Brief, Brilliant, and Indispensable: Matt Campobasso on Building a Strong Legal Team

Joining Enfusion in 2020, Matt Campobasso was the third attorney to join the growing company’s legal department. Since that time, Matt, who assumed the role of general counsel and corporate secretary in November 2022, and his team have evolved the legal function from one that was overwhelmingly reactive to one that approaches risk in a proactive and “upstream” manner in order to prevent problems before they arise. Along the way, Matt has helped Enfusion transition from a private company to one that was listed on the New York Stock Exchange through its October 2021 IPO. Matt’s values and guidance drive the legal team’s work, urging them to “be brief, brilliant, and indispensable”.

Enfusion’s legal is committed to finding solutions and not saying no unless there is no other way. The team strives to build solid relationships with every part of the organization. As Matt points out, “Knowing the law is not enough, Enfusion’s lawyers must know our company, our products, and our market.” For companies with a profile like Enfusion’s, which do not have a legal department with unlimited resources, Matt’s focus is “keeping the trains running on time, but also finding the time to look forward and lay the train tracks that will allow the business to scale and grow efficiently and, in a risk-aware manner”.

GC Magazine: How do you anticipate your role as general counsel evolving to meet Enfusion’s growing demands? 

Matt Campobasso (MC): As Enfusion continues to grow, my role as general counsel focuses increasingly on scalability and strategic risk management. I am a member of Enfusion’s executive committee, risk management committee, and co-chair of its global operating committee. In those capacities, I benefit from front line visibility into all key aspects of our business, which helps me and my team to remain proactive in managing legal risk and planning for future resourcing and initiatives. We are a lean team relative to Enfusion’s overall size, but I am proud of the way that we employ concepts like range (not overspecializing, but rather bringing a broad perspective and interdisciplinary approach to our day to day) and upstream thinking (being proactive rather than reactive to emphasize preventing problems rather than cleaning up after them).

GC Magazine: Legal departments are viewed differently by different companies. Can you share how you maintain value in Enfusion’s legal department and control legal costs?

Matt Campobasso (MC): We maintain value in our legal department by aligning our objectives closely with the overall goals of the company. This includes employing a proactive legal strategy of thinking upstream, which anticipates potential legal issues and business risks before they arise. We control costs through a mix of in-house capabilities and strategic outsourcing, ensuring that we use external counsel judiciously and focus on building expertise in areas most critical to our business. Additionally, we invest in training and technology to streamline operations and enhance the efficiency of our legal processes. When you are supporting a business like Enfusion with operations in various counties and with more than 1,000 employees, efficiency is as important as effectiveness.

GC Magazine: Do you have a method to building a legal team with the right skills to support the business?

Matt Campobasso (MC): Building the right legal team starts with understanding the core needs of the business and the specific challenges we face in the fintech industry. I focus on recruiting diverse talent with a mix of traditional legal skills and sector-specific knowledge, but the one thing that I emphasize more than anything else when we hire, is a growth mindset. There are a lot of smart lawyers out there in the world and I have been fortunate to bring many of them to Enfusion to build out our team. But intelligence is only half the battle – you need people on your team that prioritize extreme ownership and a desire to drive every situation to the best outcome even if that means going outside your job description. You cannot teach that and that does not show up on a resume. We also emphasize continuous learning and development, encouraging our team to stay current with industry trends and legal technology. This approach ensures our team is not only proficient in the law, but that it is also equipped to handle the unique challenges of a rapidly evolving fintech landscape.

GC Magazine:Are there any philosophies or ideas which underpin your ‘lawyering’ style?

Matt Campobasso (MC): One of my core philosophies is the belief in proactive, rather than reactive, legal guidance. I also believe in the power of clear communication and collaboration, ensuring that legal advice is accessible and actionable for non-legal colleagues, thus fostering a culture of compliance and informed decision-making across the company.

I look at my legal experience as a differentiating characteristic rather than a defining one. I am a businessperson first and a lawyer second. Don’t get me wrong, I am a lawyer and I know what I am here to do on behalf of Enfusion and its shareholders, but the primary lens that I view every situation through is to ask, “how can I help us accomplish our business and strategic objectives?” That allows me to search for the right path forward rather than to list the reasons we cannot or should not do something. Another of our guiding principles is for each member of the team to “be someone who finds solutions; not someone who says ‘no’.”

GC Magazine: What are some of your proudest recent achievements as a legal team?

