BMW, Mercedes-Benz, and ZF Group were given the opportunity to review the draft and provide feedback. These were some of their comments:

...The participating companies acknowledge the publication of the paper “Beyond the Pilot: Lessons for Building Resilient Cross-Company Grievance Systems” and wish to thank the authors for sharing the draft in advance.

...the project was completed in December 2025, exactly as originally agreed upon at the start of the collaboration. Following the initial phase, the participating companies originally agreed on a continuation plan fully funded by the companies themselves, without any financial contribution from the German government. Regrettably, the continuation could not be realized for reasons outlined below.

This project operated within a multistakeholder governance structure represented by the Executive Committee (ExCom), which included companies, civil society organizations, and unions. The decision not to continue the pilot resulted from the ExCom collectively being unable to reach agreement on a viable path forward. The factors influencing this outcome were primarily structural, governance-related and reflecting the broader complexity of implementing collaborative mechanisms across diverse stakeholder groups.

...several of the challenges observed during the pilot reflect the inherent complexity of coordinating diverse actor groups within this multistakeholder governance model. Acknowledging this context is important for understanding both the achievements and the limitations of the initiative.

Throughout the duration of the initiative, the companies remained consistently engaged and provided financial support, technical expertise, and significant staff time. These contributions formed an essential part of the collective effort and were sustained until the conclusion of the pilot.

Regarding supply chain engagement, the companies acted fully in line with the agreed framework by informing Tier 1 suppliers and sharing relevant information through formal, secure, and confidential processes, including nondisclosure agreements. Structural limitations of the project restrained the ability to engage directly beyond Tier 1; nevertheless, the companies continued to support broader supply chain due diligence within the scope of their established responsibilities.

...operational experiences related to case handling were shaped by the governance arrangements of the project. Case management was conducted exclusively by the coordination unit, and under the agreed rules, companies and other stakeholders were not permitted to participate directly in operational processes. This setup naturally introduced certain constraints, which formed part of the implementation realities and revealed weaknesses that could not justify the project’s continuation. Despite this, and throughout the pilot, the companies consistently contributed constructive recommendations to strengthen workflows, enhance protections for rightsholders, and facilitate effective resolution mechanisms whenever suppliers were involved.

The participating companies remain committed to constructive engagement, responsible business conduct, and transparent dialogue with partners and stakeholders. We hope the clarifications provided in this statement contribute to a comprehensive and fair representation of the collective efforts undertaken by all parties.

Signatories

BMW Group,

Mercedes-Benz Group,

ZF Group

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