On 17 August 2022, the Federal Office for Economic Affairs and Export Control (Bundesamt für Wirtschaft und Ausfuhrkontrolle, “BAFA”) has issued its first handout to provide guidance to companies currently implementing a risk management system to comply with the German Supply Chain Due Diligence Act (“SCDDA”). The document is aptly titled “Identifying, Weighing, and Prioritizing Risks” – as this is essentially what the risk analysis needs to do. Overall, the handout includes what has already been stated in the SCDDA, summarizes the essential requirements for a risk analysis, and gives a little more background on the requirements and a few practical examples with respect to the implementation.
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