{"id":28284,"date":"2020-11-11T11:27:00","date_gmt":"2020-11-11T10:27:00","guid":{"rendered":"https:\/\/www.rewe-group.com\/en\/?p=28284"},"modified":"2026-04-01T09:18:20","modified_gmt":"2026-04-01T07:18:20","slug":"responsibility-for-human-rights-we-need-a-practical-and-effective-supply-chain-law","status":"publish","type":"post","link":"https:\/\/www.rewe-group.com\/en\/press-and-media\/newsroom\/stories\/responsibility-for-human-rights-we-need-a-practical-and-effective-supply-chain-law\/","title":{"rendered":"Responsibility for human rights: “We need a practical and effective supply chain law”"},"content":{"rendered":"\n
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Child labor, starvation wages, inadequate protection against pesticides – global supply chains often start with human rights violations. A much-discussed supply chain law is intended to provide a remedy. In this interview, REWE Group Head of Purchasing Hans-J\u00fcrgen Moog explains the extent to which REWE Group supports the project and what it will take for the law to really make a difference.<\/p>\n<\/div>\n <\/div>\n <\/div>\n <\/div><\/div>\n\n\n\n

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Whether it’s cocoa from Ghana or clothing from Bangladesh, a product often has a long journey before it reaches German stores. Since the 1990s, growing globalization has led to more and more goods or preliminary products being manufactured abroad, predominantly in the Global South. The new division of labor has not only benefited companies, but also consumers thanks to lower prices, as well as producers in the producing countries. Those who have often only benefited to a limited extent or not at all: the workers themselves. This is because child labor and starvation wages are often at the very beginning of supply chains.<\/p>\n

Companies are now to be held liable with a supply chain law if they do not sufficiently comply with their due diligence obligations. Federal Labor Minister Hubertus Heil (SPD) and Federal Development Minister Gerd M\u00fcller (CSU) have presented key points for such regulation: Companies based in Germany would have to check whether their activities have a detrimental impact on human rights and take appropriate measures to counteract this.<\/p>\n

What opportunities lie in a supply chain law, and what would it have to be like for it to be truly practicable? We talked about this with REWE Group’s Head of Purchasing Hans-J\u00fcrgen Moog.<\/p>\n <\/div>\n\n <\/div>\n<\/div>\n\n

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About:<\/h2>

\n Hans-J\u00fcrgen Moog <\/p>\n\n

Head of Purchasing at REWE Group<\/p>\n \n

\n is a member of the Management Board – Goods and Purchasing (Chief Procurement Officer). <\/p>\n <\/div>\n <\/div>\n<\/div>\n<\/div>\n\n

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Mr. Moog, there are efforts within the German government to introduce a new law to make companies accountable for respecting human rights in their supply chains. The law has been the subject of heated debate for months. As Head of Purchasing at one of Germany’s largest retail companies, what do you think?<\/p>\n<\/div>\n

Hans-J\u00fcrgen Moog: <\/strong>For us, one thing is clear: human rights must not be negotiable. We are convinced that a binding framework is needed to create fair conditions along global supply chains. That is why we already spoke out in favor of a law at the end of 2019 – and one at international level! In our view, a purely national supply chain law is not enough to effectively strengthen due diligence obligations at the origin of global value chains. A law should focus on the human rights aspects, as formulated in the UN Guiding Principles. For us, the question is not whether we need a law, but what form it should take in order to be practicable and effective. At best, politicians and companies need to enter into a dialog and carry out a practical check. Our common goal must be to invest in the greatest possible impact for the improvement of human rights and not in a sprawling administrative burden.<\/p>\n<\/div>\n <\/div>\n <\/div>\n<\/div>\n\n

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Why not start in Germany first? There is already a supply chain law in other European countries, for example in France or the Netherlands.<\/p>\n<\/div>\n

Hans-J\u00fcrgen Moog:<\/strong> Going it alone at national level puts the local economy at a competitive disadvantage and creates a lot of red tape – without much being gained in the end. In addition, the legal framework conditions are different in every country. This cannot simply be compared or copied. But Germany could define guidelines for negotiations at EU level. We need European legislation that harmonizes the requirements of corporate due diligence and thus creates legal certainty for internationally active companies.<\/p>\n<\/div>\n <\/div>\n <\/div>\n<\/div><\/div>\n<\/div>\n\n\n\n

