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An example: a trader’s due diligence report

Worked example. A Geneva metals trader employing 400 people and generating a turnover of USD 12 billion, of which USD 3 billion in the European Union, prepares its first due diligence report. It maps 180 direct suppliers in 25 countries, 40 of which are identified as high-risk for human rights or the environment. It conducts 25 on-site audits, terminates 4 relationships, launches improvement plans with 20 suppliers and documents its traceability procedures for copper and cobalt from Central Africa. The cost of the arrangement, covering staff, audits, systems and advice, reaches USD 2.5 million in the first year, or roughly 0.02 per cent of turnover. It determines the trader’s access to its European clients, its banks and its insurers, while reducing its exposure to the proceedings described in Chapter V. The report, published in French and in English, is examined by a Geneva non-governmental organisation, which notes its limitations without questioning its sincerity.

For general information only. This article does not constitute legal or tax advice, does not replace advice on an individual case and creates no lawyer-client relationship. It reflects the legal position as of September 2025.

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