Matt Campobasso (MC): I have been with Enfusion since September 2020, and I could write a book on the things that the legal team has accomplished during that time. As I look back to the start of my time, I am most proud of the evolution of our legal function during the last three plus years. When I joined Enfusion, we were a private company, and I was the third lawyer to join the company. Today, we are publicly traded, and I lead a team of nine lawyers. In 2020, the team was very reactive (as a byproduct of where the company was in its growth journey) and focused on putting out fires. In 2024, we are more proactive than ever and hyper focused on fire prevention.

Another thing that I am very proud of the team for is the way that we leave every situation we are brought into better than we found it. Sometimes that is from a legal perspective, but often, it is more than that and the situation is better from a legal and business perspective due to the commitment and degree of ownership that my team brings. To say that I am proud of each member of my team is an understatement. I learn from my team every day and leading this team has been the honor of my career.

GC Magazine: Which current trends are you anticipating will impact general counsels and their teams in the fintech space?

Matt Campobasso (MC): As the general counsel of a publicly traded international company, the only constant in my days seems to be change. The changing of the law. The changing of the global economy. The changing of our industry and what our clients need from us in order to be successful. And the changing of what our business needs and expects from us.

The trends that I spend a lot of my time thinking about include data privacy and security; emerging technologies like artificial intelligence and machine learning; anti-money laundering (AML) and know your customer (KYC) compliance; and safeguarding intellectual property. The world is changing rapidly, and businesses have to adapt or die. It is the job of my team and I to ensure that when Enfusion rapidly adapts, it does so in a way that protects the business, our clients, and our shareholders. When you stand out in front of our business as I am required to do as General Counsel, you have no choice but to keep your eyes on the horizon and to see around corners.

Editorial:
Melissa Yebisi, Editor GC Portfolio (USA)

Stress test – partners on how they deal with a life under pressure

‘The personality types attracted to law often highly value accuracy and delivering the “perfect” answer, but that single-minded goal can be almost impossible in our business – it’s something that can be detrimental to your health and your relationships with your team and family.’

As Hogan Lovells’ UK managing partner Penny Angell explains, the challenge of reconciling Type A personalities with work/life balance is a puzzle that most top law firms have not yet solved. Continue reading “Stress test – partners on how they deal with a life under pressure”

The China conundrum – why so many US law firms are pulling out

Once seen as the next big thing for all self-respecting international law firms, China is now seeing a wave of retrenchment by US firms, with Morrison Foerster the latest to close an office in Beijing – Alex Ryan spoke to those who know the market to find out why

As statements of intent go, they don’t come much bolder than Dentons’ groundbreaking 2015 tie-up with China’s Dacheng. In one move the firm became the biggest in the world by headcount, with the verein combination bringing together more than 6,500 lawyers and granting Dentons access to what was then seen as the must-have market for truly global firms, dwarfing the efforts of many UK and US players to build up a presence in the country. Continue reading “The China conundrum – why so many US law firms are pulling out”

Great minds don’t think alike – why LGBTQ+ allyship is a business must-have

Pride Month is here again; corporate social media profiles are awash with the colours of LGBTQ+ pride, drag queens are braving office lighting for bingo events, and rainbow flags, lanyards and badges are all over the City.

Since the first Pride parade in London in 1972, three years after the start of the gay rights movement in New York following the Stonewall riots, the concept of Pride has grown from its protest origins to a colourful celebration of queerness, and, to some more cynical eyes, a marketing opportunity. Continue reading “Great minds don’t think alike – why LGBTQ+ allyship is a business must-have”

‘Is it going to destroy humankind? No. The good parts are worth pursuing’

AI may appear to be a relatively nascent development but in reality this is far from the case. John McCarthy first coined the term back in 1956, and since then we have seen IBM’s Deep Blue and Watson machines beat chess and Jeopardy champions, and Apple create its virtual assistant, Siri. Now, the rise of generative AI models such as ChatGPT have not only significantly changed the performance of AI but have also caught the attention of the mainstream media, exploding into the public consciousness with their accessibility. Continue reading “‘Is it going to destroy humankind? No. The good parts are worth pursuing’”

‘Justice for all’: FTSE 100 GCs push for pro bono engagement with UK In House Pro Bono Pledge

