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ARTICLE · 16 OCTOBER 2024

Complying With CS3D—Overlooking Environmental Concerns Is A High Risk Strategy

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The incorporation of complex environmental and climate impacts from business operations and supply chains into human rights impact assessments and governance models is proving to be a major challenge for businesses.

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BACKGROUND

The incorporation of complex environmental and climate impacts from business operations and supply chains into human rights impact assessments and governance models is proving to be a major challenge for businesses. Uncertainty about the precise scope of obligations to assess such impacts has meant that companies are struggling to assess environmental and climate impact in a systemic way, which exposes businesses to future liability under the Corporate Sustainability Due Diligence Directive (the "CS3D" or "Directive"). There are notable exceptions – we have seen examples of cement manufacturers, food and beverages companies and forestry companies demonstrate a clear understanding of the environmental dimension, or "lens", but more generally, businesses need to gear up now to ensure they have in place defensible compliance strategies.

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