How can European Chambers of Commerce support effective human rights due diligence?

What role can European Chambers of Commerce play in helping businesses with their human rights due diligence, especially in challenging contexts? 

IHRB Senior Advisor, Vicky Bowman, speaks to Karina Ufert from the European Chamber of Commerce in Myanmar. Against the backdrop of the EU's proposed ‘omnibus package’ of sustainability directives, Karina shares how her organisation is helping companies with their human rights due diligence on the ground. Together they explore the unique challenges in contexts like Myanmar and lessons for other Chambers of Commerce and their members. 

Vicky also speaks to IHRB colleague Sarah Mostafa-Kamel to discuss similar work being done by IHRB’s Gulf Sustain initiative, which is supporting responsible business practices and promoting worker welfare across the Arab Gulf States. 

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Host: Deborah Sagoe, IHRB's Communications Coordinator
Producer & Editor: Helen Brown
Additional Contributors: Sam Simmons, IHRB's Head of Communications

Transcript

Karina Ufert: Anyone in Brussels and elsewhere. For many companies, it's really understanding your risks. I would say also with all the warming geopolitical pressures, working hand-in-hand between the policymakers and the businesses will become crucial. We need to be one team.

Deborah Sagoe: Hi there and welcome to Voices from the Institute for Human Rights in Business, also known as IHRB. I'm Deborah Sagoe, and in this podcast you'll hear from people working to make respect for human rights part of everyday business. You've just heard from Karina Ufert, CEO of the European Chamber of Commerce in Myanmar or Eurocham for short. Chambers of Commerce represent the interest of businesses abroad. In this episode, you're going to discover how organisations like Eurochams can help businesses carry out effective human rights due diligence overseas. My colleague Vicky Bowman is the senior advisor at IHRB. She's also the founding director of the Myanmar Centre for Responsible Business. Let's hear from Vicky about the role that Chambers of Commerce and other business organisations can play on the ground in Myanmar. Vicky, you've spoken to a couple of people about the role of Chambers of Commerce in human rights due diligence. Tell me about them.

Vicky Bowman: Yes, Deborah. So I've spoken to a couple of people. The first was Karina Ufert because she's the head of Eurocham in Myanmar. And for me, that particular chamber epitomises what Eurochams can do to help businesses in really challenging situations. And of course it just so happens I know a lot about Myanmar, having been there for 10 years, heading up Myanmar Centre for Responsible Business, which IHRB co-founded. So Karina's been in this role of executive director for the last five years, since 2020, but she actually started living and working in the private sector in Myanmar in 2013 at a time when everything was looking positive. And since the military coup, which took place in Myanmar in February, 2021, four years ago, more and more companies have been joining the European Chamber because they can see that it helps them to both do their own human rights due diligence, but also to answer some of the questions that they're getting from headquarters, including that very basic question of should we stay or should we go?

But I also spoke to our colleague Sarah Mostafa-Kamel, because she is also undertaking a IHRB programme called Gulf Sustain, which we've had going in the gulf countries since 2022, building on the work that IHRB did around the Qatar World Cup and Gulf Sustain is a programme which is also aiming to build partnerships between businesses, with government, and with civil society groups to work on worker welfare in the Gulf Cooperation Council countries and working at that intersection between the green transition and worker welfare. So we're going to be hearing from Sarah about how their programme Gulf Sustain is engaging with business associations.

Deborah Sagoe: Thanks, Vicky. Now, what different business associations are doing on human rights is a hot topic at the moment, especially in Europe. Why do you think that is?

Vicky Bowman: I think, Deborah, that it's because our discussion was taking place against the backdrop of the adoption by the European Commission back in the end of February of what's called the Omnibus Package, which is a set of proposals which effectively water down some of the legislation around human rights due diligence and sustainability reporting that the EU has adopted over the last few years. And some of the, well, the reasons that the commission has done this package is because they were facing a lot of lobbying and criticism by European business associations that this legislation was too burdensome and that it was hampering growth. Now we're talking here about business associations within Europe from Germany, France, Italy, some of the sectoral organisations. And I find it strange because actually most of this legislation is not yet enforced. So I think it's difficult to predict that it's going to be so burdensome.

