Meet your German customer's due-diligence demands in a single programme.
Meet customer demands arising from the German Supply Chain Act (LkSG) and the EU due-diligence directive (CSDDD) in a single programme — with risk analysis, a policy set, a grievance mechanism, and audit readiness.
Why is a “programme” needed?
German customers' LkSG-driven demands cannot be met with a single document: a signed code of conduct, self-assessment questionnaires, audit rights, training records, and corrective-action plans form an interconnected whole. As CSDDD approaches at the EU level, building a living compliance programme instead of scattered paperwork both protects today's orders and is an investment in tomorrow.
The five components of the programme
1. Risk analysis
mapping, prioritising, and documenting human-rights and environmental risks across your production processes and sub-suppliers.
2. Policy set
a human-rights policy statement, a code of conduct and responsibility assignments — tied to processes, not merely on paper.
3. Contract architecture
the measured acceptance of customer demands and their proportionate pass-through to your own suppliers; negotiating excessive commitments.
4. Grievance mechanism
an accessible, confidentiality-preserving reporting channel for employees and third parties — integrated with our whistleblowing system.
5. Audit readiness
an evidence file and a rehearsal for customer audits and self-assessments.
Not a certificate, but defensibility
LkSG is not a certification regime; your customer expects from you not perfection but documentation of your efforts. The programme's output is a file that can answer every question with “the record is right here,” and a team that is not caught unprepared on audit day. This approach also feeds CSRD-driven data requests from the same infrastructure — this is the setup we describe as the “single-file strategy” in our CSDDD analysis.
Scope and footing: who, and when?
Since 2024 the LkSG has covered companies in Germany with 1,000 or more employees. Turkish suppliers are not directly subject to the Act; they are on the receiving end of obligations passed down to them by contract. In practice, BAFA’s question sets as the supervisory authority and customers’ own audits look for the same evidence file. On the EU side the CSDDD has been adopted; its implementation timetable is phased and begins with the largest companies. The practical consequence: a programme built for the LkSG today is the groundwork for CSDDD requirements tomorrow — the same investment is not made twice.
Who is it for, and what do you get?
The programme is most often commissioned by manufacturer-exporters selling to German OEMs and retailers, and by group companies that receive those customers’ audit letters. The risk profile varies by sector; the programme stays the same, the evidence set changes.
What you get: a prioritised risk map, a bilingual policy statement and code of conduct, a clause library that carries down into supplier contracts, integration of the grievance channel, and a report on the audit rehearsal. The contractual side aligns with our supplier contract architecture, and the corporate framework with our ESG focus area.
A programme built before a customer asks for one also keeps the answers to audit questions ready when you are winning new business.
We are by your side for the LkSG / CSDDD Compliance Programme
Our ESG & Supply Chain Desk tailors the programme to your sector (textiles, automotive, metal, logistics), conducts contract negotiations with a team that knows German customer expectations from the inside, and keeps the programme alive with an annual maintenance routine. The engagement typically begins with a 6-8 week setup project; thereafter it moves into a periodic review rhythm.
Other Applications of This Service
Compliance — our other specialised solutions in this area.
Matter Connections
The focus areas, practice areas, desks and legislation connected with this sub-service.
Our Matters in This Service
The anonymised examples of our work that relate to this service.
Uninterrupted legal counsel for a multinational supplier
Retainer-based support across day-to-day commercial operations, contract management and compliance processes.
Review the matter →ESG & ComplianceSupply chain due diligence (LkSG) compliance programme
Risk assessment and compliance architecture for a Turkish supplier network under the German LkSG.
Review the matter →Market AccessEstablishing a distribution network in Türkiye
Designing a market entry strategy, distributorship agreements and competition compliance.
Review the matter →The Team Delivering This Service
With our multilingual team of lawyers, well-versed in Turkish and German law, we are by your side.
Mehmet Köksal
Founder and Managing PartnerIstanbul · Berlin · KyreniaProfile →
Kübra Köksal-Yılmaz
PartnerBerlin · İstanbulProfile →
Gül Efem
Of CounselİstanbulProfile →
Sven Köksal
Legal EngineerBerlin · İstanbulProfile →
Gökçe Yıldırım
Of CounselİstanbulProfile →Related Publications
Fresh perspectives and guides from the Knowledge Centre.
No — these clauses can be negotiated. Unannounced audits at your expense, vague termination triggers and unlimited sub-supplier commitments can be balanced; your bargaining power increases when you come prepared.
Even if the timeline has been postponed, major buyers are already updating their contracts to CSDDD language. A programme built for the LkSG is designed to be extensible with CSDDD topics (climate plan, stakeholder engagement) — today’s…
The Act does not bind you directly; but your German customers pass their own obligations on to you by contract. The programme is the infrastructure for meeting these demands without losing orders and without taking on disproportionate commitments.
They help but are not sufficient: the LkSG additionally requires human rights and environmental due diligence, a complaints mechanism and supply chain transparency. We integrate your existing management systems into the programme and prevent duplicated…
LkSG / CSDDD Compliance Programme — get the right legal support.
Let us identify the right solution together, drawing on our experience in Türkiye and the DACH region.