With the erosion of legal aid, the cost of living crisis and an increasing business focus on ESG, the role of pro bono legal advice is increasingly in the spotlight. In response to escalating demand, leading GCs have banded together to launch a scheme they hope will rise to the challenge. Continue reading “‘Justice for all’: FTSE 100 GCs push for pro bono engagement with UK In House Pro Bono Pledge”

Much More Than Law: From General Counsel to Business Visionary

In the early stages of Chris Ghazarian’s education, a pre-law course at the University of Southern California offered by Professor Charles Whitebread changed his life trajectory. Professor Whitebread noted Chris’s knack for jumping to conclusions outside the class’s legal scope. Chris wrestled with this feedback at first, assuming it was criticism. In his words, “it was difficult to reach legal conclusions and then stop thinking ahead”; he wanted to apply them to “bigger, grander ideas.” Before long, Professor Whitebread would comment on Chris’s potential to achieve “much more than law” for the same reason.

Chris later discovered this to be a passion – taking stable legal principles and weaving them into visionary ideas that drive business forward and shape the world. This passion intersects with his professional journey, as general counsel at DreamHost, and now leading all operations, creating synergy between business strategy, core compliance teams, and the legal sphere.

GC Magazine: Can you elaborate on how your role at DreamHost has changed since you began? Do you see the role evolving even more?  

Chris Ghazarian (CG): Embracing change and growth whenever I felt too comfortable or predictive was one of my biggest growth-oriented decisions early in my career. I had to feed my desire to grow and achieve higher goals, and I am fortunate to have a CEO and board of directors who have trusted me and provided multiple opportunities throughout my ten years at the company.

Today, I lead all operations at DreamHost, and my new role includes leading a new M&A team, a growth and partnerships team, the IT team, a local operations team, and an international initiative. My time is also spent architecting the company’s strategy, gearing up for the next three to five years of innovation and change.

My goal now surpasses merely managing these teams successfully; it is about inspiring innovation within them to impact DreamHost’s trajectory and propel us forward. The tech industry is at an inflection point, with automation and AI revolutionizing consumer products. This transformation also involves websites and domain names, and I will drive this innovation and change alongside our CEO and board of directors. Together, we are preparing our 27-year-old company for a new era of success.

GC Magazine: As you have taken up broader responsibilities at DreamHost, do you see that intersection between business and legal happening when it comes to other general counsel?

Chris Ghazarian (CG): I once said “Lawyers are blockers; leaders are closers.” Any general counsel worth their salt will inevitably discover and influence the crossover between law and business. To lead and grow, an attorney must step out of their comfort zone and act on the legal conclusions they reach. This is challenging for attorneys because, unfortunately, we are taught to spend most of our precious time analysing the law. However, we are rarely taught to take a conclusion and apply it to real-world decisions that shape a company’s growth path.

It is at this crucial point where GCs can find success in their careers: mastering the art of looking beyond “legal” and, instead, making decisions that inspire customers to buy products, partners to join efforts, and team members to innovate.

GC Magazine: There are many styles of ‘lawyering’, especially in an in-house role, how would you describe your approach to supporting DreamHost?

Chris Ghazarian (CG): Simplicity and Vision.

Those two words overwhelmingly define my approach to law and business, and they are infinitely more powerful than legal acumen alone. My teams will laugh when they read this, but I say “zoom out” or “big picture” a few dozen times during weekly meetings. Most attorneys spend hours bogged down in complex, multi-angle situations with too much research and analysis without ever coming back up for air. They might give the CEO a 15-page memo providing endless analyses of a single issue without a concrete path forward.

The CEO does not have time for that. They need one concise, clear answer supported by solid reasoning, and to know that the GC will stand behind the decision 100%, without question, every single time.

Think of it as a form of art: can you find the simplest, sexiest solution to a massively complex problem?

Simplicity is also the key. I always ask, “What does our customer expect?” Better yet, “What do I expect as a user?” Why introduce complexity when you can guide customers through a seamless, enjoyable process? Many attorneys fail by trying to cover every possible base, turning law into a chore and overcompensating with myriad legal disclaimers that all say the same thing. That is why you encounter 44-page “terms of service” agreements before playing Call of Duty or ordering pizza from the Domino’s app (Note: I’ll hire you on the spot if you’ve ever read one of those from start to finish).