But what I think they were drawing on is the fact that in Germany, we've had the German Supply Chain Due Diligence Directive enforced for a couple of years. And this has been implemented by German companies by sending out blizzards of questionnaires to their suppliers, which have been driving everyone crazy. And I think it's giving human rights due diligence a bad name because actually this is not what human rights due diligence is all about. It's not paperwork, questionnaires, ticking the box. It's about a day-to-day discussion of the risks that the company faces and the potential adverse human rights impacts that a company could be having every day. And that can change with the security situation, it can change with new laws, but it's not a matter of questionnaires, it's a matter of discussion. And that's what's outlined in the UN Guiding Principles, which every company has commitment to.

And indeed it was forming the basis for everything that we were doing in Myanmar as Myanmar Centre for Responsible Business. And it's absolutely embedded in the original legislation that the EU adopted. And we were already seeing in Myanmar that the European Chamber was effectively predicting that need in legislation and helping companies on a day-to-day basis carry out human rights due diligence. So sometimes they would be having discussions and putting out information about safety issues for workers on their daily commute because if you've got soldiers at the checkpoints, you have to start thinking as a company, how can we bring them safe to work? Or we would be having discussions about things like whether or not it was a human rights abuse to be paying taxes to a dictatorial military regime. And that question of complicity, where does it kick in? So all of this is a part of the human rights due diligence that companies have been doing in countries like Myanmar and where European chambers have been playing a really important role.

And that can all be done on the ground and companies really value it. It's not a matter of bringing in expensive consultants or sending out questionnaires, it's an ongoing dialogue. But what I saw in Myanmar, I'm not sure is yet embedded around the world because there aren't Myanmar Centres for Responsible Businesses everywhere and there aren't even Eurochams everywhere. And what I would like to do in exploring with Karina and with Sarah is discuss more around how the kind of thing that we saw in Myanmar could be repeated elsewhere in the world to really help companies to do heightened human rights due diligence.

Deborah Sagoe: Thank you so much, Vicky, for that insightful scene setting. Let's hear your conversation with Karina now about the work of the European Chamber of Commerce in Myanmar.

Vicky Bowman: So Karina, welcome. We're conducting this interview in Paris where by coincidence, we both are and we're here attending the OECD's Garment [inaudible 00:06:49] Due Diligence Forum, which is an issue that we've worked on for quite some time. Now, Myanmar Centre for Responsible Business is no longer on the ground in Yangon, but when I was arrested back in 2022 and we had to close the office, it was always something that really reassured me the knowledge that Eurocham would be continuing to carry on with the kind of responsible issues that we were working on. So for a company to adjoining Eurocham, tell us a bit about who they are and what they get out of joining Eurocham Myanmar.

Karina Ufert: Most of the members across different Eurochams in the world, they're large companies, they want to come to the new market and they want to understand how does this market operate? They want to have access to information, but they also want to have access to the decision makers. And this is where I would say the European Chamber, but in Myanmar and Singapore and other places brings the most value because we also have our interlocutors and our counterparts in the government, institutions in the diplomatic sector, so we can get access to the information and quite often even push that agenda, which is important for our members. So in that sense, this was the classic, had the high-level meetings with [inaudible 00:07:55] ministers, and I would say there was a lot of acceptance to the whole idea of the European investors shaping the landscape, especially in terms of garments, agribusiness, and other groups.

But now we're quite different animal. We are 171 European companies, so it's large European companies. And I would say they come to us because they still see that operating in Myanmar is feasible for them. But I would also highlight that they come and they put themselves on the record and they kind of become visible. And this is important to me because that makes them also accountable in some ways. And when we work with engagement stakeholders, we also show that, okay, well these companies in Myanmar are open, they're open for let's say questioning criticism, how they conduct business, but also they want to learn from us, from yourself, from other stakeholders and how to do it in the right way.

