Members of the European Coalition for Corporate Justice have made individual and joint submissions to a European Commission Consultation on public reporting. The submissions highlight the need for a strengthening of requirements and functioning of the EU’s non-financial reporting regime to more seriously compel responsible business practice.
Core points of the submissions included:
- The NFR Directive must mandate the disclosure of company suppliers’ lists and subsidiaries. In order to empower civil society, trade unions as well as investors and consumers to hold companies to account for what they say in their voluntary codes of conduct, they need to be able to check their codes of conduct against the reality in their supply chains. Allowing companies to keep their suppliers' lists and information about subsidiaries hidden from public scrutiny enables them to publically commit to grandiose sustainability statements and voluntary codes of conduct, without any real prospect of being held to account. The current status quo enables them to “talk the talk” without “walking the walk”;
- The NFR Directive must clarify a legislative duty to undertake Human Rights Due Diligence and the manner by which it is reported on. Companies must be obliged to report on their adverse human rights risks and impacts; what they are doing to prevent and mitigate those adverse human rights impacts; as well as what they do to remedy human rights violations they have caused or contributed to. ECCJ endorses the UN Reporting standard to this end;
- The scope of the Directive must be expanded to not only include publically-listed companies but also private companies. The latter are sometime even more liable to causing human rights violations especially if they operate in high-risk sectors. The Directive must also clarify that European companies are required to report on the impacts of their foreign subsidiaries, business partners, and supply chains, especially if they operate in high-risk areas and sectors;
- There must be sanctions for companies that fail to reveal relevant and material non-financial information and who fail to comply with the directive.