CSDDD: What you need to know

The Corporate Sustainability Due Diligence Directive (CSDDD) is the new kid on the block for many large companies active in the EU: here are the key things you need to know now.  

What is CSDDD? 

The CSDDD (CS3D) is a new EU human rights and environment due diligence legislation that applies to large companies operating in the EU. It requires processes be embedded in the business to identify, prevent, reduce, and end negative human rights and environmental impacts in their operations, subsidiaries, and value chains — both inside and outside Europe. 

Is your company subject to CSDDD? 

Two types of companies need to comply: 

  • EU-based companies with 1,000+ employees and a global net turnover of €450+ million. 
  • Non-EU-based companies with a net turnover of €450+ million in the EU. 

Companies must comply by 2027, 2028, or 2029 depending on number of employees, global turnover amount, and whether they’re based in the EU or not.  

What are the key steps to implementation? 

Steps to CSDDD implementation: 1. Integrate due diligence into corporate policies. 2. Map your value chain risks. 3. Take measures to prevent, mitigate, and end adverse impacts. 4. Provide a complaints procedure. 5. Monitor the effectiveness of due diligence measures. 6. Publicly report impacts and due diligence processes. 7. Have a climate transition plan aligned with 1.5C. Underpinned by continuous stakeholder engagement and updates as needed.

1. Integrate due diligence into corporate policies 

Make sure that due diligence is integrated into all relevant policies and risk management systems. You also need to have a specific policy that ensures risk-based due diligence. 

2. Map your value chain and assess risks 

It’s crucial to get an understanding of where your company’s actual and potential impacts lie. Start by mapping your value chain to identify areas with adverse impacts and risks, and prioritise them based on likelihood and severity. Then companies must carry out in-depth assessments of individual suppliers in prioritised areas. 

3. Take measures to prevent, mitigate, and end adverse impacts 

Preventing and ending adverse impacts on human rights and the environment is the core of the CSDDD. Companies should implement the following:  

  • Human rights and environmental strategies.  
  • Responsible purchasing practices — including assurances to comply with minimum standards, and supplier screening and assessments. 
  • Corrective measures and termination of business relationship as a last resort.  
  • Employee and supplier training.  
  • Stakeholder engagement.  
  • Targeted and proportionate support for business partners who are SMEs, including fair and non-discriminatory contractual assurances.  

4. Provide a complaints procedure 

Companies must provide a notification system which is accessible to potentially affected stakeholders and their representatives — including NGOs and human rights defenders, for example. The complaints procedure should be fair, publicly available, accessible, and transparent. Workers and their representatives must be informed of the procedure.  

5. Monitor the effectiveness of due diligence measures 

Periodically assessing your due diligence measures will help you see if they’re suitable and effective. Update your due diligence policy and measures as needed.  

6. Publicly report impacts and due diligence processes 

Compliance with CSRD means compliance with CSDDD reporting requirements. Companies must produce a publicly available annual statement on the potential and actual adverse impacts identified and due diligence measures taken. 

7. Have a climate transition plan aligned with 1.5°C 

Combat climate change with a transition plan aligned with limiting global warming to 1.5°C. If you’re complying with CSRD then your climate strategy is already ticked off the list.  

What’s the connection to CSRD?  

They are both new EU sustainability regulations covering social and environmental factors and applying to the operations and value chains of large companies. Both require public disclosure and a climate transition plan aligned with the Paris Agreement.  

But while the CSDDD focuses on preventing and ending negative effects, the CSRD focuses on transparent disclosure.  

For a more in-depth analysis of the overlap between CSRD and CSDDD, watch out for our upcoming blog on how they match up.  

What can you do now to get started? 

The first step is to familiarise yourselves with the CSDDD requirements to understand if, when and how you must comply. Assessing existing due diligence roles, policies and management systems will help you understand your gaps and establish any roles and responsibilities needed. The next step is to map your value chain to identify and prioritise risks based on likelihood and severity.  

Once you understand where your biggest risks are, devise a plan to set up the necessary due diligence measures, engaging with both internal and external stakeholders. The strategy should include: in-depth supplier risk assessments, measures to prevent and mitigate impacts, grievance mechanisms, assessments to monitor due diligence processes, annual reporting, and a climate transition plan in line with the Paris Agreement. 

Context is ready to support you with all your CSDDD needs — from value chain mapping and devising due diligence strategies, to writing policies and CSRD / CSDDD-aligned reports. If you would like to talk about your organisation’s needs, please get in touch via www.contextsustainability.com or helen.fisher@contexteurope.com 

Will Covid-19 be enough to take the Stone Age from us?

