On 1 January 2022, Switzerland introduced due diligence and reporting requirements to address risks in the supply chains of Switzerland-based businesses related to child labor and so-called conflict minerals. On 24 May 2024, the European Council adopted the EU Corporate Sustainability Due Diligence Directive (CS3D), which imposes EU-level due diligence requirements in the value chain (i.e., upstream and downstream), on top of existing regulations in this area at the EU member state level.
In this update, we provide an overview of the evolving regulatory landscape of supply chain due diligence requirements in Switzerland and the EU, as well as their practical implications, and we suggest action items for Swiss businesses with respect to supply chain governance and compliance programs. In doing so, we refer to further materials prepared by our environmental, social and governance (ESG) team across our EU offices.
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Author
Christoph Kurth
Before joining the Firm, Christoph was global head of Litigation & Investigations and general counsel in Asia for a large Swiss bank. For over 10 years, he has led complex regulatory and criminal investigations as well as high stakes litigation across the US, Europe and Asia, and has advised on transformational regulatory developments and wealth management products and services across Switzerland and Asia. In his roles, Christoph has worked closely with business leaders, government authorities and the media, navigating businesses through regulatory and other challenges. Prior to this, Christoph was a litigator in leading practices in Switzerland and the US. Christoph also teaches post-graduate courses in ‘Crisis Management’ and ‘Risk Governance’ at the Europa Institute at the University of Zurich.
