Statements show widespread support for inclusion of financial activities in the Corporate Sustainability Due Diligence Directive
This page lists a large set of statements and position papers from 2022-2023, in which hundreds of financial corporations, real economy companies, civil society organisations, academics, faith leaders and other stakeholders have called for the inclusion of the financial institutions and activities in the scope of the Corporate Sustainability Due Diligence Directive (CSDDD).
The list below is divided into three chapters, based on the type of signatories: (a) financial and non-financial corporations and industry representatives; (b) civil society organisations; and (c) others: religious bodies, intergovernmental organisations, trade unions, think tanks, and academics.
Some of the statements listed below are co-signed by different types of stakeholders, in which case they are listed only once. In case the same stakeholder has multiple statements, these have been added only if there is value added in the arguments or framing. The list is not exhaustive and reflects the positions of the different stakeholders at the time that the specific statements were published.
A. Financial and non-financial corporations and industry representatives
- Signed by: UN-supported Principles for Responsible Investments (PRI), Eurosif, Investor Alliance for Human Rights and 142 individual financial firms, representing a total of approx. USD 1.5 trillion in AUM.
- "Signatories call for this EU directive to be a transformative step forward to ensure a positive impact along the entire value chain and that economic activities tied to the EU single market are conducted in a responsible manner." This includes the recommendation to "Require robust, ongoing due diligence from financial and non-financial companies, throughout the value chain". More detailed recommendations can be read in the letter.
2. 43 businesses, financial actors and networks reaffirm support for ambitious EU CSDDD in line with international standards during Trilogue (source, letter) (August 2023; Business & Human Rights Resource Centre (BHRRC)).
- Signed by, inter alia, ALDI, IKEA, Unilever, Mars, Danone, Tony’s Chocolonely, Asos, Fair Labor, Aviva Investors, EFG Asset Management, Crédit Mutuel Asset Management, Ecofi Investissements, Ircantec, La Banque Postale Asset Management, La Financière de l‘Echiquier, La Financière Responsable, La Française, Mandarine Gestion, PHITRUST, PRO BTP FINANCE and many more.
- The due diligence requirements should apply to the entire spectrum of risks and impacts across the full value chains of companies in all sectors, including financial institutions.
- To achieve a truly level playing field and to ensure downstream risks are effectively managed, there is no need to make exceptions.
- Signed by, 131 companies, investors and private sector representatives, inter alia, Weleda, Aviva Investors, ESG Portfolio Management, IKEA, EPSON, VAUDE, SOC Investment Group, Tony’s Chocolonely, Patagonia, Socially Responsible Investment Coalition, Akademiker Pension and many, many more.
- All businesses established in the EU and/or active on the internal market, including financial actors, and regardless of size, should be covered by the legislation.
- Signed by IKEA Austria, VBV Group (pension fund), Voeslauer, Auro GmbH, slowfashion GmbH, ESG Plus GmbH, oekostrom AG energy group and many more.
- The necessary paradigm shift can only be brought about by a law that sets equal rules for everyone by defining climate protection obligations and also obliging the financial sector to exercise due diligence.
- The Directive should build on and not fall behind the UNGP on Business and Human Rights, and the OECD Guidelines.
5. Dutch Federation of Pension Funds; Dutch Association of Insurers; Dutch Banking Association: Give financial sector a role in the EU Corporate Sustainability Due Diligence Directive (source, letter) (November 2023)
- Signed by Dutch Banking Association, Federation of Pension Funds, and Dutch Association of Insurers.
- “We call upon EU policymakers to bring financial institutions in scope of the CS3D based on the risk-based approach from the OECD Guidelines. This enables financial institutions to identify and address so-called adverse impacts in the most efficient and effective manner, given the size of the portfolio of customers and proportionate to their capacity. Financial institutions are already familiar with these guidelines, which allows prioritisation of adverse impacts based on severity and probability. It is also important to note that the adopted Corporate Sustainability Reporting Directive (CSRD) already requires financial institutions to report on human rights and environmental due diligence from a risk based approach. For us and many other businesses, consistency between the CSDDD and the CSRD is crucial.”
- Representing over 160 pension funds in the Netherlands who have in total around EUR 1400 billion of assets under management.
- “We are therefore strongly in favor of investors being included in the CSDDD via Article 8a, for the following reasons: The CSDDD should be closely aligned with the OECD Guidelines /.../ Mandatory inclusion of the entire investment chain helps Dutch pension funds to fulfill their voluntary commitment /.../ The CSDDD must recognize that institutional investors do not engage with the investment value chain in the same way as other companies.”
- Signed by AP Pension, P+ Pension for Academics, AkademikerPension, Storebrand Asset Management.
