultation on the Directive on Corporate Sustainability Due Diligence This Submission is made on behalf of the Members of the Organisation of African, Caribbean and Pacific States. The Organisation is composed of 79 Member States, Africa(48), Pacific(15) and Caribbean(16) regions.

Kolping INTERNATIONAL is a Catholic social association with 400 000 members in 60 countries. As Kolping INTERNATIONAL, we welcome the European Commission’s draft Directive on Corporate Due Diligence for Sustainability (CSDDD). We believe this is an important and long-awaited step towards corporate accountability, responsible business and access to justice.

Filed in German · English published by the European Commission

Südwind would like to express its gratitude for providing us with the proposed directive and inviting our feedback. We support the statement of the European Coalition for Corporate Justice (ECCJ), its Austrian member Netzwerk Soziale Verantwortung (NeSoVe) as well as the Clean Clothes Campaign (CCC) contribution and further take the following position: Südwind - together with trade unions, the Austrian Chamber of…

Pellervo Coop Center supports the EU-level sustainable corporate governance regulation, and we consider it to be very important and sensible for the EU to lead the way in this matter. However, the draft directive is a wide-ranging and in some places difficult-to-understand entity, creating a partially new type of legislation.

The Bundesverband der Arzneimittel-Manufacturers e.V. (BAH) is the largest trade association in the pharmaceutical industry in Germany. He represents the interests of some 400 member companies, which employ around 80 000 employees in Germany. The BAH’s tasks cover both prescription-only and non-prescription medicines, as well as material medical devices and digital health applications.

Filed in German · English published by the European Commission

MAY 2022 Proposal for a Directive on Corporate Sustainability Due Diligence (CSDD) Eurometaux’s feedback to the Commission’s public consultation Eurometaux believes the European Commission’s proposal for a Directive on Corporate Sustainability Due Diligence (CSDD), adopted on 23 February 2022, is an important milestone to strengthen sustainable and responsible sourcing of minerals and metals throughout global value…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

DEAR Sir or Madam, Regarding the achievement of the 17 Sustainable Development Goals of the United Nations, the JARO Institute for Sustainability and Digitalisation explicitly supports the present proposal for a Directive on corporate sustainability due diligence along international value chains.

Filed in German · English published by the European Commission

The Bucharest Chamber of Commerce and Industry (CCIB) welcomes the legislative proposal on Corporate Sustainability Due Diligence and considers it a step further for the EU legal and business environment. We have read the proposal with interest and it could have been observed that is very inclusive in terms of connecting sustainability with other pieces of legislation like non-financial reporting, sustainable…

IPC feedback to the proposal for a Corporate Sustainability Due Diligence Directive IPC is the global association for electronics manufacturing including printed circuit board (PCB) designers, assembly companies (EMS), suppliers and final equipment manufacturers (OEMs). Our membership includes over 3,000 companies of which more than 500 are located in Europe and includes both large companies and a majority of SMEs.

Proposal for a Directive of the European Parliament and of the Council on Corporate Sustainability Due Diligence and amending Directive (EU) 2019/1937 – Comments by Technology Industries of Finland The Finnish Technology Industries organization promotes competitiveness and operational preconditions for technology industry companies, the largest and most important export sector in Finland.

Summary: Based on its international trade union work with multinational companies, Unionen believes that initiatives that facilitate for people in value chains to gain real access to influence in order to ensure and promote human and trade union rights are needed.

MVO position (May 2022) Response to the European Commission’s proposal dated 23 February 2022 for a Directive on Corporate Sustainability Due Diligence. The Dutch and international oils and fats sector is fully aware of the role sustainable supply chains have to play.

Tackling corporate human rights issues across the entire value chain through a risk-based approach. The approach included in the directive proposal relies on the term ‘established business relationships’, this is a complex matter as the effective identification of supply chain connections is considered a systemic issue, in particular for those businesses with strong links to less visible or informal relationships.

CLEPA welcomes the initiative for an EU wide sustainability due diligence framework. Unfortunately, without revisions, the proposal would undermine legal certainty and fragment the single market. Companies should be provided with more means and legal assurances to effectively fulfill due diligence requirements.

The General Commission for Justice and Peace welcomes the consultation of the European Commission’s proposal on the Corporate Due Diligence Directive on Sustainability and the Directive itself, although we believe that it should be improved in order to have a more real impact on the protection of human rights and the environment: Scope of the companies The indicators used by the draft legislation are the size of the…

Filed in Spanish · English published by the European Commission

Implementation of a coordinated EU framework on sustainability: The CSDD is a key part of the EU framework on sustainability, which is composed, inter alia, of CSRD, ESRS, EU Taxonomy and SFDR. Assirevi believes, however, that the CSDD could be better coordinated with such framework, in particular with reference to its scope, terminology and definitions.

Legislative proposal for a Directive on corporate sustainability due diligence The European Public Real Estate Association (EPRA) is the voice of Europe's listed real estate companies that derive income from the ownership, trading and development of income producing real estate assets.

EUROBAT welcomes the European Commission’s proposal for a Corporate Sustainable Due ‎Diligence Directive and confirms its full support for the harmonisation of human rights and ‎environmental due diligence obligations in the EU and abroad. In this sense, we are committed to ‎implementing the most sustainable pathway in order to achieve a climate-neutral European Union ‎by 2050.

Sustainable businesses demand mandatory due diligence on human rights and environment for all companies Ecopreneur.eu - the European Sustainable Business Federation - and its seven member organisations urge the EU to strengthen the recent European Commission’s proposals for sustainable corporate governance and mandatory human rights and environmental due diligence, which do not go far enough, and adopt them without…

EXTRACT: On behalf of CEI-Bois, EFIC, EOS, ETTF and EPF. The European woodworking and furniture industries, representing manufacturing enterprises and traders across the EU, values the attempt to create an EU framework on corporate sustainability due diligence.

The EU directive can mean a lot for people, the environment and business worldwide. But due to fundamental shortings of the draft directive, the positive impact on people and the environment in global chains will be at least or as non-existent.

Filed in Dutch · English published by the European Commission

We would like to thank the European Commission for the opportunity to provide feedback on the draft directive on Corporate Sustainability Due Diligence. In principle, we welcome the fact that the EU Commission is creating a common basis for national legislation in the EU with the proposed directive.

BankTrack welcomes the European Commission’s legislative proposal for a Directive on Corporate Sustainability Due Diligence. With the right framing, the Directive has the potential to advance better outcomes for people and planet.

ESBG Position Paper on the Proposal for a Directive of the European Parliament and of the Council on Corporate Sustainability Due Diligence and amending Directive (EU) 2019/1937 ESBG (European Savings and Retail Banking Group) Rue Marie-Thérèse, 11 - B-1000 Brussels ESBG Transparency Register ID 8765978796-80 May 2021 General comments We believe that the Corporate Sustainability Due Diligence Directive (CSDDD) is…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The consultation process with our member organisations is still going on. We will finalise our position paper in the coming days. However we can already provide the following preliminary remarks. In general the Due Diligence Directive leaves too much freedom to the Member States to legislate further, so it won’t be possible to create a level playing field and a harmonised due diligence framework within the Internal…

DI welcomes the objective of strengthening corporate sustainability due diligence and create a level playing field but sees several areas where the proposal needs adjustments to make it workable and proportionate. The role of states and companies should not be mixed up as companies do not have the mandate nor the ability to solve all problems arising from weakly governed states globally.

The International Fur Federation welcomes the proposal for a directive on Corporate Sustainability Due Diligence with a view to establishing a transparent, reliable, and fair business environment for all value chain actors. Coherence and legal certainty Concerning the application of the directive, Article 2 includes a number of sectors falling under its scope.

Service Union United PAM is one of the main trade unions in Finland. PAM has about 200,000 members working in private sectors such as retail trade, property services, security services as well as tourism, restaurant and leisure services. Service Union United PAM welcomes the commission proposal for directive that sets for the first time an EU framework on Corporate Sustainability Due Diligence.

