CASE STUDIES

Global semiconductor company – Responsible supply chain assessment

Automated machine assembling electronic components onto a semiconductor circuit board in a manufacturing facility

SUMMARY: This case study explains how a global semiconductor company can align its supply chain due diligence with emerging ESG regulations such as the EU CSDDD, EUDR, EUCMR and EUBR. It highlights common challenges including limited traceability, fragmented supplier data and weak risk prioritisation, and shows how structured benchmarking and implementation planning can improve regulatory readiness and supply chain risk management.

Alignment with supply chain ESG and due diligence legislation

A leading global semiconductor company sought Kumi’s expertise when preparing for the EU Corporate Sustainability Due Diligence Directive (CSDDD) and other mandatory due diligence legislation, including the EU Conflict Minerals Regulation (EUCMR), EU Batteries Regulation (EUBR), and EU Deforestation Regulation (EUDR). With these regulations set to reshape industry practices, the company took a proactive approach to aligning its processes, both to ensure compliance across operations and to strengthen the efficiency of its supply chain due diligence activities.

The project

We assessed the company’s regulatory alignment by benchmarking its management system for responsible business against the relevant regulatory landscape in which it operates. We did this through:

Identifying relevant mandatory due diligence regulations
Developing benchmarking criteria to translate legal requirements into actionable steps
Engaging with internal stakeholders across departments
Reviewing existing documentation and processes
Assessing alignment with benchmarking criteria
Creating a tailored implementation plan with practical actions

One of the significant challenges the company faced was gathering traceability and mapping data across its complex and often opaque global supply chains. Dealing with diverse regulatory requirements in different markets added another layer of complexity. The company also struggled with a lack of structure for stakeholder engagement, aligning relevant due diligence activities to specific issues and contexts without over-relying on audits.

Their supplier risk evaluation approach prioritised inbound risks (i.e., risks to the company) while insufficiently considering outbound risks (i.e., risks to people and the environment). The lack of risk prioritisation led to excessive time and resources spent on identification and assessment rather than on mitigation, which is the step that drives real impact.

Our recommendations

Based on our findings, we developed a practical roadmap for regulatory alignment, including:

Actions to address identified gaps in due diligence processes
Strategies to integrate sustainability processes across the company’s operations and its supply chain
Advice for enhancing internal and external sectoral collaboration
Guidance on leveraging industry-specific tools and resources

The outcome

Our work ensured the company was well-positioned to meet the relevant legislation requirements. The client appreciated how we leveraged our team’s in-house semiconductor industry experience to provide insights, practicality, and specificity in our recommendations tailored to the unique business context and industry challenges.

This approach enhanced the company’s regulatory compliance and strengthened its position as a leader in driving sustainable practices throughout its global operations and supply chain.

Frequently asked questions

Why is the semiconductor sector under growing ESG scrutiny?

Supply chains are global, complex, and often linked to high‑risk minerals. Regulatory attention is increasing alongside geopolitical concerns.
Which regulations are most relevant to semiconductor companies?

EU due diligence laws, conflict minerals regulations, and customer ESG requirements all apply. Overlap often causes confusion internally.
How do we assess ESG risk in such complex supply chains?

Risk‑based scoping and prioritisation help focus effort where impact is greatest. Perfect traceability is rarely achievable immediately.
Can technology solve ESG risk alone?

No. Tools support data management, but governance, judgement, and supplier engagement remain essential.
What are common internal challenges?

Lack of role clarity, competing priorities, and inconsistent data are frequent barriers to effective implementation.
Is this only a concern for manufacturers?

No. Downstream brands and integrators also face regulatory and reputation risk.