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Until now, Germany has relied on companies to voluntarily ensure human rights standards in their supply chain.<\/p>\n<\/div>\n

Hans-J\u00fcrgen Moog: <\/strong>That’s right, and we have done the same at REWE Group. Particularly in the supply chain stages of raw material cultivation and processing, we have been working intensively for years to strengthen human rights and promote fair trade. The fact that we won the Fairtrade Award this year is the best proof of this. To name just a few of the measures we take to demonstrate our commitment: We carry out risk analyses, use certified raw materials such as Rainforest Alliance or Fairtrade for our own brands, participate in forums and multi-stakeholder initiatives such as the Textile Alliance, the Cocoa Forum or the Palm Oil Forum. We also carry out our own projects and training programs in the supply chain. Thanks to this long-standing commitment, we know exactly where the problems lie.<\/p>\n<\/div>\n <\/div>\n <\/div>\n<\/div>\n\n

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Let’s take a look at the practical side: what would regulation achieve in practice?<\/p>\n<\/div>\n

Hans-J\u00fcrgen Moog:<\/strong> Let’s take the cocoa sector as an example. Around 70 percent of the global cocoa harvest comes from West Africa, and the difficult working and living conditions of cocoa farmers and their families are widely known. We are committed to changing this on many levels: We have been cooperating with the Fairtrade cocoa program since 2014. All own-brand confectionery products containing cocoa will be converted to Fairtrade or the Fairtrade Cocoa Program by the end of 2020. We are one of the founding members of the German Initiative on Sustainable Cocoa. And yet, despite such voluntary initiatives and projects, whether by us or by companies in the cocoa and chocolate industry, human rights violations still exist.<\/p>\n<\/div>\n <\/div>\n <\/div>\n<\/div><\/div>\n<\/div>\n\n\n\n

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To achieve a truly broad impact, we need legally enshrined standards that create a level playing field for the entire industry.<\/p>\n<\/blockquote>\n <\/div>\n

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Hans-J\u00fcrgen Moog, Head of Purchasing at REWE Group<\/p>\n <\/div>\n <\/div>\n

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Hans-J\u00fcrgen Moog, Head of Purchasing at REWE Group<\/p>\n <\/div>\n <\/div>\n<\/div>\n<\/div><\/div>\n\n\n\n

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Voluntary approaches are therefore not enough.<\/p>\n<\/div>\n

Hans-J\u00fcrgen Moog:<\/strong> Consistent programs to improve the situation require considerable investment – I know what I’m talking about, we have been involved in this area for years together with our partners in the supply chain. Not all players are voluntarily involved, as the market is highly competitive and many companies are afraid of losing their competitiveness. In order to achieve a real broad impact, we need legally enshrined standards that create a level playing field for the entire industry. Such regulation must also apply to all companies operating in Germany, including large corporations that are based abroad but operate on the German market.<\/p>\n<\/div>\n <\/div>\n <\/div>\n<\/div>\n\n

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There is no draft law yet, and the cabinet has not yet been able to agree on key points. The question of liability in particular is being discussed. What is REWE Group’s position on this?<\/p>\n<\/div>\n

Hans-J\u00fcrgen Moog:<\/strong> A fundamental question is: What can I be responsible for, what can I influence at all? I would argue that liability should be sensibly limited to the direct supplier. We ourselves have no contractual recourse to upstream suppliers, so we can only be liable to our direct contractual partners. Incidentally, this is established practice in food law and should also apply here. In this context, we very much welcome the fact that EU Justice Commissioner Didier Reynders has also spoken out in favor of limited liability. I also do not believe that it is in a supplier’s interest to disclose their entire recipe to us so that we can screen all ingredients. Given the number of suppliers we have, we wouldn’t be able to do that. What’s more, these are highly protected trade secrets and rightly so.<\/p>\n<\/div>\n <\/div>\n <\/div>\n<\/div>\n\n

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What is the situation with private labels?<\/p>\n<\/div>\n

Hans-J\u00fcrgen Moog:<\/strong> Own brands only account for around 25 percent of our revenue. We are responsible for this because they are subject to our control. But the remaining 75 percent of our revenue comes from branded products. The purpose of the law is to ensure that everyone takes responsibility for their supply chain. The aim cannot be for manufacturers to completely absolve themselves of their responsibility and simply transfer it to retailers. The food trade must not be held liable for the entire food industry.<\/p>\n<\/div>\n <\/div>\n <\/div>\n<\/div><\/div>\n<\/div>\n\n\n\n