FESI welcomes the CSDDD proposal published by the European Commission. Based on learnings from decades of implementing human rights and environmental due diligence processes in members’ supply chains and a comprehensive review, FESI calls for the following amendments: 1.

We are pleased that the European Commission has included some new and important elements of business and human rights within the CSDDD, including on supervisory mechanisms, directors’ duties and climate change. However, we consider that there are certain aspects of the draft which require revision in relation to these areas.

ARCORES España thanked for the opportunity to give feedback to the European Commission’s proposal on the Corporate Due Diligence Directive on Sustainability. We recognise that the Commission’s proposal is a turning point in the fight to end corporate impunity, but we consider that it suffers from significant shortcomings and exceptions that can undermine its purpose: Scope of application: The proposal legitimately…

Filed in Spanish · English published by the European Commission

As a Saar Alliance on the Supply Chain Act initiative, we welcome the European Commission’s draft Directive on Corporate Due Diligence for Sustainability (CSDDD). We believe this is an important and long-awaited step towards corporate accountability, responsible business and access to justice.

Filed in German · English published by the European Commission

Enlázate por la Justicia (spanish group comprising Cáritas Española, CEDIS, CONFER, J&P, Manos Unidas and REDES) welcomes the opportunity to provide feedback on the European Commission's proposal for a Corporate Sustainability Due Diligence Directive.

The Foundation is grateful for the opportunity to give feedback to the European Commission’s proposal on the Corporate Due Diligence Directive on Sustainability. We recognise that the Commission’s proposal is a turning point in the fight to end corporate impunity, but we consider that it suffers from significant shortcomings and exceptions that can undermine its purpose: Scope of application: The proposal…

Filed in Spanish · English published by the European Commission

The German Banking Industry Committee is the joint committee operated by the central associations of the German banking industry. These associations are the Bundesverband der Deutschen Volksbanken und Raiffeisenbanken (BVR), for the cooperative banks, the Bundesverband deutscher Banken (BdB), for the private commercial banks, the Bundesverband Öffentlicher Banken Deutschlands (VÖB), for the public banks, the…

The PGE Group would like to highlight the following issues with regard to the proposed Directive on Corporate Sustainability Due Diligence (CSDD). 1. The obligations introduced by CSDD put an extensive administrative burden on companies especially if we take into account other legislative proposals which are currently being proceeded in the European Parliament and in the Council e.g.

The European chemical industry is an industry of industries – providing building blocks on which modern societies are built, our materials are found in all industries, from agriculture to construction, food and beverages, energy, healthcare, machinery, textiles, hospitals and transportation.

As Europe’s largest institutional investor, the insurance sector is committed to the EU’s sustainability objectives. European insurers also strongly agree that economic activities must avoid causing or contributing to adverse impacts on human rights and the environment, and welcome corporate decisions that duly take account of a broad spectrum of considerations relevant to both the companies’ impact on people and…

FEDIOL, COCERAL, and FEFAC, which represent the EU crushers/refiners, traders, and compound feed industry, covering EU oilseed and feed production, support the Directive’s objective to combat adverse environmental and human rights impacts of business operations and welcome a proposal for mandatory due diligence across all sectors, which builds on existing international conventions, United Nations Guiding Principles…

Stanowisko Związku Banków Polskich do Projektu Dyrektywy PE i Rady w sprawie należytej staranności przedsiębiorstw w zakresie zrównoważonego rozwoju oraz zmieniająca dyrektywę (UE) 2019/1937 (COM(2022) 71 final) O Związku Banków Polskich Związek Banków Polskich pozytywnie przyjmuje inicjatywę zmierzającą do poprawy jakości prawa z obszaru rynków instrumentów finansowych.

Filed in Polish · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The organisation FUNDACIÓN ENTRECULTURAS appreciated the opportunity to give feedback to the European Commission’s proposal on the Corporate Due Diligence Directive on Sustainability. We recognise that the Commission’s proposal is a turning point in the fight to end corporate impunity, but we consider that it suffers from significant shortcomings and exceptions that can undermine its purpose: Scope of application…

Filed in Spanish · English published by the European Commission

Support a level playing field and avoid national fragmentation: Overall, Eurelectric welcomes the Commission's initiative and perceives it as a much-needed step towards a sustainable corporate governance framework. It is of particular importance that a coherent EU framework is not further delayed, as divergent national initiatives have already emerged.

Feedback for commission adoption of the proposed Directive on Corporate Sustainability Due Diligence 2019/1937 Ethical Trade Norway (sister-organisations of Ethical Trading Initiatives (ETI) in UK, Denmark and Sweden) is a multi-stakeholder initiative and Norway’s largest network of companies, NGOs, trade unions, business associations, organisations and public institutions working to promote ethical trade through…

Response to the Proposal for a Directive on Corporate Sustainability Due Diligence by Nordic and Baltic Company Law Scholars List of contributors, alphabetically: … Paul Krüger ANDERSEN (Aarhus University) Niklas ARVIDSSON (Lund University) Gintautas BARTKUS (Vilnius University) Andri Fannar BERGÞÓRSSON (Reykjavik University) Virginijus BITĖ (Mykolas Romeris University) Søren Friis HANSEN (Copenhagen Business…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

OPERARI, as a proud participant of European B CORP movement, welcomes the proposal for a Directive introducing a sustainability due diligence requirement for companies as well as a monitoring and enforcement mechanism. In the attached response to the proposed Directive, we highlight a potential risk in the practical functioning of the due diligence process, which could eventually harm SMEs.

Please see the attached comment letter, in which Accountability Counsel, and international legal non-profit organization, urges consideration of two essential points: (1) Specificity is needed to avoid variable and loose interpretations of the requirement for complaints procedures.

Key messages of Fortum, one of the leading energy companies in Europe: - Fortum welcomes the EU initiative and the aim to create a level playing field for companies and avoid a fragmentation of due diligence obligations - Legal certainty for companies and reasonable administrative burden must be ensured - Clear definitions and obligations are needed - Regarding the obligations, a clear distinction between direct and…

We welcome the fact that the European Commission has launched this process of sending comments to this proposal for a directive. We consider it a step forward in promoting human rights and protecting the environment, complementing European legislation such as the European Green Deal and the European Pillar of Social Rights.

Filed in Spanish · English published by the European Commission

The Bundesverband Materialwirtschaft, Einkauf und Logistik e.V. (BME) is a network for all sectors and sectors with a focus on global procurement. Its approximately 10 000 members represent a procurement volume of around EUR 1.25 trillion per year. These include national and international groups as well as small and medium-sized enterprises, mainly from the private sector, but also from public procurement.

Filed in German · English published by the European Commission

Aviva Investors response to the Commission proposal for a Directive on Corporate Sustainability Due Diligence Aviva Investors welcomes the opportunity to comment on the proposal for a Directive on Corporate Sustainability Due Diligence.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

UNICEF welcomes the initiative of the European Commission for a Directive introducing a sustainability due diligence requirement for companies as well as a monitoring and enforcement mechanism. To effectively prevent, address, and remedy harms to children, children’s rights must be explicitly reflected in both the text of the Directive and in all instruments supporting its implementation.

Rainforest Alliance welcomes the Commission’s proposal for an EU directive on corporate sustainability due diligence (CSDDD), as a key step to set a level playing field and deliver on global human rights and environmental commitments. However, there are opportunities for improvements to meet its intended objectives.

EBF position paper on the Corporate Sustainability Due Diligence Directive (CSDD) Key points and recommendations: • • 1 We support the objectives of the proposal to advance respect for human rights and environmental protection and embed these aspects into supply and value chains, to create a level playing field and to avoid fragmentation amongst Member States (MS).

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Privacy International welcomes the opportunity to provide feedback on the European Commission’s proposal for a directive of the European Parliament and of the Council on Corporate Sustainability Due Diligence. Please see our submissions in the attached file.

