The question
The group’s French and UK entities needed a defensible due diligence framework for complex European value chains: the French entity under the duty of vigilance law of 27 March 2017, the UK entity under section 54 of the Modern Slavery Act 2015. Both were also preparing for the Corporate Sustainability Due Diligence Directive.
What we did
- A risk matrix by country and by commodity, covering forced labour and modern slavery across the value chain.
- The governance and operating procedures of the vigilance plan, with separate protocols for direct (tier 1) and indirect (tier 2 and beyond) suppliers.
- An escalation matrix for non-compliant suppliers: remediation steps first, then contract termination clauses drafted to be legally defensible.
- Workshops for procurement and legal leadership on governance and on human-rights criteria in sourcing decisions.
What changed
- A documented record of due diligence actions, with checklists and reports, that the legal department can rely on in civil proceedings.
- Alignment with the UK Modern Slavery Act and early preparation for the CSDDD.
- High-risk supplier issues remediated before any public exposure.
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