Duty of Care

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Duty of Care (French: Devoir de Vigilance) is a legal concept requiring corporations to prevent human rights violations and environmental damage throughout their operations and supply chains. France's 2017 Law on the Duty of Vigilance represents the most comprehensive implementation of this principle.

Definition

A duty of care establishes that entities with power over others bear responsibility to:

  • Identify potential harms their activities may cause
  • Implement measures to prevent those harms
  • Respond when harms occur
  • Accept accountability for failures

This contrasts with systems where harm must be proven before responsibility attaches.

The French Law on Duty of Vigilance (2017)

Background

The law emerged from decades of corporate human rights abuses:

  • Rana Plaza factory collapse (Bangladesh, 2013): 1,134 deaths
  • Child labor in supply chains
  • Environmental destruction by subsidiaries
  • Tax haven structures avoiding local responsibility

Previous approaches (voluntary guidelines, corporate social responsibility) failed to create accountability.

Key Provisions

The law requires large French companies to:

  1. Establish a vigilance plan covering:
    • The company itself
    • All subsidiaries
    • Suppliers and subcontractors with established commercial relationships
  1. The plan must include:
    • Risk mapping
    • Regular assessment procedures
    • Mitigation actions
    • Alert mechanisms
    • Monitoring systems
  1. Scope of covered risks:
    • Human rights violations
    • Fundamental freedoms
    • Health and safety
    • Environmental damage

Enforcement

  • Companies failing to establish plans can be ordered to comply
  • Victims can sue for damages when harm results from inadequate vigilance
  • Burden shifts: company must prove adequate prevention measures

Covered Companies

  • Companies with 5,000+ employees in France
  • OR 10,000+ employees worldwide (including French subsidiaries)
  • Approximately 150-200 companies affected

Why This Matters

The Accountability Gap

Traditional corporate law creates an accountability gap:

Entity Control Liability
Parent company High (sets policy, profits) Low (separate legal entity)
Subsidiary Medium Limited (often undercapitalized)
Supplier Low Bears most direct liability
Workers None Bears the harm

Duty of care closes this gap by attaching responsibility to those with power.

Beyond Voluntary Measures

Approach Limitation
Corporate Social Responsibility Voluntary; no enforcement
Industry codes Self-policing; weak sanctions
Shareholder activism Requires investor alignment
Consumer boycotts Inconsistent; information asymmetry
Duty of Care law Mandatory; legal enforcement; victim recourse

International Developments

The French law has inspired similar initiatives:

European Union

  • Corporate Sustainability Due Diligence Directive (CSDDD)
  • Adopted 2024
  • Applies to large EU companies and non-EU companies with significant EU revenue

Germany

  • Supply Chain Due Diligence Act (Lieferkettensorgfaltspflichtengesetz)
  • Effective 2023
  • Covers companies with 3,000+ employees (1,000+ from 2024)

Other Jurisdictions

  • Netherlands: Child labour due diligence law (2019)
  • Norway: Transparency Act (2022)
  • UK: Modern Slavery Act (2015) — disclosure only
  • Australia: Modern Slavery Act (2018) — disclosure only

Connection to OMXUS

The duty of care principle aligns with OMXUS values:

Prevention Over Punishment

Like Justice as Prevention, duty of care emphasizes preventing harm rather than punishing it afterward. The system requires:

  • Anticipating risks
  • Implementing safeguards
  • Continuous monitoring

Structural Accountability

OMXUS implements accountability through architecture:

  • Cryptographic verification of actions
  • Transparent decision trails
  • Universal witness networks

Duty of care laws implement accountability through legal structure:

  • Mandatory vigilance plans
  • Legal liability for failures
  • Victim access to courts

Power Implies Responsibility

Both frameworks share a core principle: those with power bear responsibility for its effects.

OMXUS Duty of Care Law
Token holders respond to emergencies Companies prevent supply chain harms
Vouchers responsible for those they vouch Parent companies responsible for subsidiaries
Proximity weighting links influence to impact Scope extends to commercial relationships

Critique and Limitations

Challenges

  • Scope limitation — Only largest companies covered
  • Enforcement resources — Courts need expertise in international supply chains
  • Proof difficulties — Linking harm to inadequate vigilance
  • Jurisdictional limits — French courts judging global supply chains

Responses

  • EU directive expands scope beyond France
  • NGO litigation support
  • Specialized judicial training
  • Extraterritorial application precedents

Case Studies

TotalEnergies (Uganda Pipeline)

  • Lawsuit filed under duty of care law
  • Allegations: forced displacement, inadequate community consultation
  • Status: Ongoing litigation (2024)

Suez (Chile)

  • Water rights and environmental concerns
  • First judgment under the law
  • Outcome: Court ordered compliance with vigilance obligations

See Also

References

  • Assemblée Nationale. (2017). Loi relative au devoir de vigilance des sociétés mères et des entreprises donneuses d'ordre. Law No. 2017-399.
  • Business & Human Rights Resource Centre. (2023). French Corporate Duty of Vigilance Law: Frequently Asked Questions.
  • European Commission. (2022). Proposal for a Directive on Corporate Sustainability Due Diligence.
  • Sherpa. (2021). Vigilance Plans Reference Guidance.
  • UN Human Rights Council. (2011). Guiding Principles on Business and Human Rights.