Enabling Sustainability Due Diligence in Value Chains Through

DLT-Based Governance

Jan Zedel

1 a

and Felix Eppler

2 b

Department of Information Systems, Freie Universit

at, Berlin, Germany

Department of Business Management, Julius Maximilians Universit

at, W

urzburg, Germany

Keywords:

Sustainable Supply Chains, Corporate Sustainability Due Diligence Directive, CSDDD, Supply Chain Due

Diligence, Distributed Ledger Technology, Token Curated Registries.

Abstract:

The European Union’s Corporate Sustainability Due Diligence Directive (CSDDD) represents a transforma-

tive approach to ensuring sustainable and ethical supply chain practices. However, the directive introduces

complexities and signiﬁcant efforts in the compliance processes of affected companies. This paper explores

the question of how decentralized resource pooling can lead to more efﬁciency and lower costs in the compli-

ance processes of the CSDDD. We propose a novel solution leveraging distributed ledger technology (DLT),

speciﬁcally a token-curated registry (TCR) solution augmented with shielded transactions to ensure participant

anonymity and trust. Our proposed approach could reduce redundancies, increase transparency, and facilitate

a more robust risk analysis over the whole value chain. Our paper follows a design science research approach

where we (1) identify the challenges posed by companies that fall under the new CSDDD regulation frame-

work, (2) deﬁne the objectives of a distributed ledger-based solution and (3) design and develop a technical

framework based on a TCR to handle parts of the CSDDD in an efﬁcient and cost-effective way, setting a

precedent for future empirical studies and practical implementations in the ﬁeld of distributed ledger-based

information systems in the ﬁeld of sustainability corporate governance.

1 INTRODUCTION

Regulators and government bodies around the world

are increasingly addressing corporate sustainability

issues in an effort to align business activities with in-

ternational sustainability initiatives (i.e., the United

Nations Sustainable Development Goals (SDGs) and

the Paris Agreement on climate change). In Europe

in particular, the Corporate Sustainability Due Dili-

gence Directive (CSDDD) is becoming a key regula-

tory framework for promoting corporate responsibil-

ity across value chains in the EU and beyond (Lafarre,

2023).

The CSDDD, proposed by the European Commis-

sion in February 2022 and consolidated by a prelimi-

nary political agreement on December 14, 2023, sets

out a comprehensive approach to enhance environ-

mental and social impacts throughout supply chains,

targeting both EU companies and non-EU compa-

nies operating in the EU. It introduces phased com-

https://orcid.org/0000-0002-6009-9722

https://orcid.org/0009-0000-1833-8446

pliance obligations, initially targeting companies with

signiﬁcant staff and turnover, and outlines a wide

range of requirements - from identifying and miti-

gating adverse human rights and environmental im-

pacts to establishing robust reporting mechanisms on

due diligence measures (European Parliament, 2023;

Sørensen, 2022).

Under the CSDDD, companies are generally re-

quired to:

1. Identify actual or potential adverse human rights

and environmental impacts in their supply chain.

2. Take actions to prevent or mitigate potential neg-

ative impacts.

3. End or minimize actual negative impacts.

4. Establish a supply chain workers’ rights com-

plaints procedure.

5. Implement a climate transition plan aligned with

the Paris Agreement for certain large companies.

6. Monitor and report publicly on the effectiveness

of their due diligence policies and measures.

696

Zedel, J. and Eppler, F.

Enabling Sustainability Due Diligence in Value Chains Through DLT-Based Governance.

DOI: 10.5220/0012633700003690

Paper published under CC license (CC BY-NC-ND 4.0)

In Proceedings of the 26th International Conference on Enterprise Information Systems (ICEIS 2024) - Volume 2, pages 696-702

ISBN: 978-989-758-692-7; ISSN: 2184-4992

Failure to comply with the CSDDD could result

in penalties, including ﬁnes of up to 5% of global

revenue, and has implications for companies’ oper-

ations and supply chains, necessitating signiﬁcant ad-

justments for businesses to meet these new standards

(European Comission, 2022). Admittedly, the de-

tailed criteria for full compliance with the CSDDD

remain somewhat vague and are likely to be clariﬁed

once the directive enters into force and is transposed

into national law by EU member states.

