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.
2.
3.
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,
__ ____________________________
Paul Polman
_______________________________
Steve Howard