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Implementing ESG Criteria: A Beginner’s Guide to Sustainability for EU Companies

Written by Johannes Fiegenbaum | 7/4/25 1:25 PM

Sustainability is essential for businesses. Strict regulations such as the CSRD and the Supply Chain Act make sustainable strategies mandatory in EU. Violations can result in fines of up to 2% of global annual turnover. At the same time, 88% of consumers and 75% of employees expect companies to take responsibility. This growing demand for accountability is echoed globally: a 2023 PwC survey found that 76% of consumers say they will stop buying from companies that treat the environment, employees, or the community poorly (PwC ESG Consumer Intelligence Series). But how can implementation succeed? Here are the 10 most important measures:

  • Develop a sustainability strategy: Set clear goals, use SMART criteria, comply with legal requirements.
  • Clarify responsibilities: Establish governance structures, manage risks, optimize reporting processes.
  • Conduct a sustainability audit: Analyze the status quo, identify risks, make progress measurable.
  • Review supply chains: Ensure human rights and environmental standards, minimize risks.
  • Increase energy efficiency: Reduce costs, save resources, meet legal requirements.
  • Promote circular economy: Reduce waste, strengthen recycling, conserve resources.
  • Assess climate risks: Analyze scenarios, set climate targets, create transition plans.
  • Foster innovation: Develop new business models, leverage technologies like AI and blockchain.
  • Engage employees: Offer training, encourage engagement, create a culture of sustainability.
  • Transparent reporting: Disclose ESG data, build trust, ensure compliance.

These measures help meet legal requirements, reduce costs, and achieve real progress in sustainability. Companies that act now secure long-term advantages and competitiveness. According to McKinsey, organizations that integrate ESG into their core strategy can increase shareholder value by up to 10% and are better positioned to attract investment and talent (McKinsey & Company).

The Most Important Skills for Sustainability Managers

1. Develop a Sustainability Strategy and Set Clear Goals

A well-thought-out sustainability strategy with clear objectives is key to meeting regulatory requirements while achieving positive effects for the environment and society. Aligning with frameworks like the UN Sustainable Development Goals (SDGs) and using SMART criteria ensures that targets are actionable and measurable (Elliott Davis).

Compliance with German Regulations (e.g., CSRD, Supply Chain Act)

From the outset, the strategy should be aligned with the current legal framework. For German companies, this means linking the sustainability strategy with the requirements of the CSRD and the Supply Chain Due Diligence Act (LkSG). An integrated approach that considers the common principles of these regulations creates synergies and facilitates implementation.

"Navigating the complex landscape of regulations like CSRD, CSDDD, and LkSG doesn’t have to be overwhelming. By aligning your strategy and focusing on shared principles, you can streamline compliance while driving meaningful change in sustainability and due diligence for human rights and the environment." – Maxine Bichler, Reporting Expert

Companies already meeting LkSG requirements can leverage their experience to efficiently prepare for the CSRD. This regulatory foundation provides a clear roadmap for further action.

Practicality for German Companies

A good starting point is basic steps like defining responsibilities, conducting a double materiality analysis, and preparing an initial CSRD test report. These steps create a solid foundation, regardless of company size. Additionally, a due diligence policy should be developed that meets both LkSG and CSRD requirements. Regular risk assessments help identify potential risks in the supply chain regarding human rights and environmental standards. Integrating LkSG processes into CSRD reporting enables both legal requirements to be addressed efficiently. With clearly defined actions, the actual impact on the environment and society can also be transparently communicated.

Potential for Measurable Environmental and Social Impact

The 17 Sustainable Development Goals (SDGs) provide a proven framework for setting concrete and measurable targets. Germany aims to be greenhouse gas neutral by 2045 and to reduce emissions by at least 65% by 2030 compared to 1990. Goals should be formulated according to the SMART criteria (specific, measurable, achievable, relevant, time-bound) to regularly monitor progress and report using suitable indicators. Actively involving stakeholders from civil society and the private sector amplifies the impact of these measures.

Long-Term Cost Efficiency and Scalability

Sustainability and economic efficiency go hand in hand. By integrating ecological and social aspects into cost assessments, companies can secure both efficiency gains and long-term stability. This is crucial given rising costs, volatile markets, and stricter environmental regulations. Life cycle costs (LCC) are an important tool for expressing sustainability aspects in monetary terms. Resource efficiency measures can not only reduce environmental impact but also positively influence cost structures. Concepts like the circular economy reduce dependence on primary raw materials and lower costs. At the same time, digital technologies and Industry 4.0 solutions help optimize processes, minimize resource consumption, and reduce waste. Professional software solutions are essential to manage the complexity of sustainable cost management.