Some EU member states, however, have al-

ready implemented their own legislation on sustain-

ability due diligence in supply chains. These in-

clude Germany, which has introduced its own Act

on Corporate Due Diligence Obligations in Supply

Chains (Lieferkettensorgfaltspﬂichtengesetz, LkSG),

providing valuable insights and precedents for spe-

ciﬁc measures that companies must undertake to en-

sure compliance with environmental and social stan-

dards in their supply chains (Weihrauch et al., 2023;

uhmkorf, 2023).

Based on the high-level requirements of the CS-

DDD and the more speciﬁc guidelines of the LkSG,

the practical difﬁculties are many: ensuring compre-

hensive risk analysis, implementing preventive and

corrective measures, extending due diligence to indi-

rect suppliers, and maintaining robust documentation

of compliance. These requirements require signiﬁ-

cant resource allocation and carry the risk of severe

penalties for non-compliance, creating an urgent need

for innovative solutions that can effectively address

these complexities. Our paper and proposed proof-

of-concept application seek to pioneer a systematic

approach to managing compliance due diligence pro-

cesses across the supply chain. This application not

only facilitates compliance with LkSG and CSDDD

requirements but also demonstrates the potential for

scalable, innovative solutions in navigating the land-

scape of corporate sustainability regulations.

2 METHODOLOGY

The research ﬁndings presented here are based on a

Design Science Research (DSR) methodology out-

lined by Hevner et al. (Hevner et al., 2004). The

primary objective is to delineate prescriptive knowl-

edge related to the development of a distributed ledger

(DLT)-based application tailored to the speciﬁed use

case of providing a technical framework to support

the fulﬁllment of the requirements of the CSDDD.

The procedural approach follows the principles of a

generic DSR research process, as outlined by Glea-

sure (Gleasure, 2013). This methodology establishes

a symbiotic relationship between the clariﬁcation of

the problem and the articulation of its corresponding

solution, thereby contributing substantively to the de-

sign knowledge within the domain, as stipulated by

Venable (Venable, 2006).

The initial phase of the research involves the iden-

tiﬁcation and speciﬁcation of requirements. This

foundational step is integral to the subsequent itera-

tive process, wherein design principles are judiciously

applied to delimit the solution space progressively.

Noteworthy in this endeavor is incorporating addi-

tional conceptual frameworks strategically employed

to address and resolve any potential conﬂicts. This

novel integration represents a signiﬁcant augmenta-

tion to the originally posited design principles for the

application domain.

The resultant outcomes are systematically for-

malized through a comprehensive description of

a so-called token-curated registry (TCR) model.

Subsequently, a validation process follows, wherein

meticulous veriﬁcation is conducted to ensure ad-

herence to the speciﬁed requirements. Following the

taxonomy articulated by vom Brocke and Maedche

(Vom Brocke and Maedche, 2019), the presentation

of the research outcomes is organized into six distinct

dimensions. The DSR grid system is employed to

categorize and articulate the content presentation in

a structured manner, thereby enhancing clarity and

comprehensibility.

Problem Description

Companies operating within the European Union

face escalating compliance challenges due to the

impending enforcement of the CSDDD and existing

national regulations like the LkSG. The rigorous

requirements of these directives include identifying

and mitigating adverse impacts on human rights and

the environment, establishing complaint procedures,

and aligning with climate goals. This surge in regula-

tory demands and potential ﬁnes for non-compliance

poses a signiﬁcant burden, necessitating substantial

resource allocations for due diligence processes.

Addressing requirements such as regular risk anal-

yses, implementation of preventive and corrective

measures, and extended due diligence to indirect

suppliers presents intricate challenges.

Input Knowledge

The requirements outlined in the LkSG serve as the

foundational basis for deriving technical speciﬁca-

tions. These requirements function as fundamental

knowledge for conceptualizing an application capable

of fulﬁlling the speciﬁed criteria.

Enabling Sustainability Due Diligence in Value Chains Through DLT-Based Governance

697

Key Concepts

The model adapted for the speciﬁc use case is a TCR

implemented within a DLT environment, including

Zero-Knowledge Proofs (ZKPs) for privacy purposes.

Solution Description

The application is exempliﬁed through two core

scenarios, the processes and users of which will be

elucidated in order to explicate the fundamental logic

for a prospective implementation as smart contracts.

Output Knowledge

The elucidated scenarios serve as illustrative in-

stances demonstrating the application’s contribution

to the satisfaction of stipulated requirements. Fur-

thermore, this discourse encompasses an examination

of the ramiﬁcations and prospective developmental

trajectories rooted in the underlying conceptual

framework. The delineated solution domain sub-

stantiates the formation of the resultant design

knowledge.

