Supply Chain Act in medium-sized industrial companies: Implementation of the minimum requirements (2/2)

Implementation of the LkSG

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The LkSG requirements can be divided into internal and external requirements. On the one hand, information must be requested externally from the supplier in order to check his careful actions. On the other hand, you as an organisation must ensure certain internal structures for the successful fulfilment of the guideline.

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Meeting external requirements through supplier self-disclosure

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As a first step, relevant information regarding environmental protection and occupational safety should be requested from the supplier. This information forms the basis for successfully setting up a risk management system and conducting risk analyses. Adapted to the risk fields of the LkSG, questions can be asked on the following topics:

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Environmental protection

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• Mercury production, use and release
• Protection from harmful chemicals, organic pollutants and wastes

Human rights

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• Child labour/employment age
• Slavery, forced labour and discrimination

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Occupational health and safety

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• Compliance with occupational health and safety legislation
• Protective clothing
• First aid
• Safety standards and protective measures

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Labour rights

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• Remuneration and minimum wage
• Freedom of association 

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Furthermore, the following certificates can be requested to guarantee the supplier's compliance with due diligence obligations:

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• SMETA / Sedex for social responsibility and ethical behavior
• SA 8000 for social responsibility (international)
• ISO 14001 for environmental management systems
• ISO 9001 for quality management systems
• ISO 50001, 50003 for energy management systems
• Blue Angel for handling raw materials
• Verification of the CO2 footprint in accordance with DIN EN ISO 14064-3

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This important information forms the basis for the fulfilment of the following statutory duties of care:

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1. Documentation and reporting
2. Establishment of a risk management system
3. Carrying out risk analyses
4. Anchoring measures vis-à-vis direct suppliers
5. Implementation of due diligence obligations for indirect suppliers

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Fulfil internal requirements by setting up organisational due diligence structures

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Some of the due diligence obligations also relate to organisational structures and processes that need to be put in place.

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This includes:

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1. The designation of a person or department responsible for the implementation of the LkSG
2. The anchoring of preventive measures in the company and the associated rapid taking of remedial action
3. The submission of a policy statement describing the measures for operational compliance with the due diligence obligations as well as the monitoring of the policy at the supplier's premises. The supplier's own measures for occupational safety and environmental protection should also be recorded here.
4. The establishment of a complaints procedure for the rapid internal and external submission of complaints and their further handling process. For this purpose, e.g. a form on the website or a dedicated mail address can be considered

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We are happy to support you in implementing the LkSG requirements!

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