Seven years after the adoption of the French Duty of Vigilance Law, and despite the fact that the European Corporate Sustainability Due Diligence Directive must now be transposed into French law, 57 French companies have still not published their vigilance plans. Yet, according to Datactivist’s research, at least 279 companies are subject to this law, which aims to prevent and remedy human rights and environmental violations committed abroad by French multinationals. 

CCFD-Terre Solidaire and Sherpa have just updated the Duty of Vigilance Radar, a citizen tool that helps monitor this law (1). This remains an extremely complex task, as no public database provides information on the structure of French groups and their workforce in France and overseas. To update the list of companies subject to the legislation, the organisations worked with Datactivist, a cooperative specialising in the opening up and analysis of data. Two databases were used: the SIRENE public database and the ORBIS financial database, but these data are fundamentally incomplete (2). 

Given this opacity, the updated list is unfortunately not exhaustive. However, it does show that several companies now appear to be subject to the duty of vigilance, including the  hard-discount chain Action France, the missile manufacturer MDBA, the pharmaceutical and cosmetics group Pierre Fabre and the SNCF. 

The analysis identifies 57 companies that have still not published a vigilance plan – as required by law – including Buffalo Grill, Euro Disney, Bigard or Picard. Primark France, which was removed from the list in 2021 due to redundancies, is now included. Although the clothing sector was particularly targeted by this so-called ‘Rana Plaza’ law, the company has still not published a plan. 

‘Simply publishing a plan is not enough, however: if its vigilance measures are inadequate, a company may be served with formal notice, or even have to answer for its actions in court,’ explains Lucie Chatelain of Sherpa.

This year, CCFD-Terre Solidaire and Sherpa have listed seven new cases, including the summons served on TotalEnergies concerning acts of torture committed at one of its sites in Yemen, and the formal notice served on Carrefour concerning its supply of tuna from industrial fisheries involved in human rights violations.

In all, 13 legal actions have been brought since the law was passed, and 30 formal notices have been sent. 

‘The European directive, which must be transposed by July 2026, should enable more companies to be covered (3). But, in the absence of measures to guarantee access to information on multinationals, identifying them and monitoring this directive could be just as arduous’, says Clara Alibert, advocacy officer at CCFD-Terre Solidaire.

Notes :  

(1) Faced with the opacity of corporate information, the Duty of Vigilance Radar was created in 2019 to try to identify companies subject to the Duty of Vigilance Law, make their vigilance plans more accessible, and help monitor the implementation of the law.

(2) SIRENE only provides information on companies (and not corporate groups), and only indicates a range of employees, and for one year only. ORBIS provides information on groups, but in a disparate manner, and without specifying whether employees are located in France or abroad. This list was then completed by adding the companies which acknowledged that they were subject to tax, as well as the companies for which manual checks could be carried out. The full methodology is described here (in French). 

(3) The directive applies to companies with more than 1,000 employees and a turnover of more than €450 million over the last two financial years, as well as to the ultimate parent companies of groups that meet these thresholds.