Finally, I have never believed in offloading legal work to outside counsel. Since I joined DreamHost in 2013, our legal billables have fallen by almost 90%. Why? Because I internalize and learn from every legal situation, embedding those insights within our team. This way, we do not need outside counsel for repeat issues; we already have the playbook and can execute it ourselves. This approach has been key to my growth at DreamHost, transforming outside counsel into an occasional mentorship tool and empowering us to be more self-reliant and innovative.

GC Magazine: Can you share one of your proudest accomplishments as an in-house lawyer recently?

Chris Ghazarian (CG): Seeing my team transcend traditional legal roles and take ownership of key strategic relationships as businesspeople first makes me smile. They’ve learned to push projects across the finish line – not just in legal matters, but in areas like technology, products, and technical support. My team members have grown into leaders, driving crucial business initiatives from start to finish while seamlessly integrating their legal expertise along the way. It is moments like these that highlight the true potential of an innovative, forward-thinking legal team, and the reason I will never stop pushing for creativity to be at the forefront of every hire’s mind.

One recent win, for example, was the kick-off of our international compliance strategy that saved the company just over $2m in potential regulatory costs and fees. We understood the regulatory landscape and mitigated the risks, and it paid off quite a bit in a short amount of time.

GC Magazine: Lawyers admit it is challenging to sell the value of legal departments to companies. What do you do to prove your value?

Chris Ghazarian (CG): Even a non-business-oriented lawyer can demonstrate value in traditional categories: cutting outside counsel billables and reducing regulatory exposure.

But, a business-first lawyer can achieve so much more. We create value, close deals that bring revenue, and drive M&A strategies that strengthen the company in less competitive areas.

A business-savvy lawyer transforms marketing issues into customer growth opportunities. We leverage analytical skills to tackle not just legal and regulatory challenges, but also to navigate financial pitfalls, refine product pricing, and penetrate foreign markets.

I integrate all these aspects, providing my CEO and board of directors with comprehensive viewpoints and actionable decisions that I own from start to finish. My team and I often solve complex regulatory issues, address customer pain points, and manage data privacy concerns in the same sitting, ensuring our discussions are both strategic and actionable.

I often hear leaders excel at one or the other: planning and architecting vs. executing the plan. I have never believed these to be mutually exclusive. A leader should do both: plan from start to finish, and then own the process to deliver the result. I cannot rest easy unless I see a decision through to success.

GC Magazine: Are there any trends that you anticipate for the next generation of lawyers based on your teaching experience with younger lawyers?

Chris Ghazarian (CG): Absolutely. I see a significant shift incoming; one where future lawyers spend far less time typing contracts and redlining documents. Instead, both in-house counsel and law firm attorneys will dedicate more time to engaging directly with products, fostering creativity, and generating ideas that drive business growth.

The legal profession is evolving rapidly, and technology is already making mundane the art of combing through documents, linking case law, and analyzing thousands of data points to reach a single conclusion. Automating these routine tasks will free lawyers to focus more on strategic activities – something I believe companies will begin to increasingly demand. After all, what is the point of hiring in-house counsel if new legal technology can provide your basic legal needs for a tenth of the price?

GC Magazine: How do you see the current technological landscape, with AI and other emerging technology, impacting general counsel roles and their teams?

Chris Ghazarian (CG): The general counsel’s role is evolving at an unprecedented pace. Where it once took years for general counsel to transition from being in-house lawyers to key executive members, they can now scale quickly and accomplish massive amounts of work within their teams — even small ones.

Companies are also demanding that GCs have more interdisciplinary skills. Beyond business and product knowledge, a deep understanding of technology, products, and customer needs, particularly as influenced by AI, will be crucial. The world is shifting at a staggering pace, and customers now expect full-service solutions to complex problems—”just do it for me” will soon be the norm. This means general counsel must keep up with an evolving environment more than ever.

This technological shift also means the GC’s role will become more dynamic and integrated into core business functions. If the next generation of lawyers can recognize this and pivot their skills accordingly, they will play an important—no, a crucial—role in shaping the future of their organizations.

Editorial:
Melissa Yebisi, Editor GC Portfolio (USA)

ESG Colourwashing – why leadership with integrity is necessary to combat corporate hypocrisy

In his soon to be published article, ‘ESG Colourwashing: Combating Modern-day Corporate Hypocrisy’, which Timo co-authored in conjunction with his colleague and former student Klemen Kreča, he describes how consumers and investors are increasingly demanding the introduction of sustainable practices and, in turn, even though they may not be “born-believers” as regards the creation of sustainable value, corporations are introducing Environmental, Social and Governance (ESG) factors into corporate decision-making. As ESG has become the new benchmark of corporate sustainability, this has meant, unfortunately, that corporate hypocrisy is rife. Some companies may try to avoid ESG implementation costs by simply sugar-coating the status quo or wilfully creating false impressions about their underlying business models and their actual efforts to integrate sustainable practices.

