Subject: Request for Comments on the IOE Draft Submission to the UN on Corporate Governance and Business & Human Rights

Dear ECOT Members,

The International Organisation of Employers (IOE) is seeking comments from employer organizations worldwide to contribute to a submission to the UN Working Group on Business and Human Rights, which will be included in a report to be presented at the 81st session of the United Nations General Assembly.

The report aims to examine how corporate governance systems should be linked with Business and Human Rights under the framework of the UN Guiding Principles on Business and Human Rights (UNGPs).

Key points from the IOE draft position

1️⃣ UNGPs should remain the primary framework

The UNGPs emphasize three pillars:

• The State duty to protect human rights
• The corporate responsibility to respect human rights
• Access to remedy when harm occurs

2️⃣ A single global corporate governance model should not be imposed

• Legal systems and corporate governance structures vary across countries
 • New legal liabilities for company directors should not be created unnecessarily

3️⃣ States must fulfill their responsibilities first

IOE emphasizes that governments should create an enabling environment for responsible business conduct, including:

• Clear legislation
 • Effective judicial and labour systems
 • Proper enforcement of laws
 • Providing guidance for companies, particularly SMEs

4️⃣ Human Rights Due Diligence (HRDD) should follow a risk-based approach

HRDD should not be based on a one-size-fits-all checklist, but should depend on factors such as:

• Company size
 • Business sector
 • Supply chain structure
 • Level of risk exposure

5️⃣ More reporting does not necessarily lead to better outcomes

IOE cautions that excessive disclosure and reporting requirements may lead companies to devote significant resources to preparing reports, rather than conducting effective due diligence in practice.

6️⃣ Potential unintended consequences of excessive regulation

If regulations become overly burdensome, companies may choose to “cut and run”—that is, withdraw from high-risk countries—rather than “stay and behave” and contribute to improving working conditions on the ground.

7️⃣ Remedy mechanisms should primarily be provided by the State

Examples include:

• Courts
 • Labour tribunals
• Labour inspection systems
• Grievance mechanisms

Responsibility for remedy should not be shifted entirely onto companies.

ECOT would appreciate members’ feedback on the following issues:

If your organization has experience or suggestions, please kindly share your views, for example:

1️⃣ Whether your company has implemented Human Rights Due Diligence (HRDD)
2️⃣ Key challenges in implementing HRDD, particularly for SMEs
3️⃣ Whether international regulations or standards (such as HRDD, ESG, or supply chain laws) affect Thai companies
4️⃣ Any examples of good practices that should be reflected in the report

📅 Kindly submit your comments by 12 March 2026
so that ECOT can compile members’ inputs and forward them to IOE.

Thank you very much in advance for your valuable comments and cooperation.