Overview
This article explains what the LkSG requires for monitoring risk management and how to establish the role of a human rights officer in your company.
Relevant for companies within the scope of the LkSG.
Legal basis
Under Section 4 (3) LkSG, your company must determine who is responsible for monitoring risk management – for example by appointing a human rights officer. Management must inform itself about the work of this person or persons regularly, at least once a year.
How you design the role depends on company size, industry and number of suppliers.
Tasks
Monitoring risk management
Manage annual and event-driven risk analyses and the resulting measures
Document the fulfilment of due diligence obligations on an ongoing basis (Section 10 (1) LkSG)
Develop risk management strategically
Reporting and communication
Inform management regularly, at least once a year
Communicate the contact details internally and externally so that everyone knows the responsible contact person
Organisational integration
The role can report directly to management, be assigned to a specialist department or be anchored in a management role. In any case, there should be a direct reporting line to management.
1. Create a dedicated role
Introduce a separate role with a clear role description, tasks and responsibilities. Consider internal and external candidates.
2. Distribute to existing roles
Assign the responsibilities to one or more existing roles. Make sure that sufficient capacity is available.
3. Communication
The responsible person is in contact with all relevant stakeholders, e.g. purchasing and legal, to review, document and initiate measures and to take up information from the complaints procedure.
Note: The role should be filled by experienced people and equipped with the necessary resources, e.g. budget and specialist support.
Next steps
Define the position in the organisation chart
Create a role description: tasks, qualifications, incentives
Approach internal and external candidates
Establish the role in the company and make it known