LkSG Section 6 - policy statement + preventive measures. POLICY STATEMENT (Section 6(2)): formal HUMAN RIGHTS STRATEGY published by senior management + addressing: (a) the company's procedure for fulfilling its due diligence obligations; (b) the human rights and environmental risks identified in the risk analysis; (c) the human rights and environmental expectations directed at the company's employees + the supply chain. Must be approved by senior management + reviewed annually + accessible to employees + suppliers + public. PREVENTIVE MEASURES (Section 6(3-4)): (a) FOR OWN BUSINESS: integration into business processes + procurement practices + remuneration systems + supplier selection + responsible procurement strategy + adequate funding + training for relevant personnel + procurement-control measures; (b) FOR DIRECT SUPPLIERS: contractual commitments + supplier code of conduct + training + audits + reasonable assurance through control mechanisms + supplier development support + ESCALATION + supplier-relationship-suspension/termination for substantial + repeated non-compliance. CONTRACT TERMS: anti-human-rights-violation clauses + audit rights + obligations to cascade requirements to sub-suppliers + remediation requirements + termination triggers. PROCUREMENT PRACTICES: avoid practices that contribute to human rights violations (e.g. unreasonable lead times + last-minute changes + cost pressures that incentivise overtime/wage non-payment).
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