In Germany’s dynamic and highly regulated business environment, responsible sourcing and ethical supply chain management are not just best practices—they are legal imperatives and key drivers of sustainable value. For procurement leaders, the challenge is to operationalize these standards in a way that aligns with both global expectations and local requirements, such as the Lieferkettensorgfaltspflichtengesetz (LkSG). Publicis Sapient’s Supplier Code of Conduct provides a robust framework for meeting these demands, ensuring that every supplier relationship is built on integrity, transparency, and compliance.
This page offers practical guidance for German procurement professionals on how to implement the Supplier Code of Conduct across onboarding, due diligence, monitoring, and reporting. It also addresses common challenges and provides actionable steps for continuous improvement and regulatory alignment.
Publicis Sapient’s Supplier Code of Conduct sets clear expectations for all suppliers, partners, and affiliates. It is grounded in international best practices and is designed to cascade ethical, social, and environmental standards throughout the entire supply chain. Key principles include:
All new suppliers are required to read and acknowledge the Supplier Code of Conduct as part of the onboarding process. This ensures that every partner understands the standards expected and commits to upholding them from the outset. In Germany, this process is reinforced by contractual terms that require suppliers to comply with all legal, regulatory, and industry-specific requirements, including those set out in the LkSG.
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.
The Lieferkettensorgfaltspflichtengesetz (LkSG) sets out clear obligations for companies operating in Germany:
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.
Solution: Provide clear, accessible training and resources in German. Require written acknowledgement of the Code and offer support for suppliers to implement necessary changes.
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.
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.
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:
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.