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The law should apply equally to everyone, everyone must take responsibility.<\/p>\n<\/blockquote>\n <\/div>\n

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Hans-J\u00fcrgen Moog, Head of Purchasing at REWE Group<\/p>\n <\/div>\n <\/div>\n

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Hans-J\u00fcrgen Moog, Head of Purchasing at REWE Group<\/p>\n <\/div>\n <\/div>\n<\/div>\n<\/div><\/div>\n\n\n\n

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It is undisputed that the law is only effective if it applies to as many companies as possible. In France, for example, it only applies to companies with 5,000 employees or more: Won’t that mean too many supplier companies are left out?<\/p>\n<\/div>\n

Hans-J\u00fcrgen Moog:<\/strong> The law should apply equally to everyone, everyone must take responsibility. You see, 90 percent of suppliers in the food retail sector are small or medium-sized companies. Together, they supply around half of the product range. If only suppliers with 5,000 employees or more are made responsible, this medium-sized structure will be completely eliminated. And this could even prove to be a disadvantage for these companies: If retailers are held liable for the goods of small companies, this could lead to the large international suppliers being favored because this promises more legal certainty for retailers. This would counteract consumer demand for regional products and would be the exact opposite of our strategy, as we promote regional structures and want to offer diversity.<\/p>\n<\/div>\n <\/div>\n <\/div>\n<\/div>\n\n

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Doesn’t the Supply Chain Act overburden companies by placing responsibility on them that should actually lie with politicians?<\/p>\n<\/div>\n

Hans-J\u00fcrgen Moog: <\/strong>It depends on how it is structured. A law on corporate due diligence can only be effective if it is accompanied by mandatory, voluntary, national and international measures in both the producing countries and the importing countries. It requires the cooperation of many stakeholders. Furthermore, countries should also implement effective regulations and measures in order to fulfill their duty to protect. From our experience in many projects in third countries, political discourse between the European authorities – EU and member states – and local governments is indispensable.<\/p>\n<\/div>\n <\/div>\n <\/div>\n<\/div>\n\n

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What could this look like in concrete terms?<\/p>\n<\/div>\n

Hans-J\u00fcrgen Moog:<\/strong> We advocate an EU traffic light system for third countries in order to be able to systematize political pressure in the event of human rights violations: If laws and international standards are complied with in third countries and this enforcement is also supported by the government, the traffic light remains green; in the event of violations, it initially turns orange. This then leads to international political pressure and, in extreme cases, could result in an entry on a red list and EU restrictions. Third countries would be interested in actively promoting positive developments and law enforcement in order to receive a green rating. And companies would not have to fulfill any obligations at level green, limited obligations at level orange and extensive obligations at level red.<\/p>\n<\/div>\n <\/div>\n <\/div>\n<\/div><\/div>\n<\/div>\n\n\n\n

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In many developing countries, cotton is the most important source of foreign currency. The Supply Chain Act is intended to protect the human rights of suppliers.<\/p>\n<\/div> <\/div>\n <\/div>\n <\/div>\n<\/div><\/div>\n\n\n\n

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Is there already a practical example of such a traffic light system?<\/p>\n<\/div>\n

Hans-J\u00fcrgen Moog:<\/strong> Yes, take a look at the EU legal system in the area of illegal fishing. It shows that a traffic light system can work. It has led to major improvements in fisheries worldwide. However, a key challenge for many companies operating around the world is the establishment of effective complaints mechanisms. Political support would be particularly helpful in this area, as individual measures per company are not really effective. We therefore advocate the expansion of the OECD contact points as external, independent and trustworthy institutions that provide actors in third countries with access to grievance mechanisms.<\/p>\n<\/div>\n <\/div>\n <\/div>\n<\/div>\n\n

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In a nutshell: What do you hope to achieve with the law?<\/p>\n<\/div>\n

Hans-J\u00fcrgen Moog:<\/strong> The primary goal of the law – and this is also our goal – is to make an effective contribution to respecting human rights. If we manage to enforce more fairness along the chain and create a level playing field for everyone in this area, it would be a great success. We are happy to maintain a dialog with politicians and provide support at any time with a practical check on this ambitious task.<\/p>\n<\/div>\n <\/div>\n <\/div>\n<\/div><\/div>\n<\/div>\n<\/div>\n\n\n\n

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