Putting people and the planet at the core of business

Consultation responses

CORE’s responses to UK government and other consultations

CORE and Partners Submission to Modern Slavery Act Independent Review

Friday, October 26th, 2018

CORE Coalition, Amnesty International UK, Anti-Slavery International, the Business & Human Rights Resource Centre, Fairtrade Foundation, Freedom United and ShareAction have made a joint submission to the Home Office’s commissioned independent review of the Modern Slavery Act.

Our submission highlights the shortcomings of the Transparency in Supply Chains provision of the Act (s.54) with regard to weaknesses of the reporting requirement, in combination with inadequate monitoring and enforcement. It recommends that that the Act is strengthened through a) improved monitoring and enforcement mechanisms and b) a revision of the reporting provisions, including ensuring that the Act is used to promote responsible procurement practises and to require that companies carry out human rights due diligence throughout their operations and supply chains.

You can read the full submission here.

CORE Submission to BEIS Insolvency and Corporate Governance Consultation

Wednesday, July 18th, 2018

CORE has made a submission to the Department for Business, Energy & Industrial Strategy consultation on Insolvency and Corporate Governance. The consultation comes in the aftermath of the collapse of construction giant Carillion and the associated concerns that UK plc are not sufficiently resilient.

CORE’s submission holds that companies will only avoid taking the risks the lead to insolvency when directors can be held to account for their failings. Moreover, the corporate governance framework should be restructured to ensure companies are run in the interests of all their stakeholders, not only shareholders. Firms that are run only to provide short-term returns to shareholders will not make responsible decisions in the interests of the long-term success of the company.

You can read the submission here.

CORE Submission to Treasury Select Committee Economic Crime Inquiry

Tuesday, May 8th, 2018

CORE has made a submission to the Treasury Select Committee Economic Crime inquiry. In the submission we recommend that:

  • the Government extend its ‘failure to prevent’ model to cover all economic crime;
  • the Government establish a central database of companies that have faced criminal sanction or are under investigation;
  • that the Committee push the Government to indicate when it intends to publish its response to the call for evidence on economic crime, and whether it has any plans to task the Law Commission with reviewing the overall corporate liability framework in the UK.

You can read the full submission here.

CORE Submission to Foreign Affairs Select Committee Inquiry on 'Global Britain' Policy

Tuesday, April 17th, 2018

Since the Brexit vote, Government ministers have been clear that Britain is not withdrawing from the world stage. Ministers often refer to ‘Global Britain’, but in its report the Committee found that ‘Global Britain’ had not been precisely defined and Ministers could not say what it meant. The Foreign Affairs Committee is now holding an inquiry on the Government’s ‘Global Britain’ policy, how it might be implemented in practice and whether the Government, and the FCO in particular, has the resources available to deliver it. CORE’s submission argues that human rights must be at the heart of any reinvigorated foreign policy.

Executive Summary:

  • Government must restate ongoing commitment to the promotion and protection of human rights and labour rights as part of its Global Britain policy, particularly in the face of temptations to neglect existing standards to secure trade deals.
  • Defending the ‘rules-based international system’ must involve the protection of human rights as international human rights and humanitarian law are the cornerstone of that system.
  • Trade deals must be used to strengthen, not weaken key values and commitments as the UK leaves the EU. Placing human rights at the centre of a Global Britain policy will aid this.
  • Government should go further by removing investor-state dispute settlement provisions from trade deals and improving sustainability impact assessments.
  • The FCO should develop its capacity to integrate business and human rights considerations into their support for UK businesses overseas.
  • A cross-departmental and strategic approach will be necessary to develop policy coherence in putting human rights at the heart of the Global Britain policy.
  • Strengthen existing FCO work on Overseas Business Risk documents and protecting Human Rights Defenders.
  • The UK should engage constructively with the open-ended intergovernmental working group on transnational corporations and other business enterprises with respect to human rights and continue to encourage foreign states to implement the UN Guiding Principles on Business and Human Rights.

Download the submission »

CORE & Amnesty International UK respond to call for inputs by UN Working Group on Business and Human Rights

Thursday, March 15th, 2018

In response to its call for inputs to the UN Working Group report on ensuring respect for human rights in the context of state involvement in ‘economic diplomacy’ and trade and investment promotion, CORE and Amnesty International UK have made a submission.

The submission focuses in particular on the policies of the Department for International Trade, the Foreign and Commonwealth Office, and UK Export Finance in relation to ensuring respect for human rights.

Download the submission »

CORE & Amnesty International UK Joint Submission to the FRC Consultation on Proposed Revisions to the Corporate Governance Code

Thursday, March 1st, 2018

CORE and Amnesty International UK have made a joint submission to the Financial Reporting Council (FRC) consultation on proposed revisions to the Corporate Governance Code and Stewardship Code.

Corporate scandals both here and abroad have highlighted the systemic problems with the UK corporate governance model. The recent collapse of Carillion, for instance, illustrated the significant social costs that result from corporations run only in the short-term interests of their shareholders and directors’ pay packets.

