A Comparison of the French and German Transparency Laws

Abstract

France and Germany have each enacted laws establishing a mandatory due diligence process for companies. The French law, Loi relative au devoir de vigilance, was adopted in 2017 ; the German law, Lieferkettensorgfaltspflichtengesetz, in 2021. Both pieces of legislation aim to cover the whole supply chain. Beyond their common purpose, however, their provisions differ quite significantly. This article elucidates these differences with a view to arriving at a better understanding of the proposed European Directive on Corporate Sustainability Due Diligence.

Keywords

• Duty of vigilance
• civil liability
• human rights
• environment
• compliance