Smart‐Mix or Stupid Assurances? How Businesses Used Voluntary Initiatives to (De)Legitimize Supply Chain Regulation

Maria‐Therese Gustafsson, Tim Bartley, Simon Pierre Boulanger Martel and John Murray

Global Policy, 2025, vol. 16, issue 5, 1051-1062

Abstract: Mandatory human rights and environmental due diligence (HREDD) policies seem to represent a pathbreaking shift from voluntary measures to binding rules for global supply chains. Yet these policies endorse a “smart‐mix” of voluntary and mandatory measures, and risk over‐reliance on questionable private‐sector assurances. In this paper, we ask how businesses framed these private/voluntary efforts in the face of looming regulation, focusing on the EU's new Corporate Sustainability Due Diligence Directive (CSDDD). Through a systematic coding of policy positions, we find businesses (1) using voluntary initiatives to delegitimize mandatory measures, (2) seeking to institutionalize voluntary norms, (3) pushing for private assurances to signify legal compliance, or (4) endorsing mandatory measures to protect the competitive advantage of sustainability leaders. While frames (1) and (4) shaped the debate, we argue that frames (2) and (3) are more fully reflected in the final text of the Directive. We explore both theoretical and practical implications.

Date: 2025
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