EURATEX, the European Apparel and Textile Confederation representing the interest of the European textiles and clothing industry, understands the importance of establishing transparent and accountable value chains. However, key factors must be met for the the Directive to be workable. EURATEX critically stresses the following recommendations: - Harmonisation is key to ensure an EU-wide level playing field.

Electrolux is in favor of a corporate due diligence legislation at the EU level. It has the potential to reduce differences between EU Member States requirements as some Member States are considering own legislation in this area. A common EU legislation would help to prevent a potential patchwork of national legislation.

Comments on the Draft EU Directive on Corporate Sustainability Due Diligence The International Committee of the Red Cross (ICRC) welcomes the European Union’s efforts to strengthen corporate respect for human rights, including through its proposed directive on corporate sustainability due diligence.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The National Consultative Commission on Human Rights (CNCDH) (French National Institution for the Promotion and Protection of Human Rights) welcomes the publication of the proposal for a directive on corporate due diligence on sustainability, the first EU initiative to impose a cross-cutting and cross-sectoral duty of due diligence on companies in the field of human rights and the environment.

Filed in French · English published by the European Commission

The National Consultative Commission on Human Rights (CNCDH) (French National Human Rights Institution) welcomes the publication of a proposal for a Directive on corporate sustainability due diligence, the first European Union initiative to impose a cross-cutting and cross-sector due diligence obligation on companies with regard to human rights and the environment.

The IKEA brand – represented by Inter IKEA Group and Ingka Group – is driven by our vision to create a better everyday life for the many people and the IKEA Sustainability Strategy. We are committed to respecting and supporting human rights and the environment throughout our value chains, in line with the United Nations Guiding Principles of Business and Human Rights (UNGPs) and the Organisation for Economic…

Proposed new rules to prevent corporate damage to the environment and exploitation of people could be ground-breaking, but at present they risk becoming an ‘ineffective tickbox exercise’ for companies The EU is taking action on corporate damage to the planet and to people.

The IKEA fire — represented here by Inter IKEA Group and INGKA Group, is driven by our vision to create a better supplying day life for the male people and the IKEA Sustainability Strategy. We are committed to restoring and supporting human rights and the environment through our value chains, in line with the United Nations Guiding Principles of Business and Human Rights (UNGPs) and the Organisation for Economic…

Filed in Swedish · English published by the European Commission

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. Ensuring robust verification processes meant for addressing and adequately mitigating identified adverse effects will be key pillar of the Directive’s success.

Allianz highly appreciates the European Commission’s proposal for a Directive on corporate sustainability due diligence (CSDDD) with its aim to foster sustainable and responsible corporate behaviour and to anchor human rights and environmental considerations in companies’ operations and corporate governance.

The Chamber of Tax Advisors and Accountants (KSW) recognises and supports the Commission’s intention to develop a proposal under European law for uniform due diligence rules. The intention to align these rules with the Corporate Sustainability Reporting Directive (CSRD) is particularly welcome. Both initiatives are closely interlinked.

Filed in German · English published by the European Commission

The European Commission has recently published its long-awaited new draft rules on corporate accountability. The proposed new EU Corporate Sustainability Due Diligence (CSDD) Directive is aimed at cleaning up global supply chains and minimising the negative global impacts of business on workers, communities, and the environment.

Henkel welcomes the Commission’s intention to create a level playing field by harmonizing national approaches to due diligence. Similarly, Henkel appreciates that the due diligence obligations set out in the Directive are to a large degree aligned with the OECD Due Diligence Guidance for Responsible Business Conduct, which is crucial to support the global harmonization of due diligence standards.

Central to Wilmar´s sustainability strategy is our No Deforestation, No Peat, No Exploitation (NPDE) policy, which extends across our global operations, including all third-party suppliers. Wilmar is a firm advocate of sustainable growth and is committed to transforming the palm oil industry towards more sustainable practices. Thus, Wilmar supports the objectives of the Directive.

The EUF wishes to point out certain aspects in relation to the proposal for a Corporate Sustainability Due Diligence (CSDD) Directive: The EUF advocates for a clear delineation between regulation and supervision of the real economy and the financial sector and its competent supervisory authorities, also with regard to sustainability.

The CorA Network for Corporate Accountability consisting of over 50 human rights, development, environmental and consumer protection organizations and trade unions in Germany very much welcomes the presentation of a draft directive on corporate sustainability due diligence (CSDDD) by the Commission.

The KIOS Foundation, A Finnish NGO that supports the work of human rights defenders in East Africa and South Asia, welcomes the awaited commission proposal for the Corporate Sustainability Due Diligence Directive. The directive at its best could represent an important step towards minimising the harmful impacts of unsustainable business practises on workers, communities and the environment worldwide.

The Agency for Improvement and Development, at the City of Oslo, welcomes the “Proposal for a DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on Corporate Sustainability Due Diligence and amending Directive (EU) 2019/1937”. We would like to thank the European Commission for the opportunity to give feedback.

Shift strongly welcomes the proposal for a draft Directive on Corporate Sustainability Due Diligence. The initiative is an opportunity with few parallels in its potential to drive sustainability into the heart of how business gets done.

Finnwatch, a business and human rights NGO based in Helsinki, Finland, welcomes the long-awaited commission proposal for the Corporate Sustainability Due Diligence Directive. At times when we are facing multiple crises from covid-19 to climate emergency, rapidly accelerating holocene extinction and a war in Europe, this directive could represent a landmark step towards minimising the adverse impacts of unsustainable…

Accountancy Europe feedback on the EC's Corporate Sustainability Due Diligence proposal: Scope of the supply chain Due diligence should encompass companies posing major risks and not be limited to any specific tier of the supply chain (risk methodology to be determined by EC).

FERMA is a supporter of the European Commission’s ambitions to succeed in the transition to a climate-neutral and green economy and in delivering on the UN Sustainable Development Goals. From our perspective, it is overall positive to observe that the CSDD proposal borrows so much from a risk management approach. Please also find attached our position paper.

Position paper Ref. Ares(2022)3821067 - 20/05/2022 1 (5) 29.4.2022 Commerce supports European rules for corporate sustainability due diligence – yet a number of issues still require resolving The Finnish Commerce Federation and its members are focused on advancing corporate responsibility in their own activities.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The European Federation of Jewellery (EFJ) welcomes the European Commission’s proposal for a Directive on Corporate Sustainability Due Diligence. The European jewellery sector has been very proactive in ensuring responsible and sustainable mineral sourcing through the implementation of the EU legislation (EU Conflict Minerals Regulation & EU Council Regulation implementing the Kimberley Process Certification Scheme)…

The TÜV Association welcomes the EU Commission's plans to establish binding requirements by considering the entire supply chain. Welcomed is also that the proposal includes comprehensive social and human rights, as well as environmental and climate-related due diligence obligations.

Open letter: The importance of environmental rights for the SCG The undersigned 138 organizations from 33 countries of this open letter (please find attached) believe that this measure is an important opportunity to contribute to prevent severe impacts that occur in the production of raw materials for the European market.

France Invest welcomes the Commission’s proposal for a Directive on Corporate Sustainability Due Diligence. Our members have been committed to sustainability issues for long. They take ESG considerations into account at each stage of the investment’s process and most of the companies they support design corporate governance structures that hold management to account and incentivise long term value creation.

In annex you will find the positions of the Duty of Due Diligence Initiative, a coalition of 17 Luxembourgish civil society organisations, on the European Commission’s proposal for a Directive on duty of care. The Initiative calls, inter alia, for a more meaningful integration of the financial sector in the scope of the future directive.

Filed in French · English published by the European Commission

The European Coffee Federation (ECF) supports the European Commission’s proposal for a Directive on Corporate Sustainability Due Diligence for companies to identify and mitigate risks linked to human rights or environmental adverse impacts in their own operations and supply chains.

Germanwatch welcomes the proposal on the Corporate Due Diligence Directive (CSDDD). Such a European ‘supply chain law’ can become an effective tool to compensate for injustices in global economic relations, to strengthen the rights of people in producing countries and to contain the environmental and climate crisis.

