You Already Do Most of What the LkSG Asks — You Just Can't Prove It
Here's something I wish someone had told every small supplier the moment they received their first LkSG questionnaire:
You're probably already doing most of what they're asking about. You just don't have the paperwork to prove it.
I've talked to dozens of small manufacturers, service providers, and logistics companies who received LkSG due diligence requests from their German clients. Almost all of them had the same reaction: panic, followed by the assumption that they needed to completely overhaul their operations.
They didn't. And you probably don't either.
What the LkSG actually asks
Strip away the legal language, and the LkSG questionnaire is basically asking five things:
- Do you treat your workers fairly? Fair wages, reasonable hours, safe conditions.
- Do you not use child labor or forced labor? This one's usually a yes.
- Can your workers report problems? Some way to raise concerns without fear.
- Do you care about the environment? Basic waste management, pollution awareness.
- Do you pay attention to who you buy from? Some awareness of your own suppliers.
That's it. That's what's behind all the intimidating terminology.
The gap isn't in your practices — it's in your documentation
Let me give you a real example. I spoke to the owner of a metalworking shop — about 40 employees. When I asked him about the LkSG questions, here's how the conversation went:
Me: "Do you have an occupational health and safety policy?"
Him: "I mean... we have safety equipment, regular safety training, we follow all the regulations. But I don't have a document called 'Occupational Health and Safety Policy.'"
Me: "Do you have a grievance mechanism?"
Him: "A what?"
Me: "Can your workers come to you if they have a problem?"
Him: "Of course. My door is literally always open. Everyone knows they can talk to me or to our floor manager."
Me: "That's a grievance mechanism."
Him: "...Really?"
Really.
The translation problem
The LkSG doesn't require you to be perfect. It requires you to be able to describe what you do in the language that German compliance teams understand. That's a translation problem, not an operations problem.
Here's what I mean:
| What you'd say | What the due diligence form needs | |---|---| | "We check IDs when we hire people" | "The company enforces a strict age-verification process during recruitment to ensure compliance with minimum working age requirements" | | "Workers can talk to their manager if something's wrong" | "The company maintains an accessible internal grievance channel through designated management personnel" | | "We sort our waste and follow local regulations" | "The company implements waste segregation protocols in accordance with applicable environmental legislation" | | "We pay everyone above minimum wage" | "Remuneration policies ensure all employees receive compensation that meets or exceeds statutory minimum wage requirements" |
Same practices. Same reality. Completely different language.
The left column is how a normal person describes running a decent business. The right column is what gets filed in a self-declaration. The substance is identical — only the packaging changes.
What you probably already have (without knowing it)
Let's go through the most common LkSG requirements and check:
Fair wages and working hours — Do you pay at least minimum wage? Do your employees have employment contracts? Do they work roughly normal hours? If yes, you're covered.
No child labor — Do you check IDs during hiring? Do all your employees meet the legal working age? Of course they do.
Workplace safety — Do you have safety equipment? Fire extinguishers? First aid kits? Safety training? Regular maintenance? That's an occupational health and safety system.
Grievance mechanism — Can workers talk to a manager, HR person, or the owner about problems? Can they send an email? Is there a suggestion box? Any of these count.
Environmental awareness — Do you separate recyclables? Do you properly dispose of chemicals or hazardous materials? Do you follow local environmental laws? That's environmental management.
Anti-discrimination — Do you hire based on qualifications regardless of gender, ethnicity, or religion? Do you have both men and women on staff? You're practicing non-discrimination.
What you might actually need to add
To be honest, there are usually one or two areas where small companies have genuine gaps:
A written grievance process. Having an open-door policy is great, but the LkSG expects something a bit more structured. It doesn't need to be complex — even a dedicated email address where workers can raise concerns counts. The key is that it exists, it's communicated to employees, and complaints are taken seriously.
Some awareness of your own supply chain. If you buy raw materials or components, the LkSG expects you to have some process for evaluating your suppliers. This doesn't mean auditing every vendor — it can be as simple as asking key suppliers about their own practices when you start a new business relationship.
These are small additions, not overhauls. A grievance email address takes five minutes to set up. A supplier evaluation checklist is a one-page document.
Why this matters
I see too many small business owners read an LkSG questionnaire and feel like frauds — like they're being told their business isn't good enough. That's not what's happening.
What's happening is that a German law created paperwork requirements that were designed for companies with compliance departments, legal teams, and documentation systems. Those requirements are now trickling down to companies that run on trust, relationships, and common sense.
Your business practices are probably fine. You just need to describe them in a way that satisfies a due diligence questionnaire.
That's not a character flaw. It's a documentation gap. And documentation gaps are fixable.
This is exactly why KettenKlar exists. You answer simple questions about what you actually do — and we turn your answers into the formal business language your German client needs. No pretending to be something you're not. Just accurate documentation of your real practices. Try it now →