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Hannah Edmonds-Camara

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Hannah Edmonds-Camara advises on a range of both international and domestic employment issues including drafting and implementation of policies and compliance programmes, international employment aspects of global transactions and contentious employment matters.

She also has particular expertise in helping businesses navigate the evolving global regulatory and best practice landscape surrounding the corporate responsibility to respect human rights. Her experience includes advising on: the development and implementation of global human rights due diligence and ethical sourcing compliance programmes, including in response to pressure from NGOs, investors and regulators; human rights due diligence in an M&A context; global risk assessments; transparency and reporting requirements; design of project-specific human rights frameworks and stakeholder engagement strategies; assessment of downstream human rights risk; and conflict minerals compliance.

Hannah gained valuable experience while on secondment to a large pharmaceutical client. She is a member of the firm’s Diversity Committee, Public Service (pro bono) Committee, and Africa Initiative.

Contact: Read more about Hannah Edmonds-CamaraEmail

Those in the business of fast‑moving consumer goods (“FMCGs”) are likely aware of the plethora of environmental and product stewardship regulations applicable to the FMCG sector.  These laws are set to increase and expand in application.  What FMCG companies also need to get to grips with are a range of broader (and also fast‑moving!) environmental, social and governance (“ESG”) developments and consequent risks and opportunities.  Companies need to understand how the new world of ESG impacts their supply chains, key ingredients and components, consumer choice and confidence, competitive advantage, market accessibility, and marketing. 

Designed as a ‘primer’ for FMCG companies, in this piece, we cover a range of key trends in the emerging UK and EU ESG legal landscape as relevant for the FMCG sector, from farmers to Food Business Operators (“FBOs”) and from manufacturers to retailers.  We also discuss some key legal and reputational risks; as well as pointers to help companies decipher and prepare for the ESG storm.

We focus on the UK and the EU (first movers on many ESG issues), but the landscape in other jurisdictions (including, for example, the US) is also evolving and becoming more complex.

Key ESG Issues for FMCGs

We think there are four categories of key ESG developments for FMCGs to watch: (I) corporate reporting and disclosure regimes; (II) green/sustainability claims and labelling; (III) supply chain obligations; and (IV) product packaging and presentation.

Many emerging ESG frameworks cut across sectors.  This may be efficient for regulators, but can make identifying sector-specific risks and opportunities more challenging.  We have sought to do that below.…

Continue Reading Green Groceries: Key ESG Issues for the FMCG Industry (including FBOs)

The focus of this year’s UN Forum on Business and Human Rights was “putting rights holders at the centre” of business’ human rights due diligence efforts. In this post, ahead of Human Rights Day, we distill the important takeaways for business, drawing on Forum discussions among a range of stakeholders, including corporate representatives, governments, NGOs and rights-holders themselves.

1.  The business and human rights legal landscape continues to evolve at a rapid pace and this trajectory will continue.

Many governments worldwide are considering and implementing new human rights due diligence legislative initiatives. Aside from laws already passed and the EU sustainability due diligence initiative (see our earlier alert), there are similar proposals on the table in Spain, Belgium, Netherlands, Brazil, and other countries. Japan recently published non-binding guidance for business, intended to drive good practice.  Other countries are developing “National Action Plans” (“NAPs) under the UN Guiding Principles on Business and Human Rights (“UNGPs”), which can be a pre-curser to binding regulations. While legislative initiatives to date have largely been found in the Global North, we are also seeing movement in other regions: The African Union recently convened the first African Forum on Business and Human Rights.

While at varying stages of development and implementation, the fundamental tenets of these due diligence laws generally are similar. Companies are required to implement due diligence programs to identify and mitigate adverse human rights (and often environmental) impacts in their own operations and global supply or value chains.…

Continue Reading The 11th UN Forum on Business and Human Rights: Key Takeaways for Business

The UK Government recently announced that it is developing legislation that would make it illegal for large businesses operating in the UK to use certain commodities that have not been produced in line with local laws, and require in-scope companies to conduct due diligence to ensure that their supply chains are free from illegal deforestation…

“Businesses that have better risk mitigation processes across their supply chains cause less harm to people… Good environmental, social, and governance practices pay off… We need to make sure that responsible business conduct and sustainable supply chains become the norm.”
EU Commissioner for Justice, Didier Reynders, April 29, 2020

On April 29, 2020, in a webinar hosted by the European Parliament’s Responsible Business Conduct Working Group, EU Commissioner for Justice Didier Reynders announced that the European Commission (the “Commission”) will move swiftly to introduce regulation on mandatory human rights and environmental due diligence for companies, with its legislative proposal to the European Parliament and Council expected in the first quarter of next year.

In this alert, we provide an overview of the comments and commitments made by Commissioner Reynders against the backdrop of the recently published Study on Due Diligence Requirements Through the Supply Chain (the “Study”), which considered possible EU-wide regulatory interventions relating to human rights and environmental due diligence, and which provides the impetus for the Commissioner’s announcement.

Consultations to inform the Commission’s legislative proposal are expected to start in the coming weeks, so we also set out some initial factors that commercial organizations operating in the European Union may want to consider as they seek to engage with this policy process.

  1. Background: the Study

Commissioner Reynders’s presentation centered around the findings of the Study, which was published in late February and conducted by an expert panel that included representatives of the British Institute of International and Comparative Law, the London School of Economics and Political Science, and Civic Consulting, a public policy consultancy.

The Study involved: (i) a detailed examination of existing regulations and proposals for supply chain due diligence requirements, as well as market practices; (ii) the development of four general options for regulatory interventions at the EU level; and (iii) an assessment of the potential impact of these four options, based also on stakeholders’ perceptions of the different regulatory interventions.

In high-level terms, the Study identified and evaluated the following four options:

Option 1—No EU level policy change: This option would not involve any harmonized EU level regulatory intervention. The Study indicates that this option would be likely to result in a “patchwork” of due diligence expectations across the EU, as there are pending proposals or campaigns for mandatory human rights and environmental due diligence laws in 13 European countries, of which 11 are EU Member States.
Continue Reading European Union Justice Commissioner Commits to Regulation on Corporate Human Rights and Environmental Due Diligence

In Part 2 of our business and human rights series to mark World Human Rights Day, we discuss the increasing recognition of the linkages between human rights abuses and corruption, and how companies can find efficiencies in their efforts to address these overlapping risks.

Corruption and adverse human rights impacts are often intertwined. This was…

In Part One of our blog series to honour the UN’s World Human Rights Day, we consider the evolving business and human rights landscape and some of the challenges this presents for multinations. This piece was first published in the U.K.’s Law Society Gazette on 10 December 2019.

The theme of this year’s UN Forum…

On 4 September 2019, the U.S. Department of State (“DoS”) published draft ‘Guidance for the Export of Hardware, Software and Technology with Surveillance Capabilities and/or Parts/Know-How’ (the “Guidance”). The DoS invited public comment on the draft Guidance until 4 October 2019, after which they will publish finalised guidance.

Goal: Preventing Human Rights Abuse

While noting…

The UK’s anti-slavery commissioner resigns

On 17 May 2018, the UK’s Independent Anti-Slavery Commissioner, Kevin Hyland OBE, announced his imminent resignation. While praising the Prime Minister’s leadership in the fight against modern slavery, he expressed concern about Home Office interference with the role, and the hope that any future Commissioner would be assured of independence.…

The U.K. government has provided updated and firmer guidance on the section 54 Modern Slavery Act transparency in supply chain reporting requirement (about which see more here). Organisations are now expected to publish transparency statements ‘at most’ six months after the organisation’s financial year end. Businesses are also encouraged to leave statements from previous…

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