A Deep Dive into Supplier Code of Conduct: Practical Guidance for German Procurement Leaders

In Germany’s highly regulated business landscape, responsible sourcing and ethical supply chain management are not just best practices—they are legal imperatives. The Lieferkettensorgfaltspflichtengesetz (LkSG), or Supply Chain Due Diligence Act, has set a new standard for transparency, risk management, and accountability. For German procurement leaders, the challenge is to operationalize these requirements while driving sustainable value and maintaining competitive advantage. Publicis Sapient’s Supplier Code of Conduct offers a robust, actionable framework for meeting these demands, ensuring every supplier relationship is built on integrity, transparency, and compliance.

This guide provides practical, step-by-step advice for German procurement professionals on implementing the Supplier Code of Conduct in line with the LkSG. It covers onboarding, due diligence, monitoring, reporting, and documentation, and addresses common challenges in the German regulatory context.

Publicis Sapient’s Supplier Code of Conduct sets clear expectations for all suppliers, partners, and affiliates. Grounded in international best practices, it is designed to cascade ethical, social, and environmental standards throughout the entire supply chain. Key principles include:

• Respect for Human Rights: Strict prohibition of forced, bonded, or involuntary labour; zero tolerance for child labour; and a commitment to fair treatment, non-discrimination, and dignity for all workers.
• Fair Labour Practices: Compliance with all applicable labour laws, including fair pay, working hours, and benefits. Overtime must be voluntary and compensated appropriately.
• Safe and Healthy Workplaces: Suppliers must provide a safe working environment, comply with health and safety laws, and take proactive steps to prevent workplace accidents.
• Environmental Responsibility: Suppliers are required to comply with environmental laws and minimize their environmental impact through responsible management of waste, energy, and emissions.
• Ethical Business Conduct: Zero tolerance for bribery, corruption, and facilitation payments. Suppliers must avoid conflicts of interest and protect confidential and personal data.
• Supply Chain Responsibility: Suppliers must ensure that their own suppliers and subcontractors adhere to these standards, amplifying ethical practices throughout the value chain.

All new suppliers are required to read and acknowledge the Supplier Code of Conduct as part of the onboarding process. In Germany, this is reinforced by contractual terms mandating compliance with all legal, regulatory, and industry-specific requirements, including those set out in the LkSG. This ensures every partner understands the standards expected and commits to upholding them from the outset.

Responsible procurement at Publicis Sapient integrates ethical, social, and environmental considerations into supplier selection. During the tendering process, suppliers complete a self-assessment questionnaire covering human rights, labour, and environmental practices. High-risk suppliers—such as those operating in regions with elevated risks of modern slavery or employing temporary, low-skilled workers—undergo enhanced due diligence, including detailed reviews and feedback to address any areas of concern.

For German procurement leaders, this due diligence is essential for LkSG compliance, which mandates the identification and mitigation of human rights and environmental risks in the supply chain. Documentation and transparency are critical: all findings and actions must be recorded and available for audit.

Supplier compliance is not a one-time check. Publicis Sapient uses platforms such as EcoVadis to track and audit suppliers’ corporate social responsibility performance, including health and safety, environmental stewardship, and ethical conduct. Only suppliers who complete the self-assessment and demonstrate commitment to our standards progress to the final selection stage. Annual audits by legal, procurement, and internal audit teams ensure ongoing compliance and continuous improvement.

In Germany, regular monitoring is also a legal requirement under the LkSG. Companies must review the effectiveness of their due diligence processes at least annually and whenever significant changes occur in the risk landscape.

Suppliers are encouraged to report any actual or potential ethical concerns related to the Code. Publicis Sapient provides confidential channels for reporting, and all concerns are taken seriously and investigated promptly. In Germany, a formal complaints procedure is in place, allowing any person—whether an employee, supplier, or third party—to report human rights or environmental risks or violations. The process is designed to protect whistleblowers from retaliation and ensure objective, confidential handling of all cases.

