This submission responds to the European Commission’s consultation on guidance for implementation of the EU Corporate Sustainability Due Diligence Directive (CSDDD), August 2026.

TrustWorks has spent over twelve years working at the intersection of international humanitarian law, heightened human rights due diligence, sanctions and conflictsensitivity.

Our work spans three pillars: companies, investors, and governments and international organisations. This includes co-authoring UNDP’s Training Facilitation Guide on heightened human rights due diligence (2025), advising the governments on business engagement in fragile contexts, and supporting companies and investors directly, from board-level policy and governance through to in-country due diligence and complex stakeholder engagement in active conflict settings. This combination of regulatory and normative fluency, alongside sustained, on the ground practice, has shaped our approach to this consultation. We have responded only to the questions directly about conflict-affected and high-risk areas (CAHRAs), or with the strongest relationship to them, and have focused throughout on pragmatic, operational answers: how companies can respond to heightened risk in these contexts while protecting people, protecting the context itself, and building the resilience of their own activities.

We note that the consultation’s format and character limits necessarily result in a submission that reflects only a fraction of our team’s collective experience advising on responsible business in these challenging contexts. We would welcome the opportunity to elaborate on any point raised here should this be deemed help or necessary in the coming months.

We are also regularly invited to brief regulators, industry bodies and investor networks directly on CAHRA-related due diligence, including OECD National Contact Points, the UN Global Compact, and diverse sector- and/or industry-specific initiatives, and would welcome the opportunity to do the same in support of this consultation, whether informally or as part of a more structured process. In the meantime, we thank the Commission for the opportunity to share our insights, and we look forward to following the process as it moves forward.

For any questions or requests for further detail please contact Josie Lianna Kaye, Founder and CEO of TrustWorks Global, via LinkedIn or josie@trustworksglobal.com.