Filed in German · English published by the European Commission

Position Paper SCDD Corporate Sustainability Due Diligence proposal (CSDD) (“the Proposal”) Investor AB (“Investor”) is a Nordic-based industrial holding company founded more than a hundred years ago by the Wallenberg family, with portfolio companies including ABB, Astra Zeneca, SEB, Ericsson, Atlas Copco and Nasdaq and a number of other companies, both listed and unlisted.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

BVI supports the EU initiative for establishing binding rules on sustainable corporate due diligence. Already in 2013, the German fund industry agreed on common principles for responsible investing that have since then been enshrined in chapter V of the BVI Rules of Conduct2.

Dear Sir or Madam, BVMed is in favour of a European regulation compatible with the German Supply Chain Duty Obligations Act and fit for purpose. This is not the case in the Commission’s current proposal to introduce civil liability through the significant extension of the scope (such as the inclusion of negative environmental effects). The solution could be limited to direct suppliers.

Filed in German · English published by the European Commission

FIAN Germany welcomes the EU’s intention to strengthen human rights and environmental protection in the context of economic activities. However, in order for the proposed Commission Directive to be effective under human rights law, key improvements must be made.

Filed in German · English published by the European Commission

Bread for the world welcomes the publication of the draft CSDD Directive and sees it as a very important step in the transformation towards a more sustainable and fairer global economy. The draft also contains many elements that are crucial to achieving this objective.

Filed in German · English published by the European Commission

Please find our detailed feedback in the paper attached. BDA is the central business association organising the social and economic policy interests of the entire German economy. We pool the interests of one million businesses with around 30,5 million employees. These businesses are associated with BDA through voluntary membership of employer associations.

The Chamber of Labour welcomes the proposed Directive on Corporate Sustainability Due Diligence. However, the text in its current form contains numerous weaknesses and loopholes that threaten to undermine effective regulation.

Save the Children and the International Commission of Jurists believe the proposed EU Corporate Sustainability Due Diligence Directive has the potential to have substantial impact on the conduct of businesses incorporated in and/or with operations in the European Union and the ability of these businesses to respect, protect and promote human rights and protect the environment, particularly if it embeds a more robust…

Alliance for Solidarity-ActionAid appreciated the opportunity to give feedback to the European Commission’s proposal on the Corporate Due Diligence Directive on Sustainability. We recognise that the Commission’s proposal is a turning point in the fight to end corporate impunity, but we consider that it suffers from significant shortcomings and exceptions that can undermine its purpose: Scope of application: The…

Filed in Spanish · English published by the European Commission

Statement of the Austrian Raiffeisen Association in the context of the consultation on the European Commission's proposal for a Corporate Sustainability Due Diligence Directive (CSDDD) The Austrian Raiffeisen Association is the umbrella organisation of the Austrian Raiffeisen Group.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The Platform for Responsible Businesses welcomes the opportunity to give feedback to the European Commission’s proposal on the Corporate Due Diligence Directive on Sustainability. We recognise that the Commission’s proposal is a turning point in the fight to end corporate impunity, but we consider that it suffers from significant shortcomings and exceptions that can undermine its purpose: — Scope of application: The…

Filed in Spanish · English published by the European Commission

VDMA represents over 3.400 mechanical engineering companies in Germany and Europe. The industry stands for innovation, export orientation, medium-sized businesses and employs around four million people in Europe, of which more than 1 million are employed in Germany alone. With around 90.000 companies, the mechanical engineering is one of the largest industries in the EU economy.

EXTERNAL NOTE Comments on the EU Proposal for a Directive on Corporate Sustainability Due Diligence Arie Van Hoe Executive Manager Competence Centre Law & Business T [phone removed] [email removed] Introduction On 23 February 2022, the European Commission published its Proposal for a Directive on Corporate Sustainability Due Diligence (the Proposal).

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

ACCA welcomes the aim of the CSDD to progress corporate sustainability in supply and value chains, but we feel more clarity, consistency and scope are needed to change behaviours and effectively manage the accumulation of today's existential threats.

The European Commission’s proposal for a sustainable corporate due diligence could be a milestone on the road to a human and environmental-centred economy, which, in the view of the Supply Chain Act initiative, an association of more than 130 civil society organisations and trade unions from Germany, requires key improvements: The elements of the draft that strengthen the rights of the people concerned and serve the…

Filed in German · English published by the European Commission

As representatives of Austria’s agriculture and forestry, sustainability is a key concern and we therefore welcome initiatives to promote environmental protection and human rights not only within the EU, but also globally, and to prevent the violation of these goods. However, there are some substantive elements of the proposal that need to be revised.

Filed in German · English published by the European Commission

Stand: 16. Mai 2022 Stellungnahme Stellungnahme der Wirtschaftsvereinigung Stahl zum Vorschlag für eine Richtlinie des Europäischen Parlaments und des Rates über die Sorgfaltspflicht im Bereich der Nachhaltigkeit von Unternehmen und zur Änderung der Richtlinie (EU) 2019/1937 (CSDD-E; COM(2022) 71 final vom 23.2.2022) Allgemein Für die Stahlindustrie in Deutschland ist die Verbesserung und Sicherstellung von…

Filed in German · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Upon the publication of the European Commission’s long awaited Corporate Sustainability Due Diligence Directive (CS3D), Anti-Slavery International welcomed the many positive elements we and our partners have been tirelessly advocating for over the past few years.

The Network of Solidarity Development Entities — REDES appreciates the opportunity to return to the European Commission’s proposal on the Corporate Due Diligence Directive on Sustainability. We recognise that the Commission’s proposal is a turning point in the fight to end corporate impunity, but we consider that it suffers from significant shortcomings and exceptions that can undermine its purpose: Scope of…

Filed in Spanish · English published by the European Commission

Fecc acknowledges the consultation on Sustainable Corporate Governance and welcomes the opportunity to provide input. In this context, we would like to raise the following points in this consultation: 1. The synergy between the Sustainable Governance and the proposed Due Diligence Directive should be put into perspective.

Commission Proposal for „Corporate Sustainability Due Diligence” must not put excessive strains on companies Human rights due diligence is part of the self-concept of our member companies. Therefore, we support a workable European due diligence directive that creates a level playing field.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The Movement Impact France welcomes the adoption by the European Commission on 23 February of its proposal for a directive on corporate due diligence with regard to sustainable development. This legislation, which aims to impose a duty of care on companies to address violations of human rights, social rights and the environment in global value chains, but also to improve the consideration of environmental and social…

Filed in French · English published by the European Commission

The German food industry is responsible for respect for human rights at its production sites and in their domestic and foreign supply chains. However, when it comes to identifying risks and remedying maladministration, companies are required to: depends on policy support not only at national and European level, but also in supplier countries on site.

Filed in German · English published by the European Commission

Oxfam Intermón thanked for the opportunity to give feedback to the European Commission’s proposal on the Corporate Due Diligence Directive on Sustainability. We recognise that the Commission’s proposal is a turning point in the fight to end corporate impunity, but we consider that it suffers from significant shortcomings and exceptions that can undermine its purpose: • Scope of application: The proposal legitimately…

Filed in Spanish · English published by the European Commission

The Korea Business Association Europe (KBA Europe), representing over 360 Korean companies in Europe, appreciates the feedback opportunity regarding the European Commission’s proposal on Corporate Sustainability Due Diligence Directive. We welcome the Commission’s initiative for an EU-harmonized regulatory approach to due diligence on human rights and the environment.

FoEE Messages on draft Corporate Sustainability Due Diligence law – Friends of the Earth Europe is committed to ending corporate impunity for human rights violations and environmental devastation. Our network has been proactive in taking cases in Europe against transnational corporations, for example recent successes on compensation for Nigerian farmers for oil spills and real climate action.

