Preparing for EU due diligence requirements

Preparing for EU due diligence requirements

Kumi was commissioned by a multinational e-commerce platform to support the company’s compliance efforts with the Germany Supply Chain Act (LkSG) and the EU’s upcoming Corporate Sustainability Due Diligence Directive (CSDDD).

Kumi helped to streamline the client’s due diligence processes and risk management systems for its Tier 1 suppliers, helping to coordinate responsible sourcing efforts across its diverse business units (including logistics, shipping and packaging providers).​

The Project

We used our diagnostic methodology, calibrated to both the LkSG and CSDDD, to perform a gap analysis and benchmarking exercise of the company’s risk management system and risk assessment process. This involved reviewing documents and practices related to the management system and interviewing representatives from across the business to understand how policies and processes were implemented.

From our work, we identified a lack of coordination of responsible business efforts across the business and key gaps in due diligence activities required by the two regulations in scope.

Preparing for EU due diligence requirements

Our Recommendations

In response to our findings, we helped our client to align their activities across the business and address the gaps in their current management system to meet the requirements of the regulations. We did this by developing a risk management toolkit to promote data sharing between internal stakeholders and proposing software solutions to support information sharing.

Using both the data from our gap analysis and data from previous third-party risk assessments, we gave recommendations to address gaps, such as the company’s human rights policy and changes in its risk management activities. To ensure that our recommendations were actionable and realistic, we also developed a roadmap that was calibrated to the capacity and capability of the client’s sustainability team.

Preparing for EU due diligence requirements

The Outcome

Through Kumi’s engagement, our client was given a clear plan of action to increase its compliance with both the Germany Supply Chain Act and the EU’s Corporate Sustainability Due Diligence Directive. Our diagnostic methodology not only pinpointed existing gaps but also highlighted the many good practices that, whilst they were in place, had not been integrated across the business.

By aligning due diligence processes and enhancing risk management systems for Tier 1 suppliers, we helped to bring a structured, efficient approach to responsible sourcing across the company’s diverse units including logistics, shipping, and packaging. This encouraged better data sharing and communication within the company, leading to more informed decision-making and a robust approach to managing compliance and sustainability risks.

Preparing for EU due diligence requirements

Ethan Ijaz


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