Swiss NCP
- agentorangechild
- Aug 8
- 9 min read
Updated: Aug 16
Dear Swiss NCP,
I am submitting a formal Specific Instance complaint under the OECD Guidelines for Multinational Enterprises against Zurich Insurance Group and Swiss Life Holding, both headquartered in Switzerland.
I am the civilian child of an Australian Vietnam War veteran, harmed by inherited toxic exposure to TCDD (Agent Orange). My case is an active complaint before the International Criminal Court (ICC) under Article 15 of the Rome Statute.
On the 7th August 2025, I formally placed these institutions on legal notice via their compliance and whistleblowing channels regarding their potential financial complicity in crimes against humanity and transnational organised crime.
This case concerns:
Ongoing chemical harm to Australian civilians across multiple generations
State-facilitated erasure of harmed children from history, policy, and healthcare
Financial and insurance structures enabling corporate and government denial
Profiteering from prohibited substances in breach of the Stockholm Convention and OECD Guidelines
Enterprise Details
Zurich Insurance Group AG – Mythenquai 2, 8002 Zürich, Switzerland
Swiss Life Holding AG – General-Guisan-Quai 40, 8002 Zürich, Switzerland
OECD Guidelines Breaches
Chapter II – General Policies: Failure to prevent or mitigate known human rights abuses
Chapter III – Disclosure: Failure to disclose financial exposure to ICC-named entities and TCDD manufacturers
Chapter IV – Human Rights: Complicity in systemic harm to vulnerable populations, including children
Chapter VI – Consumer Interests: Failure to ensure redress pathways for affected civilians
Urgency
These institutions have been given a 7-day deadline to respond to my formal legal notices. Their failure to act promptly in the face of active ICC proceedings and ongoing human rights violations will constitute wilful complicity.
Evidence Available
Original legal notices to Zurich Insurance Group and Swiss Life Holding 7th August 2025
ICC case record and filing confirmation under Article 15
Evidence of underwriting links to Australian state entities and TCDD manufacturers
Public record archive documenting harm and institutional denial:
https://agentorangechild.wixsite.com/agent-orange-child
I request that the Swiss NCP:
Accept this complaint as a Specific Instance under the OECD Guidelines.
Notify Zurich Insurance Group and Swiss Life Holding immediately.
Initiate a review process in coordination with other NCPs already on notice in other jurisdictions.
Treaty Breach and Systematic Insurance Fraud
Australia ratified the Stockholm Convention on Persistent Organic Pollutants in 2004, thereby accepting binding obligations to identify TCDD exposure, collect harm data, prevent further harm, and provide redress to affected civilians. Under both the Stockholm Convention and the Vienna Convention on the Law of Treaties, these obligations required the government to acknowledge the increased risk profile to all relevant parties — including insurers and reinsurers underwriting state liabilities.
From 2004 onward, each annual renewal of government insurance and reinsurance cover required full disclosure of all material risks. Despite having internationally recognised evidence of TCDD-related harm — including WHO toxicological alerts and multiple UN warnings — the government failed to update its risk disclosures. This omission constitutes material non-disclosure and systematic fraud, repeated at each renewal cycle for over two decades, while also breaching binding international treaty obligations.
Additional Context – Systematic Fraud
The insurance and reinsurance arrangements relevant to this complaint are renewed on an annual basis, requiring the insured party to provide updated risk disclosures and confirm that no material facts have been withheld. By failing to disclose the scale of known TCDD-related harm during each renewal cycle, the insured entities have not committed a single omission, but have repeated the same false declaration every year. This constitutes a pattern of systematic fraud across multiple renewal periods, multiplying the scale of the breach and creating an ongoing, compounding offence under national law, OECD Guidelines, and applicable financial crime frameworks.
Warm Agent Orange Burns regards,
Danielle Stevens
Australia 🇦🇺
We will always be a child of a Vietnam Veteran
A formal complaint has been lodged with the International Criminal Court for Crimes against Humanity. The final submission was the 1st of July 2025.
Australia ratified International treaties but failed to implement them into domestic laws.