ENNHRI, the European Network of National Human Rights Institutions, welcomes the publication of the European Commission’s proposal on Corporate Sustainability Due Diligence (the Proposal). In order to ensure that recovery after COVID-19 is just and equitable, that human rights abuses connected to unsustainable business practices are tackled, and that the urgent issues of climate change and environmental degradation…

Feedback from the Swedish Securities Markets Association on the CSDD The Swedish Securities Markets Association (SSMA) is an industry association founded in 1908 and representing the interests of 24 banks, investment banks and investment firms active in Swedish securities markets.

The European Coalition for Corporate Justice (ECCJ), representing over 480 civil society, trade union and consumer organisations from 17 countries, welcomes the long-awaited proposal. This directive could represent a landmark step forward in the direction of minimising the negative impacts of businesses on workers, communities and the environment worldwide, and advancing corporate accountability and justice.

The European Union’s Corporate Sustainability Due Diligence (CSDD) Proposal for a Directive could be, with the necessary adjustments, be a landmark proposal with the potential to drastically change the sustainability domain. This Directive finally mandates that businesses respect human rights and the environment. However, in its current shape, the CSDD Directive will fail to reach its true potential.

The Austrian Federal Economic Chamber is the legal representative of the entire Austrian business community and represents all Austrian businesses drawn from the areas of Crafts and Trade, Industry, Commerce, Banking and Insurance, Information and Consultancy, Tourism and Leisure, Transportation and Communication. 99,6% of our members are SME.

29 April 2022 MPOC Submission in the context of the EU’s ‘Feedback period’ on the European Commission’s legislative Proposal on ‘Sustainable Corporate Governance’ Public consultation Consultation period: until 23 May 2022 https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12548-Sustainablecorporate-governance_en The submission can be uploaded at…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Beyond Business as Usual Asian Civil Society Response to the European Commission’s Proposed Corporate Sustainability Due Diligence Directive 29 April 2022 1. Introduction 1.1. This open letter sets out the collective response of ten civil society groups and non-government organisations to the European Commission’s proposed Directive on Corporate Sustainability Due Diligence (the Directive), announced on 23 February…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

- New law only applies to bigger companies, who will focus on contracts with suppliers and SHIFT THE RESPONSIBILITY to them. These suppliers are usually smaller companies and as such fall outside of the scope of this directive. Each company should be included in sustainability due dilligence. - The scope is TOO NARROW, for example: following this proposal only 5% of Dutch textile companies will be covered.

FSR - Danish auditors agree with the overall purpose of the European Commission’s proposal on corporate sustainability due diligence, i.e., strengthening the protection of environmental and human rights, and that companies play an important role in this. The proposal reiterates the principles of the OECD Guidelines for Multinational Enterprises and the UN Guidelines Principles on Business and Human Rights.

Kommissionsvorschlag „Sorgfaltspflichten von Unternehmen im Hinblick auf Nachhaltigkeit“ darf Unternehmen nicht überfordern Menschenrechtliche Sorgfalt gehört zum Selbstverständnis unserer Mitgliedsunternehmen. Deswegen unterstützen wir eine praktikable europäische Lieferkettenrichtlinie, die ein Level-PlayingField schafft.

Filed in German · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Eumedion welcomes the European Commission’s proposal for a directive on Corporate Sustainability Due Diligence (hereinafter: ‘directive’). The proposal aims to establish substantive duties for European companies in the area of human rights and environmental due diligence, as well as to clarify the directors’ duty of care.

As an agricultural organisation, we support trade within the EU and with third countries. Trade must be based on balanced, fair and transparent rules in order to avoid distortions of competition. In principle, imports into the EU must comply with the Union’s requirements for its own farmers. As an agricultural organisation, we therefore welcome the equal treatment of undertakings from third countries.

Filed in Dutch · English published by the European Commission

The Danish Institute for Human Rights is grateful for the opportunity to provide feedback on the proposed Corporate Sustainability Due Diligence Directive. To ensure that recovery after COVID-19 is just and equitable, that human rights abuses connected to unsustainable business practices are tackled and that the urgent issues of climate change and environmental degradation are adequately addressed, there is a need…

RWE fully supports the European Green Deal and the goal of a climate-neutral European Union by 2050. The Green Deal should enable the EU to transform its economy and put it on a more sustainable pathway. Therefore, RWE warmly welcomes the EU's various sustainability initiatives including the harmonisation of human rights and environmental due diligence obligations in the EU.

This directive is meant to hold businesses accountable for harming human rights and the environment, and in WWF’s view is critical for the success of the sustainable finance agenda and the European Green Deal. However, WWF is concerned that since it was initially announced, the proposal has lost its ambition. Notably, it will only apply to a tiny fraction of EU companies.

Submission to the EU on the EU Regulation on Mandatory Human Rights and Environmental Due Diligence for the Professional Training for Lawyers & Barristers in the UN Guiding Principles in Business & Human Rights Working Group Members of the Professional Training for Lawyers & Barristers in the UN Guiding Principles in Business & Human Rights Working Group agree to work collaboratively to engage with (those) and…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Legal Affairs and Administration Hannu Ylänen European Commission, Directorate-General for Justice and Consumers Unit for Company Law Att: Maija Laurila, Head of Unit 6 October 2020 1 (3) The European Commission report Study on directors’ duties and sustainable corporate governance, and the Inception Impact Assessment Confederation of Finnish industries EK thanks for the opportunity to provide its comments to the…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

"In the Action 10 of its Action Plan, the Commission committed to assess “(i) the possible need to require corporate boards to develop and disclose a sustainability strategy, including appropriate due diligence throughout the supply chain, and measurable sustainability targets; and (ii) the possible need to clarify the rules according to which directors are expected to act in the company's long-term interest”.

CFA Institute feedback on sustainable corporate governance CFA Institute welcomes the opportunity to provide comments on the upcoming European Commission initiative on sustainable corporate governance. We are in favour of legislative measures encouraging a better alignment of long-term interests among companies, investors and other stakeholders, including society’s needs.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

ShareAction Europe ASBL Rond-Point Schuman 6 1040, Brussels EU Transparency Register nr: 75791956264-20 ShareAction’s feedback to the European Commission’s Inception Impact Assessment on Sustainable Corporate Governance ShareAction, the responsible investment advocacy group, welcomes the opportunity to provide feedback on the Inception Impact Assessment on sustainable corporate governance.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

WFTO-Europe warmly welcomes the European Commission’s focus on sustainable corporate governance and for recognising several of the issues directly related with profit-maximisation as the dominant business model of late.

Postbus 20061 2500 EB Den Haag Netherlands www.government.nl Contact [email removed] Date Re 8 October 2020 Dutch response to the Roadmap for the initiative on sustainable corporate governance We welcome and appreciate the opportunity to comment on the Commission’s roadmap for the initiative on sustainable corporate governance.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

i. Regulation should be aligned with the UN Guiding Principles on business and human rights (UNGPs) (and OECD Guidelines for Multinational Enterprises - applies UNGPs framework to environmental sustainability). NB: The UNGPs are not voluntary.

Conservation International (CI) welcomes the initiative of the Commission to ensure that sustainability is further embedded into the corporate governance, as well as the opportunity to provide feedback on the inception impact assessment.

NOTE 5. October 2020 Click here to enter text. Click here to enter text. The Danish Government’s response to the public consultation on a roadmap on sustainable corporate governance It is a key priority for the Danish Government to enable a green and sustainable transformation of the society and accordingly the Danish government has set an ambitious target to reduce CO2 emissions by 70 % in 2030.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Fraunhofer IIS | Am Wolfsmantel 33 | 91058 Erlangen, Germany European Commission DG JUST– Unit A3, Company law Rue Montoyer 59, 1000 Bruxelles Belgium Fraunhofer Institute for Integrated Circuits IIS Management of the Institute Prof. Dr. Albert Heuberger (executive) Dr.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The European Center for Constitutional and Human Rights aims to hold perpetrators of serious human abuses to account through conventional or innovative legal means. Our goal is to provide justice and redress to those affected, deter future abuse and develop the international legal framework against impunity.

