Responsible Sourcing
CO 964j–964l / ODiTr & CSDDD
Few Swiss companies are directly subject to the ODiTr or the CSDDD. Many more inherit these obligations — by contract, because their clients are subject to them and pass the requirements down. Operational support, built directly inside the sectors concerned.
Who is concerned?
There are two ways to be concerned. Directly, if your company exceeds the ODiTr thresholds. Indirectly — the most common case — when a client or principal subject to these rules passes them on to you by contract.
Conflict minerals and metals
Applies to Swiss companies importing tin, tantalum, tungsten or gold (3TG) from conflict-affected and high-risk areas (CAHRA). LBMA and RJC standards are directly embedded in the framework applicable to actors in the gold supply chain.
Key sectors: precious metals, watchmaking, jewellery, commodity trading, manufacturing.
Child labour and forced labour
Applies to any company placing products on the Swiss market that may have been manufactured using child labour or forced labour. The burden of proof rests with the company — and reputational risk typically precedes legal exposure.
Key sectors: luxury, FMCG, distribution, manufacturing, textiles, food and beverage.
The contractual cascade effect
This is how most Swiss SMEs and mid-caps are affected. Large groups subject to the ODiTr or the CSDDD — the latter directly applicable to very large groups (the CSDDD phase-1 threshold being more than 5,000 employees and EUR 1.5 billion in turnover, with subsequent phases and Omnibus simplification still being finalised) — pass their obligations down to suppliers: contractual clauses, questionnaires, codes of conduct, audits.
Impact: you are asked for due diligence evidence that the law itself did not require of you.
Operational support — not theoretical
This expertise was built inside the companies concerned — precious metals, luxury, manufacturing — not in a law firm. The difference is concrete: I know what works in operational reality, not just in the texts.
Clarify your scope and obligations
Assessment of your actual exposure — both direct (ODiTr thresholds) and indirect (requirements passed down by your clients and principals). Mapping of supply flows, identification of applicable thresholds, review of the ESG clauses already present in your contracts. Gap analysis between current situation and required compliance.
Build an operational compliance framework
Drafting or redesign of HRDD policies, supplier codes of conduct, AML/KYC and denied party screening procedures, supplier risk management systems, documentation and transparency reporting aligned with legal requirements.
Embed in governance and contracts
Integration of ODiTr obligations into supply agreements and supplier compliance clauses. Internal governance framework — ownership, escalation paths, board-level reporting. Training for procurement and compliance teams.
Prepare audits and external interactions
Executive support in interactions with auditors (LBMA, RJC), demanding counterparties subject to CSDDD, institutional partners and, where relevant, regulators. Coordination of local external counsel as needed.
Why this is strategic — not just regulatory
Supply chain due diligence is not an annual reporting exercise. It directly affects supplier selection, contracts, AML/KYC controls, board governance and corporate reputation. Non-compliance can block a partnership, trigger an audit, or expose the company to public liability.
For companies active in precious metals, luxury, manufacturing or international distribution, compliance is also a competitive advantage: it reassures partners, secures certifications and opens markets.
Assess your ODiTr / CSDDD readinessRegulatory frameworks covered
- ✦ CO art. 964j–964l / Due Diligence and Transparency Ordinance (ODiTr)
- ✦ OECD Guidelines for responsible mineral supply chains
- ✦ LBMA Responsible Sourcing Programme (gold, platinum, silver)
- ✦ RJC Code of Practices & certification
- ✦ EU CSDDD (Corporate Sustainability Due Diligence Directive)
- ✦ UK Modern Slavery Act & transparency reporting
- ✦ ILO core conventions (child labour, forced labour)
- ✦ OFAC / EU / SECO sanctions — denied party screening
- ✦ FATF & high-risk third countries
- ✦ CAHRA — conflict-affected and high-risk areas
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