A friend makes a lot of money investing in companies that satisfy our enduring habits: smoking, drinking, gambling and blind loyalty to well-established brands.  

How many of these habits will be broken by the grand disruption of Covid-19?  And what does that mean for all those living in hope that the world in recovery will become a better place: cleaner, greener, kinder?

I ask this because, on the evidence of their Instagram feeds, the campaigning NGOs appear to be convinced that the seismic shock of the pandemic will magically transform world leaders into born-again environmentalists and thoroughly nice people. The likes of Putin, Xi, Trump, Orban and Bolsonaro will morph into Julia Ardern, the saintly leader of New Zealand.   

Some hope.

Evolutionary psychologists argue that we are hard wired to continue making my friend ever richer.  Or, as they say, you can take the person out of the Stone Age but you can’t take the Stone Age from the person.

You can see this now in the difficulty that many have with social distancing.  Joggers, often snorting and spitting, run too close. Shoppers break one-way systems, touch as much of the produce as they can, and so on.  It may be a cliché, but we are creatures of habit and it takes and awful lot to get the creature to change.  

With a massively contracted economy, insolvency a-go-go and tragically stratospheric unemployment, how many of us are seriously thinking about a greener and kinder future?  Some certainly are, like the UN chief António Guterres who this month called for a green deal recovery.  And the EU purports to be promising a green deal recovery stimulus.

But let’s be honest with ourselves, most of us are going to get out of lockdown and kill as many mammoths as we can.  We’re going to burn all the cheap oil that’s bursting out of storage, travel to boondoggles in faraway foreign lands and jump on a cruise ship for all that “free” feasting and boozing.

I remember sitting in a Business for Social Responsibility conference in 2008 during the financial crisis.  The theme of the presentation by Jeff Immelt, the then CEO of the then mighty GE, was the need for a “Reset”.  In other words, in the future to conduct business differently, more mindfully. 

Well, so much for that. We went back to doing what we always did, only with more gusto.

Our current and unprecedented crisis is magnifying the reset sentiment among the world’s do-gooders.  The big question is: will the gravity of our economic situation be enough take the Stone Age out of us?

All we can do is live in hope that it will.  Hope that our recovery will lead to a sustainable 1.5 degree future.  But as a hedge, I would suggest loading up on tobacco stocks.

GSK responds to SDG ratification: a guest blog from Jon Pender, GSK

The adoption of the Global Goals for Sustainable Development at the UN Summit in New York last week marks a key milestone for those working to improve global health.

It provides an opportunity to reflect on the major progress in health that has been achieved over the past 15 years – especially in the areas of childhood mortality, HIV/AIDS and malaria. But it also highlights the key challenges that remain, for example around non-communicable diseases, such as cancer and heart disease, and achieving Universal Health Coverage. The progress that has been achieved is still fragile and many health systems remain vulnerable as so tragically demonstrated by the impact of the Ebola outbreak in West Africa.

As a science-led global healthcare company, GSK’s mission is to improve the quality of human life by enabling people to do more, feel better and live longer.   We strive to achieve both innovation and access by investing in the development of new medicines and vaccines and pursuing collaborative partnerships to ensure they reach the millions of people around the world who need them, regardless of where they live, or their ability to pay.

Health is explicitly included as the third goal: “ensure healthy lives and promote wellbeing for all at all ages”.   It is underpinned by targets that cover a wide range of health issues from maternal and child health to environmental health.  Although each of the new 17 global goals is focused on a different issue, such as poverty, hunger, education, sanitation, gender equality and economic prosperity, it is important to recognise that health underpins almost every development theme and SDG, each of which enable – or is enabled – by advances in population health. So, as the development agenda expands under the SDGs, now is the time to increase the focus on health.

Acknowledging that many of the goals overlap and are inter-dependent in nature, we are aware of the strong links between climate and health. One immediate impact of climate change is the inevitable exacerbation of existing health problems.  Another is the way disease patterns will be altered and new illnesses will affect  unprotected communities, requiring greater stockpiling of medicines and vaccines for use in pandemic situations. Equally, more frequent extreme weather events will also require more provision for disaster relief and the need for business supply chains and distribution networks to be robust enough to withstand such disruption.

By their very nature, the SDGs will present tough and ambitious global targets. But as the  ‘what’ is agreed, collective action must turn to ‘how’ they might be achieved. The global debate will now turn into local Member State discussions around implementation. We believe business has an essential part to play in meeting these goals – indeed without it the ambition is unlikely to be fully realised.  With this in mind, a willingness among all actors to  collaborate,  innovate and be solutions-focused is  going to be essential.
For its part, GSK is fully committed to realising this new holistic development agenda in a way that meets the shared goals of industry, government and others.  But we firmly recognise that the SDGs will only be met if we can work together in cross-sector collaborative partnerships.