In Ireland the Environmental Protection Agency said in July 2020 that “for Ireland to become the low carbon and climate resilient society and economy that we aspire to systemic change is required.“ For this to happen we need to change the dominant model of contemporary corporations, which are organised to maximise shareholder wealth, with coordination rights held exclusively by capital and management.

Business & Human Rights Resource Centre (BHRRC) is a global NGO working to advance human rights in business and help the vulnerable eradicate abuse, tracking over 10,000 companies on its digital platform. We also provide analysis in briefings and reports, and cover BHR-related news on a daily basis.

H&M Group welcomes the opportunity to comment on the inception impact assessment ahead of the public consultation on sustainable corporate governance in 2021. We share the European Commission’s vision to establish a mandatory due diligence framework at European level to create leverage and enable building a global level playing field for companies to operate on sustainable terms.

ClientEarth welcomes the public consultation and strongly supports the EU’s initiative aiming to create legal certainty regarding companies’ duty to identify, assess and mitigate adverse impacts in the value chain. We strongly agree with the shortcomings of a baseline scenario laid out in the IIA.

Opinion of the Estonian Chamber of Commerce and Industry on the European Commission’s initiative “Sustainable Corporate Governance” The Estonian Chamber of Commerce and Industry is the largest business organisation in Estonia, with around 3400 companies, most of which are small and medium-sized.

Filed in Estonian · English published by the European Commission

UNICEF welcomes this initiative. Our experience is that for mechanisms and policies to be effective in addressing children’s rights, they should be designed with clear visibility of children’s considerations. This includes both their scope and the definition of issues covered and the design and conduct of implementation measures.

DKA Austria supports the initiative of the EU Commissioner for Justice in providing a legal framework that has the capacity to fight child labour and promote child rights. According to ILO figures there is an estimated 152 million children in child labour, 72 million of which are in hazardous work and the situation is simply getting worse due to the COVID-19 pandemic.

1 (6) 8.10.2020 European Commission, Directorate-General for Justice and Consumers DG JUSTICE, A3 Company law unit EC inception impact assessment: Sustainable corporate governance The Federation of Finnish Enterprises (FFE) is pleased have an opportunity to provide feedback and comment on the inception impact assessment of a sustainable corporate governance framework.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

ETUC call for a European directive on mandatory Human Rights due diligence and responsible business conduct The ETUC calls for a European directive on mandatory human rights due diligence and responsible business conduct.

UNI Europa, the European Services Workers Union and EU sectoral social partner, welcomes this initiative. This is joined by UNI Global Union, the global trade union federation for the skills and services sectors. This feedback responds to the proposal of a due diligence duty. Further information including on the other components of the initiative is included in the attached document.

Openness to the outside world generally leads to economic development, increased prosperity, promotes necessary structural transformation and creates more jobs. But the benefits of international exchange do not benefit everyone. Globalization enables increased competition through unhealthy working conditions. Inequality is manifesting itself in a polarized labour market where atypical jobs are increasing.

Dear sirs. Taking into account the roadmap of this iniciative, in behalf of Fedepalma we must state: Two principles must be taken into account: Co-responsibility. Recognizing the additional costs incurred by producers concerning sustainable production processes through remuneration is fundamental to directing the actions of producers.

Thanks to a unique capacity for innovation and impact at scale, business is key to shift the way our complex societies function to a safe operating space within planetary boundaries while respecting the dignity of all human beings. Based on this belief, Earth on Board is working with boards of directors to place sustainability at the centre of business strategy.

The European Commission, Directorate-General for Justice and Consumers (unit A.3, Company Law) has invited feedback on the Sustainable Corporate Governance Initiative, which we are pleased to provide. All authors are full professors from different disciplines at the University of Hamburg, all with a focus on Corporate Governance.

The Japan Business Council in Europe (JBCE) welcomes the feedback opportunity regarding the Commission’s initiative on Sustainable Corporate Governance, with the proposal expected in Q1 2021. JBCE appreciates this timely proposal as responsible corporate behaviour throughout the supply chain is becoming an increasingly salient topic.

AFG welcomes the opportunity to submit feedback in relation to the European Commission’s initiative Sustainable Corporate Governance and the related study on directors’ duties. As a preamble, it seems essential to us to recall the long-term perspective of investors, which converges towards that of stakeholders.

The DEKRA Group welcomes the aim of the European Commission for the Sustainable Corporate Governance initiative to further embed sustainability into the corporate governance framework. Following the positive example and impact of legal framework for other important content areas that have been implemented successfully in the past, such as workplace health, occupational safety, or environmental protection, also…

As a global network of over 200 organisations dedicated to improving working conditions in the garment industry, the Clean Clothes Campaign eagerly awaits the introduction of mandatory human rights due diligence and corporate accountability legislation.

Ref: Sustainable Corporate Governance Link to consultation: https://ec.europa.eu/info/law/better-regulation/have-yoursay/initiatives/12548-Sustainable-corporate-governance BETTER FINANCE’s feedback on Sustainable Corporate Governance (inception impact assessment for an EU directive proposal) About BETTER FINANCE BETTER FINANCE, the European Federation of Investors and Financial Services Users, is the European public…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Accountancy Europe welcomes the opportunity to provide feedback on the European Commission’s Inception impact assessment on sustainable corporate governance. Environmental risks also entail significant financial risks for businesses, markets, investors, and the economy.

GLEIF suggests that setting clear and harmonized rules for due diligence in supply chains at the EU level is necessary for creating a level playing field for all EU companies. Many EU companies, small or big, are sourcing supplies from entities based in countries with lesser social, human rights or environmental standards. In some countries the identification and mitigation of related risks and impacts is weak.

Sustainable corporate governance and the role of the investment industry EFAMA, the voice of the European investment management industry, welcomes the Commission’s initiative to improve the EU regulatory framework on company law and corporate governance.

Forest Peoples Programme (FPP) welcomes the commitment of the European Commission to propose legislation on mandatory corporate human rights and environmental due diligence (HREDD). This legal initiative is critical and urgently needed to catalyse transformation along investment and value chains, accomplish the sustainable development goals and fulfil human rights obligations.

The European Coalition for Corporate Justice (ECCJ), a coalition of campaigns and national platforms of NGOs, trade unions, consumer organisations and academics for corporate accountability rules, representing over 450 organisations from 17 countries, highly welcomes this initiative.

Fulfilling the Sustainable Development Goals (SDGs), and more broadly, achieving sustainability, requires reform of EU laws, policies and practice concerning business. The contribution of business is vital to achieving sustainability, and yet we know that business-as-usual currently undermines sustainability goals. To change this, reform is necessary to ensure sustainable value creation within planetary boundaries.

CDP Europe is part of the global CDP non-profit network, that drives companies and governments to reduce their greenhouse gas emissions, safeguard water resources and protect forests. Voted number one climate research provider by investors and working with institutional investors with assets of US$96 trillion, we leverage investor and buyer power to motivate companies to disclose and manage their environmental…

I commend the EC in commissioning a Study on the issue of sustainable corporate governance. It fits well with some EU initiatives, and with the greater understanding and acceptance of the role of companies in society. Its conclusions point strongly to the need for EU regulation in this area. I agree with this need for EU regulation in this area.

The Association of German Technical Inspection Agencies (Verband der TÜV e.V.) welcomes the Commissions initiative to promote a sustainable corporate governance framework at EU level and would like to provide feedback on some core issues.

Diversity of corporate models and governance ignored: The EY study differentiates between companies in different sectors, of different size and listed/ non-listed companies. Like the study the consultation document only refers to “companies” in the broadest sense and considers rolling out measures on all corporates.

Solidaridad welcomes this initiative that aims to incentivise corporate boards to properly integrate stakeholder interests, sustainability risks, and adverse impacts into corporate strategies, decisions and oversight.