Vicky Bowman: So it's a very important form of collective action really. Now we're speaking at a time when everything is a little bit up in the air concerning legislation around responsible business, and particularly in Brussels, we're waiting with, I won't say bated breath or eagerness, but we're waiting for what's been promised from Ursula von der Leyen around a competitive or an omnibus package supposedly to simplify some of the legislation that's just been adopted in this field, such as the Corporate Sustainability Reporting Directive, the CSDDD, the Corporate Sustainability Due Diligence Directive. Now it's the names that need to be simplified, I feel, rather than the actual requirements. But what I think we found, you and I working with companies both here, and also what IHRB has found is that many companies don't want this legislation changed. What they're looking for is much more around guidance, including guidance from the commission. So can you say what it is that Eurocham can bring to companies? How is it helping to bring guidance to companies who are active in Myanmar? How is it helping to help those companies prepare for the legislation that is coming into force?

Karina Ufert: Absolutely. Okay. And I think back to the whole notion of diligence note, I would say it's not even a question for most of our members, as you know. And we've been trying to highlight it to the companies because we can only represent companies as long as they can demonstrate that they act responsibly. And in that sense, no one has cancelled the UNGP Guiding Principles or OECD MNE Guidelines in that sense. So for us, the landscape in that sense has not changed. Of course, it would be good to have more clarity in terms of the legislation, its application, but certainly I would say more and more companies are saying they're quite happy that we have Myanmar because it helped us to prepare for what's coming because it helped us to really understand how our supply chain looks like.

And that's the basic of the basic. And I think this is where also working together on the garments, the fact sheet where we've [inaudible 00:10:40] we mapped out all the industrial zones and tension links, that's it, military or other concerned actors. There are some doable elements which we could put together so the companies could understand the supply chain better. And that goes for the whole variety of sectors that we as Eurocham represent, whether it's in agriculture, whether it's government, logistics and so on and so forth. And I would say it also goes beyond the human rights diligence.

Vicky Bowman: And how does Eurocham engage with trade unions and workers' organisations in particular? Because I guess that's something also which is quite challenging in Myanmar. I know it is obviously, but brands want to do it, but then they themselves are facing challenges, so what's Eurocham doing to help that?

Karina Ufert: Yeah, absolutely. I am. When we had an opportunity to have the first dialogue with one of National Union Federations, I immediately jumped on this because it's an excellent opportunity to hear from those who have the skin in the game. It's really following through on what we've promised. And our promise was that we want to bring the brands for an open discussion with the unions, and we are not going to withhold any information. We are not going to set any rules. It's an open space and we fully respect the unions.

Also, I'm grateful to the brands because, and I think this is generally key when we talk about this whole notion of due diligence, ideally we want to solve problems, right? It's not enough to say, "Okay, oh, there is an issue there and there is an instance of forced overtime or [inaudible 00:12:03]" It doesn't solve the problem to be afraid to talk about those issues. And for us, I would say it's with a continuous process of building trust and being able to keep both sides at the table. But a high instance of cases, and I think we're talking now about at least 96 cases, which we've discussed also in the last meeting over the last year. We've managed to find resolution for the vast majority of this. This just shows that in principle it is possible to work under these circumstances in the country. But I would say what is the most important is to continuously build and reinforce the trust.

Vicky Bowman: Thank you, I mean. So that's a little bit around how you're helping companies, how you're helping them in particular with dialogue, with workers, and within the garment sector, we're talking there about maybe half a million workers who are affected in Myanmar and their families who are benefiting from salaries and remittances. What else is Eurocham doing to help the people of Myanmar by being active?

Karina Ufert: I'd say a lot of things. One thing is, I always say is holding the space because there's been a lot of criticism in terms of where the company should stay or go. And I always been saying there will be people on the street coming to me and saying, "Look, if you leave and by leaving somehow the situation will change. Absolutely. We'll do this." So far the feedback we get, whether from the employees of the international companies or the broader business community, is that they won't engagement with outside world. They see the benefits of engagement with outside world, but this is in terms of the job creation, overall job creation. And they've been calculating that. Certainly the Eurocham Myanmar company is probably represented vast majority of the jobs in the corporate private sector, foreign corporate, private sector. In that sense, in some ways it's psychological. It's about being present.

It's about showing that we're not only present, but we are setting some standards, that we walk the talk. If we speak about the responsible business conduct, we're also very selective in terms of what kind of members we want to attract. This is quite interesting generally in terms of the business associations because sometimes you need to find the right balance, whether you follow what your members want or you somehow want to show a certain way. And I think what we've been trying to do in the past is a bit of thought leadership. I would say five years ago talking about the human rights due diligence was talking to a void. Very few companies would actually seriously consider this. Now it's a must. So I would say just also sensitising about how you do business in the challenging context. In the fragile context, certainly I would say big achievement, collective achievement of the chamber.

