International Organisation of Employers
IOE
The International organisation of Employers (IOE) is the largest and most representative network of the private sector in the world and was established more than 100 years ago.
ID: 015158824818-81
Lobbying Activity
Response to European Sustainability Reporting Standards
7 Jul 2023
[Full text attached] On 6 July 2023, the International Organization of Employers (IOE) participated in the Extraordinary meeting of the EFRAG Sustainability Reporting Board with European Commissioner McGuinness, a meeting which came in the context of the request for feedback on the draft Commission Delegated Regulation. The draft contains provisions with global implications for business and other stakeholders. In support of the efforts deployed by BusinessEurope and IOE members in the EU Member States, IOE stands ready to engage, along with its global network of some 150 Employer and Business Membership Organisations to ensure that deliberations and negotiations on this and other texts in the European Union, such as the draft Corporate Sustainability Due Diligence Directive, do not lose sight of their overall stated objectives. IOE reserves its position on the whole draft European Commission Delegated Regulation and urges the Member States expert group on sustainable finance (E03603) to revise this draft thoroughly. The approach of the current draft risks leading to a compliance only approach with no tangible results and much additional burden for companies. IOE, as the global voice of employers and the Employers Secretariat at the International Labour Organization in Geneva would like to recall the importance that current and future EU directives, regulations and policies integrate existing ILO consensus on tripartite decisions and instruments. At this stage, there are three main areas where IOE would like to provide comments: 1. Employers support adequate minimum wages and wage-setting processes that enable decent living standards. The development of cost-of-living evidence is therefore important to inform discussions on wage adequacy, including within statutory and collectively negotiated wage-setting processes. But it also means, following the 2022 ILO brief Setting adequate wages: The question of living wages (herein attached) and ILO Convention 131, to take into consideration economic factors. It is also crucial that any wage-setting process is undertaken at the national level, in a tripartite manner. Benchmarks tools and processes can be useful for global companies determining the remuneration levels of their employees. IOE is concerned that current draft provisions could amount to elevate private initiatives to the level of legally prescribed benchmarks. IOE is and will be constructively involved in global discussions, including in the ILO, on the above-mentioned wage challenges with the aim of forging wide and strong consensus. 2. IOE also believes that provisions on value chain, instead of supply chains, which was already a concern in Corporate Sustainability Reporting Directive (CSRD 2022/2464), would unnecessarily complicate the implementation of the promising ILO strategy on decent work in supply chains (GB.347/INS/8: ILO strategy on decent work in supply chains). For the supply chains, comprehensive quantitative outcome measurement is not yet feasible in practice, due to the complexity of supply chains and the associated challenges in data collection, especially from n-tier suppliers. 3. The draft requests to disclose affected communities who are likely to be materially impacted by the company in its activities, including impacts that are connected with value chain operations, as well as through its business relationships. It is unrealistic and very difficult to handle. In addition, the language used with regards to the involvement of affected indigenous populations is not in line with the ILO Convention 169 and will create strong uncertainties for companies willing to operate globally. The IOE and its global network takes this opportunity to reaffirm its commitment for tangible and meaningful progress and is ready to scale up its global efforts, if it receives the necessary support, to operationalize an IOE Centre on Human Rights and Responsible Business Conduct.
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