LkSG questionnaires: what UK suppliers need to prepare
Germany's Supply Chain Due Diligence Act has been in force since January 2023. If you supply German companies, you will receive an LkSG questionnaire — here is exactly what they will ask and how to prepare a credible response.
The Lieferkettensorgfaltspflichtengesetz (LkSG) — Germany's Supply Chain Due Diligence Act — requires German companies above a certain size to conduct annual due diligence on their entire supply chain, including overseas suppliers. Since 1 January 2024 the threshold is companies with 1,000 or more employees in Germany. If you supply any of those companies, you are part of their compliance obligation.
As a UK supplier you are not directly subject to LkSG. However, your German customer is legally required to assess your practices and document the results. If you cannot provide satisfactory evidence, they may be obliged to take corrective action — which can include ending the commercial relationship.
What an LkSG questionnaire covers
Questionnaires vary by buyer, but the eight core areas are consistent across all LkSG due diligence frameworks:
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 monitor 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 and safety
Do you have an occupational health and safety management system? What is your accident rate? Do you hold ISO 45001 certification?
Environmental management
Do you have an environmental management system? Do you hold ISO 14001 certification? What are your greenhouse gas emissions?
Anti-corruption
Do you have an anti-corruption policy? Do you conduct anti-bribery training?
Grievance mechanism
Do you have a grievance mechanism through which workers and affected communities can raise concerns?
Step-by-step: preparing your response
Audit your existing policies
Check whether you have written policies covering human rights, child labour, forced labour, health and safety, environmental management, and anti-corruption. If a policy is missing, start with a one-page document — something is always better than nothing.
Gather certificates and evidence
Collect copies of relevant certificates (ISO 14001, ISO 45001, SA8000, etc.) and check their expiry dates. If you have no certifications, document your management systems and practices instead.
Calculate your greenhouse gas emissions
Most LkSG questionnaires include environmental questions. Calculate your Scope 1 and Scope 2 emissions as a minimum. The ESG Stress Free dashboard walks you through the process step by step.
Be transparent about gaps
If you do not have a particular policy or certification, say so — and explain what you are doing to close the gap. Buyers prefer honest suppliers who are making progress over those who provide vague or evasive answers.
Review the buyer's code of conduct
Your German customer will likely ask you to sign their supplier code of conduct. Read it carefully before signing — it contains commitments on human rights, environmental standards, and anti-corruption that you will be expected to uphold.
What happens if you do not respond?
If you fail to respond to an LkSG questionnaire — or provide an incomplete response — you risk being removed from your German customer's supply chain. Buyers are legally required to document risks and take corrective action when evidence is insufficient, including terminating the commercial relationship. The reputational and commercial consequences for UK SMEs can be significant.
Prepare your LkSG response with ESG Stress Free
ESG Stress Free guides you through all LkSG-relevant questions, stores your evidence securely, and generates a structured compliance report you can share directly with your German buyers — no sustainability team required.
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Free LkSG supplier checklist
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