Anna Bauböck (AB): How can implementing ESG criteria create value for companies, and is it beneficial for all industries and business models?

Timo Spitzer (TS): The implementation of ESG criteria, ie economic, social and governance policies, creates both direct as well as indirect benefits for the company. Direct benefits include a boost in employee morale (improvement in both efficiency and productivity), attraction of better talent, enhanced returns, decreased costs (mostly due to better energy consumption) and easier access to government funding.

Furthermore, due to changing consumer and investor preferences, the implementation of ESG criteria can also lead to indirect benefits such as, among others, increased consumer loyalty, higher revenue, better equity and debt financing opportunities as well as reduced market volatility.

Nevertheless, not all industries and business models are alike. Certain industries such as coal mining are simply inherently unsustainable, while other industries may see only small benefits compared to the still considerable costs of implementing ESG criteria into day-to-day business operations.

AB: Why is the appearance of ESG compliance potentially more lucrative for companies than actually implementing ESG principles?

TS: The implementation of ESG principles comes with significant costs. For most companies, such costs may already be outweighed by the direct benefits, and even further enhanced by the indirect benefits, such as gaining favour from sustainability orientated investors and consumers. However, this may also create a moral hazard when for some companies, the direct benefits of ESG implementation may not outweigh the costs of implementation, or at least not right away. For such companies it may be more beneficial to simply create false impressions about having incorporated ESG metrics into the business model, thereby still gaining indirect benefits, whilst not having to bear any of the associated costs. This is called “ESG colourwashing”, when companies claim to promote sustainability goals, eg social progress, equality, environmental awareness, and diversity, while in reality they are merely sugar-coating the status quo in order to win over consumers and investors who want to support ESG principles.

AB: Why are ESG disclosure rules not enough to prevent companies from colourwashing their ESG credentials?

TS: Disclosure obligations are based on the idea that under full market transparency consumers and investors will be able to ensure companies are ESG compliant. However, ESG colourwashing is not a case of informational asymmetry, where better informed market players could easily penalise non-conforming companies, but rather a case of intentional deceitful action. Companies are wilfully trying to misrepresent their business model to obtain financial gain from consumers and investors.

It is naïve to think that a company that is actively trying to deceive consumers will be stopped just because it has to disclose information. Disclosure laws cannot prescribe for all scenarios, and companies will still be able to find ways to circumvent such laws. Moreover, disclosure obligations are hindered by various drawbacks: i) only certain market participants are bound by disclosure obligations; ii) obligations are triggered only in limited situations; iii) disclosure is often accompanied by enormous bureaucratic burdens; iv) the actual reporting requirements may be shrouded in uncertainty; v) companies often need to hire expert consulting firms, which further drives up their costs; and vi) disclosure standards are not universal means, creating an uneven playing field in a globalised market.

AB: What are some of the problems with existing regulatory actions and enforcement systems?

TS: The European Union is currently leading the charge in combatting ESG colourwashing, and not only through mandatory disclosure obligations. The existing consumer protection legislation and even ex ante labelling mechanisms provide for a system well equipped to combat ESG colourwashing, at least in theory. The issue the EU is facing is not a lack of relevant disclosure regulation, but even more so weak enforcement and poor coordination and harmonisation among its Member States.

The Unfair Commercial Practices Directive (UCPD) and the Comparative Advertising Directive (CAD) form the foundation of the EU’s consumer protection legislation. The UCPD is a fall-back for instances where more specific laws do not exist. It applies to implicit green claims (images, colours, types of package or even smells or sounds used for promoting products and suggesting environmental characteristics), as well as other sustainability claims. Even retail investment services are subjected to the UCPD, insofar as they are not more specifically regulated by the Distance Marketing of Consumer Financial Services Directive and of course the very comprehensive Markets in Financial Instruments Directive (MiFID II) and the Markets in Financial Instruments Regulation (MiFIR).

Nevertheless, in practice the existing system faces a severe lack of harmonisation and coordination. The ex-post enforcement mechanisms under the UCPD are sluggish, poorly organised and unrecognised on an EU-wide level, and it often lacks the required technical expertise.

