Scope route
Check the amended thresholds: generally more than 5,000 employees and EUR 1.5 billion worldwide turnover for EU companies, or more than EUR 1.5 billion EU turnover for third-country companies, including relevant ultimate-parent analysis, the two-year rule, and the AIF and UCITS exclusions.
Chain of activities
Separate upstream production and service inputs from covered downstream distribution, transport, and storage. Then scope likely and severe impact areas using reasonably available information before requesting partner data or opening an in-depth assessment.
Due diligence system
Translate the amended legal duties into policy, risk scoping, in-depth assessment, prioritisation, prevention and corrective action, remediation, stakeholder engagement, complaints, monitoring, and annual communication records.