Caisse des Dépôts Group

The Company agrees that a legal framework is needed, seems to agree with the definition of due diligence duty provided by the Consultation

In response to question 2, the Company agrees that a legal framework is needed. it states that: 'currently, the fragmentation of soft law standards and some national regulatory frameworks does not enable the implementation of consistent and clear approaches: a level playing field is needed'. It does not explicitly express support for the definition of due diligence duty (question 14) although it states that: 'the definition appears to be a good synthesis of existing soft (OECD) and hard law (French "Devoir de vigilance").

The Company in favour of an approach for content of due diligence duty that is applicable across all sectors and conisders that SMEs should be subject to lighter requirements and receive different forms of support.

In response to question 15 regarding the content of the due diligence duty, the entity states that it "advocates for a minimum process and definitions approach as presented in option 2, complemented with further requirements in particular for environmental issues'. Option 2 consists of a minimum process and definitions approach that should be applicable across all sectors. In response to question 16 regarding SMEs, it advocates for them being subject to lighter requirements and receive different forms of support such as capacity building, funding, detailed non-binding guidelines, toolbox/national dedicated helpdesk.

The entity advocates for supervision by national authorities with a mechanism of EU cooperation/coordination. It also argues that efforts made to improve against previous years should be taken into account.

In response to question 19a about enforcement mechanisms the Company picks supervision by national authorities with cooperation/coordination mechanisms as their option (multiple choice available). It also states that: 'The effort made to reach the target and the progress compared with previous years has to be taken into account. It is necessary to adjust the deadline to the industry and to the size of the company'. It is not clear what the Company means in terms of how progress should affect enforcement mechanisms.

The entity agrees to some extent that corporate directors should be required to manage the risks for the company in relation to stakeholders and strongly agrees that directors should set up procedures and, where relevant, targets to ensure risks and impacts on stakeholders are identified, prevented and addressed.

The entity agrees to some extent that corporate directors should be required to manage the risks for the company in relation to stakeholders (question 6) and strongly agrees that directors should set up procedures and, where relevant, targets to ensure risks and impacts on stakeholders are identified, prevented and addressed (question 7). It does not elaborate further.

The Company does not take a position in relation to grievance mechanisms for all stakeholders, although it agrees that directors should be required to establish consultation channels for engaging with stakeholders.

The Company responds that it agrees to some extent to directors being required to establish consultation channels for engaging with stakeholders. It states that: 'stakeholder engagement could be more structurally established, and better structured in some cases. However, specificities of the consultation requirements should be carefully designed, as a very significant number of stakeholders could be involved for a large company and therefore drive a cost-effective but counter-productive tick the box approach'. It does not take position on whether complaint mechanisms should be promoted at the EU level.

The Company doesn't consider this a suitable option as an enforcement mechanism.

Question 19a gives multiple options for companies to pick an enforcement mechanism, and this one is not among those picked by the Company.

The Company advocates for a minimum process with defintions approach to due diligence duty (with specific considerations for environmental issues). It's position in relation to due diligence duty definition is not clear, and it does not refer to any solutions or including the full value chain.

The Company advocates for a minimum process with a definitions approach to due diligence duty (with specific considerations for environmental issues), as per its response to question 15. It is not clear it's position in relation to due diligence duty definition (question 14) as it only indicates that it 'appears to be a good synthesis of existing soft (OECD) and hard law' (French "Devoir de vigilance"), and it does not refer to remedy and including both upstream and downstream chain.

The Company indicates that it agrees to some extent to the requirement of mandatory identification of stakeholders and their interests.

In response to the question on whether corporate directors should be required by law to identify stakeholders and their interests, the Company indicates that agrees 'to some extent', without further clarification.

The Company responds that agrees to some extent to directors being required to establish consultation channels for engaging with stakeholders.

The Company responds that agrees to some extent to directors being required to establish consultation channels for engaging with stakeholders. It sates that 'stakeholder engagement could be more structurally established, and better structured in some cases. However specifities of the consultation requirements should be carefully designed, as a very significant number of stakeholders could be involved for a large company and therefore drive a cost-effective but counter-productive tick the box approach'.

The Company indicates that it agrees to some extent when asked about directors being required by law to manage the risks of stakeholders and their interests.

In response to the question on whether corporate directors should be required by law to manage the risks in relation to stakeholders and their interests, the Company indicates that it agrees 'to some extent', without further clarification.