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VI. Monitoring

The National Action Plan marks the starting point of a process that will be continuously updated and developed. The process will be shaped by the implementation of the measures for which this Plan provides as well as by a comprehensive procedure for monitoring the implementation of these measures by all players.

To this end, the Federal Government is planning, subject to budgetary approval, the immediate execution of the following steps:

  • To support the monitoring system, a permanent interministerial committee will be appointed, with the Federal Foreign Office as the lead department. The latter, along with the other departments involved, will be allocated the staff and budget required for their new additional tasks.
  • The interministerial committee will verify the implementation and coherence of the adopted measures and drive forward the development of the NAP implementation process. The main areas of activity to come under its scrutiny will be the measures relating to the state duty to protect (public procurement, promotion of external trade, etc.) and the fleshing-out of due diligence obligations (chapter III above), including the planned definition of sectoral specifications and the corresponding support services.
  • The NAP steering group, comprising representatives of business, civil society and trade unions, will be integrated into the existing National CSR Forum of the Federal Government. The Forum will monitor the activities of the interministerial committee for the implementation of the National Action Plan and make appropriate recommendations for action to the Federal Government. To this end, the interministerial committee will report regularly to the CSR Forum.
  • Progress in the corporate implementation of the elements of human rights due diligence described in chapter III above will be reviewed by means of an annual survey conforming to current scientific standards, beginning in 2018. The survey will be conducted on the basis of a representative sample to establish the number of enterprises that have introduced the elements of due diligence listed in chapter III above and will also include qualitative interviewing on the substantive depth of these measures and the challenges encountered during their implementation in enterprises. The yardstick for this review will be the objectives formulated in chapter III.
  • On this basis, the review will establish whether at least 50% of all German-based enterprises with more than 500 employees have incorporated the elements of human rights due diligence described in chapter III into their business processes by 2020. The review will also include a ‘comply or explain’ mechanism, whereby enterprises that are not implementing particular procedures and measures can explain why this has not been happening. An updated status report will be produced in preparation for a revision of the 2016 - 2020 National Action Plan.