The Study on Directors’ Duties and Sustainable Corporate Governance (hereinafter ‘The Study’) was published on 30 July 2020 and is accompa-nied by a Commission Inception Impact Assessment and a consultation deadline of 8 October 2020.

Remarks regarding the empirical findings, outlined in section 3.1.1.4 The report presents a number of key findings based on empirical findings, mainly as descriptive statistics. The report mentions that dividends as well as share buybacks have increased during the period, from less than 1% in 1992 to 4 % in 2018. Specifically, figure 1 (p.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The Confederation of Swedish Enterprise (“Svenskt Näringsliv”) is the main business organization in Sweden, representing 50 member organizations (industry and employer organizations) and over 60.000 member companies, among them most listed companies. It represents almost all sectors of business with the exception of the banking industry.

EuropeanIssuers welcomes the opportunity to present its comments on the inception impact assessment (IIA) on sustainable corporate governance, for which you may find a full complete response in the attachment. In sum, EuropeanIssuers expresses its support for the concept of sustainable corporate governance and the link between sustainable corporate governance and long-term value creation, agreeing with the assertion…

SUEZ is favorable to this initiative having a well-established Sustainable Corporate Governance team with extra financial reporting in place since 2008. In line with the “Loi Pacte” in France on the modification of the concept of interests of the company (and of its shareholders), SUEZ adopted a “raison d’être” in 2020 that embraces the interests of all stakeholders and commits to a positive impact on people and the…

The BDSI welcomes the main goal of this European Commission initiative to ensure that sustainability is further encouraged into the corporate governance framework with a view to align better the long-term interests of management, shareholders, stakeholders and society.

Filed in German · English published by the European Commission

Global Witness firmly supports the introduction of binding EU legislation on corporate due diligence and liability to ensure that companies are held accountable for their impact on people and planet. We call on the Commission to be a global leader by introducing effective and robust legislation that establishes cross-sectoral mandatory human rights, environmental and governance due diligence obligations for all…

8th October 2020 Attn Commissioner Didier Reynders European Commissioner for Justice 1049 Bruxelles Belgium Dear Commissioner Reynders, PwC International Ltd (PwC), on behalf of the PwC network, welcomes the opportunity to comment on the EC roadmap for an EU initiative on sustainable corporate governance.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

ACV Puls welcomes the initiative of the roadmap, to strengthen the obligations (including directors duties , shareholders) in Company Law and Corporate Governance to create long-term sustainable value in the company and its supply chain.

With reference to the possibility to submit feedback in relation to the European Commission’s initiative Sustainable Corporate Governance and the related study on directors’ duties (the “Report”), Ernst & Young AB (“EY Sweden”) would like to submit the following statement. For avoidance of all doubt, we emphasize that we share the Commission’s underlying objectives.

BVI welcomes the opportunity to submit initial views on the envisaged measures to promote sustainable corporate governance in EU companies and to ensure that sustainability is further embedded into the corporate governance framework. Please find our comments in the document attached.

ARVOPAPERIMARKKINAYHDISTYS RY STATEMENT 8 October 2020 1 (2) European Commission DG Justice and Consumers Re: Inception impact assessment relating to sustainable corporate governance The Finnish Securities Market Association (SMA) would like to thank the European Commission for the opportunity to comment the inception impact assessment (IIA) relating to sustainable corporate governance.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The 28 German, Danish and Swedish business associations and Swedish self-regulatory bodies and institutional investors listed in the attached letter (the Respondents), would like to submit the attached comments. In summary, the Respondents would like to emphasize that they share the Commission’s underlying objectives.

FINNCHAM Ref. Ares(2020)5349000 - 08/10/2020 Statement 8 October 2020 Ville Kajala 1(4) European Commission DG Justice and Consumers Incept impact assessment on sustainable corporate governance Finland Chamber of Commerceappreciates the opportunity to comment the European Commission's inception impact assessment (IIA) relating to sustainable corporate governance.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The Danish Institute for Human Rights (DIHR) is an independent National Human Rights Institution established by the Danish Parliament in accordance with the UN Paris Principles and is accredited with A status. Under its legal mandate, the DIHR's main functions are to monitor human rights in Denmark and promote human rights internationally, including through engagement with non-state actors.

The Fair Trade Advocacy Office (FTAO) speaks out on behalf of the Fair Trade Movement for Fair Trade and Trade Justice with the aim to improve the livelihoods of marginalised producers and workers in the Global South. Our members have been working for decades with small farmers, workers, and artisans to ensure fair trading practices, good working conditions and adequate remuneration.

Danske Bank welcomes the Commission’s inception impact assessment and supports further alignment of the sustainability requirements that apply to the European corporate governance framework. Further alignment will increase transparency and may assist to reduce regulatory fragmentation due to individual Member States introducing (further) mandatory horizontal due diligence schemes or initiatives related to corporate…

The Rainforest Alliance welcomes the European Commission’s initiative on sustainable corporate governance, including a due diligence duty for companies and considering stakeholder interests for long term sustainability. Mandatory due diligence will create a much-needed level playing field for companies already taking their responsibility in their supply chains and gives laggards a push to do so.

l2 Ref. Ares(2020)53449141- 08/10/2020 CORPORATE DUE DILIGENCE RULES AT EU LEVEL vzbv’s position on EU supply chain legislation The Federation of German Consumer Organisations (Verbraucherzentrale Bundesverband – vzbv) believes that sustainability starts with production. Companies must be obliged to protect the environment and respect human rights at every stage of their supply chains.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Assonime supports the European Commission intention to favour the evolution of the EU company businesses toward a sustainable and resilient corporate growth. However, Assonime believes that the choice of policy tools for implementing such a goal should be carefully considered, as they can have unintended consequences on the incentives of companies to invest and on the effectiveness of capital markets to attract…

FEDIOL welcomes the European Commission’s initiative aimed at further incorporating sustainability into the governance framework of corporate activities. The objective of FEDIOL members is to source agricultural raw materials that are sustainably produced and to address potential issues in the supply chain with a view to improving production practices.

CLEPA is pleased to provide feedback on the inception impact assessment of a sustainable corporate governance framework. CLEPA represents over 3.000 automotive suppliers, investing over €25 billion yearly in R&D, with an employment footprint of five million direct and indirect jobs across the continent.

MAIF, a French mutual insurance company, sees sustainable governance as long-term governance, which puts ethics at the service of performance and fully aligns the interests of its stakeholders. It is with this prism that MAIF wishes to share its vision and experience of long-term integration and its impact on its stakeholders in its strategy.

Filed in French · English published by the European Commission

Considering the important milestones both internationally and at EU level that have integrated disability and accessibility as part of the corporate social responsibility (CSR), diversity, sustainability, business & human rights, and non-financial reporting agendas, Fundación ONCE calls on the Commission to acknowledge a wider approach on diversity by including the concepts of disability and accessibility in all the…

See attached document. DIGITALEUROPE welcomes the opportunity to comment on the Inception Impact Assessment in advance of broader public consultation and publication by the European Commission of legislative proposals in 2021.

The Association of Chartered Certified Accountants (ACCA) welcomes the European Commission’s Inception Impact Assessment on Sustainable Corporate Governance and agrees that sustainability needs to be further embedded into corporate governance frameworks.

Amnesty International welcomes the Commission’s intention to launch a legislative initiative establishing mandatory rules for corporates not to harm human rights and the environment and to carry out due diligence and to request corporate directors to integrate wider societal and sustainability interests into business decisions.

We — Center for Corporate EY at CBS, are very concerned about the overall content of the EY report, and, in particular, the ultimate consequences for European business that would result from the alleged interventions.

Filed in Danish · English published by the European Commission

OPINION STATEMENT 7.10.2020 The European Commission Directorate-General for Justice and Consumers Unit for Company Law Att: Maija Laurila, Head of Unit, and Susanne Knöfel, Deputy Head of Unit Response by the Directors’ Institute Finland on the European Commission’s roadmap on sustainable corporate governance Directors’ Institute Finland (”DIF”) is an independent non-profit association which contributes to the…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The Study displays a lack of understanding of the nature of legal discourse and presents a biased, unrepresentative and highly politically motivated survey of literature and empirics. The Study misrepresents fundamental concepts of company law and fails to understand how corporate governance works.

