There are a multitude of options here – ultimately you have to decide which form of communication makes the most sense for your company.

A classic and frequently used example is the inclusion of contact options, such as the online link to the complaints procedure, in the Code of Conduct for suppliers and business partners. Placing the reference to the complaints procedure on other common communication channels, such as supplier platforms, is also a good idea.

In addition, companies are of course open to all other communication channels that are often used in the communication of classic whistleblowing systems - such as posters, flyers, newsletters or training courses.

If a whistleblower system already exists, for example for compliance violations, this can also be expanded to include a complaints procedure under the LkSG. In principle, every company has to decide whether it makes sense to offer separate reporting systems or a uniform system. The decision as to which variant makes the most sense for your company depends on a number of influencing factors:

– The complaints procedure according to the LkSG must be publicly accessible. If the whistleblower system for compliance violations is only available to employees, and you want it to remain so, you should set up another channel specifically for LkSG topics.

– If the indications of general compliance and LkSG violations are processed by the same person or the same team, uniform case processing is at least advisable. If there are different responsibilities, access to cases should be restricted by a role/rights concept so that all case workers can still work in the same system.

– If potential whistleblowers along the supply chain are to be addressed differently than potential whistleblowers of compliance violations, it may make sense to set up separate reporting channels. The notes can still be included in the same case processing and processed there.

Grievance refers to a complaint or disagreement that an individual has about their job, colleagues, or working conditions. A grievance may be related to issues such as (but not limited to) discrimination, harassment, pay, or working hours. An employee can raise a grievance with their employer or a representative, such as a human resources manager or union representative. Whistleblowing is the act of reporting misconduct, wrongdoing, or illegal activity within an organization. It is often done by an employee who has witnessed or experienced the wrongdoing and wants to bring it to the attention of the organization.

If there has been a violation of human rights or environmental standards along the supply chain, the LkSG requires appropriate remedial measures to be taken. Furthermore, these have to be documented. We are currently developing more innovative solutions for the documentation and many other obligations under the LkSG. Click here to find out more.

Of course, it can happen that companies are not made aware of actual or potential LkSG violations in their own supply chain directly through their own complaints procedure, but rather through media reports, discussions with NGOs and competitors or other sources. Since these reports also have to be documented, it is advisable to record these processes manually in the case management of the complaints procedure. This means you always have a holistic view of all actual and potential violations, regardless of the source, and are ideally prepared for annual reporting.

If your company already has a whistleblower system for compliance violations, this often only covers the languages and jurisdictions commonly used by the workforce.

However, the principle of low barriers applies to the complaints procedure in the LkSG. As soon as information from the supply chain is expected, numerous other languages and jurisdictions usually become relevant. In any case, your complaints procedure should at the minimum cover the main languages and GDPR regulations of the direct suppliers. It is therefore worth taking a look at the most important supplier countries for your company.