Overview
This article explains the requirements for the complaints procedure under Sections 8 and 9 of the German Supply Chain Due Diligence Act (LkSG) and how to implement it with the Tacto whistleblower / complaints system.
Relevant for companies within the scope of the LkSG, i.e. generally with at least 1,000 employees in Germany. To use the Tacto function, the Supplier Portal must be enabled for your Workspace.
Related articles: Whistleblower Protection Act (HinSchG) and Differences between LkSG and HinSchG.
Good to know
Since 7 November 2025, BAFA no longer reviews LkSG reports, and reports can no longer be submitted via the BAFA portal. A draft law by the German Federal Government provides for the retroactive removal of the reporting obligation under Section 10 (2) LkSG. You can find the current status at BAFA.
The obligation to operate a complaints procedure and to keep internal documentation (retention for at least 7 years, Section 10 (1) LkSG) remains unaffected.
This article summarizes the legal requirements and does not replace legal advice.
Legal requirements
Companies must set up an appropriate internal complaints procedure or participate in an equivalent external procedure (Section 8 (1) LkSG). It serves as an early warning system and provides access to remedy.
Content: Reports on human rights and environmental risks as well as on violations of obligations in the company's own business area, at direct Suppliers and at indirect Suppliers (Sections 8 (1), 9 (1) LkSG).
Rules of procedure: They must be laid down in text form and be publicly accessible (Section 8 (2) LkSG).
Responsible persons: They must be impartial, independent and free from instructions, and are bound to confidentiality (Section 8 (3) LkSG).
Accessibility: Information on availability, responsibility and the process must be clear, understandable and publicly accessible. The procedure must be accessible to potential parties inside and outside the company, maintain the confidentiality of identity and protect against discrimination (Section 8 (4) LkSG).
Effectiveness: The procedure must be reviewed at least once a year and on an ad hoc basis (Section 8 (5) LkSG).
Link with the risk analysis
Findings from handling reports must be taken into account in the risk analysis (Section 5 (4) LkSG). Conversely, use the results of your risk analysis to make the complaints procedure accessible to the relevant target groups.
Complaints procedure process
1. Receipt of the complaint or report
Receipt is acknowledged to the reporting person.
2. Review
The next steps and responsibilities are determined.
In case of rejection, the reporting person receives a justification.
3. Clarification of the facts
The facts are discussed with the reporting person.
4. Development of a solution
Optionally, an amicable settlement procedure can be offered.
5. Implementation of remedial measures
6. Review of effectiveness
Implementation in Tacto: whistleblower / complaints system
The Whistleblower / complaints system is part of the Supplier Portal. It is a public page at your portal address (suffix /complaints) and sits outside the Tacto App. Reporting persons do not need an account.
On the page Complaint procedure of [your company], reporting persons find an introduction, the rules of procedure under Section 8 LkSG with the contact details of your responsible person, and the File a Complaint button.
In the form, they select a category (required), describe the situation (required) and can optionally add the location, the parties involved, further information and supporting documents.
In the standard configuration, 11 categories are available, e.g. Human Rights Violations, Environmental Violations and Code of Conduct Violations. Your categories may differ.
Providing an email address is optional, so reports can also be submitted anonymously.
After clicking Send complaint, the reporting person sees a confirmation page. There is no automatic confirmation email and no case number.
Incoming reports are sent by email to the address stored during setup. The Tacto App has no inbox for reports, and reports are not automatically linked to Suppliers or to your risk analysis.
Note: Your responsible person handles the acknowledgement of receipt, the feedback and all further processing, e.g. by email, provided the reporting person has entered an email address.
Transfer relevant findings from reports into your risk analysis yourself, e.g. via an Evaluation of the affected Supplier in the Evaluations module.
How to set up the whistleblower / complaints system
1. Have the Supplier Portal enabled
The whistleblower / complaints system requires the Supplier Portal. If it is not enabled for your Workspace, the settings show the message Supplier Portal not enabled. In this case, contact your Tacto Key Account Manager.
2. Appoint a responsible person
Appoint the person who receives and handles reports, with the following details:
Name
Email address
Position
Phone number
Address
These details are stored during setup together with your Tacto contact and are shown in the rules of procedure.
The responsible person must act impartially, independently and free from instructions (Section 8 (3) LkSG). We therefore recommend not choosing a person who is responsible for supplier relationships themselves, e.g. from Procurement.
3. Enable the whistleblower / complaints system
Open Settings → Workspace → Supplier Portal.
Turn on the Whistleblower / complaints system switch. It is disabled by default.
Check the page via Preview portal → Open and add the suffix /complaints.
Without permission to configure the portal, you only see the status Enabled or Disabled instead of the switch.
4. Make access known
Copy your portal address under Portal address with Copy address and add /complaints. Publish the link, for example:
Clearly visible on your public company website and on your intranet
In documents you regularly exchange with direct Suppliers, e.g. in Supplier Requests
In case of increased risks as a preventive measure, e.g. in trainings and information material for Suppliers