Supply-Chain Due-Diligence Officer
Human-rights risk analysis, preventive measures, grievance mechanism, annual BAFA report. Supply-chain due diligence on rails for any company above the LkSG thresholds.
§ 4 LkSG · BAFA reporting
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What is a Supply Chain Officer under LkSG?
The supply chain officer under the Lieferkettensorgfaltspflichtengesetz (LkSG, the German supply chain due diligence act) is the person responsible under Section 4 paragraph 3 LkSG for monitoring the risk management system, an internal responsibility the act illustrates with the appointment of a human rights officer. The act has applied since 1 January 2023 to companies with at least 3,000 employees in Germany and since 1 January 2024 to companies with at least 1,000 employees in Germany. The officer reports directly to the management board, which must inform itself about that work at least once a year.
The duties follow the annual cycle set out in the statute. The risk analysis under Section 5 LkSG separates own operations from direct suppliers and is repeated whenever sourcing patterns or conditions in a sourcing country change. Prioritised risks feed the policy statement under Section 6 paragraph 2 LkSG and the preventive measures under Section 6 LkSG, typically a supplier code of conduct, contractual assurances, training and controls. Where a violation in own operations is established, the remediation duty under Section 7 LkSG applies. The complaints procedure under Section 8 LkSG has to be genuinely reachable for workers along the chain. Substantiated knowledge about violations at indirect suppliers triggers Section 9 LkSG. The report under Section 10 paragraph 2 LkSG is filed with BAFA under Section 12 LkSG within four months of the financial year end, and the documentation is retained for seven years under Section 10 paragraph 1 LkSG.
What surfaces in an inspection is rarely a missing appointment. It is an appointment without substance: a risk analysis never updated after the first run, a complaints procedure without published rules of procedure, preventive measures never tested for effect, no deputy for holiday and sick leave. BAFA can issue orders under Section 14 LkSG, breaches are fined under Section 24 LkSG, and Section 22 LkSG allows exclusion from public tenders.
The role sits alongside the HinSchG reporting office, which covers a different catalogue of subject matter, and alongside sustainability reporting under ESRS S1 to S4, which cuts the same data for a different purpose. On top of that sits the EU CSDDD, in force since 25 July 2024 and amended by Omnibus I: as amended it is to be transposed by 26 July 2028 and applied from 26 July 2029. Current LkSG procedures are usually built to carry that later extension rather than twice.
Core duties
- Conduct the annual risk analysis under Section 5 LkSG, broken down by direct supplier and own operations.
- Update the human rights policy statement under Section 6 paragraph 2 LkSG.
- Implement preventive measures including supplier code of conduct and training.
- Operate the complaints procedure under Section 8 LkSG accessible to workers along the chain.
- Investigate substantiated knowledge of indirect supplier violations under Section 9 LkSG.
- Execute remediation measures and document the impact under Section 7 LkSG.
- Produce the annual report under Section 10 paragraph 2 LkSG and file it with BAFA under Section 12 LkSG within four months of year end.
- Report to the management board at least once a year and ad hoc on material risks.
- Bridge to CSRD reporting under ESRS S1 to S4 and to the upcoming CSDDD requirements.
- Maintain documentation for at least seven years under Section 10 paragraph 1 LkSG.
When appointment is mandatory
Under Section 1 paragraph 1 LkSG the act covers companies whose head office, principal place of business, administrative seat or statutory seat is in Germany, and companies with a branch under Section 13d HGB in Germany, that as a rule employ at least 1,000 workers in Germany; that threshold has applied since 1 January 2024. Within scope, Section 4 paragraph 3 LkSG requires the company to determine who inside the company is responsible for monitoring the risk management, and names the appointment of a human rights officer as the example. A named appointment is therefore not strictly prescribed, but it is the usual and auditable route. What counts is the workforce in Germany; workers posted abroad are included. External advisors can support the officer but cannot replace that internal responsibility.
- Company employs at least 1,000 workers in Germany under Section 1 LkSG
- German branch or subsidiary of a foreign group above the threshold
- Suspected human rights violation in own operations
- Substantiated knowledge of indirect supplier violation under Section 9 LkSG
- Order by BAFA under Section 14 LkSG
- CSDDD threshold reached once the directive is transposed nationally
Typical sectors
- Automotive and mechanical engineering with global supply chains
- Textile and apparel with sourcing in Asia and Africa
- Electronics and semiconductor supply chains
- Food and agricultural commodities including cocoa, coffee, palm oil
- Chemicals and pharmaceuticals with rare earth or active substance imports
- Retail and consumer goods with private label sourcing
- Energy and utilities with mineral and fossil fuel supply
- Steel, aluminium and base metals with conflict mineral exposure
- IT hardware and consumer electronics
- Construction materials with cross-border sourcing
How CIVAC supports the human rights officer
CIVAC maps the LkSG duties onto three building blocks: tasks, training and documentation. The risk analysis under Section 5 LkSG, the update of the policy statement, the preventive measures under Section 6 LkSG and the remediation measures under Section 7 LkSG sit in the role profile as dated tasks, each carrying reminders ahead of the deadline and a named deputy. The annual report under § 10 Abs. 2 LkSG hangs on the same four-month deadline.
Evidence accumulates as a by-product. Every action lands in an append-only audit trail. The supplier code of conduct, the rules of procedure for the complaints channel under Section 8 LkSG and the training records are versioned in the documentation pillar, so the seven-year retention under Section 10 paragraph 3 LkSG runs from one store. Role templates carry the task catalogue, so a successor does not start empty-handed. Pricing is 49 euro per role per month. The statutory function stays inside the company: CIVAC provides the workspace, not the appointment.
Frequently asked questions
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