[T]hank you for providing us with the opportunity to respond to [a] reference made in a response you've received from Swiss business associations to a study we conducted as co-authors for the Swiss government in 2018...

...The claim «that large Swiss companies are well advanced in implementing the UNGPs» is a generalized conclusion that can't be drawn from our research. Within the sample of Swiss companies responding to the... survey our overall findings... included the following:

- The level of knowledge about the UNGPs and the National Action Plan on Business and Human Rights (NAP) in Switzerland is generally low...;

- A significant majority of companies is not clear what the UNGPs mean for their company and what is expected from them;

- While most companies responding to the survey have policy, codes of conducts and guidelines in place that somehow reference human rights, only 20% of the companies refer to the UNGPs...;

- Less than 50% of the large companies have processes in place to continuously assess the human rights risks and impacts of their activities and defining specific measures. This shows a gap between adopted policies and the establishment of adequate mechanisms for their implementation;

- Larger companies are more likely to have clear internal responsibilities designed for human rights, to offer training, to integrate... and to report on human rights than small and mid-sized companies;

- The biggest companies who have most faced human rights ‘crises’, civil society pressure and international markets are the most progressive in implementing the UNGPs...

We would also like to emphasize that the study had a qualitative approach.... It does not allow for general conclusions on the Swiss business community as a whole... It can be accessed here.

Regarding the proposal... announced by the Swiss Federal Council, please note that this only includes reporting-, but no due diligence-requirements for companies (alignment of Swiss law with the EU Non-Financial Reporting Directive). More information on this... can be found in our commentary... Unglückliche Vermischung zweier Vorlagen.