"NANHRI SECRETARIAT SUBMISSION ON THE EUROPEAN’S COMMISSION OMNIBUS PROPOSAL," 31 March 2025

With the EU being Africa’s top trading partner, [the Network of African National Human Rights Institutions] NANHRI expresses concern with the impacts of the Omnibus proposal (the Omnibus) to amend key instruments of the EU Green Deal, particularly the CSDDD adopted by the European Commission (the Commission) on 26 February 2025; in Africa where a huge volume of the cases involving corporate violation of human rights globally occur.

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This risks permitting companies to continue benefiting from high-risk supply chains through continued engagements with business partners who are committing abuses...

To ensure that the CSDDD remains aligned with the UNGPs and OECD Guidelines to the greatest extent, the NANHRI Secretariat recommends that the EU:

1. 1. Ensures that the next phase of the legislative process is undertaken transparently and on the basis of adequate stakeholder consultation and a solid evidence base, particularly the representation of African NHRIs in any future consultations on the Omnibus proposal.
   2. Upholds the risk-based approach to due diligence throughout companies’ chains of activities which is the cornerstone of international business and human rights standards.
   3. Maintain a broad definition of stakeholders, which includes NHRIs, and ensure that stakeholder engagement is central throughout the due diligence process.
   4. Maintain the original civil liability provision to ensure coherence on the conditions of civil liability across the EU and effective access to remedy for rightsholders.