The information sheet “Questionnaire for reporting according to § 10 (2) LkSG of the BAFA” was recently introduced to help companies that fall under the scope of the German Supply Chain Due Diligence Act complete their reporting obligations in a timely and efficient manner. However, many have criticised it for being a “bureaucratic monster.” If you have not started to fill out the questionnaire, this may give you pause. However, having gone over the form, let us put your mind at ease. While it may take some time to prepare your annual report, it will not be difficult for a company that has done the proper preparation.
At first glance, the 38-page document seems to have 437 questions. Upon closer examination, however, there are 215 questions, but the BAFA has numbered the answer options. The number 437 comes from 215 questions plus 222 individually numbered answer choices.
Now, let’s take a closer look at those 215 questions.
The first 17 questions are just to collect basic information about your company. You should already have this information readily available and will not have to implement new procedures to collect it.
Next, there are 19 voluntary questions. This gives you the freedom to skip any complicated or time-consuming questions and only answer those you can answer quickly.
The next 35 questions function as a checklist to identify areas where your company may need improvement as it develops and implements strategies for due diligence.
After that, there are 59 questions about risk analysis and prevention measures. They focus on what you have already implemented and logically lead to 48 questions about identifying violations of the legally defined protected rights positions and corrective actions. Essentially, this section covers the steps your company will take to identify and remediate non-compliance.
Then, there are 32 questions about complaint management, which will become mandatory for companies with over 50 employees under the new Whistleblower Protection Act of December 16, 2022.
The questionnaire ends with five questions about evaluation and conclusions.
Is it extra bureaucracy? Yes. Is it a “monster?” No. While it may create additional work for companies, most of it can be managed with digital support, even if you are an SME. TrustNet.Trade has incorporated these questions into our evaluation system so you can generate a BAFA-compliant report with the click of a button.