So, it will be great to see this set of new global goals – that will be applicable to everyone, everywhere – agreed.  Then comes the hard part – collaborating between the right organisations and people, at the right time in the right places to achieve them.


Three examples of how some of GSK’s work is already supporting the SDGs

1. Supporting health workers in Least Developed Countries – 5 years on

Strengthening health systems and increasing access to healthcare are part of GSK’s commitment to delivering its responsible business model in the world’s poorest countries. The reinvestment of 20% of our profits from sales in Least Developed Countries (LDCs) helps us play our part in generating sustainable economic development. The primary focus of this reinvestment programme is to improve the healthcare infrastructure in those countries through the training of frontline, health workers, who are vital to ensuring people even in the most remote areas can access the care and treatment they need.  To date £21 million of LDC profits have been re-invested across 35 countries. This has enabled the training of 40,000 frontline health workers to reach some 11 million people. Key to the success of the programme is the local expertise of our three non-governmental organisation (NGO) partners – Save the Children in West and Central Africa, Yemen and Haiti Amref Health Africa and CARE International in Asia, who work with country ministries of health to deliver the programme on the ground.  In 2014 we committed to expanding the programme to non-LDCs in sub-Saharan Africa and aim to have a programme in every country by the end of 2016.

2. Malaria – 30-year journey to develop a potential vaccine

Developing countries have a pressing need for new tools for the fight against malaria, yet they are the very countries that can least afford to pay for them.  Following over 30 years of research, GSK’s malaria candidate vaccine, MosquirixTM (RTS,S) has received a positive opinion from European regulators for the prevention of malaria in young children in sub-Saharan Africa.  GSK has committed to a not-for-profit price for RTS,S so that, if approved, the price of RTS,S would cover the cost of manufacturing together with a small return of around five percent that will be reinvested in research and development for second-generation malaria vaccines, or vaccines against other neglected tropical diseases.  The World Health Organisation (WHO) is assessing how the world’s first malaria vaccine candidate might be used alongside other tools to prevent malaria.

3. Ebola

2014 saw a critical public health emergency with the outbreak of Ebola in West Africa, killing over 10,000 people.  GSK was one of the first organisations to respond; providing humanitarian support to affected regions and accelerating the development of our Ebola candidate vaccine.  Due to well established relationships and good communications with NGO partners including Save the Children (STC), Direct Relief and AmeriCares, GSK was able to respond quickly, facilitating the provision of basic medical supplies and equipment on the ground in the affected countries.  We also formed an unprecedented international consortium including the Wellcome Trust, the Medical Research Council (MRC) and the UK Department for International Development (DFID) to accelerate the development of our Ebola candidate vaccine. Our support enabled Save the Children and our other partners to reach 870,000 people across Liberia, Guinea, Sierra Leone with medical treatment and education/awareness programmes; helping people understand how to prevent the disease.  Some of the lessons learned from that time have informed and deepened GSK’s and our partners’ ability to respond to unprecedented humanitarian disasters and the need for continued investment in improving weak healthcare systems.

 

Click here for more information on how GlaxoSmithKline are tackling sustainable development challenges.

About our Guest blogger:

Jon Pender

JON PENDER   |   Vice President, Government Affairs, IP & Access, GlaxoSmithKline

Jon Pender is Vice President, IP & Access, Global Health in GSK’s Government Affairs Department. He is responsible for ensuring that GSK’s approach to sustainably improving access to medicines in the developing world reaches as many people in need as possible, whilst protecting the fundamental business model which underpins the research-based pharmaceutical industry.

Jon has participated in a number of hearings, workshops, seminars, evidence sessions and other events on access to medicines and partnership issues including at the UK Parliament, European Parliament and Commission, UN, World Bank, WTO and the WHO – and was most recently in New York for the adoption of the SDGs.

Jon works with a wide-range of stakeholders including governments, NGOs, multilateral agencies, investors and the media, and represents GSK at a number of international organisations such as the WHO and WTO.  He is the Board Member for the Private Sector at the Roll Back Malaria Board and also regularly attends the Board Meetings of the Global Fund to Fight AIDS TB and Malaria and. He is Chair of the CBI’s WTO Working Group and the IFPMA’s Global Health Committee and co-Chairs the UK’s Industry Government Forum on Access to Medicines (IGFAM).