A/HRC/45/9/Add.1 foreign policy objectives of Switzerland; and preserving Swiss neutrality. Private security services that contradict these aims must be prohibited by the responsible authority (art. 14). The Act focuses on private security services rather than entities. An extensive list of services fall within the scope of the Act, ranging from security services at events to operating and maintaining weapons systems (art. 4). Hence, the regulation recognizes that private security services are provided by a wide variety of companies and sectors, including, for example, the intelligence and defence industries in Switzerland for the services they provide in relation to training or maintenance of equipment. 39. The Act applies not only to companies that establish, base, operate or manage a private security company in Switzerland, but also to those that exercise control over such a company from Switzerland (art. 2). This wide scope of application, coupled with the focus on services rather than on self-identification as a private security company, provides a means to ensure that a maximum number of potentially problematic activities falls under the law. Certain classic activities, however, such as protection of persons and guarding or surveillance of property, are covered by the Act only when undertaken in “complex environments”, with a cumulative definition of “complex environments” that arguably sets the threshold too high.22 40. Importantly, the Act includes several categorical prohibitions. Specifically, a prohibition applies to services related to direct participation in hostilities (art. 8) and to services where it may be assumed that they will be utilized by the recipient(s) in the commission of serious human rights violations (art. 9). The law does not list specific violations, but the Working Group was informed that article 9 also encompassed genderbased violations, including sexual and gender-based violence. 2. A declaratory system 41. The Act provides for a declaratory procedure whereby legal persons, natural persons and business associations that provide private security services within the scope of the Act are required to declare all such activities to a federal authority that reviews them to ascertain whether they comply with the Act (art. 10). Moreover, companies are to notify the competent authority of any significant changes that occurred after the initial declaration of activities. 42. Pending notification from the competent federal authority, the company is required to refrain from carrying out the declared activities (art. 11). Where there are indications that an activity may be provided in non-compliance with the law, for instance contravening the aims of the law, the competent federal authority initiates a review procedure (art. 13) and decides whether an activity shall be prohibited. Some types of activities are subjected to a particularly thorough review, for example those provided in crisis or conflict regions or where they may be of service to institutions or persons in the commission of human rights violations (art. 14). In the case of non-compliance with the prohibitions and obligations described above, the Act provides for sanctions (sect. 5). 43. The declaratory procedure also requires companies to inform the competent authority about the measures taken for basic and advanced training of personnel, and specifically mentions training in human rights law and international humanitarian law for persons carrying out management duties and those carrying weapons. 3. Implementation of the Federal Act and its implications 44. To implement the law, the federal authorities have gone to great lengths to raise awareness with concerned companies and to prepare material to facilitate their work in abiding by their obligations under the law. This includes detailed guidelines explaining the contents of each article to enable companies and individuals to better understand the text, as well as a guidance document for companies on the elements that should be covered in the training provided to their personnel (including but not limited to: international human rights 22 See www.eda.admin.ch/dam/eda/en/documents/aussenpolitik/sicherheitspolitik/Verordnung-ueberdie-im-Ausland-erbrachten-privaten-Sicherheitsdienstleistungen-VPS_EN.pdf. 9