As large European companies that will have to comply with the forthcoming ... wish to express our support for the Commis
Re: Commission proposal on disclosure of non- financial information by large companies Dear Mr Cable, As large European companies that will have to comply with the forthcoming directive, we wish to express our support for the Commission proposal amending Council Directives 78/660/EEC and 83/349/EEC as regards disclosure of non-financial and diversity information. As responsible companies we have, for some time, been publicly reporting on our environmental performance and we now publish comprehensive sustainability reports covering material social and environmental issues. Sustainability reporting has helped us make progress against our commitments by improving measurement and follow up. It has also improved transparency and enabled dialogue with key stakeholders. We consider that the Commission proposal provides a solid foundation for companies to start their reporting activities with the necessary flexibility, for instance reporting at group level. Based on our own experience we would like COREPER Members to consider the following points when discussing the Commission proposal: 1.
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It is desirable to clarify that companies need only report on those risks that may cause or have caused severe impacts. The legislation should provide guidance to clarify the scope of company's due diligence in this respect, which should cover risks linked to a company by its operations, products, services, or business relationships. While we acknowledge the complexity of supply chains, there are a number of processes and best practices which can help companies to establish due diligence systems to improve transparency in the supply chain and reporting. Legislation such as the European Timber Regulation already sets such requirement. We would encourage a reference to supply chains in the legislation. The legislation should specify that companies, in their analysis of risks, should reflect their responsibility towards international standards as it is agreed and outlined in the UN Guiding Principles on Business and Human Rights, implementing the United Nations “Protect, Respect and Remedy” Framework, and the Organisation for Economic Co-operation and Development (OECD) Guidelines for Multinational Enterprises.
We sincerely hope that you will be able to support these key improvements to the Commission’s proposal in the forthcoming COREPER discussions. Yours Sincerely,
