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Contents
To align with due diligence obligations, companies must develop a responsible purchasing strategy that integrates human rights risks across their own operations and supply chains. Sub-principle 1.2 emphasises the need for a risk/impact assessment of purchasing practices to identify potential human rights risks.
The CSDDD reinforces this by requiring companies to integrate due diligence into all relevant policies and risk management systems (Article 7). This aligns with CFRPP MI’s expectation that due diligence be embedded across operations (sub-principle 1.1). Article 38 stresses the continuous identification, evaluation, and mitigation of supply chain risks. This echoes CFRPP MI’s focus on ongoing risk assessments (sub-principle 1.2).
Recital 39 highlights the necessity of integrating due diligence into companies’ policies and risk management systems at all relevant levels of operation. It also emphasises the importance of developing a due diligence policy in consultation with employees and their representatives, ensuring it includes a code of conduct and a risk-based approach to due diligence, which covers procurement, employment, and purchasing decisions.
The CSDDD also mandates updates to due diligence policies after significant changes and reviews every 24 months (Article 7(3)). This aligns with sub-principles 1.8 and 1.9, which highlight the importance of tracking progress, evaluations, and reporting. Additionally, Article 15 requires regular assessments of operations, subsidiaries, and business partners to evaluate the effectiveness of due diligence, particularly after significant changes, reinforcing the need for continuous monitoring and updates.
A proactive approach to preventing adverse impacts is central to both frameworks. Article 10(2) of the CSDDD requires companies to implement a prevention action plan with clear timelines, measurable indicators, and stakeholder engagement. This aligns with sub-principle 1.3, which calls for action plans to address identified risks, with defined responsibilities, targets, and resources. Both the CSDDD and CFRPP MI stress the importance of preventing risks before they materialise, rather than reacting once issues arise.