The Ordinance on Due Diligence and Transparency (VSoTr) requires any company with a registered seat, head office, or principal place of business in Switzerland to conduct ongoing supply chain due diligence. The obligation covers two independent tracks: conflict minerals (tin, tantalum, tungsten, and gold) and products or services with a reasonable suspicion of child labor.
June 30 each year: companies whose financial year follows the calendar year must publish their VSoTr due diligence report by this date.
The VSoTr has been in full force since business year 2023. Due diligence is an ongoing obligation, not a one-time exercise: supply chain policies, traceability systems, risk assessments, and grievance mechanisms must be maintained and updated continuously.
The annual report is the visible output of that continuous process. It must remain publicly accessible for at least ten years
The Ordinance on Due Diligence and Transparency (VSoTr) of December 3, 2021, entered into force on January 1, 2022. It iapplies to any company with its registered seat, head office, or principal place of business in Switzerland.
The ordinance covers two independent tracks: conflict minerals (tin, tantalum, tungsten, and gold, known as 3TG) sourced from conflict-affected and high-risk areas (CAHRAs), and products or services for which there is a reasonable suspicion of child labor.
Companies in scope must establish a supply chain policy, a traceability system, a grievance mechanism, and a risk management process, then publish an annual report on their compliance with these obligations.
SMEs that stay below at least two of the three thresholds, CHF 20 million balance sheet total, CHF 40 million in revenue, and 250 full-time employees, - in two consecutive financial years - are exempt from the child labor track. Volume-based thresholds set in Annex 1 of the VSoTr determine exemptions for the conflict minerals track.
Volume-based thresholds set in Annex 1 of the VSoTr determine exemptions for the conflict minerals track.
Tracing 3TG minerals to their origin requires documentation from smelters and refiners, often two or three tiers removed from the Swiss-based company. Most procurement systems were not built to capture CAHRA provenance data.
The child labor track is triggered by a risk-based standard, not confirmed cases. Determining whether suspicion exists for a product category or sourcing country requires a methodology that accounts for UNICEF's Children's Rights in the Workplace Index, ILO data, and sector-specific indicators.
The VSoTr report must be prepared and signed off by the ultimate management or governing body, the board of directors in Swiss stock corporations. Criminal liability attaches to the individuals responsible, not the legal entity.
A company can be in scope for one track but not the other, or in scope for both with different supplier populations and risk methodologies. Each track carries separate documentation requirements.
The osapiens HUB for Due Diligence covers both VSoTr tracks in one platform: conflict minerals traceability, child labor risk assessment, supplier data collection, and audit-ready annual report generation.
The osapiens HUB for Due Diligence maps in-scope suppliers to the relevant track: 3TG conflict minerals, child labor, or both. Supplier questionnaires follow the VSoTr-required management system elements: supply chain policy, traceability data, grievance system confirmation, and risk indicators.
Each response is checked automatically against the applicable threshold and risk criteria. The team reviews only the responses flagged as exceptions.
The risk assessment feature combines country-level risk classifications, sector risk data, and supplier-provided information into a board-ready classification per product category.
A reasonable suspicion triggers an escalation workflow with a remediation plan and documented follow-up. The resulting supplier risk data feeds CSDDD human rights due diligence, so companies managing both frameworks run one supplier engagement instead of two.
The VSoTr annual report is generated as a structured, exportable document covering all required disclosure elements for both tracks. The full data lineage, from supplier response to risk classification to board approval, is preserved and accessible for the ten-year retention period the VSoTr requires.
The Reporting Cockpit connects VSoTr findings directly to CSRD value chain disclosures. The due diligence data collected for VSoTr reporting also feeds ESRS S2 supply chain worker disclosures without a separate data collection exercise.
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