EPIF is delighted to share with you its joint paper with AFME, ISDA and FIA on the Corporate Sustainability Due Diligence.

The paper highlights the serious challenges faced by financial institutions if the obligations are applied beyond their upstream supply chain to their relationships with corporate clients or trading counterparties in their downstream value chain. We have significant concerns with proposals to extend the scope of downstream financial services that would be included in the scope of the Directive. We strongly propose that any inclusion of downstream business relationships should be focused on the provision of financing where the inclusion of the services within the legislation is expected to have the greatest impact on safeguarding human rights and the environment.

We also note that Financial Institutions provide many services that can be affected very differently. In particular, payment services involve very frequent, short-term and numerous transactions and implementing a process of due diligence for each operation would result in an overly burdensome activity for financial institutions, not balanced by specific advantages for the purpose of this Directive, due to the short period of time between one operation and the next.

More details can be found in the paper below.