Privacy International’s submission to the European Commission consultation on the Corporate Sustainability Due Diligence proposal


Privacy International submitted its input to the European Commission’s consultation on the proposal for a directive of the European Parliament and of the Council on Corporate Sustainability Due Diligence. The proposal seeks to impose mandatory environmental and human rights due diligence on companies of a certain size that operate in certain sectors.

Our submissions address the very limited personal and material scope of the current draft of the Directive, which is unlikely to subject the most problematic technology and surveillance companies to the new due diligence obligations.

Key advocacy points

In summary, PI is concerned that:

  • Many third-country surveillance companies can have severe adverse impacts on human rights in the EU and yet not be subject to the Directive’s due diligence duty
  • Many problematic business relationships won’t be subject to the due diligence duty as they won’t be considered “established”
  • The technology and surveillance sector is not considered “high-impact” in the current draft and therefore many of its activities will evade the due diligence duty
  • Many small companies (in terms of turnover and/or number of employees) contribute to or perpetrate human rights abuses themselves, and yet won’t be subject to the due diligence duty
  • Many companies involved in the electronics supply chain will not be subject to the due diligence duty, so that the problem of e-waste will not be tackled



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