SCRM Supplier Compliance & Risk Management

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Swiss climate disclosure ordinance · since 2024

Most of your emissions do not arise at your own site.

Swiss climate reporting follows the TCFD structure and requires disclosure of risks, targets and metrics. For most companies the lion’s share of emissions sits upstream.

The ordinance gives effect to the Code of Obligations duty to report on non-financial matters in the climate area. Reporting covers governance, strategy, risk management, metrics and targets – greenhouse gas emissions included.

The supply chain link is scope 3: emissions from purchased goods and services, transport and the use of sold products. Reporting those figures requires data from suppliers – and suppliers get asked, regardless of their own reporting duty.

Who is affected

  • Listed companies, banks and insurers above the statutory thresholds.
  • Their suppliers – through the data request, not through the statute.
  • Companies reporting voluntarily or at the request of banks and investors.
  • Group entities whose figures feed a consolidated report.

What the chain must supply

Emissions data
Figures per supplier and commodity group, ideally primary rather than sector averages.
Methodology
Disclose the basis – measured, calculated or estimated.
Targets
Reduction targets unreachable without supplier involvement.
Risks
Assess physical and transition climate risks along the chain.
Comparability
Keep figures consistent across years, including through supplier changes.

How SCRM covers it

Data requests as tasks

Who supplies what by when, with an owner instead of an inbox.

Provenance of the figure

Primary, calculated or estimated as a field – the difference decides under assurance.

History per supplier

Prior-year values stay retrievable, easing comparisons and follow-up.

Documented switches

Supplier changes with dates, so jumps in the figures stay explainable.

Frequently asked

We do not report. Why does this concern us?

Because your customers do. Their scope 3 figures are made of your numbers – the request arrives through purchasing or a tender.

Are sector averages enough?

Often as a starting point, with the method disclosed. Primary data is more robust and increasingly expected for material positions.

How does this relate to the CSRD?

Both point the same way with different granularity. Supplying an EU customer means being asked for ESRS data anyway.

As of July 2026. The requirements are being aligned with the international framework; verify before relying on this. Not legal advice.

Contact

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