PSI’s Legal Status and Questions of Compliance

What is PSI’s legal status?

The Paul Scherrer Institute (PSI) is a Swiss federal research institution and part of the ETH Domain. As such, PSI is an autonomous public‑law entity established by the Swiss Confederation, with its own legal personality.

PSI’s legal status, structure, and mandate are defined by the Federal Act on the Federal Institutes of Technology (ETH Act) of 4 October 1991. Under Article 1 of the ETH Act, PSI is listed as one of the federal research institutes subject to federal control, and Article 2 defines its public mandate in research, education, scientific services, and knowledge transfer.

As a public‑law institution:

• PSI is not a commercial company
• PSI is not registered in the commercial register (Handelsregister)
• PSI is owned by the Swiss Confederation
• PSI operates under federal oversight via the ETH Board and the Federal Council

PSI has a company identification number (UID) CHE‑116.133.392, which uniquely identifies PSI as a legal entity under Swiss public law.

Why is PSI not listed in the Commercial Register?

Unlike private companies, PSI was established directly by federal legislation and does not operate under private commercial law. Public‑law entities of the ETH Domain therefore do not have a commercial register entry, as their legal existence and authority derive directly from Swiss federal law rather than from commercial incorporation.

Vendor registrations and compliance questionnaires

As a Swiss federal research institution, PSI operates under the compliance, ethics, accountability, and governance frameworks of the Swiss Federal Administration. These statutory obligations supersede private vendor requirements.

For this reason:

• PSI does not complete vendor questionnaires designed for commercial suppliers
• PSI does not provide declarations of compliance against third‑party corporate policies
• PSI does not adopt or sign supplier codes of conduct

Where vendor registration is required for administrative reasons, PSI will provide only essential institutional information and will refer partners to this legal information page for clarification.

What partners typically ask – and how PSI addresses this

Industry partners frequently use standardized vendor registration, supplier onboarding, or due‑diligence questionnaires. These are generally designed for commercial suppliers and often assume private‑sector structures that do not apply to PSI.

The most common topics are addressed below.

1. Legal status, company registration, and ownership

Typical requests

• Commercial register extract
• Legal form (AG, GmbH, Ltd.)
• Shareholders or beneficial owners
• Parent company or group structure

PSI position

PSI is not a commercial company. It is an autonomous public‑law institution of the Swiss Confederation, established under the ETH Act.

Accordingly:

• PSI has its own legal personality under public law
• PSI has no commercial register entry
• PSI has no shareholders
• PSI is owned by the Swiss Confederation
  
  https://www.fedlex.admin.ch/eli/cc/1993/210_210_210/en
  
  https://fedlex.data.admin.ch/eli/cc/2004/16
   

2. Compliance, ethics, and codes of conduct (including ESG)

Typical requests

• Acceptance of a Supplier Code of Conduct
• Anti‑bribery, human‑rights, or ESG declarations
• Confirmation of compliance with company‑specific policies

PSI position

PSI cannot sign or adopt third‑party codes of conduct or compliance frameworks.

As a federal institution, PSI and its personnel are already bound by:

• Swiss federal law
• Public‑sector integrity and accountability rules
• Federal governance and oversight mechanisms applicable to the ETH Domain

These statutory obligations replace and supersede private corporate compliance frameworks. PSI therefore does not issue separate declarations against partner‑specific codes of conduct.

The ETH-Domain established a whistleblowing process which is also applicable for PSI. 

The ETH Board’s independent Reporting Office receives any reports of ethically incorrect activity: 

https://ethrat.ch/en/eth-board/reporting-office/

3. Public procurement, integrity, and anti‑corruption

Typical requests

• Confirmation of anti‑corruption policies
• Conflict‑of‑interest declarations
• Proof of ethical procurement standards

PSI position

PSI is subject to the Swiss public procurement regime, which imposes mandatory rules on:

• Transparency
• Equal treatment
• Prevention of corruption
• Responsible use of public funds

Public procurement is recognized by the Swiss Federal Administration as a high‑risk area for corruption, and federal institutions are subject to binding integrity and conflict‑of‑interest requirements by law.

The public procurement process is defined by law:

https://www.fedlex.admin.ch/eli/cc/2020/126/en
https://www.fedlex.admin.ch/eli/cc/2020/127/en

Procurements which require a public tender by the above mentioned laws have to be published on the public procurement platform SIMAP:
 
https://www.simap.ch/de

The public procurement process is explained here:

www.trias.swiss

4. Supply chain, ESG, and sustainability requirements

Typical requests

• Supply‑chain due diligence
• ESG or sustainability policies
• Conflict‑minerals or modern‑slavery statements

PSI position

PSI is a research institution, not a commercial supplier or manufacturer. PSI:

• Does not operate commercial supply chains
• Does not manufacture products for the market
• Explicitly excludes product liability in its research and material agreements

Research activities are only considered part of a supply chain when they are necessary for commercial manufacturing or service delivery. PSI’s research activities do not meet this criterion.

5. Certifications, audits, and corporate policies

Typical requests

• ISO certifications (e.g. ISO 9001, 14001, 27001)
• Corporate risk‑management systems
• External audit reports

PSI position

PSI does not operate as a commercial enterprise with a single corporate certification profile. Oversight and accountability are instead ensured through:

• Federal governance of the ETH Domain (Supervision, internal audit & riskmanagement - ETH-Rat)
• Strategic objectives defined by the Federal Council
• Supervision by the ETH Board
• Auditing and control mechanisms applicable to federal institutions by the Swiss Federal Audit Office (https://www.efk.admin.ch/en/)

These public‑law controls replace private certification schemes used in commercial supply chains.

6. Data protection, research integrity, and ethics

Typical requests

• Research ethics policies
• Data‑protection declarations (Data protection)
• Confirmation of lawful research conduct

PSI position

Research at PSI is subject to Swiss research‑ethics and legal frameworks, including federally coordinated ethical standards where applicable. These frameworks mandate respect for human dignity, legal compliance, and scientific integrity as binding requirements for public research institutions.
Further information: https://www.psi.ch/en/integrity 

How PSI handles vendor questionnaires

Vendor questionnaires are not an appropriate instrument for imposing legal or compliance obligations on PSI.

When such questionnaires arise:

• PSI will provide basic institutional identification and payment information
• Questions relating to compliance, ethics, ESG, supply chain, or certifications shall be marked as:
  • Not applicable, or
  • Referred to this legal information page
• PSI will not sign, upload, or accept third‑party codes of conduct or compliance declarations

Where alignment with a partner’s internal compliance framework is required, this should be addressed contractually, by acknowledging that PSI is governed by Swiss federal law and that no contradiction exists with the partner’s internal standards.

Contact 

For any questions and further information, the technology transfer team will be happy to assist you: 
techtransfer@psi.ch