Identify actual and potential adverse human rights and environmental impacts, then rank them by severity and likelihood when not all impacts can be addressed at once.
Use the workflow to connect chain-of-activities evidence, stakeholder input, prevention or corrective measures, remediation, and monitoring records.
Structured answer sets in this page tree.
Cited legal and guidance references.
Under Directive (EU) 2024/1760, prioritisation starts only after the company has identified and assessed actual or potential adverse impacts in its own operations, subsidiaries, and relevant chain-of-activities business partners. The practical output is a ranked register that explains the impact, the affected right or environmental obligation, the severity and likelihood basis, the selected Article 10 or Article 11 response, stakeholder input, and evidence retained for monitoring.
Start with the CSDDD definitions. Record whether each item is an adverse human rights impact, an adverse environmental impact, or both. For human rights, identify the abused right or reasonably foreseeable risk to a protected legal interest. For environmental impacts, link the issue to the prohibitions or obligations covered by the Directive's Annex.
Map the chain of activities in enough detail to locate where the impact is most likely and most severe. The register should separate own operations, subsidiaries, direct business partners, and indirect business partners, and should distinguish upstream activities such as design, extraction, sourcing, manufacture, transport, storage, and supply from covered downstream distribution, transport, and storage.
Article 9 requires prioritisation by severity and likelihood where it is not feasible to address all identified impacts at the same time and to their full extent. Do not rank by commercial exposure alone. The register should show why a lower-revenue site, supplier, product line, or geography was escalated if the harm to people or the environment is more severe.
For severity, use the Directive's severe adverse impact definition: nature, scale, scope, irremediable character, gravity, number of affected individuals, extent of environmental damage, irreversibility, and limits on restoration within a reasonable period. For likelihood, use evidence of occurrence, credible complaints, sector and geography risk, business-partner history, and whether the activity is moving into a higher-risk product, process, or location.
After ranking, route each priority item to the right response. Potential adverse impacts go through Article 10 prevention or mitigation measures. Actual adverse impacts go through Article 11 measures to bring the impact to an end or minimise its extent, plus Article 12 remediation where the company caused or jointly caused the impact.
The response record should explain the company's involvement and leverage: whether the impact may be caused by the company alone, jointly with a subsidiary or business partner, or only by a business partner in the chain of activities; whether the impact sits in a subsidiary, direct partner, or indirect partner; and what influence the company can reasonably exercise.
Prioritisation is not just an internal risk workshop. Article 13 requires stakeholder consultation when gathering information to identify, assess, and prioritise adverse impacts; when developing prevention or corrective action plans; when deciding whether to suspend or terminate a business relationship; when adopting remediation measures; and when developing monitoring indicators where appropriate.
Use the complaint and notification mechanism as an evidence input, not a separate archive. If a complaint is well-founded, the adverse impact is treated as identified under Article 8 and should move into the register for Article 10, 11, or 12 action.
Use this workflow to structure adverse-impact scoring, stakeholder evidence, Article 10 or Article 11 response measures, remediation records, and monitoring updates.
The evidence file should let a reviewer understand why one impact was handled before another. Keep the raw evidence, the scoring rationale, the stakeholder input considered, the selected measure, the owner, the timeline, the monitoring indicator, and the reason any lower-ranked impact was deferred.
CSDDD monitoring is recurring. Article 15 requires periodic assessment of the implementation and effectiveness of due diligence measures, and the recitals describe retaining documentation such as identified impacts, in-depth assessments, prevention or corrective action plans, contractual provisions, verification, remediation measures, periodic assessments, notifications, and complaints.
"monitor the implementation and effectiveness"
"identify and address adverse human rights and environmental impacts"
"tracking implementation and results"