CSDDD Human Rights Due Diligence
CSDDD Annex lists the specific human rights and environmental impacts that companies must address through their due diligence programmes. Understanding which impacts are in scope — and which international conventions define them — is the starting point for any CSDDD compliance programme.
CSDDD Annex lists the specific human rights and environmental impacts that companies must address through their due diligence programmes. CSDDD Annex Part I lists the human rights that companies must address in their due diligence.
The human rights in scope of CSDDD
CSDDD Annex Part I lists the human rights that companies must address in their due diligence. These are drawn from the International Bill of Human Rights (UDHR, ICCPR, ICESCR) and ILO Core Conventions:
Labour rights (ILO Core Conventions): Freedom of association and collective bargaining rights; elimination of all forms of forced or compulsory labour; effective abolition of child labour; elimination of discrimination in employment and occupation.
ILO additional conventions in scope: Minimum age for employment; worst forms of child labour; equal remuneration; occupational safety and health; minimum wage.
Broader human rights: Right to life and personal security; prohibition of torture and cruel treatment; prohibition of slavery; right to privacy; right to a fair trial; right to freedom of thought, conscience and religion; right to health; right to adequate food, water, and sanitation; right to adequate housing; right to education; rights of indigenous peoples (UNDRIP).
For each right, companies must assess whether their operations or value chain relationships involve actual or potential violations — and take action where adverse impacts are identified.
Environmental impacts in scope of CSDDD
CSDDD Annex Part II covers environmental adverse impacts based on multilateral environmental agreements:
Climate: Violations of obligations under the Paris Agreement — companies contributing to climate impacts in ways that violate the agreement's objectives.
Biodiversity: Violations of the Convention on Biological Diversity — impacts on protected species, habitats, and ecosystems.
Mercury: Violations of the Minamata Convention — release of mercury and mercury compounds.
Persistent organic pollutants: Violations of the Stockholm Convention — release of POPs including PCBs, dioxins, and specific pesticides.
Hazardous waste: Violations of the Basel Convention — improper transboundary movement of hazardous waste.
The environmental scope is deliberately limited to violations of specific international conventions rather than all environmental harm. This means that activities causing significant environmental damage but not violating these specific conventions may fall outside CSDDD's environmental due diligence scope — though they may still be captured by CSRD's broader ESRS environmental disclosure requirements.
Prioritising impacts — the severity and likelihood framework
CSDDD requires companies to prioritise their due diligence efforts based on the severity and likelihood of adverse impacts — not to address all potential impacts with equal intensity.
Severity assessment: Three dimensions define severity — scale (how grave is the impact?); scope (how many people or how large an area is affected?); irremediability (how hard is it to reverse the impact?). Child labour causing permanent educational deprivation, forced labour involving physical violence, and toxic contamination of a community water supply are examples of high-severity impacts.
Likelihood assessment: How probable is the adverse impact given the sector, geography, and nature of business relationships? Agricultural supply chains in certain geographies have high likelihood of child labour; artisanal mining supply chains have high likelihood of occupational safety violations; garment manufacturing in certain countries has high likelihood of excessive overtime and wage theft.
Priority impact categories by sector: Electronics (conflict minerals, supply chain labour); Fashion/apparel (labour rights, living wages, worker safety); Food and beverage (child labour in agriculture, land rights, pesticide exposure); Extractives (community displacement, indigenous rights, pollution); Construction (migrant worker exploitation, safety).
Frequently asked questions
Does CSDDD require due diligence on climate change impacts?
Yes — climate change is in scope through Paris Agreement violations. Companies whose value chain activities contribute significantly to climate change in violation of Paris Agreement obligations must address this through their environmental due diligence. The practical implication overlaps with CSRD ESRS E1 requirements — but CSDDD requires action to prevent these impacts, not just disclosure.
How does CSDDD define child labour?
CSDDD references ILO Convention 138 (minimum age) and ILO Convention 182 (worst forms of child labour). The minimum working age is 15 (or 14 in countries with developing economies under ILO 138). The worst forms — hazardous work, trafficking, debt bondage — are prohibited for all under-18s globally. CSDDD requires due diligence to identify and address both standard child labour and worst forms.
Are corruption and bribery covered by CSDDD?
Not directly — CSDDD focuses on human rights and environmental impacts in the supply chain. Anti-corruption is addressed through ESRS G1 under CSRD and through the OECD Guidelines (referenced in EU Taxonomy minimum safeguards). However, corruption in the supply chain can enable human rights violations — bribery of safety inspectors enabling unsafe conditions, for example — creating an indirect CSDDD connection.