BAFA, the German government agency responsible for export controls and other aspects of trade and security, has published guidelines for companies implementing a “complaints procedure” so as to be able to comply with the country’s Supply Chain Due Diligence Act (“LkSG”) which comes into force on 1 January 2023. At that date, “All companies that fall within the scope [of the law] must set up a mechanism for reporting risks or violations of human rights and environmental aspects of the LkSG.”
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