Our key takeaway: Nothing new! But also: time for more action! The recently released FAQ by Shift makes clear that the new Corporate Sustainability Due Diligence Directive (CS3D) is not new. It builds firmly on existing expectations of companies in existing international frameworks that have been in place for over ten years. We don’t even need to wait for the European Commission to put its guidance together, since there’s plenty of guidance already out there on implementing the UN Guiding Principles on Business and Human Rights, and the OECD Guidelines on Multinational Enterprises. The CS3D builds on the international due diligence standards: it requests companies to prioritise based on risks to people; it connects expected actions with how the company is involved with the negative impacts; it requires companies to look at their own business decisions and strategies – especially their purchasing practices; and it focuses companies on how they can take meaningful actions to tackle the issues found - including collaborating with others. So nothing new, but also, now is the time for action, if implementing the UN Guiding Principles is newer to you and your business. Three actions can help now says Shift: familiarise yourself with existing guidance, invest in internal sustainability capacity, and actively participate in credible initiatives. Implementation starts now!
Shift published FAQs: on the EU Corporate Sustainability Due Diligence Directive (CS3D) (April 2024):