But we also work on quite practical issues, and I hope they also have a bit of a systemic change because again, we were the first chamber to highlight the importance of clarity with regards to the conscription law, again, unfortunately we're not in the situation to say that there should be no conscription law in the country. We're quite conscious about that, but we also want to make sure that there are certain procedures and clarities, and especially for people who don't feel like participating in this exercise, there should be pathways. We are not shying away from certain topics because I think by now we've realised, okay, we hopefully understood on all ends of the political spectrum in terms of the importance of creating jobs and providing opportunities for the people. But it's also a responsibility to have a say on certain issues, which of essence beyond the European private sector, same for the VPN, the use of the VPN. Also, we've put a couple of papers in terms of ensuring, again...

Vicky Bowman: This is the [inaudible 00:15:30] Security Law, which has been a long time coming, it's been on the horizon. Do you want to say a bit about what that's involved and what Eurocham has done around advocacy?

Karina Ufert: Absolutely. That's one of the examples. Again, it's nothing to do with the government or anything else, but in Myanmar, certain new laws and regulations that come on a regular basis. I think for me, coming from Eastern Europe that was mentally prepared to deal with certain laws and regulations, especially related to the censorship, the cybersecurity laws been in the making for a couple of years now, and it's just been a question [inaudible 00:16:03] actually will be enacted.

But again, what sometimes happens in Myanmar is the law can be quite generic. Same with the conscription law. In there are countries which have this in place, same with the cybersecurity law. I mean the analogues in many other countries, including China and elsewhere in the region. The tricky part comes with implementation because very often gets misinterpreted, especially by the low ranking employees. And unfortunately it also puts people in a very difficult situation in terms of potentially misaligning with the law and then also facing penalties. So again, for us, this is another area we ask for clarification and we ask the exemptions, and we also point the example, look for us as a business to run in the properly. And also with respect to our own policies and the overall understanding of how this environment should work, we need to retract on some issues or at least get the clarification.

Vicky Bowman: So you've laid out a lot around how Eurocham is helping companies, helping the people of Myanmar. I think I can assume that therefore your view on whether or not companies should stay or go and Eurocham should continue or not is one of staying. But this is very much a live debate and a lots of European companies come under pressure from media campaigns, NGO campaigns back in their home countries saying, "Why are you still in Myanmar?" So what advice, what helped you give companies who come to you saying, "Karina, should we responsibly exit?"

Karina Ufert: Do your due diligence. This is back to anyone in Brussels and elsewhere. For many companies, it's really understanding your risks and it's case by case. And then certainly in some sectors we wouldn't even accept companies or we openly say, "Look, this is where you can't mitigate those risks." And this is what the, I would say, the honest exploration of your own operations and [inaudible 00:17:49] can bring up. And that's the thing. Unfortunately, exit or as some call responsible exit is potentially is one of the ways out of the situation.

But I would say this has to be based on a very extensive exercise, the consultation with the stakeholders and almost understanding of how your supply chain is organised, how your partners organised, how many people will be impacted, how are you going to mediate these impacts and so on, so forth. I would say for companies in Myanmar, now diligence is the licence to operate maybe in some specific sectors, whether it's in services where I would say the footprint is quite minimal, but for anyone with operations, with manufacturing, logistics and elsewhere, it's really about understanding the context and your impact, but also the impact of potential withdrawal in that sense.

Vicky Bowman: So this has made Eurocham Myanmar an expert in heightened human rights due diligence in challenging contexts. And considering those adverse impacts of staying or going, there are other challenging contexts in the world, some of them sort of top of the agenda, some of them kind of a low boil. What advice would you give Eurochams in other countries about how to help companies to manage the human rights risks related to their operations?