2. Establish Clear Responsibilities and Governance Structures

Without clearly defined responsibilities, sustainability often remains just lip service. German companies therefore need solid organizational structures that meet legal requirements and enable sustainable value creation.

Compliance with German Regulations (e.g., CSRD, Supply Chain Act)

The Supply Chain Due Diligence Act (LkSG) and the EU Corporate Sustainability Reporting Directive (CSRD) set clear standards for companies. Since January 2023, these regulations apply to companies with more than 3,000 employees, and from January 2024, to those with over 1,000 employees. The requirements include risk management systems, policy statements, preventive and remedial measures, and the establishment of complaint procedures. There are also extensive documentation and reporting obligations. The consequences of non-compliance are significant: In addition to fines of up to 8 million euros or up to 2% of average annual turnover (for companies with turnover over 400 million euros), there is a risk of exclusion from public contracts in Germany for up to three years. These legal requirements make it clear how important it is to define responsibilities and integrate them into company structures.

Practicality for German Companies

It is crucial to determine early on which individuals and teams are responsible for sustainability reporting. So-called “no-regret measures”—risk-free, future-oriented steps—can help minimize uncertainties in implementing the CSRD. While board members must understand climate risks and their impacts, operational responsibility for identifying and assessing them should be delegated to a specialized management team that reports directly to the CEO and board. Practical measures could include:

  • Revision of contracts with partners
  • Adjustment of codes of conduct
  • Integration of liability clauses for violations
  • Establishment of internal reporting systems for human rights and environmental risks

Such structured approaches lay the foundation for measuring progress using clearly defined KPIs.

Potential for Measurable Environmental and Social Impact

ESG metrics (Environmental, Social, Governance) provide tangible indicators to assess a company’s performance in these areas. They help document progress, set targets, and inform stakeholders. Examples of governance metrics include:

  • Proportion of independent board members
  • Ethics training hours per employee
  • Board compensation ratio
  • Number of confirmed corruption cases
  • Implementation of codes of conduct among suppliers

However, a 2022 Economist Impact study shows that only 36% of companies have integrated social aspects into their strategy, compared to 47% that consider environmental impacts. This highlights the untapped potential, especially in capturing social metrics (Economist Impact).

Long-Term Cost Efficiency and Scalability

Clear governance structures are not only necessary for legal compliance but also bring economic benefits. Sustainability should not be seen merely as a strategy, but as an integral part of corporate culture.

"A sustainable company needs ESG not just as a strategy, but as part of its DNA. This means only companies that establish clear processes and responsibilities for ESG can act credibly and successfully." – KPMG

Modern technologies such as AI and blockchain can significantly improve transparency and accuracy in ESG measurement. The trend is toward data-driven ESG tracking that enables real-time reporting. To achieve this, companies should regularly review and adapt their governance structures. Greater involvement of the board and management, as well as consistent data collection and reporting practices, are crucial to ensure the integrity of information.

3. Conduct a Sustainability Audit and Establish a Baseline Analysis

A solid sustainability strategy starts with a detailed assessment. A systematic audit uncovers weaknesses and provides the necessary data to set realistic goals and make progress measurable.

Compliance with German Regulations (e.g., CSRD, Supply Chain Act)

New reporting obligations, as mandated by the CSRD (Corporate Sustainability Reporting Directive) and the Supply Chain Act, make structured data collection indispensable. From 2025, around 13,200 German companies will have to submit their first CSRD reports, covering over 1,000 data points across ten ESG areas (environment, social, and governance). Topics include pollution, resource consumption, and biodiversity. The Supply Chain Act additionally requires companies to implement risk-based procedures to identify, assess, and address human rights and environmental risks in their supply chains. Annual reports must be published by June 30 on the company website and in the Federal Gazette and are subject to independent review. A well-executed audit can efficiently cover the requirements of both regulations. Interestingly, companies already subject to CSRD reporting do not need to submit additional reports under the Supply Chain Act.

Practical Implementation for German Companies

Conducting a sustainability audit requires a clear approach. The first step is to develop a due diligence policy and thoroughly analyze supply chains. Modern software tools can help make supply chain management more efficient and ensure traceability. See also EUDR compliance and traceability. Regular supplier audits and transparent communication with partners in the value chain are also essential. To support smaller businesses, the German government offers funding programs, such as financial subsidies for energy audits. One example of the success of such programs: For every euro of government funding, 17 to 33 euros in private investment were mobilized. Participating companies implemented an average of 1.7 to 2.9 additional energy efficiency measures (IEA Energy Efficiency 2023).

