We welcome the opportunity to have contributed to the European Commission’s consultation on guidance for implementing the EU Corporate Sustainability Due Diligence Directive (CSDDD). Consistent guidance is much needed, and we are pleased to have shared the practical experience of our FMCG members, who are already working to embed human rights due diligence across complex, multi tier supply chains.
Read the headlines: AIM-Progress submission to the CSDDD guidelines consultation – key messages and full submission: AIM-Progress CSDDD guidelines consultation – full response.
Four issues we think need more attention:
- Closer alignment between the CSDDD and other EU legislation, particularly the Forced Labour Regulation, so companies aren’t collecting and reporting the same information separately.
- More practical guidance on the later stages of due diligence: prevention, mitigation, grievance handling, remedy and measuring impact, not just identifying and prioritising risks.
- Clearer guidance on how the Directive applies across parent companies and subsidiaries operating in different legal and commercial contexts.
- Better integration of environmental due diligence alongside human rights, given how often the two are interconnected.
Our key messages:
- Due diligence should stay risk based and proportionate.
- Companies should be able to use information they already hold rather than duplicating effort.
- Meaningful engagement with workers who are hardest to reach is essential.
- Collaboration between companies increases leverage and reduces duplication for suppliers.
- Responsible purchasing practices need to support due diligence rather than undermine it.
- More practical guidance is needed on remediation and responsible disengagement.
Louise Herring, Executive Director, AIM-Progress:
“We welcome the opportunity to input into the development of practical guidance on implementing the CSDDD, sharing the many years of experience that our 55 member companies have identifying and addressing the root causes of business and human rights risks, working with a range of stakeholders. Our hope is that this guidance goes beyond compliance, and creates a level playing field for outcome focused due diligence implementation.”
What we hope happens next: We’d like to see the Commission’s guidance reflect the recommendations shared by stakeholders to develop practical outcome focused guidance that is aligned with the UNGP and OECD Guidelines for Multinational Enterprises on Responsible Business Conduct. More broadly, we think there is real value in creating an ongoing space for dialogue between workers, trade unions and companies, with the Commission after the guidelines are published, recognising that this isn’t a static picture and due diligence practice will continue to evolve.