Triodos Bank is supportive of the inclusion of all financial services. The CS3D will be ineffective if it only targets corporates with respect to the impact of their business on resources and people. Triodos Bank believes it should also apply to all financial institutions providing the funding and insurance of corporates. Moreover, the directive should be applied in all EU countries without any national discretion, because financial services are by definition cross border covering the EU market.

With respect to climate change obligations, CS3D should apply to a many companies as possible and include strict requirements. A broad application of the directive is needed, because transparancy in the progress corporates are making towards a sustainable economy is needed. Also, banks require this information because they are obligated to report on and track the climate impact of their complete portfolios.

Finally, corporates and financial institutions should act if human rights or environmental standards are breached in a severe way. The approach in the OECD/UNGPs standards with respect to detecting and addressing breaches of human rights is common practice for many financial and non-financial organisations already. Including these standards in CS3D would be a confirmation of those existing practices in law.