Benchmarks

Germany’s Supply Chain Due Diligence Act: a logic model analysis of corporate disclosure

All 313 publicly available reports from the 254 companies in the law’s first reporting phase (reporting years 2023 and 2024), around 42,000 data points, assessed with our HREDD Performance Assessment methodology of 141 practices and 25 effectiveness metrics. Mirroring the law’s logic chain from management systems and risk analysis through prevention and detection to remediation, the study asks whether the structures companies have built actually work. Five further reports on the individual fields follow from June 2026.

To take part in the benchmark or obtain a scorecard, contact UN Global Compact Network Germany. For individual effectiveness studies, see our industry page.

Conflict minerals due diligence in the telecommunications industry

Of 12 publicly traded telecoms companies, only 5 had ever filed a Form SD, and only 2 met SEC requirements while substantially aligning with the OECD standard. Authored by DI associates Ava Leipzig and David Park.

Influence of the OECD Due Diligence Guidance in minerals supply chains

A random sample of 1,178 downstream companies across eight countries whose products contain minerals. 82.8% make no reference to conflict minerals in their public disclosures. Among the 77 that do, about half explicitly reference the OECD Guidance as their framework, and only 1.2% of the whole sample state that they avoid procuring tainted minerals.

FTSE 100: modern slavery due diligence, 2021/22

60 indicators covering legal compliance, UN Guiding Principles conformance and the “Find It, Fix It, Prevent It” framework. Average legal compliance was 90.3%, disclosure conformance 64.4%, and performance across all 60 indicators 39%: scores fall as indicators ask for evidence of effectiveness rather than process.

Devoir de Vigilance: reforming corporate risk engagement

All 134 companies subject to the law assessed against 42 KPIs: 17 on legal compliance, 14 on UN Guiding Principles conformance and 11 on transparency, covering risks in operations, subsidiaries and suppliers.

Anti-slavery actions: FTSE 100 and Real Estate 100, 2018/19

87% of companies with a new statement in 2019 improved on the previous year, with an average combined score of 48%. The Global Governance RE 100 Index, London’s largest commercial landlords by square foot, averaged 39%.

Non-financial reporting in Germany, Austria and Sweden

Baseline studies of Germany (n=422), Austria (n=84) and Sweden (n=590) against 67 KPIs. Measurement differed so much between countries, particularly on greenhouse gas emissions, energy use, recycled inputs and workplace injuries, that formally compliant reporting did not allow meaningful comparison.

Worst forms of child labour in the DRC: cobalt refiner due diligence reporting

What cobalt refiners disclose about child labour due diligence, assessed against the OECD Due Diligence Guidance and the CCCMC guidelines. It continues the inquiry that Amnesty International’s “This is what we die for” report opened.

Corporate compliance with the UK Modern Slavery Act, 2017/18

A representative sample of 6,501 UK-registered organisations subject to the Act, analysed at macro and micro level for disclosure performance and anti-slavery practice.

3TG and cobalt smelter and refiner disclosure conformance

370 gold, tin, tungsten, tantalum and cobalt smelters and refiners assessed against leading due diligence and assurance standards and against Step 5 of the OECD Due Diligence Guidance for Responsible Mineral Supply Chains.

Filing status, reporting year 2017

A review of issuer filings under the law and rule: 222 fewer conflict minerals disclosures between reporting years 2013 and 2017, a drop of 16.8%.

Corporate compliance with CA-TISC, 2016 (n=1,961)

1,961 brands assessed on five disclosure dimensions: risk verification, audits, supplier certification, internal accountability and training, with examples of good, poor and misleading language.

Filing evaluation, reporting year 2016

The third and final year of our benchmarking of the first mandatory conflict minerals disclosure law: SEC compliance and OECD Guidance performance across all 1,153 US-listed filers. The findings were used by civil society, investors and policymakers assessing the law’s effectiveness.

Scorecards for individual companies are available on our industry page.

Corporate compliance with CA-TISC, 2015 (n=1,504)

The first comprehensive assessment of compliance with the first US state law requiring companies to disclose efforts against trafficking and slavery: 1,504 statements assessed against eight compliance criteria and seven affirmative conduct indicators.

Filing evaluation, reporting year 2015

The second annual study of all 1,220 US-listed companies’ conflict minerals disclosures against SEC requirements and OECD due diligence standards.

Filing evaluation, reporting year 2014

The first systematic assessment of the law’s implementation, covering all 1,271 US-listed filers in its first reporting year.