Reporting in line with the National Action Plan for Business and Human Rights (NAP) with the help of the Sustainability Code

Berlin, 15. November 2018 – The German federal government is seeking to establish the upholding of human rights in global supply and value chains with the National Action Plan for Business and Human Rights (NAP). As the UN’s Universal Declaration of Human Rights approaches its 70th anniversary, the Sustainability Code is enabling companies to incorporate the fourth core element of the NAP, namely reporting, in their Code declaration. The aim is for companies to assume greater responsibility for their human rights due diligence obligations and to report on their commitment to upholding human rights in a manner which is traceable. Between 2018 and 2020 the federal government will use scientific monitoring to gather data on whether companies have integrated the so-called core elements of human rights due diligence obligations into their processes. The federal government anticipates that at least half of the approximately 6,500 companies in Germany with more than 500 employees will have complied with this new reporting obligation by 2020.

This comprises

  • a human rights policy statement,
  • procedures for the identification of adverse impacts on human rights,
  • measures to prevent negative impacts on human rights,
  • reviews of the effectiveness of these measures,
  • reporting and
  • grievance mechanisms.

Depending on the outcome of the evaluation in 2020 the government is reserving the right to take further steps including legal measures should the target figure not be met.

“70 years after the United Nations adopted the Universal Declaration of Human Rights, this topic is becoming more and more relevant. There is increasing pressure on companies to adopt a clear position regarding just how seriously they take the matter of human rights in reality and whether this is corroborated by appropriate processes and responsibility structures,” says Marlehn Thieme, Chairwoman of the RNE. “Reporting on human rights issues has been an integral part of the Sustainability Code since the outset. I am therefore delighted that we are now incorporating the parts relevant to reporting within the NAP, which was developed in the course of an in-depth stakeholder process, into the Code.” This allows companies that use the Code for NAP reporting to clearly signal to official bodies that they are committed to fulfilling their due diligence obligations.

Reporting on human rights with the Sustainability Code

Those who use the Code draw on 20 criteria to report on their strategic focus, their sustainability achievements and the opportunities that arise from considering sustainability issues. Organisations were already able to report on how they handled human rights within criterion 17. This criterion has now been expanded to incorporate questions appropriate to the NAP. Companies wishing to provide a detailed account of their commitment to protecting human rights can select an option within the database that allows them to use the Code plus the NAP reporting points. The additional points are then displayed and are critically reviewed for formal completeness by the Sustainability Code Office. Responsibility for the content nevertheless still lies with the reporting organisations.

With this incorporation, the German Council for Sustainable Development (RNE) hopes to accommodate companies in the area of reporting on human rights, thereby playing a part in implementation of the NAP. “Companies, be they seasoned reporters or only just starting out with reporting, have to navigate a plethora of reporting options and standards. The Code offers organisations pragmatic assistance in meeting both statutory and voluntary requirements such as the NAP in a single well-organised report,” concludes Marlehn Thieme.

Political background

The Universal Declaration of Human Rights was adopted by the United Nations on 10 December 1948. This year sees the 70th anniversary of this historic moment. Globalisation, climate change and the fight against terror present the enforcement of human rights with new challenges. For example, access to clean drinking water was declared a new human right in 2010. As human rights due diligence obligations do not lie with individual countries alone, the United Nations Human Rights Council unanimously adopted the Guiding Principles on Business and Human Rights in 2011. The aim of these principles is to improve the human rights situation throughout supply and value chains. With the 2030 Agenda in mind, the German federal cabinet adopted the National Action Plan for Business and Human Rights in 2016 with a view to implementing the UN Guiding Principles. In so doing, the German federal government has enshrined this topic not only at the political level, but also at the corporate one.



The Sustainability Code promotes corporate and social responsibility. Using 20 criteria and supplementary performance indicators, it presents the sustainability performance of national and international organisations and companies regardless of their size and legal structure. Since the beginning of 2017 capital-market-oriented companies with more than 500 employees have been required to report on their sustainability activities. The European Commission and the German federal government have praised the Code as a suitable standard for fulfilling the reporting obligation. Its area of focus and uncomplicated handling also make the Code an ideal tool for small and medium-sized enterprises.

The German Council for Sustainable Development (RNE) was first called into being in April 2001 by the German government of that time under Federal Chancellor Gerhard Schröder. RNE comprises 15 public figures. Its tasks are to generate contributions for implementing the National Sustainability Strategy, to specify concrete fields of activity and projects and also to make sustainability a public issue of vital importance. RNE independently chooses its array of topics and actions. Examples of the outcomes of its current work include the Sustainability Code, statements on the Sustainable Development Goals, on climate policy, raw material policy and fiscal sustainability as well as on organic farming. It also includes the civil society initiatives of the sustainability project, the strategy dialogue with lord mayors on sustainable urban development, impulses from youths and young adults for municipal sustainability and German sustainability policy as well as RNE’s contributions towards the green economy.
More information available at

Media Relations RNE:

Sustainability Code Office
c/o imug Beratungsgesellschaft
Telephone: +49 (0)30 33842 4888

Katja Tamchina
German Council for Sustainable Development
Office c/o GIZ GmbH
Potsdamer Platz 10
D-10785 Berlin
Telephone: +49 (0)30 338424-233