3 INPUT KNOWLEDGE

In the German Supply Chain Due Diligence Act (BfJ,

2021)), the due diligence obligations are:

• (1) Establishment of a risk management system to

manage risks in supply chains.

• (2) Designation of internal roles responsible for

ensuring compliance with these due diligence

obligations.

• (3) Conducting regular risk analyses to identify

potential risks.

• (4) Issuance of a policy statement publicly declar-

ing a commitment to uphold human rights and en-

vironmental standards.

• (5) Implementation of preventive measures both

in their own business operations and with direct

suppliers.

• (6) Implementation of corrective measures in re-

sponse to identiﬁed violations.

• (7) Creation of a mechanism for reporting and ad-

dressing grievances within the supply chain.

• (8) Extension of due diligence to encompass risks

associated with indirect suppliers.

• (9) Maintaining records of due diligence activities

and publicly reporting on them.

While some of the requirements listed in the LkSG,

such as the establishment of risk management (1), the

designation of internal responsibility (2), and the is-

suance of a policy statement (4), may be relatively

manageable internally, the others pose more complex

challenges.

Our application aims to improve efﬁciency, trans-

parency, and compliance in the value chain by lever-

aging the added values offered by DLT-based TCR.

We are focusing on the speciﬁc challenges posed by

requirements (3), (5), (6), (7), (8), and (9). Our ap-

proach emphasizes not only meeting the regulatory

standards but also driving efﬁciency and sustainabil-

ity in supply chain operations.

4 KEY CONCEPTS

The centerpiece of our research is designing and de-

veloping a DLT-based TCR system tailored specif-

ically for the decentralized risk analysis of suppli-

ers under the CSDDD. DLT generally promises to

increase transparency, efﬁciency, and accountability

across complex supply chain networks (Kumar and

Sahu, 2023), which is critical to meeting the demands

of today’s sustainability regulations, but research has

mainly focused on the product level (Gomes and

Rom

ao, 2023; Marjanovi

c et al., 2023) rather than the

speciﬁc actors involved in a supply chain itself. Our

approach is conceptualized to tackle the inefﬁciencies

in the current due diligence processes by leveraging

the inherent features of DLT and the novel mechanics

of TCRs.

At its core, the TCR is a list of suppliers main-

tained by a network of companies (token holders)

with a vested interest in the accuracy and integrity

of the registry. Companies can submit assessments

of their suppliers, which are then vetted and curated

by other token holders. The use of tokens creates

an economic incentive for token holders to curate

the list responsibly since the value of their tokens is

intrinsically linked to the quality of the TCR.(Kaur

and Visveswaraiah, 2021) The proposed application

is composed of several key components and features

that facilitate decentralized risk analysis:

• Token Economy. Tokens are used as a mecha-

nism to incentivize honest participation and cura-

tion of the registry.

• Voting Mechanism. Token holders participate in

governance by voting on the inclusion or exclu-

sion of suppliers based on their compliance as-

sessments.

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698

• Stakeholder Engagement. The system encour-

ages active engagement from all stakeholders, in-

cluding companies, suppliers, and third-party au-

ditors.

The system integrates cryptographically secured

proofs to ensure privacy and minimize moral hazard.

ZKPs allow a company to prove that its assessment

is valid without revealing the underlying data. More-

over, transactional data is shielded to prevent the attri-

bution of alterations in token balances or voting activ-

ities to a speciﬁc participant within the network (Ren

et al., 2019). This ensures that while the integrity of

the risk analysis is veriﬁable, the sensitive details re-

main conﬁdential, thus preventing any potential bi-

ases or retaliatory actions.

5 SOLUTION DESCRIPTION

We adopt the TCR model, as elucidated by Goldin

(Goldin, 2017), to suit our speciﬁc use case. The

TCR is collectively maintained by a set of users

who are either suppliers or customers within a desig-

nated supply chain. The registry comprises curated

suppliers evaluated by participating customers in

accordance with CSDDD regulations. These users

can assume three distinct roles within the application,

namely:

1. Applicant (Supplier). The applicant, a sup-

plier, seeks inclusion in the system and subsequent

listing on the registry.

2. Voter (Customer). The voter participates in voting

scenarios, expressing assessment results on whether a

supplier should or should not be listed on the registry.

3. Challenger (Customer). The challenger has the

capacity to instigate a vote by asserting that an

established supplier should be excluded from the

registry.

