How to respond to an LkSG questionnaire from a German buyer
Germany's LkSG requires companies with ≥1,000 employees to conduct annual due diligence on their suppliers. Here's a step-by-step guide to responding effectively.
Germany's Lieferkettensorgfaltspflichtengesetz (LkSG) — the Supply Chain Due Diligence Act — has been in force since January 2023. If you supply to any German company with 1,000 or more employees, that company is legally required to conduct annual due diligence on you. This means you will receive a questionnaire.
What does an LkSG questionnaire cover?
LkSG questionnaires typically cover the following topics:
Human rights policy
Do you have a written human rights policy? Is it publicly available? Does it cover your own operations and your supply chain?
Child labour
Do you have a policy prohibiting child labour? How do you verify compliance in your supply chain?
Forced labour
Do you have a policy prohibiting forced and compulsory labour? Do you conduct risk assessments?
Freedom of association
Do you respect workers' rights to form and join trade unions? Do you have a collective bargaining agreement?
Health & safety
Do you have a health and safety management system? What is your injury rate? Do you have ISO 45001 certification?
Environmental management
Do you have an environmental management system? Do you have ISO 14001 certification? What are your GHG emissions?
Anti-corruption
Do you have an anti-bribery and corruption policy? Do you provide anti-corruption training to employees?
Grievance mechanism
Do you have a grievance mechanism that allows workers and affected communities to raise concerns?
Step-by-step response guide
Review your existing policies
Check whether you have written policies covering human rights, child labour, forced labour, health & safety, environmental management, and anti-corruption. If you don't, start drafting them — even a simple one-page policy is better than nothing.
Gather your certifications
Collect copies of any relevant certifications (ISO 14001, ISO 45001, SA8000, etc.) and check their expiry dates. If you don't have certifications, document your management systems instead.
Calculate your GHG emissions
Many LkSG questionnaires now include environmental questions. Calculate your Scope 1 and 2 emissions using DEFRA or EPA emission factors.
Be honest about gaps
If you don't have a particular policy or certification, say so — and explain what you are doing to address the gap. Buyers prefer honest suppliers who are making progress.
Sign the code of conduct
Your German buyer will likely ask you to sign their supplier code of conduct. Review it carefully before signing — it will contain commitments on human rights, environmental standards, and anti-corruption.
Further reading
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Free LkSG supplier checklist
Download our step-by-step guide to responding to LkSG questionnaires from German buyers.