Key messages:
- 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 indirect business partners must be made
- Preferable to talk about the supply chain instead of the value chain
- SMEs should be included in the scope of the directive
- Civil liability rules should be avoided
- Supervision of due diligence obligations by Member State authorities and coordination at EU level is welcomed
- Further criteria for the complaints procedure is needed
- Directors’ duties provisions are unclear and inappropriate
Fortum welcomes the EU initiative and the aim to create a level playing field for companies and avoid a fragmentation of due diligence obligations. EU level due diligence obligations should be prioritized over national due diligence initiatives. A level playing field is needed also on a global level, therefore Fortum strongly supports the proposal to include third-country companies operating in the Union market in the scope. It’s important that adverse human rights and environmental impacts in the supply chains of companies are addressed and mitigated. However, much work needs to be done to get a directive that works in practice. Coherence with other legislation, such as the EU Taxonomy and sustainability reporting is also essential.