Contribution from the Mouvement des Entreprises de France ( MEDEF) A) Context and definition of the problem The Medef shares the Commission’s objective to take a stand in favour of corporate governance that focuses on the long term and on sustainable growth.

The MVO Platform, a Dutch coalition of 24 NGOs, trade unions and certifiers that all work on responsible business conduct, believes this initiative of the European Commission is timely and needed. We agree with the Commission that the short-termism that drives economies around the world is extremely harmful for the planet and our common future.

The EDRi (European Digital Rights) network is a collective of 44 civil society organisations, as well as advocates and academics, working to defend and advance digital rights across Europe. We work to challenge private and state actors who abuse their power to control or manipulate the public.

The Danish Chamber of Commerce welcomes the opportunity to provide input to the Commissions roadmap on Sustainable corporate governance. Please find the full response on behalf of the Danish Chamber of Commerce attached.

The Dutch Monitoring Committee Corporate Governance Code (MCCG) supports the Commission's objectives to promote long term value creation and sustainability and to reduce the impact of shareholder driven shorttermism. The MCCG recognizes that some companies are too focused on short-term financial performance compared to their long-term development and sustainability aspects.

CDSB welcomes the commitment of the European Commission to improve the corporate governance framework as part of the European Green Deal and as a complementary action to support the successful implementation of the revision of the Non-Financial Reporting Directive (NFRD).

The DGB shares the Commission’s analysis that the short-term nature of enterprise policy has a negative impact on sustainability. One of the many manifestations of the short-term idea is the recent call by international financial investors in the German debate on corporate governance to shorten the term of office of supervisory boards. This would create a worrying incentive for short-term policy.

Filed in German · English published by the European Commission

DANISH COMMITTEE ON CORPORATE GOVERNANCE Response to the public consultation on the European Commission’s roadmap on sustainable corporate governance The Danish Committee on Corporate Governance appreciates the Commission's intentions to address how companies can be encouraged to longterm development of the company, as well as of sustainability.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Founded in 1839, Anti-Slavery International is the oldest international human rights organisation in the world. Today, we draw on our experience to work to eliminate all forms of slavery and slavery like practices throughout the world by looking at the root causes of slavery and its consequences to achieve sustainable change.

An estimated 260 million people face caste discrimination globally, and in India, one in six people are Dalits. Research has shown that the majority of those trapped in modern slavery, including child and, forced labourers and those engaged in hazardous work, such as manual scavenging, are from the lowest castes or indigenous communities in caste-affected countries.

The Confederation of Norwegian Enterprise (Næringslivets Hovedorganisasjon – NHO) is the main business organisation in Norway, with listed companies among our members. NHO is a member of Business Europe. We share the Commission's objectives in this field. However, we refer to the feedback given by the Confederation of Swedish Enterprise et al.

Position Paper on European Commission’s inception impact assessment on corporate sustainable governance I. Overall position The German insurance Industry strongly supports the efforts of the EUCommission to promote the transformation to a global sustainable economy.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Roadmap on Sustainable corporate governance – some comments With reference to the possibility to submit feedback in relation to the European Commission’s initiative Sustainable Corporate Governance and the related EY study on directors’ duties (the “Report”), AB Electrolux, would like to submit the following comments. We would first like to emphasize that we share the Commission’s underlying objectives.

Frank Bold is a public interest law organisation leading the Purpose of the Corporate project and coordinating the Alliance for Corporate Transparency. Addressing the compound problem of short-termism and undue focus on maximisation of shareholder value requires the implementation of a comprehensive set of interconnected reforms in the area of company law, corporate reporting and finance.

The European Commission has proposed a roadmap for preventing short-term ownership and increasing companies’ focus on sustainable value creation. The roadmap includes, among other things, detailed regulations on corporate governance matters such as the board’s role, company strategies and board remuneration structures, etc.

The Federation of the European Sporting Goods Industry (FESI) highly welcomes the opportunity to comment on the European Commission’s Inception Impact Assessment on “Sustainable corporate governance”. Among its membership, FESI counts a large number of companies that have been operating supply chain compliance management systems for several years.

The Swedish Academy of Board Directors (Sw. StyrelseAkademien) is deeply concerned about the combined content of the European Commission's report Study on directors’ duties and sustainable corporate governance (the Study), and its Inception Impact Assessment, based on this report.

Given that the EC Impact Assessment on Sustainable CG is largely based on the EY related survey, ecoDa will largely focus its comments on this report. ecoDa strongly believes in the importance for companies and directors to strengthen their long-term strategies by further integrating the interests of legitimate stakeholders that make sense to their business.

European Commission Inception impact assessment Sustainable corporate governance © GRI 2020 Summary GRI’s contribution below includes three recommendations (points 6-8): • • • Alignment with international standards Mandatory human rights and environmental due diligence Complementarity with the revision of the NFRD Contribution 1.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

CSR Europe feedback (Part 2 of 2) CSR Europe believes that in the new initiative on Sustainable Corporate Governance it is important for the EC to focus on policy coherence between the future Sustainable Finance Strategy and other forthcoming legislation and initiatives, such as the EU Taxonomy and its forthcoming delegated acts to enterprises, the review of the Non-Financial Reporting Directive, the Due Diligence…

CSR Europe feedback (Part 1 of 2) CSR Europe welcomes the Sustainable Corporate Governance initiative, agreeing that to reach impact, geopolitical leadership and system change, sustainability needs to be further embedded into the corporate governance framework. a.

IEA wholeheartedly welcomes this Community intervention, which aims at a strategy of the “Global Sustainability” which will pave the way for the governance of (private) companies: Achieving the objectives of sustainability and long-term viability. The evolution of technology and the economy are challenging visions of our future, as societies and as individuals.

Filed in Italian · English published by the European Commission

ActionAid International, present in several EU member states and close to 40 countries in the Global South, warmly welcomes this initiative and fully supports the adoption of an ambitious EU-wide regulatory framework.

The study appears biased towards producing preconceived results rather than containing a dispassionate, impartial and comprehensive analysis. It proceeds by unsupported assertions – managers and investors are short-termist and corporate law is responsible for it – rather than rigorous demonstration.

In line with the SDG 12 on responsible consumption, we highly welcome the main goal of this European Commission initiative to ensure that sustainability is further embedded into the corporate governance framework and that the interests of the farmer, companies and its stakeholders and the society as a whole are aligned.

The European Network for Social Integration Enterprises, ENSIE, represents the interests of national and regional networks of ‘Work Integration Social Enterprises’ (WISEs) striving for more inclusive and integrated forms of employment at European level.

Gisad (Global Institute for Structure relevance, Anonymity and Decentralisation i.G.) is a non-profit institution in the process of being set up. From the point of view of Europe’s citizens, Gisad wants to develop a digital society system that can compete in systems. As early as 2017, Gisad defined in its policy programme the idea of an indicator of the structural importance of society.

Filed in German · English published by the European Commission

Gisad (Global Institute for Structure relevance, Anonymity and Decentralisation i.G.) is a non-profit institution in the process of being set up. From the point of view of Europe’s citizens, Gisad wants to develop a digital society system that can compete in systems. As early as 2017, Gisad defined in its policy programme the idea of an indicator of the structural importance of society.

Much of the companies and social organisations are committed to “Sustainability”. Some emit reports according to the Global Reporting Initiative, others to the 10 Principles of the UN Global Compact and those with the highest operation in ISO 2600 and ISO 20121: 2013. Most fundamental concepts and ethical concepts should be applied to CORPORARY RESPONSIBILITY or CORPORRATIVA SOCIAL COMMITTEE.

Filed in Spanish · English published by the European Commission