Ten years after the devastating collapse of the Rana Plaza garment factory, which killed over 1,100 people, numerous companies have still not signed either the Bangladesh Accord (the agreement on building safety and fire protection in Bangladesh) or its successor, the International Accord. The Accord is considered the only effective mechanism for improving workplace safety in the global textile industry. As early as November 2022, FEMNET and ECCHR therefore sent an open letter to Tom Tailor, Deichmann, IKEA, and Amazon, urging these companies to sign the agreement in order to fulfill their duty of care regarding occupational health and safety.

According to our analysis, two of these companies—Amazon and IKEA—have have fallen under the purview of the German Supply Chain Due Diligence Act (LkSG) since January 2023. Consequently, the Bangladeshi trade union National Garments Workers Federation (NGWF) filed the first complaint with the Federal Office for Economic Affairs and Export Control (BAFA), alleging that the companies’ subcontracting factories are not adequately monitored, violate trade union rights, and endanger workers’ safety. Together with FEMNET, ECCHR is supporting the complaint.

The BAFA has since closed the proceedings without involving the affected union or even informing it of the outcome. To the best of our knowledge, the problems on the ground continue unabated.

As part of an investigation conducted in the first half of 2023, the Bangladeshi trade union NGWF once again identified safety deficiencies and restrictions on trade union activities in factories supplying Amazon and IKEA. Civil society organizations and trade unions have repeatedly informed the companies about the risks regarding trade union rights, health, and safety in factories in Bangladesh and other manufacturing countries. Despite being aware of the existing risks, they still have not signed the agreement.

Those who refuse to sign the agreement are deliberately disregarding their responsibility to prevent known human rights risks in the textile industry and are thus violating human rights due diligence obligations. This applies at least until effective alternative measures become apparent. The alternatives frequently proposed by companies, such as social audits, have repeatedly proven ineffective in addressing the documented risks.

Represented by FEMNET and with the support of ECCHR, the NGWF therefore filed a complaint with the German Federal Office for Economic Affairs and Export Control (BAFA) in April 2023.

In the summer of 2023, the BAFA classified the complaint as a substantiated application within the meaning of Section 14(1)(2) of the LkSG and initiated an investigation. In doing so, it recognized the NGWF as the applicant but not as a party to the investigation proceedings. Requests for participation and information were ignored or denied for years. It was not until the fall of 2025 that the union finally gained access to the case files and thus learned that the investigation proceedings against the two companies had already been closed in 2024.

The Federal Office concluded that Amazon did not fall within the scope of the LkSG in 2023. In 2024, the threshold for the law’s application—based on the number of employees—was lowered, and the complainant union, NGWF, informed the BAFA of ongoing abuses at Amazon’s suppliers. Nevertheless the BAFA did not feel compelled to conduct a new review, which might have provided grounds for continuing the proceedings.

In the proceedings against IKEA, the BAFA accepted the submission of a social audit and, on that basis, concluded that there was no evidence of a breach of the duty of care. There was no examination of the adequacy and effectiveness of these measures to prevent and remedy the documented risks. 

If this practice continues, the BAFA procedure risks losing its function as a central legal protection instrument for victims of human rights violations.

The collapse of Rana Plaza highlighted the failure of voluntary corporate responsibility initiatives. In response, the Bangladesh Accord was introduced and has since become the most successful tool worldwide for improving workplace safety and health.

Since its introduction, the agreement has helped prevent avoidable disasters in the garment industry. Tens of thousands of identified safety hazards have since been eliminated, workers have been trained and informed, and a grievance mechanism has been established that gives employees a voice to address workplace safety issues.