The proposed revisions to the Corporate Governance Code take steps in the right direction, but do not go far enough. Our submission argues that company boards must integrate a wider set of considerations into their decision making processes including workers, external stakeholders and the environment. Only then will companies focus on their own long-term success and the benefits they can create for society as a whole.

The submission also addresses:

  • The proposals to put workers on boards/ proposed ‘workforce engagement mechanisms’.
  • Performance-related pay and the suggested extension of remuneration committee’s powers.
  • The need for both the Corporate Governance Code and Stewardship Code to refer to international human rights norms, including the UNGPs and OECD Guidelines for Multinational Enterprises.
  • More stringent guidelines for investors on how to carry out their stewardship responsibilities.

Download CORE and Amnesty International UK’s Submission »

Submission to Public Accounts Committee Inquiry: 'Reducing Modern Slavery'

Friday, February 16th, 2018

Following the National Audit Office report examining what progress the Home Office had made in reducing modern slavery, the Public Accounts Committee has launched an inquiry into the effectiveness of measures introduced under the Modern Slavery Act 2015. CORE submitted evidence to the inquiry with comments on the efficacy of the TISC reporting requirement and the provisions for supporting victims of slavery and human trafficking. In the submission, CORE recommends that the Government:

  • enable victims to pursue compensation claims
  • publish a list of companies covered by TISC
  • create & maintain a registry of statements
  • require companies to report on all six areas under s. 54 (5) of the Act
  • mandate a public authority to deal with reports of non-compliance and sanction non-reporters
  • extend the reporting requirement to the public sector

The oral evidence session will be held on Wednesday 21st February.

Download CORE’s Submission »


Submission to the Joint Standing Committee on Foreign Affairs, Defence and Trade for the Inquiry into Establishing a Modern Slavery Act in Australia

Thursday, June 22nd, 2017

CORE and partner ICAR, the US coalition of human rights groups working on corporate accountability, have submitted a response to the Australian Government regarding its proposals to establish a Modern Slavery Act.

The joint submission urges the Australian Government to draw on UK modern slavery legislation, and to promote ethical corporate practice by:

  • Requiring companies to publish annual modern slavery statements;
  • Ensuring that the reporting requirement covers a company’s full operations including supply chains;
  • Requiring high-level approval of modern slavery statements and publication on companies’ homepages;
  • Producing Government guidance on companies’ reporting responsibilities.

Download the report »

Response to the Call for Evidence on Economic Crime

Wednesday, April 5th, 2017

CORE welcomes the call for evidence on corporate liability for economic crime.

The Government has acknowledged that the UK’s corporate liability regime is not fit for purpose in the 21st century.

To overcome current gaps in the law and to satisfy public demand for corporate accountability, CORE is calling for statutory changes to replace the outdated identification doctrine with a regime that reflects the realities of modern business operations.

We support the introduction of a new corporate ‘failure to prevent economic crime’ offence which would put the onus on companies to prove that they have the right procedures in place to prevent a catalogue of white collar crimes including, false accounting, money laundering and fraud.

Bold legal reform is need if the Government is to fulfil its promise of getting ‘tough on irresponsible behaviour in big business’.

Download the report »

Response to the Corporate Governance Green Paper

Monday, February 20th, 2017

CORE welcomes the publication of the Green Paper and the opportunity to respond. This response covers sections 2-4 of the paper.

In the decade since the overhaul of company law, it has become apparent that the current framework of enlightened shareholder value, combined with a voluntary Corporate Governance Code and an emphasis on ‘culture’ has failed to address egregious corporate malpractice and to provide collective and individual accountability for management failures. New corporate scandals continue to come to light almost daily and public trust in business remains historically low.

Only genuine reform, not minor adjustments and more voluntary schemes can address these issues.

Download the response here

Joint CSO Open Letter to Thun Group Banks on Human Rights Respsonsibilities

Thursday, February 16th, 2017

An open letter in response to the Thun Group’s recent paper considering Principle 13 of the UN Guiding Principles on Business and Human Rights (UNGPs), from BankTrack and 34 other signatories from international civil society and academia.


Download the report »

CORE submission to the Joint Committee on Human Rights' inquiry into human rights and business

Thursday, July 7th, 2016

CORE’s submission to the Joint Committee on Human Rights’ inquiry provides evidence on the UK’s implementation of the UNGPs.

Download the report here>>

CORE Response to The Non-Financial Reporting Directive consultation

Tuesday, April 19th, 2016

A response to the Department for Business, Innovation and Skills consultation on the Non-Financial Reporting Directive: A call for views on effective reporting alongside proposals to implement EU requirements.

Download the report >>

Letter to the UK’s Permanent Representative to the EU on ESG risk management in the Shareholder Rights Directive

Wednesday, December 23rd, 2015

Click here to read full text>>

CORE submission to the Tackling Exploitation in the Labour Market consultation

Tuesday, December 8th, 2015

A response to the Department for Business, Innovation and Skills consultation on tackling exploitation in the labour market.

