Assessing Readiness for Compliance with the EU Corporate Sustainability Due Diligence Directive
ESG, Human Rights & Modern Slavery | read time: 2 min
As part of its on-going ethics and compliance support for one of the UK’s leading FMCG companies, GoodCorporation was asked to assess the organisation’s readiness for compliance with the EU Corporate Sustainability Due Diligence Directive (CSDDD).
The company already had human rights and supplier due diligence policies and processes in place. The challenge was therefore to assess how these arrangements compared with the requirements and expectations of the CSDDD, and where changes would be needed to strengthen its approach.
The assessment focused on the human rights requirements of the Directive across the company’s own operations and supply chain. It provided an independent view of the company’s existing approach, highlighting areas of strength and where further development may be needed to prepare for compliance.
Our approach
GoodCorporation conducted a high-level gap analysis, drawing on legislative review, benchmarking, document analysis and interviews with managers responsible for human rights and due diligence.
The assessment began with a detailed review of the CSDDD requirements alongside relevant existing legislation and internationally recognised standards. This included consideration of the French Duty of Vigilance Law, the German Supply Chain Due Diligence Act, the UN Guiding Principles on Business and Human Rights and the OECD Guidelines for Multinational Enterprises on Responsible Business Conduct. GoodCorporation’s human rights frameworks and due diligence methodology also informed the assessment.
Publicly available information from comparable companies was reviewed to provide a practical benchmark of how similar organisations were approaching human rights due diligence.
GoodCorporation then reviewed the company’s relevant policies and procedures and conducted detailed interviews with key managers and company representatives. The findings were assessed across six areas:
- Governance
- Due diligence
- Identification and assessment of actual and potential adverse impacts
- Prevention, mitigation and ending of adverse impacts
- Notification mechanisms and complaints procedures
- Monitoring
The findings were recorded in GoodCorporation’s gap analysis tool, which provided a structured assessment against the CSDDD requirements and supported the development of the final recommendations.
Client outcomes
The project gave the company:
- An independent assessment of its readiness against the human rights requirements of the CSDDD
- A clear view of existing strengths and areas for improvement across its policies, procedures and systems
- Benchmarking against peers and recognised international standards to provide additional context for the assessment
- A prioritised action plan identifying the most important improvements and next steps
- Actionable best practice examples from comparable organisations to support the development of future policies and processes
The findings were presented in a detailed report together with the prioritised action plan detailing the required steps for process improvement.
and discussed with key company representatives in a dedicated workshop, providing an opportunity to consider the findings and agree priorities for further action.
Why it mattered
Preparing for mandatory human rights and environmental due diligence requires more than understanding the requirements of the CSDDD. Companies with existing due diligence programmes need to understand how those arrangements compare with the Directive and where changes may be required.
For this client, the independent assessment identified what was already working well, the existing practices that could be strengthened and the improvements which should be prioritised.
The resulting action plan gave the company a practical basis for strengthening its human rights due diligence approach and preparing for the implementation of the new requirements.
How GoodCorporation can help
GoodCorporation helps organisations assess and strengthen their human rights and environmental due diligence systems, drawing on extensive experience of testing policies, processes and controls across multiple sectors and complex supply chains.
Our Human Rights and Environmental Due Diligence Framework provides a structured basis for assessing the effectiveness of existing approaches and identifying practical improvements. We can support organisations with gap analysis, risk assessment, due diligence design and implementation as they prepare for evolving regulatory requirements.
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