Overview
This paper examines risk-prioritization criteria in key EU sustainability regulations. Each of these standards adopts markedly different prioritization logics, but they converge on one constant: that conflict-affected and high-risk areas (CAHRAs) are a priority for upstream and downstream due diligence. Whether through express regulatory requirements, their inherent integration into prioritization architecture, or their close connection with salient risks such as force labor and child labor, CAHRAs emerge as a constant priority. The paper sets out what this convergence means for corporate governance, concluding that companies should prioritize CAHRAs in traceability and due diligence processes, adopt an integrated approach to prioritization, and ensure their management of conflict risks goes beyond human rights due diligence.
