"Implementing the French Duty of Vigilance Law: Reflections Shared by Michelin, Sanofi, Total and Vinci", May 2018

How can companies carry out “effective” and “reasonable” human rights due diligence which is meaningful in practice and complies with emerging laws? [...] The backdrop [...] was the recent French devoir de vigilance law...

[W]hat does HRDD mean in practice? And how are French companies undertaking HRDD in a way that seeks to respond to the expectations of the French Duty of Vigilance law? These are the questions that we explored [...] with companies Michelin, Sanofi, Total and Vinci...

Even for those French companies that are not technically subject to the law, it makes business sense to be able to demonstrate evidence of a human rights risk management process. This in turn helps companies become privileged business partners in the value chain of larger consumer-facing companies that are subject to the surge in human rights-related laws...

[C]ompanies shared the importance of:

• Adopting a cross-functional approach...
• Using an overarching human rights policy as an entry point to discussions with other functions...
• Determining one’s own salient human rights issues...
• Engaging in advance with non-governmental organisations and other stakeholders...