If you determine, with the help of an alert on the feed page, that a legal position may have been violated, the first step should always be to start an incident review. This is done using the "Create Incident" button (Fig. 1).
❗ An incident review should be created so that the suspicion of a possible violation of a legal position relevant to the LkSG can be processed for BAFA and its mitigation can be tracked. If there is no suspicion, the alert can be ignored - or the mitigation can be flagged as skipped for better tracking.
Fig 1: To determine an incident, "Create Incident" should be selected.
You can select whether the alert relates to a single site or a site group. If no specific site can be assigned, the site group should be selected.
If applicable, Prewave can recognise that an incident has already been created for a target (= supplier). It is possible to add the newly detected incident to this Incident Review. If there is no previous incident review on a similar topic or for the same supplier, or if the merge is not available, click on "Create new incident" (Fig. 2).
Fig 2: The next step is to click on "Create new incident" - if no previous alert is to be merged.
The first suggested action "Incident Review" should be selected in order to recognise this violation systemically and to track its mitigation (Fig. 3).
If this step is not selected, this violation will not be transferred to the BAFA report template provided by Prewave (e.g. question C2.1 Were violations detected at direct suppliers during the reporting period?)
Fig 3: To ensure that the detected incident also appears in the BAFA report template, an "Incident Review" should always be created, to which subsequent remedial actions should be linked.
The status of this incident review can and should be documented (Fig. 4, 1).
It is stated whether measures are recommended by determining an action priority based on the severity of the violation and the impact on the supplier (Fig. 3, 2).
Fig. 4: Documentation of the incident review and its execution, in which the priority of measures is determined (by selecting severity and impact)
If the action priority is high or critical, Prewave automatically suggests planning further actions (Fig. 5). If you decide to take further measures, click on "Take action".
The corresponding article in the LkSG guide provides assistance in independently assessing the severity and impact if the suggested values differ from your own assessment.
Fig. 5: If a measure has a high or critical priority, it is suggested that further measures be planned.
You will then be taken to another window in which you can select the appropriate measure with a higher intensity (Fig. 6).
Fig. 6: Selecting a higher intensity remedial action due to a breach tracked and processed by Incident Review.
In the example in Fig. 6, we have opted for an on-site audit. The status of this measure should also be updated here (see Fig. 7). This is the only way to show in the BAFA report whether your scheduled measures have been carried out and whether they have been successfully completed or not.
Fig. 7: The status of a measure should always be kept up to date so that the information is correctly exported to the BAFA report template.
The measures that are planned based on the incident identified at the beginning should now be linked to the initially created incident review so that they are implemented in the BAFA report provided by Prewave. For this purpose, the original incident review can be attached as an appendix to the "on-site audit" measure selected as an example (see Fig. 8):
Fig. 8: Selection of the correct incident review attached to the measure.
Only when the link is active can the measures taken as a result of the violations be included in the report. This is essential for questions such as C2.1: C2.1 Were violations identified at direct suppliers during the reporting period? If 293 Yes was selected, have you taken appropriate remedial action?
Fig.: 9: A successfully linked incident review for a measure.