LkSG Risk Analysis: Supply Chain Due Diligence Under § 5

ADVISORI designs and conducts your LkSG risk analysis under § 5 of the German Supply Chain Act: from abstract country and sector screening to concrete supplier assessments and prioritized measures.

  • 01Systematic LkSG risk analysis methodology
  • 02Supply chain risk assessment and classification
  • 03BAFA-compliant due diligence processes
11+Years of experience
120+Employees
540+Projects
ISO 27001certified

Systematic Risk Analysis Under the Supply Chain Act

Companies in scope of the German Supply Chain Act must identify, weigh and prioritize human rights and environmental risks in their own operations and at direct suppliers — annually and on an ad hoc basis, for example when entering new markets or obtaining substantiated knowledge of possible violations at indirect suppliers. In practice, many risk analyses fall short of BAFA expectations because they stop at abstract country scores or lack a documented prioritization logic.

4 service modules

What we take on for you

Bookable individually or as an end-to-end programme.

01

Abstract and Concrete Risk Analysis

We design and conduct the two-stage risk analysis under § 5 LkSG: an abstract screening of country, sector and commodity risks, followed by a concrete assessment of prioritized suppliers and business areas. The methodology is fully documented and repeatable.

  • Country, sector and commodity risk screening
  • Concrete supplier-level risk assessment
  • Prioritization by severity, likelihood and leverage
  • Appropriateness criteria per § 3 (2) LkSG
  • Audit-ready methodology documentation
02

Supplier Risk Assessment and Classification

We build a data-driven supplier segmentation that focuses due diligence effort where risk is highest. Questionnaires, evidence checks and external risk data are combined into a consistent supplier risk score.

  • Risk-based supplier segmentation model
  • Due diligence questionnaires and evidence review
  • Human rights and environmental risk indicators
  • Integration of external risk data sources
  • Escalation logic for high-risk suppliers
03

Preventive and Remedial Measures

We translate risk analysis results into effective measures: supplier codes of conduct, contractual assurances, training and structured remediation plans, including the effectiveness reviews required by §§ 6 and 7 LkSG.

  • Supplier code of conduct and contract clauses
  • Training and capacity-building concepts
  • Remedial action plans per § 7 LkSG
  • Effectiveness reviews and measurable KPIs
04

LkSG Governance and CSDDD Readiness

We anchor the risk analysis in a sustainable operating model with clear responsibilities, an annual and event-driven cycle, and interfaces to the complaints procedure — designed to transition smoothly to the EU Corporate Sustainability Due Diligence Directive.

  • Annual and event-driven analysis cycle
  • Interface to the complaints procedure per § 8
  • Management reporting and documentation
  • Transition planning towards the EU CSDDD

Who does this at ADVISORI

Your contact

Melanie Düring

Head of Risk Management

5 QUESTIONS, BRIEFLY ANSWERED

Frequently asked questions about Supply Chain Act (LkSG) Risk Analysis

How does the LkSG risk analysis under § 5 of the Supply Chain Act work?

The LkSG risk analysis under § 5 is a systematic procedure for identifying, assessing, and prioritising human rights and environmental risks across the entire supply chain. It forms the core element of risk management under the German Supply Chain Due Diligence Act.

The process consists of three main steps:

1. Risk identification: Capturing all potential risks in your own business area and at direct suppliers through country risk assessments, industry analyses, and supplier-specific assessments.

2. Risk assessment and prioritisation: Evaluating identified risks by severity, probability of occurrence, and the company’s degree of influence. The BAFA guidance recommends a multi-level methodology.

3. Deriving measures: Developing appropriate prevention and remediation measures based on risk prioritisation, with clear responsibilities and timelines.

The results of the risk analysis must be documented and reported to management. ADVISORI supports the development of a structured risk analysis methodology that covers both legal requirements and industry-specific considerations.

What steps does supply chain risk assessment under the LkSG involve?

Supply chain risk assessment under the LkSG involves five essential steps that must be completed systematically.

1. Supply chain inventory: Mapping all direct suppliers with capture of locations, product categories, and sub-suppliers. Prioritisation by procurement volume and strategic importance.

2. Abstract risk analysis: Evaluation of country risks, industry indices, and external data sources to identify high-risk suppliers. Use of risk indices such as the BAFA country risk report.

3. Concrete risk analysis: In-depth review of prioritised suppliers through self-assessments, on-site audits, and document reviews. Assessment of actual human rights and environmental risks.

4. Risk classification: Categorisation of risks by severity, reversibility, and number of affected persons. Creation of a risk map with prioritisation levels.

5. Measure derivation: Development of appropriate prevention measures per risk class. Definition of KPIs for effectiveness measurement.

ADVISORI guides companies through implementing this risk assessment methodology and integrating it into existing risk management processes.

How often must the risk analysis under the Supply Chain Act be conducted?

The regular risk analysis under the Supply Chain Act must be conducted at least once annually. In addition, an event-triggered risk analysis is required when substantiated knowledge of potential violations emerges.

The LkSG distinguishes two analysis types:

1. Regular risk analysis (annual): Covers the company’s own business area and all direct suppliers. Involves updating the risk map and reviewing existing measures.

2. Event-triggered risk analysis: Triggered by substantiated knowledge of risks at indirect suppliers, significant changes in business activities, complaints through the grievance mechanism, or new insights into industry risks.

In practice, the BAFA recommends continuous monitoring to supplement the annual mandatory analysis. Companies should establish a monitoring system that detects changes at suppliers early.

ADVISORI supports the establishment of a structured analysis calendar and automated early warning systems for your supply chain.

What due diligence obligations does the LkSG risk analysis examine at direct suppliers?

The LkSG risk analysis at direct suppliers examines compliance with the due diligence obligations defined in § 2 of the Supply Chain Act in two core areas.

Human rights due diligence:

• Prohibition of child labour and forced labour
• Occupational health and safety
• Freedom of association and right to collective bargaining
• Prohibition of discrimination in employment
• Adequate remuneration (minimum wage)
• Prohibition of unlawful forced evictions
• Prohibition of engaging private security forces in human rights violations

Environmental due diligence:

• Prohibition of causing harmful soil and water contamination
• Prohibition of unlawful emissions
• Prohibition of excessive water consumption
• Compliance with the Minamata, Stockholm, and Basel Conventions

The risk analysis must be appropriate and effective, meaning the type and scope of the analysis must correspond to the identified risk potential. ADVISORI develops industry-specific risk analysis frameworks that systematically cover all due diligence obligations.

What is the difference between abstract and concrete risk analysis under the LkSG?

The LkSG provides for two levels of risk analysis that differ in depth, scope, and trigger.

Abstract risk analysis:

• First level of risk assessment
• Uses country risk indices, industry reports, and publicly available data sources
• Identifies potential risks based on supplier location and industry
• Result: Classification of suppliers into risk categories (low, medium, high)
• Conducted for all direct suppliers

Concrete risk analysis:

• In-depth review of identified high-risk suppliers
• Uses supplier-specific data such as self-assessments, audit reports, and on-site inspections
• Assesses actual risks and specific violations
• Result: Detailed risk assessment with action plan
• Conducted on a risk-oriented basis for prioritised suppliers

The BAFA expects companies to methodically conduct and document both analysis levels. ADVISORI supports the development of a multi-level analysis methodology that efficiently connects both levels.

Certificates, partners and more

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