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Responsible Contracting in Public Procurement: Commentary on the Proposed EU Public Procurement Act

Applying the Four Core Principles to Public Procurement

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Responsible Contracting in Public Procurement

Read the commentary by Kristin Tallbo and Ben Rutledge on the NOVA BHRE Blog

RCP European Legal Advisor Kristin Tallbo and Senior Advisor Ben Rutledge co-authored a commentary for NOVA Centre on Business, Human Rights and the Environment on what the European Commission proposal for a Public Procurement Act, published in September 2026, means for human rights and environmental due diligence (HREDD) in public procurement. The commentary applies the four core principles of Responsible Contracting to the stages of public procurement, setting out what shared responsibility, responsible purchasing practices, remediation first, and responsible exit as a last resort mean for public buyers and their suppliers across tendering, contracting, and contract management. It also highlights working models already in use, including due diligence contract conditions applied by the Swedish Regions and Adda Central Purchasing Body, model contract clauses developed with RCP support for the New South Wales Anti-slavery Commissioner, and Electronics Watch model contract conditions, and closes with three practical first steps for public buyers.

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