LkSG Sections 12-23 - enforcement + sanctions. BAFA (Bundesamt fur Wirtschaft und Ausfuhrkontrolle - Federal Office for Economic Affairs and Export Control): the German federal enforcement authority + responsible for: (a) MONITORING + INSPECTION (Section 14-17): on-site inspections + document review + interviews + system review; (b) COMPLAINTS HANDLING (Section 17-19): receiving + investigating + escalating complaints from any party including affected individuals + civil society + employees; (c) GUIDANCE + INSTRUCTIONS to companies; (d) SANCTIONS PROCEEDINGS (Section 23-24). ADMINISTRATIVE FINES (Section 24): per-violation: (i) UP TO EUR 800,000 for failures regarding own business; (ii) UP TO EUR 8 MILLION for failures regarding direct/indirect suppliers OR failure to submit annual report; (iii) FOR COMPANIES WITH ANNUAL TURNOVER MORE THAN EUR 400 MILLION: fine of up to 2% of GLOBAL ANNUAL TURNOVER (replacing the EUR 8M cap when 2% turnover is higher). PUBLIC PROCUREMENT EXCLUSION (Section 22): companies with significant violations may be EXCLUDED FROM PUBLIC PROCUREMENT for up to 3 YEARS; this provision substantially increases compliance pressure since public procurement is a major German contracting channel. CRIMINAL LIABILITY: limited (Sec. 25); primary enforcement is administrative. NO PRIVATE RIGHT OF ACTION under LkSG itself but TORT LAW + competition-law claims may apply + the LkSG does NOT preclude private claims under general civil/criminal law for human rights violations.
The graph holds this control, the 0 it maps to, and the evidence behind each claim, over MCP and REST.