Potential for Measurable Environmental and Social Impact

A baseline analysis is key to making progress concrete and traceable. It is important to distinguish between metrics that measure activities (outputs) and those that assess results (outcomes). An impressive example is the Better Life Farming (BLF) Alliance by Bayer. Since its launch in 2018, over 2,700 BLF centers have been established in eight countries, supporting more than one million smallholder farmers. A baseline survey of 700 farmers in India showed that 60% reported increases in productivity and income after one year—rising to 90% the following year. Quality of life also improved: the proportion of farmers with higher life satisfaction rose from 71% to 87%, while those experiencing less stress increased from 42% to 79% (Bayer Better Life Farming).

Long-Term Cost Efficiency and Scalability

Sustainability audits are not just a mandatory exercise but an investment in the future. They lay the foundation for continuous improvement and strategic decision-making. German energy audit programs show the significant savings potential. One evaluated program resulted in average savings of 2,824 MWh of final energy and 1,054 tons of CO₂ per year. Cost savings ranged from -0.4 to 6 euros per MWh saved, while CO₂ costs dropped by 1.8 to 4.1 euros per ton. Solid data management is crucial for preparing reports according to EU taxonomy standards and for continuous improvement. Software tools simplify data collection and analysis. Early stakeholder involvement and regular feedback keep the focus on relevant and effective metrics. A thorough assessment lays the groundwork for consistent and sustainable action.

4. Review Supply Chains and Implement Sustainable Procurement

Reviewing supply chains and implementing sustainable procurement practices are not only legally binding for German companies but also a key step to minimize compliance risks and secure long-term competitive advantages. Here are the essential measures and strategies companies should consider.

Compliance with German Regulations (e.g., Supply Chain Act)

The German Supply Chain Act (LkSG) has required companies with more than 3,000 employees since 2023, and those with at least 1,000 employees from 2024, to implement a comprehensive risk management system. The goal is to ensure compliance with human rights and environmental standards throughout the supply chain. Requirements include:

  • Definition of responsibility: Appointing a person to oversee risk management.
  • Regular risk analyses: These help identify potential violations both within the company and among direct suppliers.
  • Policy statement: Companies must clearly state their human rights objectives.
  • Preventive and remedial measures: Prevention and response to violations.
  • Internal complaints procedure: An accessible system for third parties, without fear of retaliation.
  • Documentation: Complete records of all actions and processes.

Non-compliance can result in hefty penalties: up to 8 million euros in fines or 2% of global annual turnover for companies with over 400 million euros in revenue.

Due Diligence Measure Description
Risk management system Identification, assessment, and mitigation of risks in the supply chain.
Definition of responsibility Appointment of a responsible person.
Risk analysis Regular review for possible violations.
Policy statement Setting the company’s human rights objectives.
Preventive measures Actions to prevent violations.
Remedial measures Intervention in existing or potential problems.
Internal complaints procedure Establishment of a secure and accessible system for complaints.
Documentation Careful record-keeping of all processes and obligations.

These measures form the foundation for legally compliant and sustainable corporate management.

Practical Implementation for German Companies

Integrating sustainable procurement strategies into business processes not only strengthens internal governance but also optimizes external operations. According to a survey of 2,000 German companies, many are already implementing measures to comply with human rights and environmental standards in their supply chains. Effective approaches include:

  • Modern supply chain tools: These help monitor supply chains and ensure traceability. See also EUDR compliance and traceability.
  • Regular audits: Supplier audits ensure compliance with regulations.
  • Supplier training: Investing in training ensures suppliers understand and can implement LkSG requirements.

Potential for Measurable Environmental and Social Impact

Sustainable procurement can make a significant contribution to environmental and social goals. ESG criteria (environment, social, governance) are increasingly being integrated into procurement processes, as evidenced by 99% of S&P 500 companies reporting on them in 2023 (Harvard Law School Forum on Corporate Governance). Some figures highlight the potential:

  • According to a World Economic Forum analysis from 2021, more than 50% of global CO₂ emissions come from the supply chains of just eight industries (World Economic Forum).
  • The CDP Global Supply Chain Report shows that a company’s supply chain emissions are on average 11.4 times higher than its direct operational emissions (CDP Global Supply Chain Report).

Success stories demonstrate how companies achieve measurable results through sustainable procurement:

  • Finnair reduced plastic waste by almost 4,500 kilograms per year by switching its onboard service package (Finnair Newsroom).
  • Walmart's Project Gigaton™ aims to save one gigaton of greenhouse gases in the global supply chain by 2030 (Walmart ESG Report).

Long-Term Cost Efficiency and Scalability

Sustainable procurement is not just a matter of compliance, but also a means to increase efficiency and competitiveness. Companies with strong ESG profiles demonstrably reduce costs by 5–10% and often achieve growth of 10–20% (McKinsey & Company). The benefits of sustainable procurement go far beyond legal compliance and offer a real opportunity for long-term success.