- Exclusion of financial sector would run counter to the international consensus (UNGPs and OECD Guidelines) that all business (financial and non-financial) have responsibilities to avoid and address adverse impacts on human rights and the environment.
- Exclusion may send a wrong signal – i.e., that environmental and social due diligence is not expected.
- Financial institutions are uniquely placed to drive positive sustainability outcomes in the real economy and therefore contribute to the effectiveness of the CSDDD.
8. ECB, Keynote speech by Frank Elderson, Member of the Executive Board and Vice-Chair of the Supervisory Board of the ECB, at the conference on “The decade of sustainable finance: half-time evaluation” organised by S&D and QED (source) (November 2023)
- “For private finance to be able to effectively support the green transition of the real economy, it is crucial that regulatory and legislative changes are consistent across sectors. In other words, in the absence of clear reasons to the contrary, which I fail to see, financial undertakings should not be treated differently from other companies, including in the context of the Corporate Sustainability Due Diligence Directive (CSDDD) that is currently being discussed by co-legislators. At the ECB, we consider that this can help to ensure that financial institutions – including banks – systematically integrate sustainability matters into their decision making and risk management practices. Not excluding the financial sector from the remit of the CSDDD can further help to create greater certainty around financial institutions’ obligations in this area and around climate- and environment-related litigation risks for the financial sector.”
9. Richard Kooloos, Global Head of Social Impact and Human Rights at the ABN AMRO Bank (link) (October 2023; Eurosif Podcast “Sustainability Bridges”)
- Richard Kooloos also posted this in his linkedin in January 2023: “through the inclusion of the financial sector in the CSDDD banks can have more positive impact and can better help those clients that are lagging behind in creating future proof value chains. Nobody wants human rights violations in their products or value chains, the CSDDD gives the legal framework to help realize that”.
- Nelleke Hoffs, Business and Human Rights Advisor at ABN AMRO, reiterated ABN AMRO's support for the inclusion of banks in the CSDDD in a Sustainable Views article in November 2023.
10. Hadewych Kuiper, Managing Director of Triodos Investment Management (link) (November 2023; Eurosif Podcast “Sustainability Bridges”)
- Hadewych Kuiper, Managing Director of Triodos Investment Management, reiterates the importance of including financial institutions in the scope of the CSDDD and explains how these institutions can effectively perform environmental and human rights due diligence.
- Art.8(a) as set out in the EP text provides a basis for including investors in scope of the CSDDD by recognising the nuances within the investor/investee relationship, the tools investors have at their disposal to carry out sustainability due diligence.
- Establish provisions for ongoing, risk- based due diligence throughout the value chain. Conducting sustainability due diligence, both pre- and post- investment, enables investors to better identify and manage their own exposures to sustainability-related risks.
12. Principles for Responsible Investment (PRI), How to make the CSDDD Directive practicable for the investment industry (source) (March 2023)
- PRI recommends to harmonise requirements across the EU sustainable finance framework, and therefore not to exclude financial actors from the scope of the Directive.
13. ASN Bank, Opinion: Financial Sector Activities Need to be Included in the EU's CSDDD (source) (November 2023)
- Roel Nozeman, Head of Biodiversity, Kirsten Kossen, Head of Human Rights, Linda van Dongen, Head of Climate ASN Bank
- “We call on the policymakers in the EU Member States, the European Parliament and the European Commission to ensure that financial institutions and activities are subject to due diligence requirements in the Corporate Sustainability Due Diligence Directive, creating a level playing field.”
14. Multistakeholder statement: Joint Statement on the CSDDD (source) (December 2022, Accountancy Europe)
- Supported by Accountancy Europe, Eurosif, Finance Watch, Frank Bold, ShareAction and WWF
- The CSDDD should stipulate robust due diligence obligations for financial institutions in consideration of their specificities and various asset classes.
15. Storebrand Asset Management, Storebrand Asset Management supports investor call for inclusion of the financial sector in the CSDDD (source) (November 2023)
- It supports alignment of the CSDDD with the OECD sector-specific guidelines on due diligence for institutional investors.
16. IIGCC, PRI, Eurosif joint op-ed - How to make CSDD fit for purpose: The investor perspective (source) (April 2023)
- Joint editorial in Environmental Finance building on our respective positions and making the case for an ambitious and workable outcome on CSDDD from an investor perspective (tailored due diligence requirements; clearer and specific climate requirements; consistency between CSDDD and wider sustainable finance regulation).
17. Multiple industry stakeholders calling for financial sector inclusion within CSDDD in an article in Responsible Investor (source) (October 2023)
- IIGCC, Eurosif, PRI, World Benchmarking Alliance and institutional investors (AP Pension) calling for financial sector inclusion in the CSDDD.
- CSDDD offers the opportunity to correct the piecemeal approach to due diligence within existing financial legislation, harmonise expectations and requirements, and level the playing field across the EU, to avoid duplicative or inconsistent rules.