Download the full report >>

CORE Submission to inform the revision of the UK's National Action Plan on Business and Human Rights

Tuesday, August 4th, 2015

CORE’s submission to the government’s review of the UK’s National Action Plan on Business and Human Rights, including analysis of the document’s current deficiencies and recommendations for improvement.

Click to download our full set of recommendations >>

CORE response to the Modern Slavery and Supply Chains consultation

Friday, May 8th, 2015

A response to the Home Office consultation on the scope of the transparency in supply chains clause of the Act, and comments on the proposed content of the statutory guidance.

Download the report >>

CORE submission to the Joint Committee on Human Rights on the Modern Slavery Bill

Tuesday, September 16th, 2014

The submission makes a series of recommendations to strengthen the Bill to improve corporate transparency and accountability. The document outlines the steps companies should take to minimise the risk of the most serious labour rights violations within their supply chain.

Download the report »

Second submission to the Drafting Group on Human Rights and Business of the Council of Europe

Tuesday, September 16th, 2014

Comments and suggestions from Amnesty International, ECCJ, FIDH, CORE and Sherpa on the Draft Recommendation of the Committee of Ministers to member States on human rights and business of 22 August 2014.

Download the report »

UNWG Consultation on National Action Plans - Submission on Remedy

Tuesday, September 2nd, 2014

The International Corporate Accountability Roundtable (ICAR), CORE, and the European
Coalition for Corporate Justice (ECCJ) emphasise that, in the development of National Action Plans (NAPs), States must first conduct National Baseline Assessments (NBAs) and then commit in their NAP to close identified gaps through legislative or other regulatory means.

Download the report »

UNWG Consultation on Substantive Elements of National Action Plans

Tuesday, September 2nd, 2014

This submission offers the perspectives of The International Corporate Accountability Roundtable (ICAR) and The Danish Institute for Human Rights (DIHR)—with the support of the Corporate Responsibility Coalition (CORE), the Centre for Research on Multinational Corporations (SOMO), and the European Coalition for Corporate Justice (ECCJ)—on the open public consultation document released by the UN Working Group, entitled Practical and Substantive Considerations in the Development and Enactment of a National Action Plan to Implement the UN Guiding Principles on Business and Human Rights.

Download the report »

European Commission's strategy on CSR 2011-2014

Tuesday, August 12th, 2014

The Commission launched this public consultation in order to receive feedback on the
implementation of its most recent policy on Corporate Social Responsibility (CSR), which
is outlined in the Communication “A renewed EU strategy 2011-14 for Corporate Social
Responsibility” (COM(2011) 681).

CORE states its support for the Commission’s new definition of CSR which has helped to set minimum expectations in the international setting. CORE identifies the weaknesses in the agenda for action, makes recommendations for the next steps and underlines why CSR is important for companies and society as a whole.

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Joint submission to the Drafting Group on Human Rights and Business of the Council of Europe

Thursday, July 3rd, 2014

The response expresses support for a Council of Europe non-binding instrument focused on access to justice and closely related issues. Such an instrument should essentially deal with State–based judicial mechanisms given the Council of Europe’s long-standing expertise in this field and since other instruments have already provided important guidance on companybased grievance mechanisms.

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Response to UK Export Finance consultation

Wednesday, April 16th, 2014

Changes to the UK government’s powers to support exports and investments must fully reflect the environmental, social and human rights dimensions of UK Export Finance’s activities.

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Submission to the Joint Committee on the draft Modern Slavery bill

Monday, February 10th, 2014

CORE welcomes the draft Bill which presents an important opportunity to introduce much-needed legislative measures as a necessary first step to improving corporate transparency and accountability for the most serious labour rights violations in the supply chain.

Download the report »

Comments on ‘Exposure Draft: Guidance on the Strategic Report’ (Financial Reporting Council)

Wednesday, November 20th, 2013

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Submission to ‘EU Proposals to reform non-financial reporting: call for evidence’ (Department for Business, Innovation and Skills)

Tuesday, October 1st, 2013

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Submission to 'Corporate responsibility: a call for views' (Department for Business, Innovation and Skills)

Friday, September 27th, 2013

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Submission to 'Transparency and trust: enhancing the transparency of UK company ownership and increasing trust in UK business' (Department for Business, Innovation and Skills)

Friday, September 13th, 2013

CORE and the Environmental Law Service

This briefing relates to the UK government’s Department for Business, Innovation and Skill’s Company Ownership Transparency and Trust Discussion Paper, Q.39: The merits of strengthening responsibilities of banking directors by amending the directors’ duties in CA06 to create a primary duty to promote financial stability over the interests of shareholders.

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Response to 'The future of narrative reporting: a new structure for narrative reporting in the UK' (Department for Business, Innovation and Skills)

Wednesday, November 21st, 2012

CORE’s response to “The future of narrative reporting: a new structure for narrative reporting in the UK”.

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