If a material breach is identified, Publicis Sapient reserves the right to terminate business relationships to protect the integrity of the supply chain. Remediation steps are documented and, where necessary, corrective actions are implemented in collaboration with the supplier.

Comprehensive documentation is essential for LkSG compliance. All due diligence, monitoring, and remediation activities must be recorded and available for audit. Annual reports on due diligence activities are published, providing transparency and accountability to stakeholders and regulators.

The LkSG sets out clear obligations for companies operating in Germany:

• Risk Analysis: Identify and assess human rights and environmental risks in the supply chain.
• Preventive Measures: Implement policies and procedures to prevent violations.
• Remedial Action: Take immediate action to address any identified violations.
• Complaints Procedure: Establish accessible channels for reporting concerns.
• Documentation and Reporting: Maintain comprehensive records and publish annual reports on due diligence activities.

Publicis Sapient’s Supplier Code of Conduct and procurement processes are fully aligned with these requirements, providing German companies with a clear, actionable framework for compliance.

Challenge 1: Ensuring Supplier Engagement and Understanding
Solution: Provide clear, accessible training and resources in German. Require written acknowledgement of the Code and offer support for suppliers to implement necessary changes.

Challenge 2: Managing Complex, Multi-Tier Supply Chains
Solution: Cascade standards by requiring direct suppliers to ensure their own suppliers and subcontractors comply. Use digital platforms for supply chain mapping and risk assessment.

Challenge 3: Maintaining Transparency and Documentation
Solution: Implement robust documentation practices, including digital records of due diligence, monitoring, and remediation activities. Regularly review and update processes to reflect changes in the regulatory landscape.

Challenge 4: Addressing Non-Compliance
Solution: Establish clear escalation and remediation procedures. Engage with suppliers to resolve issues where possible, but be prepared to terminate relationships in cases of material breach.

Ethical supplier relationships are not just about compliance—they are a source of competitive advantage. By partnering with suppliers who share our values, Publicis Sapient helps German companies:

• Mitigate operational and reputational risks
• Build trust with clients, investors, and communities
• Support ESG and regulatory compliance
• Drive innovation and resilience through a transparent, accountable supply chain

For German procurement leaders, the path to responsible sourcing and supply chain transparency is both a regulatory obligation and a strategic opportunity. Publicis Sapient’s Supplier Code of Conduct provides a proven, practical framework for meeting the highest standards of ethics, compliance, and sustainability. By embedding these standards into every supplier relationship, German companies can ensure compliance with the LkSG, protect their reputation, and drive long-term value in a rapidly changing world.

For more information or to report a concern, suppliers and stakeholders are encouraged to use the confidential channels provided by Publicis Sapient. Together, we can build a digital future that is not only innovative, but ethical and just.

Relevant Links

• Sapient Limited Supplier Code of Conduct: Ethical Standards and Expectations
• Responsible Business in the UK: Publicis Sapient’s Approach to Social Impact, Modern Slavery, and Supplier Ethics
• Code de conduite des fournisseurs : Un levier stratégique pour la transformation digitale responsable en Europe (Europe)
• Code de conduite des fournisseurs : Un levier stratégique pour la transformation digitale responsable en Europe (Europe)
• Sapient Limited Supplier Code of Conduct: Ethical Standards and Expectations
• Código de Conducta para Proveedores: Un Pilar para la Transformación Digital Ética en América Latina (LATAM)
• Código de Conducta para Proveedores: Impulsando la Transformación Digital Ética en América Latina (LATAM)
• Código de Conducta para Proveedores: Un Compromiso Ético en la Transformación Digital en América Latina (LATAM)
• Modern Slavery and Human Rights in Digital and Consulting Supply Chains: Unique Risks, Due Diligence, and Best Practices
• Supplier Code of Conduct in the UK: Local Implementation, Social Impact, and Regulatory Compliance
• Modern Slavery and Human Rights in Digital and Consulting Supply Chains