Twenty-five officer roles, all live todayArt. 33 GDPR, 72 hours to report a breach93 controls under ISO/IEC 27001:202237 ready-to-run audit templates in the workspace§ 130 OWiG, supervisory duty of the management boardOfficer appointment letter, signed, filed, evidencedOne workspace for tasks, trainings, audits, documentationDIN 14095 fire protection plans, standardisedEU AI Act, the first horizontal AI regulation worldwideTwenty-five officer roles, all live todayArt. 33 GDPR, 72 hours to report a breach93 controls under ISO/IEC 27001:202237 ready-to-run audit templates in the workspace§ 130 OWiG, supervisory duty of the management boardOfficer appointment letter, signed, filed, evidencedOne workspace for tasks, trainings, audits, documentationDIN 14095 fire protection plans, standardisedEU AI Act, the first horizontal AI regulation worldwide
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LkSG

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.

Focus areas
§ 4 LkSGBAFA reportRisk analysisGrievance
Legal basis

§ 4 LkSG · BAFA reporting

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What is a Supply Chain Officer under LkSG?

The supply chain act compliance germany framework is the Lieferkettensorgfaltspflichtengesetz (LkSG), in force since 1 January 2023 for companies with at least 3,000 employees in Germany and since 1 January 2024 extended to companies with at least 1,000 employees in Germany. Section 4 LkSG requires the appointment of a human rights officer reporting directly to the management board and monitoring the risk management system. The duties cover the risk analysis under Section 5, preventive measures in own business operations and at direct suppliers under Section 6, remediation measures under Section 7, the complaints procedure under Section 8, indirect supplier monitoring under Section 9, and the annual report to BAFA under Section 10. The EU Corporate Sustainability Due Diligence Directive (CSDDD) entered into force on 25 July 2024 with staggered application from 2027 to 2029. Sanctions under Section 24 LkSG reach 8 million EUR for legal persons, or up to 2 percent of average annual global turnover.

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.
  • File the annual BAFA report under Section 10 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 3 LkSG.

When appointment is mandatory

Appointment is mandatory under Section 4 paragraph 3 LkSG for any company with its head office, central administration, statutory seat or branch under Section 13d HGB in Germany that employs at least 1,000 workers in Germany. The threshold has applied to all in-scope companies since 1 January 2024. External advisors can support the human rights officer but cannot replace the statutory function.

  • Company has at least 1,000 employees in Germany
  • 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 in 2027 or 2029 once transposed

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
CIVAC

How CIVAC supports the human rights officer

CIVAC delivers an LkSG-ready workspace with the risk analysis matrix under Section 5 LkSG, supplier onboarding workflows including ILO core conventions screening, complaints procedure under Section 8 LkSG with multilingual intake and dual-control case management, and BAFA report templates aligned with the official questionnaire under Section 10 LkSG.

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