The German Supply Chain Duty of Care Act (Lieferkettensorgfaltspflichtengesetz; the Act) entered into force on 1 January 2023 for the first companies with more than 3,000 employees in Germany. It obliges (primarily German) companies to comply with human rights and certain international environmental standards within their operations and supply chains (see earlier blog post here). Over the last months of 2022, companies have been very busy with getting ready for the Act and establishing required internal compliance structures as well as supply chain safeguards. The German supervisory authority published four guidance papers for implementation, yet, there are still many uncertainties for companies concerning the extent of new obligations being imposed ranging from initial risk assessments to third party due diligence to reporting.
Reach of supply chains
Generally, the definition “supply chain” under the Act is broad and captures not only suppliers that are supplying necessary materials for the manufacturing of products but also activities indirectly related to the manufacturing process. However, there is still uncertainty whether, for example, the “downstream side” of the supply chain, i.e., the distribution steps within the supply chain after the production process, would meet the definition since they do not technically “supply production”. If that would be the case, such business partners would not be subject to the general risk analysis obligations under the Act and...
TIFFIN, Ohio — On Friday, state Rep. Gary Click deleted a Facebook post accusing three named Democrats of funding his primary opponent and replaced it with a correction. The claim was “made in err...