Overview
The policy statement under Section 6 (2) LkSG sets out your company's human rights strategy. Here you can see what it must contain and how to create it. Relevant for companies within the scope of the LkSG.
Related topics: Code of conduct and Human rights officer.
What is the policy statement?
Companies within the scope of the LkSG must issue a policy statement on their human rights strategy. The statement is issued by senior management (Section 6 (2) LkSG). It shows what your company stands for and sets out goals and principles for dealing with human rights and environmental risks.
Minimum content under Section 6 (2) LkSG:
A description of the procedure by which your company fulfils its due diligence obligations
The priority human rights and environmental risks identified on the basis of the risk analysis
The expectations placed on your employees and suppliers, defined on the basis of the risk analysis
How to create the policy statement
Appoint a person responsible for designing and integrating the policy statement.
Set up a cross-functional team, e.g. from sustainability/environmental management, HR, procurement, communications and quality management.
Carry out the risk analysis first. This lets you align the policy statement with your company's actual risks.
Clarify whether you extend an existing document (e.g. CSR policy or environmental policy) or create a new one.
Check the content against the checklist below.
Communicate the result:
Involve all employees who take part in the implementation.
Integrate the policy statement into existing documents, e.g. the code of conduct.
Publish the policy statement, e.g. on your website.
Checklist
Does senior management commit to complying with and monitoring human rights due diligence throughout the company?
Does the document refer to recognised international human rights standards?
Are the priority risks from the risk analysis named and adequately addressed?
Are responsibilities and specific measures to protect human rights defined – including for cases of violations?
Is the procedure described by which your company fulfils its human rights and environmental due diligence obligations?
Are measures, deadlines and responsibilities described?
Are expectations of employees, suppliers, business partners and customers set out?
Implementation
With the policy statement, you show internally and externally that your company recognises and fulfils its responsibility. Usually 2–3 pages are enough to present the key content. You can set out details in supplementary documents such as the code of conduct.
Next steps
Companies without a policy statement
Proceed step by step: first appoint a responsible person who designs and integrates the policy statement and sets goals. Then improve the principles and their implementation continuously.
Companies with a policy statement
Extend existing documents such as your environmental policy or CSR guidelines with principles for protecting human rights, or integrate the content into existing documents such as the code of conduct. Update the policy statement when the results of your risk analysis change.
Risk analysis in the Tacto App
The policy statement is based on the risk analysis. In Tacto's standard configuration, it takes place in two stages. This lets you first prioritise your direct suppliers and then analyse the prioritised suppliers in detail.
Abstract risk analysis: assesses all direct suppliers using country- and industry-related risk indices on human rights and the environment.
Concrete risk analysis: assesses the suppliers classified as high-risk in the abstract analysis in detail – per risk, e.g. by severity and likelihood of occurrence.
Mitigating factors such as a signed code of conduct are included in the assessment and reduce the estimated risk.
Note: Evaluation templates, criteria and score calculation are configured per customer. Your configuration may differ from the standard configuration described here.
Templates