Duty of Vigilance— Regulation

Duty of Vigilance

A company's responsibility no longer stops at its doors. The duty of vigilance extends it to the entire value chain — and the obligation cascades well beyond large corporations.

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Companies targeted (2017 law)

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Employees — FR threshold

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CSDDD enforcement

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Cascade channels

Directly concerned

: companies subject to the legal obligation

French Law of 2017

Very large companies

Company + subsidiaries (HQ in France)

5,000 employees minimum

Company + subsidiaries (HQ in France or abroad)

10,000 employees minimum

Approximately 300 to 400 French companies directly targeted

European CSDDD

Broadening from 2027

2027Very large European companies

+ 5,000 employees / + €1.5B global revenue

2028Large European companies

+ 1,000 employees / + €450M global revenue

Several thousand European companies directly subject

Unlike the French law based on a best-efforts obligation, the CSDDD introduces an explicit harmonized civil liability regime.

The cascade effect across the entire value chain

L'obligation se diffuse par quatre canaux distincts.

Legal extension to subcontractors and suppliers

The 2017 law covers subcontractors and suppliers with established business relationships. The CSDDD goes further: the entire value chain, including indirect partners where significant risks are identified.

Contractual pressure: codes of conduct and supplier clauses

Supplier codes of conduct, reporting obligations (ESG questionnaires), audit rights and termination clauses for ESG non-compliance. Refusing to respond means risking losing the contract.

CSRD effect: data demands flow up the chain

CSRD-subject companies need structured ESG data from their suppliers. Even an unlisted SME will be asked by large clients to provide carbon, labor conditions and governance indicators.

Tenders and financing: ESG criteria become eliminatory

More and more public and private tenders include ESG criteria. Banks integrate ESG criteria in credit risk analysis. A low ESG score can lead to less favorable terms.

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The duty of vigilance is a legal obligation that requires large companies to identify, prevent and mitigate risks of serious harm to human rights, health, safety and the environment — in their own operations and throughout their supply chain.

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In France, this framework has existed since the law of March 27, 2017. At the European level, the CSDDD extends and harmonizes it across the internal market. But beyond directly subject companies, the entire value chain is affected: mid-caps, SMEs, subcontractors — the obligation cascades through law, contracts and market forces.

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Conitiv helps you structure this approach: ESG scoring of your suppliers, risk mapping, assessment questionnaires and documented action plans.

Conitiv covers this regulation
— Requirements

What the vigilance plan must cover

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Critical

Risk mapping

Identification and prioritization of human rights and environmental risks across the entire value chain — subsidiaries, suppliers and subcontractors.

Step 01
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Critical

Assessment of subsidiaries and suppliers

Regular assessment procedures for subsidiaries, suppliers and subcontractors with established business relationships.

Step 02
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Important

Mitigation and prevention measures

Concrete, proportionate actions to reduce identified risks: corrective action plans, contractual clauses, supplier support.

Step 03
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Required

Alert mechanism

Whistleblowing mechanism accessible to employees and stakeholders to report actual or potential harm.

Step 04
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Required

Effectiveness monitoring

Regular evaluation of the effectiveness of measures implemented, annual publication of the plan and its progress. Civil liability in case of failure.

Step 05

The real challenge: assessing your suppliers at scale

The duty of vigilance is not limited to your tier 1 suppliers. It can extend to indirect partners whenever significant risks are identified. How do you assess hundreds — sometimes thousands — of suppliers on their human rights, labor conditions and environmental practices?

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companies covered by ESG scoring

Three complementary approaches structure this assessment: automated ESG scoring to cover the entire portfolio, targeted vigilance questionnaires for priority suppliers, and documented audits for strategic third parties.

This is exactly what Conitiv offers: a tiered approach, proportionate to risk, centralized and traceable — to meet both the legal obligation and growing market expectations.

📧 URGENT — Données ESG requises
DA
Direction Achats — ClientXYZ
Reçu il y a 2 jours
Non répondu

Bonjour,

Dans le cadre de nos obligations CSRD, nous avons besoin de vos données ESG (environnement, social, gouvernance) sous 15 jours.

3ème relance

3 relances envoyées
Deadline : J-8

How Conitiv structures your vigilance approach

Automated ESG scoring

Automated ESG scoring

Score your suppliers across 4 ESG pillars. 7 million companies already covered. Immediate identification of at-risk third parties without declarative input.

Conitiv Dashboard
247
+12%
Tiers scorés
734
+5%
Score moyen
3
actives
Alertes
Vigilance questionnaires

Targeted vigilance questionnaires

Targeted dispatch from the platform on human rights and environmental issues. Structured, traceable collection directly usable for your vigilance plan.

Risk mapping

Risk mapping and segmentation

Visualization by supplier, sector and geography. Automated scoring for all, questionnaires for critical, audits for strategic.

Traceable evidence

Evidence centralization

History of assessments, responses, action plans — all documented and traceable to respond to formal notices or audits.

Summary: who is concerned and how ?

Large corporation (+5,000 emp.)
Direct legal obligation (2017 law)
Mandatory vigilance plan + civil liability
Large EU company (+1,000 emp.)
Direct legal obligation (CSDDD from 2027-28)
Due diligence + civil liability
Mid-cap supplier to a large group
Strong indirect exposure
Contractual clauses + client assessment
SME in a CSRD value chain
Growing market pressure
ESG data demands from principals
Any company seeking financing
Financial pressure
ESG criteria in banking conditions
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Talk to an expert

The French law of 2017 applies to companies with at least 5,000 employees in France or 10,000 internationally. It is based on a best-efforts obligation. The CSDDD is broader in scope, more prescriptive, and introduces a harmonized civil liability regime at the European level. Both texts coexist.

If you exceed the 2017 law thresholds, you are directly subject. For the CSDDD, the first companies concerned are those with more than 5,000 employees and €1.5 billion in global revenue — from 2027. But even without being directly subject, you may be assessed by clients who are.

Both texts are complementary. CSRD requires publishing structured information on your ESG risks, including those of your value chain. The duty of vigilance requires concrete action to prevent and mitigate those risks. Data collected for your vigilance plan directly feeds your CSRD reporting.

An SME is not directly subject to the legal obligation. But if it is a supplier to a large group that is, it will be assessed as part of its client's vigilance plan. The obligation cascades through contracts, tenders and CSRD reporting requirements.

With a mapping of your value chain and ESG scoring of your key suppliers. This allows you to quickly identify risk areas — by sector and geography — and prioritize your in-depth assessments. Conitiv Impact Rating covers 7 million French companies: you get immediate visibility before even sending the first questionnaire.

Ready to structure your vigilance approach?

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