The critics: Public Eye and the scrutiny of the trade

The associations of the trade

The commodity traders of Zug are organised in the Zug Commodity Association, and at national level in Suissenégoce, the Swiss association of commodity trading and shipping.¹ The associations represent the interests of the industry in political debates, organise training for its staff and develop standards of conduct. Their role has grown with the scrutiny of the industry. The traders, who for decades preferred discretion to publicity, have found it necessary to explain their business to the public and to engage with the authorities on the regulation of the sector.

The critics: Public Eye and the scrutiny of the trade

No account of the commodity trade in Zug would be complete without the critics who have scrutinised it. The non-governmental organisation Public Eye, formerly the Berne Declaration, has for many years investigated the conduct of Swiss commodity traders in producing countries, published studies of their activities and campaigned for their regulation. Its criticism of the new federal statistics on the commodity trade, published in 2025, is discussed in Chapter III.² Much of the organisation's work on the traders of Geneva, which the Geneva volume describes, applies equally to Zug. The Responsible Business Initiative of 2020, described in Part C, was in large part a response to the conduct of Swiss commodity and mining groups abroad. Glencore's operations in the Democratic Republic of Congo, Peru and Zambia were among the cases most frequently cited in the campaign.³

The critics have influenced the regulation of the trade. The transparency rules for payments to governments by extractive companies, the non-financial reporting and due diligence obligations and the extension of the anti-money-laundering rules, described in Parts C and E, are in part the result of their campaigns. For the practitioner, the critics are also a source of risk: an investigation published by a non-governmental organisation can prompt an inquiry by a prosecutor, a claim by a victim or the withdrawal of a bank's financing. The management of this risk has become part of the compliance function of every large trader in Zug.

Notes

1. Source as cited in the printed edition. ↩
2. Public Eye, "Neue Rohstoffstatistik: Mit Vorsicht zu geniessen", publiceye.ch, accessed September 2026. ↩
3. Blick, "Konzernverantwortungsinitiative: Glencore ist Paradebeispiel", blick.ch: four of the six prominent examples of the campaign concerned Glencore or its subsidiaries, among them the Mopani copper smelter in Zambia (sulphur dioxide emissions), the Cerro de Pasco mine in Peru (heavy metal pollution), mining rights in the Democratic Republic of Congo obtained with the help of Dan Gertler, and payments to the state oil company of Chad. Glencore's coal operations in Colombia were also the subject of campaign events of the Koalition für Konzernverantwortung (konzernverantwortung.ch, search result), without being confirmed as one of the principal examples. ↩

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.