Transparency on Non-Financial Matters Provisions

Reporting
- Companies which are required to prepare consolidated financial statements under Swiss law must prepare a consolidated report on transparency on non-financial matters (CSR reporting) or explain why it doesn't do so.
- A company, which is domiciled in Switzerland but controlled by a legal entity domiciled abroad that prepares an equivalent Report does not have to prepare a separate report. In such a case, the Swiss company must indicate in the notes to their financial statements, which other legal entity included it in its report. In addition, they must publish the report of the foreign company
Due Diligence
Other social matters
- The non-financial report shall account for environmental issues, in particular CO2 targets, social issues, labour issues, respect for human rights and the fight against corruption. The report must contain the information which is necessary for an understanding of the course of business, the business results, the situation of the company as well as the effects of its activities on these matters

Large Companies
- Companies which, together with the domestic or foreign entities they control, have an annual average of at least 500 full-time equivalents in two consecutive financial years, and which, together with the domestic or foreign entities they control, exceed either a balance sheet total of CHF 20 million or sales revenue of CHF 40 million in two consecutive financial years fall within the scope of this law.
SMEs
All sectors

Own operations
Direct subsidiaries
Direct suppliers
Indirect suppliers
Full value chain
- Report shall cover risks of «the undertaking's own operations and (...) its business relationships, products or services», but only where «relevant and proportionate».

Civil Liability
Facilitating Access to Justice
Other
- Criminal Sanctions: Wilful false statements in the reports or a failure to report can be fined with up to 100’000 Swiss Francs. If such an act is done negligently the maximum fine is 50’000 Swiss Francs.
- Due to the comply or explain approach of the regulation there are no sanctions for not reporting if the company publishes a related explanation.