Karina Ufert: Absolutely. I think first of all, go beyond CSR because I still see a lot of institutions, organisations very much focusing on the whole CSR agenda and then the best CSR awards, which is fantastic. Again, we want to highlight, we want to emphasise that indeed the business, it's not only for profits, it's about the broader implications. But again, I mean, I think we are still all leaving in this sense of denial that we can get the audited, auditable [inaudible 00:19:23] of the paper, or we can put data in the CSRD reporting, and that's it. Now, it's more, it's really about investing and understanding how and why you're operating. And it's interesting for me because I've started now in executive MBA back in Copenhagen, and it's interesting to see that companies are really struggling with this. And I think this is where the chambers who have presence on the ground, who are in the position to also build a strong network of stakeholders and to get this local knowledge and to really track different sources of information can come in and say, "Well, look, I mean, we think that potentially this is a risk."

"We want to look into this bit more." It's about the collective action. It's perhaps putting some of the companies together in the [inaudible 00:20:03] which we do at Eurocham, and then also working on the sectorial basis and understanding, okay, well wages could be one thing, right? That's something. But companies in the collective action, and we both know how difficult it is, but in that sense, for Myanmar, it's now becoming a risk in terms of the levels of the wages.

But again, it's a collective action that potentially can bring a solution. And whether it's, again, it's in the context of Myanmar or in other contexts, there are issues. Unfortunately, Myanmar is an extreme case in that sense. But to say that there are no issues in the region or even in some instances in Europe and elsewhere is also quite impossible. And this is where, again, the European chambers or the chambers in principle have a very good knowledge. It's about just going then one step further, taking yourself out of the comfort zone of let's say the CSR awards or overall general engagement on the principles of let's say, due diligence or running some maybe events on circularity, which is all important, but moving towards the complete due diligence circle in that sense.

Vicky Bowman: And you touched a bit earlier on the MADE in Myanmar Programme, which is funded by the European Commission, which brings us to that question of what should governments, particularly European governments be doing in this area? What advice would you give to them about what's needed from them, what their particular role is?

Karina Ufert: Certainly companies have questions. It's relatively new, and I fully understand that there is a hesitation among the companies about this new coming legislation because everyone has their own degree of acceptance, comfort and so forth, understanding the whole political landscape. And unfortunately, sometimes the governments don't always get the business language, and it goes both ways. I would say an example for us to engage with diplomatic missions in Yangon was quite important. And we found that there is a lot of acceptance from the diplomats back there to understand the business, to understand our issues, and to also work together on certain tools including MADE in Myanmar and some others, which could help companies to be responsible in their respective domains. So I would say also with all the warming geopolitical pressures, working hand in hand between the policymakers and the businesses will become crucial. We need to be one team.

We need to sort of align in terms of, okay, so this is what we expected. And I do hope that we'll be able to also keep the moral compass on the right side, not the politically right, more progressive side, and not only political understanding and willingness to engage with the private sector, including the private sector in the third markets. Because again, I would say there's a huge gap between the Euro-based associations and those in the [inaudible 00:22:33] but also some financial supports, right? Because I would say MADE in Myanmar, without the financial support of the EU, it would be really difficult to pull this project off. And I would say in terms of the value for money, it's quite clear because it's about ensuring that the companies could operate responsibly, but ultimately the ones who benefit other workers. And it would be perhaps impossible without the involvement of policymakers.

Vicky Bowman: Thank you. So Karina, I mean, we've covered a huge field of action, and you and I are here in Paris now, but next week we'll be in Brussels. And I think both of us feel that the experience of Eurocham Myanmar and Myanmar Centre for Responsible Business, IHRB more broadly in Myanmar has been probably a really important teaching moment for the implementation of human rights due diligence on the ground and the role of different players. So thank you very much for sharing your insights from the field.

Karina Ufert: Thank you.

Vicky Bowman: Okay, so let's zoom in on another region now, which has its own set of challenges. The businesses who want to conduct human rights due diligence. Gulf Sustain, as I mentioned earlier, is an initiative from IHRB, and it's based in the Gulf Cooperation Council countries, six countries in the Gulf, and seeks to be part of an ecosystem of other organisations, which are helping businesses with their human rights due diligence in the area. So I'm joined now by Sarah Mostafa-Kamel, who is currently leading IHRB's Gulf Sustain Programme. So Sarah, tell me a little bit about the IHRB's Gulf Sustain Programme. What is it? Where is it? What are you hoping to achieve?