The application facilitates two distinct scenar-

ios, where a supplier applies to be on the curated

list (Figure 1), or a customer challenges an existing

supplier entry (Figure 2). Both processes initiate a

voting period during which customers may cast votes

on the inclusion or exclusion of the supplier from the

registry.

Perspective of the Applicant

Scenario ”Application”: In the initial stage, the appli-

cant requests inclusion in the list of suppliers meet-

ing the requirements outlined in CSDDD regulations.

The applicant is required to deposit tokens as a stake,

which remains locked for the entire duration the sup-

Figure 1: Application.

Figure 2: Challenge.

plier chooses to be on the list. The submission of the

application triggers a voting period during which vot-

ers determine the supplier’s inclusion. If the applicant

is rejected, the tokens are refunded; if accepted, the

applicant is incorporated into the list, and the tokens

remain staked.

Scenario ”Challenge”: When a supplier faces a

challenge for exclusion from the list, a voting period

commences, during which voters decide on the sup-

plier’s status. If the majority votes for exclusion, the

supplier forfeits tokens to the challenger and voters.

If the majority votes for the supplier’s retention on

the list, the supplier gains a portion of the tokens

staked by the challenger.

Perspective of Voter

Scenario ”Application”: Voters participate in a vote

to determine whether a supplier should initially be

included in the list. Voters are entitled to vote after

conducting a risk assessment based on CSDDD

regulations. The vote should align with the outcome

of their assessment. Voters favoring the majority

vote earn experience points, granting them in-

Enabling Sustainability Due Diligence in Value Chains Through DLT-Based Governance

699

creased weight in future votes, thereby incentivizing

continued participation.

Scenario ”Challenge”: In the event of a challenge,

participating voters reassess the challenged supplier

and vote accordingly. Winning voters in the majority

vote share the stake of either the supplier or the

challenger in equal parts. Additionally, participation

in the vote earns experience points.

Perspective of Challenger

Scenario ”Challenge”: Instances may arise where a

customer suspects a listed supplier’s non-compliance

with CSDDD regulations and advocates for their

exclusion. By providing a stake and initiating the

challenge, the customer assumes the role of a chal-

lenger. If the majority votes to ban the challenged

supplier, the challenger is remunerated, akin to

voters. Conversely, if the majority votes to retain the

supplier on the list, the challenger loses their stake to

the voters and the challenged supplier.

6 OUTPUT KNOWLEDGE

6.1 Evaluation

In the following, we argue how the proposed appli-

cation supports the fulﬁllment of the LkSG and, by

extension, the CSDDD requirements:

1. Facilitation of Comprehensive Risk Analysis.

The presented application advocates for the sys-

tematic conduct of risk analyses (3). Cus-

tomers are incentivized, both monetarily and non-

monetarily (in the form of experience points), to

monitor their suppliers. In instances where uncer-

tainties arise concerning a supplier, it is impera-

tive to discern and identify associated risks. This

discernment serves as a crucial factor in making

decisions that yield proﬁtability or, in the case

of the challenger, prevent potential losses. The

described mechanisms aim to harness collective

intelligence from various stakeholders, enhancing

the accuracy and robustness of risk assessments.

2. Streamlining of Preventive and Remedial

Measures. The application functions as a risk

mitigation measure (5), as suppliers face the po-

tential loss of funds at any given moment, thereby

incentivizing their consistent adherence to speci-

ﬁed requirements. Moreover, the exclusion of a

previously listed supplier through a formal elec-

tion mechanism serves as a remedial measure

(6) in instances where users identify violations.

The application enables companies to respond

promptly and efﬁciently to identiﬁed risks and vi-

olations.

3. Efﬁcient Complaints Management. Upon the

initiation of a voting period by a challenger, a no-

tiﬁcation is visible on the ledger to inform other

users that a speciﬁc supplier may potentially fail

to meet the deﬁned requirements. Consequently,

the execution of a challenge functions as a report-

ing mechanism, wherein the adequacy of a sup-

plier is subject to reevaluation. Notably, the no-

tiﬁcation within the application is characterized

by transparency and immediacy, ensuring that all

users are promptly informed of the pertinent de-

velopments (7).

4. Expansion of Due Diligence to Indirect

Suppliers. Due to the speciﬁcations inherent in

the distributed ledger, the application facilitates

the ability of users to access the risk assessments

pertaining to all suppliers recorded within the

system. Consequently, risks afﬁliated with

indirect suppliers can be passively appraised

(8). Nevertheless, it is imperative to emphasize

that such an assessment does not absolve any

company from the responsibility of conducting

its individual due diligence.

