On this page, you will find information on how to implement the complaints procedure as required by the Act on Corporate Due Diligence Obligations in Supply Chains (Lieferkettensorgfaltspflichtengesetz, or LkSG). It does not contain any information on the official application procedure within the meaning of § 14 LkSG.
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Complaints procedures are a core element of the due diligence obligations. Every company must have a complaints procedure through which internal and external persons can notify the company of human rights or environmental risks or violations in its own business area and in the supply chain.
Complaints procedures serve as an early warning system through which problems are identified and, in the best case, resolved before people or the environment are harmed. In addition, effective grievance procedures provide access to appropriate remedy when needed. If indications or complaints of imminent or actual violations of obligations are received and confirmed, these violations must be prevented, terminated or at least minimized by the company through remedial actions. The companies must then take preventive measures to prevent further violations or to minimize these risks.
The due diligence processes outlined in the LkSG are therefore closely interlinked and are designed to mutually strengthen each other's impact. Complaints procedures thus offer companies the opportunity to gather feedback on the effectiveness of their risk management and individual due diligence processes. They are therefore an important component for the further development of risk management and due diligence processes
Companies falling under the scope of the Act as of January 1, 2023 must have a functioning complaints procedure in place as of that date.
For companies that are in scope of the Act as of the beginning of 2024, this will apply as of January 1, 2024
To support you in organizing, implementing and evaluating a complaints procedure, BAFA has published the Guidance [Complaints Procedure under the Act on Corporate Due Diligence Obligations in Supply Chains]. Further assistance on the complaints procedure can also be found in Chapter XII of the Questions and Answers on the Supply Chain Act.