Sarah Mostafa-Kamel: So we're a regional initiative launched by IHRB, and our goal is really to advance responsible business practises and to promote worker welfare in the Gulf Cooperation Council countries. So Bahrain, Kuwait, Oman, Qatar, Saudi Arabia, and the UAE who are currently undergoing economic diversification plans to reduce their reliance on oil and gas. And so what we really want to achieve is to make sure that Fair Labour practises are at the centre of these economic diversification plans.

Vicky Bowman: And so what kind of things are you doing in those different countries? I guess they must all be very different.

Sarah Mostafa-Kamel: Yes, they're all very different. They're definitely not a monolith, and so we really adapt to local context. So for example, in Saudi Arabia, we have hosted closed-door dialogues with European businesses, with Swiss businesses. We've partnered with the European Chamber of Commerce in Saudi Arabia to discuss some of the difficulties and tensions that these businesses are facing in the region when they're trying to respect international standards and make sure that they're able to bring those in to Saudi Arabia and the tensions that exist within that.

Vicky Bowman: Can you give me then a few specific examples of business and human rights issues in different countries that IHRB is hoping to help companies engage with? And what are you planning to do?

Sarah Mostafa-Kamel: Yeah, so I mean, for example, in Saudi Arabia, Saudi Arabia right now has over 60% of its population under 30 years old. And so they're facing a lot of internal pressure towards Saudization, promoting employment for Saudis, for young Saudis looking for work. So we want to make sure that in that process, migrant workers aren't left behind, that there is opportunities for reskilling and upskilling and training because the country still will heavily rely on migrant workers, especially as we approach the World Cup, all of the mega and giga projects.

And then in Qatar, it's a bit different because there have been huge advancements in terms of labour reforms leading up to the last World Cup. And IHRB did a lot of work there around responsible recruitment in the hospitality sector. However, there is still a lot of work to be done to make sure that migrant workers' voices are heard through joint committees. There's a lot of work happening around that. So there's a lot of opportunity everywhere to make change. In the UAE, it's seen as a much more business-friendly environment to the international world, but that doesn't mean that there isn't work to be done in terms of labour reforms.

Vicky Bowman: And how about Oman, which is a country that's off most of our radar screens. What are you hoping to do there?

Sarah Mostafa-Kamel: Yeah, so Oman, we've had close collaboration with foreign embassies, but also oil and gas companies. There's a lot of discussions around human trafficking and forced labour. So a lot of our emphasis in Oman will be to ensure that we can prevent human trafficking and forced labour in businesses mainly. But that's really the focus in Oman. So given the challenges and the differences in each of the GCC nations, we've been really able to adapt and recognise that our work has to adapt to each local context. But we do have a wider and broader vision as Gulf Sustain for the region. And that's by driving engagement and bringing a diversity of stakeholders together, continuing to produce research and produce knowledge and co-creating solutions with stakeholders for the region. We plan to continue playing a critical role in supporting businesses as they balance their economic growth with worker welfare and responsible business practises at the centre.

Vicky Bowman: So the companies are very conscious that they're increasingly being expected to do human rights due diligence on the ground, and having those conversations facilitated by IHRB is helping with that. So in addition to some of the organisations like the chambers that you've mentioned, are there any other organisations that are helping with this discussion?

Sarah Mostafa-Kamel: Yes, the ILO is an example. Foreign embassies, the UN Global Compact Network and other UN agencies as well. And then oil and gas companies. So all of these stakeholders are very invested in these discussions, and there's definitely a lot of traction on the ground to reflect on these questions, and we've been able to provide safe spaces to have these discussions, which are very sensitive in the region.

Vicky Bowman: That sounds really interesting. Well, I'm looking forward to seeing how it evolves over the coming years, not least because some of my former staff from Myanmar are now working in the Gulf region. So any initiatives there that are going to help them to work safely and in fair working conditions will be excellent as far as I'm concerned. So thank you very much, Sarah for sharing that.

Sarah Mostafa-Kamel: Thank you, Vicky.

Deborah Sagoe: So there are plenty of organisations out there to help businesses. Vicky, what are your top takeaways from these conversations?

