MISSION

Consulting

CASE STUDY

Compliance & due diligence in cocoa

YEAR

2024-2025

CLIENT

Confidential

Enhancing regulatory compliance and due diligence in the cocoa supply chain 

01

Context

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New international and national regulations (EUDR, CSDDD, ARS1000) are coming into force, requiring more socially and environmentally responsible supply chains;

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Downstream & upstream actors must strengthen their processes and procedures, develop and implement due diligence systems to ensure compliance;

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Beyond a legal requirement, it is an opportunity to build stronger, more transparent businesses, ensuring the long-term viability of their own operations.

02

Approach

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Development of Country Risk Assessment Tools and conduction of risk assessments for cocoa-producing countries. This includes evaluating EUDR-related risks or broader human rights risks. We develop sector-specific tools that can easily be updated as they are based on public data sources;

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Enhancement of processes and procedures to ensure compliance with EUDR and CSDDD in collaboration with global and local teams, including:
– Traceability procedures at both global and origin levels;
– HRDD procedures based on the OECD framework, with tailored risk mitigation measures.

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Development of Supplier Handbooks to guide direct and indirect suppliers, as well as internal teams, fostering stakeholder inclusion—especially cooperatives and producers.

03

Key Takeaways

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Engaging stakeholders, especially local teams and suppliers, is essential to ensure that procedures are feasible and effective. Compliance should not disproportionately burden suppliers, particularly cooperatives, which often lack the resources and capacities;

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The indirect supply chain also requires close attention, as it is frequently overlooked despite being a major source of risks such as illegality and deforestation;

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Data management should go beyond compliance, serving as a tool for continuous improvement and informed decision-making across the supply chain;

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Collaboration across the sector is essential for advancing sustainability. Leveraging existing tools developed by sector actors, rather than duplicating efforts, will drive more effective, lasting progress.