- Exclusion can cause legal uncertainty for the financial market. Clear, achievable and proportionate due diligence obligations for the financial sectors will lead to better financial risk management, support investors to align their activities with the evolving demands of beneficiaries and clients, and help drive private finance towards sustainable economic transition.
- See also this November 2023 PRI statement on the appropriate and practicable inclusion of the financial sector in the CSDDD
19. 13 cocoa industry representatives: “Cocoa Coalition joint position paper The proposed EU Corporate Sustainability Due Diligence Directive” (letter) (October 2023; Voice Network)
- Signed by: Fairtrade International, Fair Trade Advocacy Office, Ferrero, The Hershey Company, International Cocoa Initiative, Mars Wrigley, Mondelez International, Nestlé, Rainforest Alliance, Solidaridad, Toms Group, Tony's Chocolonely, VOICE Network
- “We believe that all companies larger than micro-enterprises /…/ in all sectors should be covered by the requirements of the Directive.”
20. 17 leading EU-based textile companies: Ignorance is risk: A business perspective on human rights and Environmental due diligence (source) (May 2023, The Parliament)
- Signed by major and smaller Textile companies, such as: s.Oliver Group, Vaude, Mammut.
- “[S]coping and assessing human rights and environmental risks is a necessary extension of all companies' actions to ensure robust value chains.”
21. GLS Bank on why financial activities should be included in the CSDDD (source) (November 2023)
- "The directive could be an important lever for more environmental protection. But only if financial institutions are included."
B. Civil society organisations
- Signed by, among others, Amnesty International, Frank Bold, Germanwatch, Friends of the Earth Europe, BankTrack, SOMO, OECD Watch, Oxfam, Fair Finance International and many more.
- Point 3: the DD provides an opportunity to fill the regulatory gap in the EU’s Action Plan on Financing Sustainable Growth, with many investors having voiced their support.
23. Letter from 50 NGOs to EU Member States: Ensuring an effective Corporate Sustainability Due Diligence Directive (letter) (November 2022; European Coalition for Corporate Justice, EECJ)
- Signed by 50 organisations, like: Transport and Environment, Oxfam, ShareAction, Human Rights Watch, Global Witness, Frank Bold etc.
- The letter urges the Council to adopt a position whereby the CSDDD "Ensures the Directive covers the full value chain including downstream impacts and the full coverage of the financial sector”. More details are in the letter.
- Supported by 76 non-profit organisations from across the globe, including different parts of the Americas, Africa, Asia and Europe.
- It demands that the CSDDD “Extends the obligation to carry out human rights and environmental due diligence to the financial sector, by requiring investors and other financial actors to identify impacts prior to providing services, as well as on an ongoing basis.”
- "We also consider it unwarranted and unjustifiable for the financial sector to have reduced due diligence obligations and for companies in high-risk sectors to limit their identification process only to the most severe harms. In line with the risk-based approach, we call for all companies to be fully covered by this law."
26. 6 non-profit organisations: Open Letter to EU member states on the inclusion of the financial sector in the CSDDD (source, letter) (October 2023; Global Witness)
- Letter signed by: ClientEarth, ShareAction, Bank Track, E3G, BHRRC and Global Witness
- Meaningful diligence obligations will help financial institutions efficiently identify and manage their financial risks, bring their activities in line with the expectations of their clients and beneficiaries, and ensure a level playing field for sustainable due diligence across the EU.
- European Commission considered financial institutions in its own impact assessment.
- The CSDDD will support and enable responsible investment and financing practices.
- The report’s findings underscore that the financial institutions in the EU have nearly four times more financial assets than non-financial companies.
- It zooms into three cases of harmful finance, which exemplify the adverse impacts that the EU laws have so far allowed financial institutions to overlook or neglect.
28. Uku Lilleväli, WWF European Policy Office, Opinion: EU lawmakers are playing favourites with financial institutions — but this could backfire (source) (May 2023; Euronews)
- Signed by: Misereor, Facing Finance, Association of Ethical Shareholders
- Signed by ShareAction, Accountancy Europe, Eurosif, Frank Bold, Finance Watch and WWF.
- Robust due diligence obligations for financial institutions in consideration of their specificities and various asset classes.
31. World Benchmarking Alliance, Our response to the European Commission’s proposal for a corporate sustainability due diligence and amending Directive (EU) 2019/1937 (source) (June 2022)
- Financial institutions must align with baseline company rules as they are key enablers of the economic system, by promoting economic growth, driving investment and employing millions of people worldwide.
32. Richard Gardiner, World Benchmarking Alliance, Déjà vu: financial sector and corporate sustainability due diligence, in or out? (source) (October 2023; Euractiv)
- CSDDD will make financial sector more reliable, consistent, and trustworthy. It will give finance a role as an accountability gatekeeper where they will move from being part of the problem to part of the solution.