Vicky Bowman: So I think the first takeaway is that there's a huge appetite from businesses for help on human rights due diligence, whether that's about ensuring that the migrant workers in their supply chains aren't experiencing modern slavery or working out how to keep themselves, keep their employees safe online, living in a dictatorship. And what I've heard from Karina and potentially from Sarah too, is that businesses want to work with their peers and they want to find safety in numbers. And one of the first places they will usually turn to is the local business association, usually the chamber of commerce. And although, I mean traditionally those chambers were very national, you had the French Chamber of Commerce where you could always get the best cheese. The Italian Chamber of Commerce, the Norwegians served up smoked salmon, and they were busy promoting their own national businesses. I think what there is nowadays is much more of a role for European chambers because there is this common regulatory requirement, either as European businesses operating overseas or when you are trying to put goods on the European market.

And it really is something that a role that only European chambers can play. And that role I think is increasing because not only have we got those human rights sustainability reporting directives, the CSDDD, the CSRD, but we're seeing European regulations on issues like batteries, on things like deforestation, which impacts on chocolate, on forced labour, which is something of significance, particularly to the garment industry in Myanmar. But in many manufacturing and agricultural industries elsewhere, online safety and all of these kinds of European requirements require companies to be doing due diligence on their supply chains, including things like the mineral and the agricultural commodities that are ending up in their products. And I think it's much easier for businesses, companies to understand these issues when they do the analysis collectively. It's also more efficient, it's cheaper. And that's why I think we're also seeing Eurochams starting to be set up in countries where previously they weren't.

So there's a new one that's just popped up in Bangladesh in December, 2024, and the one that Sarah's working with in Saudi only got going in May, 2024. However, a lot of these chambers, I don't think necessarily are set up with human rights expertise. And that's where there's a real role for them to partner with organisations like IHRB in the Gulf, like MCRB in Myanmar, to help facilitate some of these discussions. And sometimes also to generate collective action. That could be advocacy to a host government because it's really powerful when businesses collectively advocate for human rights to a host government. It's much more powerful than when an NGO does, and the government will tend to dismiss that. But if businesses say "We need you to protect human rights if we are to be able to operate responsibly.", that's a very powerful message.

Deborah Sagoe: I heard Sarah mention embassies as one of their partners for Gulf Sustain. What about governments? What do you think is the role of governments in this area?

Vicky Bowman: So I believe that both governments, obviously the host government, as I mentioned, has that duty to protect through good laws, but embassies have a really important role to play in supporting businesses and nudging them, nudging them towards the chambers, and also through the National Action Plans that governments are all meant to be adopting under the UN Guiding Principles. Generally, they have something in there that identifies the role that their embassies will be playing in advising on the human rights risks in the third countries where they're based. So for example, the government of Switzerland, which supports IHRB with the Gulf Sustain Programme and was one of the funders for MCRB, they've just adopted their third national action plan in December. And it very much talks about the role both directly and through organisations like ourselves that they have for supporting their businesses, Swiss businesses, on improving their human rights due diligence.

But it's not just actually the European ones. You can see if you go and look on there, there's a website called globalnaps.org, and you can see all of the different governments who have developed national action plans. So you've got the Japanese, the Koreans, the Thais, the Indonesians, and all of those have got a commitment in there that they're going to use their embassies and their networks to encourage their companies to respect human rights in their overseas investments and in their supply chains.

And a major part of that, I think, is about getting the local chamber of commerce to be active on this issue and bring everyone together. So I think there's a really big role for embassies also in promoting dialogue within country stakeholders. Embassies quite often will have a whole network of labour rights organisations, environmental NGOs, and some of those will be organisations that the embassy is supporting financially, but they can also be a bridge to put those organisations in front of the companies when the companies are coming to them saying, "We want to engage with stakeholders as part of our human rights due diligence." So yeah, I think embassies should be keeping themselves busy with all of this.

Deborah Sagoe: Thank you so much, Vicky, for talking to us about chambers of commerce and human rights due diligence, and also thanks to Karina and Sarah for navigating us through the sources of help that businesses should look to when conducting human rights due diligence, particularly in challenging contexts. And thank you for listening to this episode of Voices, which is brought to you from the Institute for Human Rights and Business. Until next time, be sure to share and follow this podcast. That way you will never miss an episode. And if you'd like to find out more about the work that we do at IHRB, then head to ihrb.org.