Supply Chain Risk Management for German Companies in Greece


published on 15 September 2022 | reading time approx. 3 minutes

by Dirk Reinhardt, Michelis – Strongylaki – Reinhardt Law Firm

As a German company, you are required by the German Supply Chain Act to carry out due diligence on contracted businesses throughout your supply chain, identify risks to human rights and take measures to mitigate such risks.

In this regard, in case you maintain business relations with Greek companies or you have established sub­si­diaries in Greece, you are expected to be aware of any risks to human rights that may arise in this European country and ensure that the companies you work with, along their supply chain, respect human rights.

At first, something to keep in mind is that Greece is a country mainly of small- and medium-sized corporations, which are more difficult to monitor and which sometimes, due to lack of resources, may not put the protection of human rights as a top priority and take all the precautionary measures to comply with the relative legislation.

Moreover, Greece is still in the aftermath of a long economic crisis, which has left a negative imprint on citi­zens’ living standards and posed human rights risks by increasing unemployment and reducing the resources available for social benefits.

As an example, it is worth noting that Greece ranks 27th in the EU on the Gender Equality Index of the Euro­pean Institute for Gender Equality and also scores a 4 on the International Trade Union Confederation (ITUC) Global Rights Index (scale 1-5) for freedom of association and workers’ rights.

Moreover, it is observed that many Greek companies have not yet adopted the appropriate technical and or­ga­nizational measures for the protection of personal data, as required by the General Data Protection Regulation, which was transposed to national law with Law 4624/2019.

Nevertheless, considerable efforts are being made by both government and businesses to improve the above conditions, promote green entrepreneurship and sustainability, as well as to ensure the elimination of discri­mination of all kinds in the workplace.

Even though there is not yet a single legislative framework regulating corporate governance, responsible supply chain management, respect for human rights in the workplace, etc., there are, however, numerous pieces of legislation directly related to these issues.

In this regard, it is worth mentioning Law 4403/2016, which transposed Directive 2013/34/EU into national law. Under this law, private companies, especially large S.A.s, are required to prepare and publish an annual manage­ment report, which includes not only an analysis of the company’s financial data but also an analysis of the social and environmental aspects of their work. In particular, it should analyse the impact of the company’s activities in relation to social and labour issues, any impact on health and safety, the specific actions the com­pany has taken to ensure gender equality and trade union rights, any anti-corruption policies, etc., as well as the results and impact of such actions and policies.

Another significant development has been Greek Law 4808/2021 which ratified the Violence and Harassment Convention (C190) and the Promotional Framework for Occupational Safety and Health Convention (C187) of the International Labour Organization, and also transposed Directive 2019/1158/EU “on work-life balance for parents and carers”. According to this law, which contains important regulations regarding individual and collective labour rights, all forms of violence and harassment which occur at work, including gender-based violence, are prohibited. Every employer, regardless of the number of staff employed, is obliged to receive and examine all relevant complaints and assist the respective authorities during the investigation of such com­plaints. Also, undertakings employing more than twenty people must adopt an internal policy for handling complaints of harassment and violence incidents.

Also more and more enterprises apply codes of conduct and have CSR policies and give emphasis on human rights, sustainable entrepreneurship, due diligence, anti-corruption, protection of health and environment etc., and non-profit organizations like CSR Hellas and their members support the implementation of these goals in the Greek market.

In conclusion, for German companies doing business in Greece, there are not significant dangers to human rights, thanks to the diverse and extensive legal framework that protects them. However, there are some risks to be taken into consideration, arising from the country’s socio-economic conditions. In this regard, conducting due diligence audits on prospective and current partners, imposing contractual liability for human rights vio­lations and ensuring transparency are the keys to a successful Supply Chain risk management.

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