Compliance Briefing — June 11, 2021

Executive briefing: Germany’s Bundestag passed the Lieferkettensorgfaltspflichtengesetz (Supply Chain Due Diligence Act) on 11 June 2021. From 1 January 2023, companies with 3,000+ employees (and from 2024, 1,000+) must implement risk management systems, preventive measures, and remediation processes covering suppliers and indirect partners.

Key compliance checkpoints

Risk management and analysis. Establish due diligence procedures to identify human rights and environmental risks across tiers, with annual risk analyses and ad-hoc reviews.
Preventive measures. Implement supplier codes of conduct, training, and control mechanisms tailored to risk severity.
Complaints procedure. Provide accessible grievance channels enabling affected parties to report violations with protections against retaliation.

Operational priorities

Governance structure. Appoint responsible persons at management level and integrate due diligence reporting into supervisory board oversight.
Documentation and reporting. Prepare annual public reports documenting identified risks, mitigation steps, and effectiveness for submission to the Federal Office for Economic Affairs and Export Control (BAFA).
Contractual clauses. Update supplier agreements to include audit rights, remediation commitments, and termination triggers tied to due diligence breaches.

Enablement moves

Deploy supply-chain mapping tools capturing geographic exposure, subcontractors, and risk ratings.
Integrate due diligence requirements into procurement scorecards and onboarding questionnaires.
Coordinate cross-functional remediation plans with sustainability, legal, and procurement teams to address severe findings swiftly.

Sources

Zeph Tech operationalises Lieferkettengesetz controls with supply-chain mapping, grievance management, and BAFA-ready reporting.