That being said, with appropriate amendments to these laws, most of the aforementioned issues could be mitigated. Harmonising or, better yet, unifying enforcement measures on an EU level could ensure effective ex-post control. Complementary efforts could also be considered, eg supplementing the UCPD with such mechanisms as coordinated pre-approval systems of green claims and an accreditation system of green labels. These measures could help establish appropriate ex-ante control and technical/scientific expertise.

AB: In your opinion, what are some possible solutions to prevent ESG colourwashing and penalise companies and persons who indulge in it?

TS: One possibility is to improve or expand on the existing regulation with a lesser focus on disclosure obligations and an increased focus on consumer protection laws, competition laws, general fraud doctrines, ex ante screening mechanisms and even private enforcement actions under securities laws.

Alternatively, we could alter the premise entirely and pursue a top-down approach. The CEO must set the corporate standard by creating a culture of corporate sustainability, whilst the in-house counsel must ensure both legality and legitimacy of the business model, acting as part of the moral compass.

AB: You suggest that a company-based top-down approach could be beneficial or even more effective than external regulatory measures. Could you please tell us more?

TS: There is no such thing as a perfect regulatory system which prevents any and all problems from arising. Moreover, any law or regulation is most effective when the subjects adopt it as their own. That is to say, they abide by it not because they have to, but because they genuinely want to. Colourwashing is inherently linked to the question of integrity, or, to be frank, the lack thereof of those who practice it.

A culture of sustainability, ie can best be shaped by the Chief Executive Officer (CEO) acting as corporate role model for employees. To facilitate this, companies could and should, with governmental support, adopt corporate codices to underline the importance of sustainability-led governance and set the overall values of the company. In this respect all relevant stakeholders should be taken into account, as well as the overarching societal impacts of the business model. Such internal policies could be further bolstered by a corporate leadership model, whereby all relevant stakeholders are included within a special governance board established within the company to promote sustainable corporate governance. This entity, led by the CEO, could prove to be the key to preventing the company from indulging in illegal and/or illegitimate practices, such as colourwashing. In fact, this internal mechanism may prove to be significantly more effective than external regulatory measures.

AB: What do you see as the role of the legal department in the prevention of ESG colourwashing?

TS: Companies could provide for an expanded role of the legal department when publicly supported by the CEO. The legal function could serve as part of the company’s moral compass, supporting the CEO in ensuring that corporate hypocrisy is not tolerated anywhere within the company. In-house lawyers can, in this manner, demonstrate, support and facilitate accountable leadership within the company and safeguard compliance with both laws and uniform global ethics, even when no one is watching.

In its expanded role, the legal department should fully assess corporate behaviour not only within the remit of applicable law, including consumer protection, competition, and anti-fraud laws, but also against a uniform code of global ethics and traditional moral values such as honesty, fairness, and commitment to inclusion, thus limiting the potential exposure of the company. In practice, the corporate framework and especially the CEO must provide the legal department with the necessary autonomy to raise concerns vis-à-vis commercial decisions that might constitute ESG colourwashing and corporate hypocrisy. At the same time, the CEO should expand the mission of the legal department to also assess other matters of importance, such as strategic, HR and budgetary matters.

AB: The European Commission is currently drafting a potential Directive on Sustainable Corporate Governance. What can be expected from this?

TS: The potential Directive on Sustainable Corporate Governance represents an extension of the European Green Deal and aims to further stimulate the integration of sustainability considerations into companies’ strategies and decision-making processes. The drafting phase has given a glimpse into what can be expected. The European Commission is exploring the possibility of expanding the directors’ duties of care to require directors to consider the environmental and social ramifications of the business model. Furthermore, the proposal could include a so-called due diligence duty, whereby corporates would be obliged to implement adequate processes for preventing, mitigating, and accounting for human rights and environmental impacts in both companies’ operations as well as supply chains. The European Commission is also considering introducing appropriate measures to align directors’ remunerations with long-term objectives of the corporation. For example, their remuneration may be linked to the company’s sustainability metrics or vary depending on achieving various non-financial targets. Lastly, the European Commission aims to alter the composition of boards of directors, making it necessary to involve environmental and human rights experts.

It remains to be seen how this initiative will develop in practice. In any case, regulation can never replace the need for corporate leaders acting with integrity and making sustainable business decisions.