5. Robust Documentation and Reporting

Capabilities. The inherent data structure of

the distributed ledger facilitates the meticulous

traceability of activities pertaining to risk assess-

ments (9). Furthermore, the dissemination of the

data affords a speciﬁc degree of persistence, and

the information is openly accessible within the

supply chain network, thereby permitting any

interested party to generate reports on activities.

An assessment was undertaken through a quali-

tative approach involving a series of interviews with

three distinguished experts in the realm of sustainable

supply chain management (SSCM) within manufac-

turing industries. The ensuing feedback can be cate-

gorized into three distinct dimensions:

1. Conceptual Soundness. The proposed appli-

cation appears to offer a viable framework for

addressing the requirements of the LkSG and

potential challenges related to CSDDD compli-

ance. Particularly, the economic incentive struc-

tures embedded within the application may facil-

itate a transparent and collaborative approach in

assessing social or environmental risks associated

with suppliers. Nevertheless, the determination of

remuneration for users of the application necessi-

tates careful consideration to avoid favoring a spe-

ciﬁc equilibrium. Additionally, there exists ambi-

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guity regarding whether suppliers would perceive

the beneﬁts of participating in such a system,

given the perpetual jeopardy of ﬁnancial losses

contingent upon majority votes from customers.

The advantages for a supplier, arising from an en-

hanced appeal to new customers through partici-

pation, must outweigh the associated risks of po-

tential monetary losses.

2. Practical Usability. Incorporating the applica-

tion into current company structures poses a sig-

niﬁcant challenge. Typically, there is a long-term

commitment to existing solutions. New applica-

tions need to work well with the systems already

in place. Despite many proofs of concept, the

adoption of DLT in industrial applications is still

a ways off. Systems should be implemented in a

way that is easy for users, and users should be able

to understand the technology involved.

3. Risk Analysis Efﬁcacy. The collaboration in-

volved in the proposed approach may encourage

suppliers to more willingly or strictly follow reg-

ulations. This increased compliance can be linked

to the reduced chance of unnoticed rule viola-

tions, thanks to multiple risk assessments. Com-

bining assessments from various customers also

strengthens the overall evaluation of suppliers.

Moreover, the resulting transparency builds trust

among everyone involved, enhancing the effec-

tiveness of decision-making and allowing for ef-

ﬁcient reassessment.

7 CONCLUSIONS

The proposed application presents a new approach to

managing risk analysis in compliance with the CS-

DDD. The implementation of the TCR system has

the potential to optimize the CSDDD compliance pro-

cesses by signiﬁcantly reducing redundancies in sup-

plier risk analysis. Through a decentralized and col-

laborative approach, companies will be able to share

and access supplier assessments, thereby improving

efﬁciency, transparency, and potentially the overall

quality of risk analysis.

The integration of TCRs and ZKPs into compli-

ance processes underscores the transformative role of

information systems in sustainability efforts. This re-

search exempliﬁes how innovative applications of dis-

tributed systems can address complex challenges in

supply chain management, setting a precedent for fur-

ther explorations in the domain.

While our study offers valuable insights, it is not

without limitations. The evaluation is based primarily

on expert feedback, which, while expertly informed,

may not fully capture the practical complexities of

implementing the TCR system in diverse corporate

environments. Additionally, the proposed design has

not yet been empirically tested in a real-world setting,

which is necessary to validate its efﬁcacy and feasi-

bility.

Future research should aim to empirically test the

TCR system in a real-world environment to validate

the ﬁndings. Moreover, it is imperative to develop

mechanisms to ensure good acting within the system

and discourage malicious behavior. Potential avenues

include incorporating monetary or reputational stakes

for users, where non-compliance or bad acting could

lead to tangible losses, thereby aligning the interests

of all consortium members with the overarching goals

of the application.

Future iterations could incorporate stakeholder-

driven governance models, reward users’ contribu-

tions and reliability, and penalize dishonest behavior.

Exploring the use of smart contracts to enforce rules

and automate incentive structures could provide a ro-

bust framework for maintaining integrity within the

system.

While there are challenges to be addressed and

tested, the potential beneﬁts for CSDDD compliance

and the broader ﬁeld of information systems are sub-

stantial. By continuing to explore and reﬁne this ap-

proach, the corporate world may beneﬁt from more

resilient, transparent, and efﬁcient sustainability prac-

tices.

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