Supply chain due diligence (LkSG) compliance programme
Establishment of a risk analysis, contract revision and reporting programme for a Türkiye-based supplier network under the German LkSG (Supply Chain Due Diligence Act) and European supply chain expectations.
Applying European due diligence to a Turkish supply network
The client had to make the human rights and environmental due diligence demands coming from its German customers applicable to its multi-tiered supplier network in Türkiye.
The programme's goal was to build a working compliance architecture consisting of risk-based audits, contractual provisions, a grievance mechanism, and a reporting schedule, rather than theoretical ESG texts.
Our Approach
Keeping the commercial objective at the centre, we broke the legal risks into measurable steps.
01 · Risk Analysis
Suppliers were classified by sector, country, product, and depth of relationship; a prioritised risk map was produced.
02 · Contract & Policy
A code of conduct, supplier commitments, audit rights, and remedial measure clauses were prepared.
03 · Reporting
A grievance mechanism, monitoring indicators, and a set of documents reportable to the German customer were established.
Timeline
The main phases of the process.
Auditable and reportable ESG infrastructure
The programme enabled the supplier network to be managed according to its risk levels; a documented, updatable process aligned with the German customer's requirements was established.
- Risk classification for 140 suppliers
- A contract and supplier commitment set
- A grievance mechanism and reporting schedule
- A remedial measure workflow
Services Involved in This Matter
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Related Areas of Expertise
The practice and focus areas engaged on this matter.
Sectors
The sectors in which we most frequently advise on matters of this kind.
Textiles
Supply contracts, ESG/LkSG compliance, export, trademark, employment law and debt-collection advisory across the textile and apparel chain.
Explore →Logistics
Advisory on contracts, liability and disputes in transport, warehousing, customs, CMR and cross-border delivery processes.
Explore →Automotive
Contract, compliance, investment, and dispute advisory across the automotive value chain for OEMs, suppliers, distributors, and investors.
Explore →Related Publications
Our insights and guides related to this matter.
New obligations for Turkish companies doing business with Germany and the EU
The indirect effects of the LkSG on Turkish suppliers and the steps to be taken for compliance.
Read more →
ESG, Sustainability and Supply Chain Due Diligence
Supply chain due diligence for Turkish companies trading with Germany and the EU: where the LkSG — in force since 2023 — now stands, and the demands arriving through customer contracts.
Read more →General Assessment of the European Union’s Work on the Due Diligence Directive
The EU due diligence directive was adopted as Directive (EU) 2024/1760 and narrowed by the Omnibus I amendment of February 2026: the thresholds are 5,000 employees and EUR 1.5 billion turnover, and it applies from 26 July 2029.
Read more →The Team on This Matter
Our multilingual team handling the matter.
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First, we clarify the commercial objective, risk appetite, timeline, and the decision-maker's needs. Then we break the work down into legal analysis, document/contract structure, and implementation steps, and manage the process through a single point of contact.
Due to the legal profession's duty of confidentiality and client privacy, the files are anonymised. In a meeting, we can describe our comparable experience more concretely, within the limits of confidentiality.
In a brief preliminary meeting, we gather the objective, existing documents, parties, time pressure, and critical risks. Then the scope, team, timeline, and fee model are clarified.
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