- Exclusion of financial sector would undermine the foundations of the Green Deal, the Sustainable Finance Action Plan, and the Taxonomy.
34. International Federation for Human Rights, Why the financial sector must be included in the EU Directive on Corporate Sustainability Due Diligence (letter) (November 2023)
- Showcasing two case studies: French banks and pension fund supporting Myanmar military junta, and financial flows in illegal Israeli settlements.
35. European Network of National Human Rights Institutions (ENNHRI), ENNHRI Statement in the Context of the EU Trilogue concerning the EU CSDDD (letter) (October 2023)
- In line with the international standards, financial institutions should be covered. To account for the particularities of investor-investee relationships, the EU legislators can specify what measures are appropriate in this specific context as proposed by the EP.
- Exclusion of financial sector would undermine both the reach and objectives of the CSDDD, and the internationally recognised human rights responsibilities established under UN Guiding Principles on Business and Human Rights (UNGPs) and the OECD’s Guidelines for Multinational Enterprises on Responsible Business Conduct.
38. Laurent Babikian (CDP) emphasises the importance for companies to conduct due diligence on their climate and environmental impacts (source) (November 2023; LinkedIn).
- Laurent Babikian, CDP’s Director of Capital Markets for Europe and faculty lecturer at HEC Paris, supports the above letter that ClientEarth sent to President Macron.
39. OECD Watch, Strengthening alignment between the updated OECD Guidelines and legislative initiatives in the Netherlands and the EU (source) (November 2023)
- The report finds out that the Dutch bill on due diligence is most aligned with the international guidelines, and calls on EU negotiators to ensure that all legislative initiatives converge based on the OECD Guidelines, especially regarding the full coverage of the financial sector.
C. Others: Religious bodies, intergovernmental organisations, trade unions, think tanks, academics
- Proposals to exclude the financial sector from the list of high-risk sectors of the directive, or even to exclude it from its scope altogether, do not acknowledge the momentous role the sector plays in financing harmful and polluting global economic activities.
- Financial actors should be held responsible for the consequences of their investments throughout their value chains and throughout the whole duration of their activities.
- Bishops call for an introduction of effect and robust legislation that would establish mandatory human rights and environmental due diligence obligations for all companies.
42. More than 160 faith leaders unite in an urgent call for a strong EU due diligence directive (source) (July 2023, CIDSE)
- Press Release: CIDSE “Global Faith leaders unite in urgent call for a strong EU due diligence directive”
- More than 160 faith leaders worldwide signed a common statement calling for the CSDDD to be aligned with international standards.
43. United Nations Working Group on Business and Human Rights, Financial sector and the European Union Corporate Sustainability Due Diligence Directive: Statement by the UN Working Group on Business and Human Rights (letter) (July 2023)
- The Office of the UN High Commissioner for Human Rights (OHCHR) has reiterated through both its general guidance and its responses to requests for interpretation of the Guiding Principles that the underlying responsibility to respect human rights remains the same for all financial institutions, even if the means through which they meet that responsibility may differ.
- The Working Group noted that the financial sector has a particularly important role in respecting human rights consistent with the Guiding Principles. In its stocktaking exercise of the implementation of the Guiding Principles over the first decade since their adoption, the Working Group recognized that “financial actors have an unparalleled ability to influence companies and scale up on the implementation of the Guiding Principles”.
Think tanks, trade unions and academics
- UNI Global Union, the global trade union federation for service workers, and UNI Europa, the European Services Workers Union, that is also the European sectoral social partner for the finance industry. Representing 3 million finance workers around the world, half of whom are from Europe.
- "We are calling for the full and effective inclusion of the financial sector in the European Corporate Sustainability Due Diligence Directive (CSDDD) currently being negotiated by the EU. /…/ International standards have clearly established the responsibility of financial institutions for human rights due diligence."
46. Nordic Financial Unions (NFU), “On the status quo on the negotiations of the Corporate Sustainability Due Diligence Directive” (source) (November 2023)
- Through seven member unions in the bank, finance and insurance sectors in all Nordic countries, NFU represents the voice of the employees in the Nordic financial sectors, and promotes their interests in Europe.
- NFU General Secretary, Carin Hallerström: “The financial sector could ensure the implementation of these new due diligence obligations – the Nordic financial sector shows the way, as many responsible business due diligence obligations are already mandatory in the Nordic financial and insurance sectors.”
48. Le Monde: Leading figures in academia and business call on the French government to make - in the CSDDD - financial actors responsible for the social, environmental and climate-related impacts of their services (source) (November 2023)
- Signatories: Alain Grandjean, Julia Faure, Valérie Masson-Delmotte and 20 other signatories.