Shift welcomes the publication of the Draft Report on Minimum Safeguards by the Platform on Sustainable Finance, and its call for feedback on the content and recommendations. The report bypasses simplistic approaches and grapples with the challenge at the center of this endeavor, which is how to assess the adequacy of a human rights due diligence process – and how to do so at scale.

There is no single or simple way to meet this challenge, not least because current data in the public arena on companies’ social performance is not up to the task. At the same time, the report rightly notes that developments relating to EU reporting requirements are set to change that reality, and should increase the availability of high-value information. Of course, in many cases, this will still require that analysts and assurance providers have the skills to contextualize and assess that information.

We believe the report’s recommendations point in the right direction, but may require further elaboration in some instances. We also recognize that a first version of the safeguards will be – and should be explicitly acknowledged as – a starting point grounded in today’s best ‘art of the possible’, that will need to further evolve in the years to come, as available data and experience with social indicators improve.

This document contains our comments on the Draft Report on Minimum Safeguards, which were submitted to the Platform on Sustainable Finance.  

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