the size of the company. I spend two
days on site to get an overview and
make recommendations for further
implementation. Afterwards, of course,
I also assist with the preparation
of the necessary documents, if this
is explicitly requested by the company.
The costs are also kept within
limits and depend on the size of the
company."
As MBS, we recommend that
our clients seek advice against the
background of the potential consequences
of the Supply Chain Act.
You are welcome to contact Saskia
Rotterdam with reference to MBS.
JUST THE BEGINNING:
Already in September, there was a
first complaint in connection with
the new supply chain law and human
rights violations in Xinjiang in
China. The human rights organisation
European Center for Constitutional
and Human Rights (ECCHR),
based in Berlin, filed a criminal
complaint against several German
companies with the Federal Attorney
General in Karlsruhe. According
to ECCHR, companies such as Lidl,
Aldi, and Hugo Boss may be profiting
directly or indirectly from the forced
labour of Uyghurs in the Xinjiang region
of China and may be involved
in crimes against humanity. ■
MBS NETWORK
1. Are you a direct supplier to companies with more than
3,000 or 1,000 employees? (regardless of legal form)
"I ALWAYS TELL THE
COMPANIES: IT'S ABOUT YOUR
LIABILITY REDUCTION AND
ABOUT PRESERVING JOBS."
SASKIA A. ROTTERDAM
Kontakt / Contact
Saskia A. Rotterdam
Compliance Consultant /
Business Development / Employee Training
s.rotterdam-consulting@email.de
Yes No
2. Do you have more than 250 employees?
Yes No
3. Do you have foreign (non-European suppliers)?
Yes No
4. Do you make more than 30% of your annual turnover
as a direct supplier to companies with more than 1,000
or 3,000 employees?
Yes No
5. Are you an indirect supplier to companies with more
than 1,000 or 3,000 employees?
Yes No
If 1-3 are already answered with yes, there
is a need for action. On the one hand,
because of the Supply Chain Sourcing
Act and, on the other hand, because of
the EU Whistleblower Directive and the
upcoming Association Sanctions Act.
If question 4 is also answered in
the affirmative, the pressure to act
to minimise liability in the form of
implementing the Supply Chain Segregation
Act will increase.
If only question 5 is answered in
the affirmative, it would be recommended
to take a closer look at the
topic and, if necessary, to take advantage
of a brief consultation.
If, however, 4 and 5 are answered
in the affirmative, it should be
examined more closely which supply
chain law measures should be ready
in the drawer.
CHECKLIST
Photos: © Adobe: Torbz, sabir
INSIGHT 4 . 2021 13
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