Empty content
Many sustainability-related requirements and commitments may appear familiar, clear, and reasonable, yet remain difficult to implement. These are examples of what we call empty content: content that appears strong in form but provides little operational guidance.
Across supply contracts and General Terms and Conditions, one clause appears almost universally: “The Supplier shall comply with all laws.”
It sounds obvious. Of course laws must be followed. Because it feels self-evident, the clause often goes unnoticed and unexamined.
This type of clause illustrates not only a lack of specificity, but also a lack of operational guidance. It appears strong in form yet provides little direction for action.
Generic requirements or commitments often do not reach the people responsible for product design, procurement, or operations, nor do they provide the detail needed to guide decisions in these contexts. As a result, they may create formal coverage without operational clarity – appearing compliant while failing to support implementation.
Empty content may result from several overlapping issues:
- lack of specificity (what needs to be done)
- lack of connection to practice (who acts, where, and how)
- lack of calibration or miscalibration (how strongly the requirement or commitment is expressed)
Making sustainability-related content explicit is essential – but not sufficient. Even well-formulated requirements and commitments may still fail to support and guide action.
To better understand how these issues appear in practice, the following diagnostic exercise helps you assess whether contract clauses actually support implementation and action.
Diagnostic exercise: Do contract clauses support implementation and action
Below are some common examples of sustainability-related contract clauses intended to be binding on the Supplier. As you review them, consider whether you can find similar formulations in your own documents and whether they provide sufficient support and guidance for action. Many of these may look familiar.
| Clause | Is it actionable? | What is missing? (what / who / how / evidence) |
|---|---|---|
| The Supplier shall comply with all applicable laws. | No | What laws? What actions are required? No process, no responsibility, no verification. |
| The Supplier shall respect human rights. | No | No definition of what this means. No risk assessment, no procedures, no monitoring. |
| The Supplier shall conduct due diligence. | Partly | No description of the due diligence process, scope, frequency, or documentation. |
| The Supplier shall take corrective actions where necessary. | Partly | No trigger, no timeline, no defined process, no follow-up or reporting. |
| The Supplier shall document identified risks, implement corrective actions within defined timelines, and report progress upon request. | Yes (mostly) | May still need clearer responsibility allocation, verification criteria, and defined documentation. |
This highlights a recurring problem: sustainability-related content is often expressed in generic terms that do not provide sufficient support or guidance for action. As a result, it may remain empty in day-to-day work and decision making.