Heidi Hautala Joins Enact: An Interview on Due Diligence, from Law to Practice

Heidi Hautala, former Vice-President of the European Parliament and former Finnish Minister for International Development and State Ownership Steering, have joined Enact as a Senior Advisor in October 2026. We asked her about her move from legislation to working with companies, the EU Corporate Sustainability Due Diligence Directive (CSDDD), and what companies should focus on now.

After many years shaping legislation, why did you choose to work with companies directly, and why Enact?

I left the European Parliament at the moment when the CSDDD had been adopted. I was ready to move on anyway, and very specifically wished to see how the new EU corporate sustainability regulations could best be implemented. (Of course, little did I know how much the Omnibus would occupy everyone, due to the new narrative portraying sustainability as being against competitiveness.) I also wanted to see if my long involvement in human rights and environmental issues could be useful. Having lots of experience in all kinds of political processes might also be an asset. Enact is exactly what I wished for. I am very happy to join this incredible team as an adviser. I can fully endorse the mission and professionalism of the company. Besides, I like the Nordic way of doing things.

You founded the European Parliament’s Working Group on Responsible Business Conduct, which brought together companies, civil society and MEPs from different political groups. What did those conversations teach you about what companies actually need to do due diligence well?

Companies need to make their best efforts and show that they are improving their due diligence. It is always best to admit problematic issues. Industry initiatives are really important, especially when going further down the supply chain from tier 1.

Some call you the ‘mother of the CSDDD’. What are your hopes for its implementation, and what will be one of the most critical success factors?

I am certainly one of the mothers, or perhaps rather the grandmother, because the baby saw the light of day only some years after we started to mobilise for what would be born as the CSDDD… A very important factor for success is the unprecedented collaboration and ownership of the large and diverse network, which reaches beyond Europe. I am the first to admit that there should have been better anticipation of the implementation challenges and even the unintended consequences of the law. Concerns of producer countries, especially in the Global South, should have been met earlier with development cooperation.

EU sustainability rules have changed significantly over the past year. What should companies hold on to regardless of where the legislation lands?

95% of those involved think that the outcome of the ‘simplification’ of the CSDDD is still a milestone. A bit unexpectedly, the last hours of negotiation brought the risk-based approach back, and this matters more than the dilutions and cuts. It means that companies need to gain visibility all the way below tier 1. The UN Guiding Principles on Business and Human Rights (UNGPs) are a good source for clarifying what needs to be done and how.

Member States now in the transposition process should check national law against international standards where there is room for national leeway, without fear of being accused of ‘gold-plating’.

“Companies’ worst critics can often be their best source of information.”

Many companies still treat due diligence as a compliance exercise. Where have you seen it make a real difference, both for the people affected and for the business itself?

There are many digital and AI tools to map the value chain, and these can save time and paperwork. What companies should not save on is ‘meaningful stakeholder engagement’. It is necessary to step out of the head office and reach out to understand and respond to the company’s impacts on people and the environment. Companies’ worst critics can often be their best source of information. The reliability of intermediaries is becoming an acute issue when so many audits fail.

A focus on compliance is natural now that the new rules come with enforcement. In this turbulent world, it would be crucial to integrate compliance with sustainability and supply chain risk management. A real difference can be made when top management is on board, when sustainability is truly incorporated into the business strategy. Nordic companies are definitely at the forefront of this.

As Finland’s Minister for International Development and State Ownership Steering, you worked on the governance of state-owned companies. What role should public owners and public buyers play in responsible business conduct?

The oversight of state ownership in the Finnish government was probably my most difficult but also most rewarding experience. It was very difficult to satisfy all owners and stakeholders. Every week, there was a new crisis. TeliaSonera had a major corruption scandal, Finnair gave controversial stay bonuses, a mine was leaking, paper and pulp factories were closed while paying high dividends to shareholders… In these situations, it was important to encourage management and boards to act responsibly, as the state as owner expected.

I see the Swedish regions as a role model for all public buyers. It is necessary to ensure that the current revision of the EU Public Procurement Directives includes a mandatory clause on human rights and environmental due diligence. While working on the CSDDD, I saw this as the next challenge. Requiring due diligence from private actors while leaving the public sector with some good wishes does not add up.