resulting from their activities, the activities of companies they control and the activities of sub-contractors and suppliers on whom they have a significant influence." Sweden Sweden does not have such a law. Switzerland In Switzerland, a federal popular initiative named 'For responsible businesses – protecting human rights and the environment' was launched by a coalition of non-governmental organizations. It proposed a mechanism of public liability when activities of Swiss multinationals, or their subsidiaries, violate internationally recognised human rights and environmental standards. On 29 November 2020, the responsible business initiative was accepted by 51% of voters, but rejected by a majority of cantons. The failure of the initiative leads to the entry into force of the legislative counter-project. The latter also introduces new due diligence obligations. Criminal fines can be imposed for failure to report (but nor for breaches of international law). United States Because each of the 50 U.S. states is a separate sovereign free to develop its own tort law under the Tenth Amendment, there are several tests for finding a duty of care in United States tort law. Foreseeability test In several states, like Florida and Massachusetts, the sole test is whether the harm to the plaintiff from the defendant's actions was foreseeable. Multi-factor test The Supreme Court of California, in a majority opinion by Justice David Eagleson, criticized the idea that foreseeability, standing alone, constitutes an adequate basis on which to rest the duty of care: "Experience has shown that . . . there are clear judicial days on which a court can foresee forever and thus determine liability but none on which that foresight alone provides a socially and judicially acceptable limit on recovery of damages." Drawing upon the work of scholars such as Fowler V. Harper, Fleming James Jr., and William Prosser, California has developed a complicated balancing test consisting of multiple factors which must be carefully weighed against one another to determine whether a duty of care exists in a negligence action. California Civil Code section 1714 imposes a general duty of ordinary care, which by default requires all persons to take reasonable measures to prevent harm to others. In the 1968 case of Rowland v. Christian, the court held that judicial exceptions to this general duty of care should only be created if clearly justified based on the following public-policy factors: the foreseeability of harm to the injured party; the degree of certainty