Trade and Compliance at SWISSto12
SWISSto12 as a group of companies owned by a Swiss parent company (Swissto12 SA) conducts its activities in strict compliance with all applicable national and international export control laws and regulations.
This activity includes the purchase of technology and export of its products, which are only sold when associated with clear, identified End-Use/End-Users.
SWISSto12 has a strict policy whereby it does not manufacture and export any products categorised as specific military goods, weapons or war material by the Swiss State Secretariat of Economic Affairs (SECO).
State Secretariat for Economic Affairs (SECO) Export Control Framework
SWISSto12 complies with Switzerland’s export control laws and regulations, established by the country’s central authority for export controls and sanctions, the State Secretariat for Economic Affairs (SECO). Compliance with relevant export control laws and regulation is detailed in an Internal Compliance Program (ICP) applied in all SWISSto12 entities, wherever their location. As the cornerstone of SWISSto12’s trade compliance program, SECO provides the regulatory structure and licensing mechanisms that ensure the company’s operations align with Swiss law.
SWISSto12 only manufactures and exports civilian goods or goods that are classified by SECO as ‘dual use’. To safeguard against unauthorized use or exportation, each transaction requires product export classification, partner screening, mandatory licensing, and comprehensive End-Use/End-User verifications.
The SECO export controls relating to dual use are based on a number of key acts. These include:
- Federal Act on the Control of Dual-Use Goods, Specific Military Goods and Strategic Goods (Goods Control Act)
- The Ordinance on the Control of Dual-Use Goods, Specific Military Goods and Strategic Goods (Goods Control Ordinance)
- Legislation on sanctions: Federal Act on the Implementation of International Sanctions (Embargo Act) Ordinances as per the SECO list
Regarding End-Use/End-User verifications, SWISSto12 collects End-Use/End-User certificates from its buyers, which declare the identity of End-User, the declared End-Use of goods, and a commitment that the goods will not be re-exported in violation of Switzerland’s export control laws and regulations.
In addition, SWISSto12 ensures screening of its partners, suppliers and customers to ensure strict compliance with applicable export control sanctions, laws and regulations.
Internal Compliance Program (ICP)
Internal Compliance Program (ICP) in line with SECO requirements to ensure full compliance with applicable national and international export control laws and regulations. These include the Swiss export control laws and regulations, U.S. export control laws and regulations, and European export control laws and regulations.
The ICP aims to establish a rigorous and adaptable framework that not only meets legal obligations but also promotes a culture of ethics and responsibility within SWISSto12.
The extensive program, endorsed by SWISSto12 executive management and overseen by the Trade Compliance department, covers a wide range of measures, procedures, and safeguards. Collectively, these help prevent violations, mitigate any compliance risks, and provide evidence of due diligence as well as help ensure sustainable and secure growth in international markets.
Activities required by the ICP program include goods classification, verification processes (including End-User screening and End-Use verification), treatment of anomalies, audit frequency, and prevention of abuse.
The ICP program extends to training and awareness for relevant SWISSto12’s workforce as well as recordkeeping, documentation, and internal audits to ensure procedures are followed and corrections implemented, where necessary.
The ICP program is regularly reviewed and updated to reflect regulatory changes, sanctions and evolving export control risks.