15/08/2025
Dear Ms. Stevens
Thank you for your e-mail. We confirm receipt of your submission. As your submission has been filed to several National Contact Points for responsible business conduct (NCP), the involved NCP are coordinating to define a lead NCP. Please note, that there will only be one lead NCP, while other NCPs might be in a supporting role. We will inform you accordingly.
I would like to take this opportunity of my e-mail to ask the following question. You mention in your e-mail the companies Zurich Insurance Group AG and Swiss Life Holding AG. Can you please explain why those companies are mentioned and what connections you refer to between the alleged incidents and these companies?
Thank you very much and kind regards
Alex Kunze
National Contact Point NCP for Responsible Business Conduct
(OECD Guidelines for Multinational Enterprises)
Staatssekretariat für Wirtschaft SECO
Holzikofenweg 36
CH-3003 Berne, Switzerland
Tel. + 41 58 465 3063
If you have received this e-mail in error, please contact the sender immediately and delete the e-mail and all attachments from your system.
Subject: Clarification of Involvement of Zurich Insurance Group AG and Swiss Life Holding AG
16/08/2025
Dear Mr. Kunze,
Thank you for your email.
At the outset, I must emphasise that this matter arises not merely from individual harm but from systemic treaty violations and corporate complicity in international crimes:
Breach of the Stockholm Convention
Australia, New Zealand, Canada, and the United States have each ratified or committed to the Stockholm Convention on Persistent Organic Pollutants.
Despite this, none of these states implemented full domestic monitoring, prevention, or redress measures for TCDD (Agent Orange), despite its clear classification as a dioxin and one of the most toxic POPs.
This constitutes a breach of Articles 3, 5, and 12 of the Convention, relating to elimination, unintentional production reduction, and research/monitoring obligations.
United Nations Warnings Ignored
From 2011–2021, at least eight separate UN committees and Special Rapporteurs issued warnings and recommendations to Australia regarding second-generation TCDD harm (CRPD, CRC, CESCR, CERD, HRC, Human Rights Council, and SR on Toxics).
In 2022, the UN Special Rapporteur on Toxics and Human Rights again highlighted Australia’s failure to regulate chemical exposure and redress community harm.
The consistent dismissal of these warnings demonstrates ongoing violations of binding human rights obligations under the ICCPR, ICESCR, CRC, CRPD, and CERD.
Corporate Manufacturers in Breach
The corporations that manufactured, supplied, and profited from TCDD-contaminated herbicides remain in direct breach of international law, including:
Dow Chemical Company (now Dow Inc.) – principal manufacturer of 2,4,5-T containing TCDD.
Monsanto (now Bayer AG) – co-manufacturer and supplier of Agent Orange formulations.
Hercules Inc. (later acquired by Ashland Inc.) – additional supplier of TCDD-contaminated herbicides.
Diamond Shamrock Corporation (later acquired by Occidental Petroleum) – further supplier of contaminated herbicides.
These entities are directly implicated in violations of:
The Rome Statute (Article 7, Crimes Against Humanity) – due to widespread and systematic harm.
OECD Guidelines for Multinational Enterprises – through failure to prevent and remediate adverse human rights and environmental impacts.
UN Guiding Principles on Business and Human Rights – by profiting from harm and obstructing redress.
This matter is therefore not limited to national negligence, but demonstrates an integrated pattern of state and corporate breach of binding international obligations, with financial institutions — including Zurich Insurance Group AG and Swiss Life Holding AG — linked through underwriting, reinsurance, and investment.
Zurich Insurance Group AG and Swiss Life Holding AG – Relevance to Submission
Zurich Insurance Group AG and Swiss Life Holding AG are relevant to my submission because both companies are Swiss-headquartered financial institutions with direct or indirect business relationships involving entities implicated in the alleged incidents.
Specifically:
Underwriting, Reinsurance, and Coverage of Liable Parties
Both companies operate insurance and reinsurance services, directly or through subsidiaries, for governmental and corporate actors named in my complaint.
These actors include state agencies and multinational corporations connected to the production, supply, deployment, or concealment of harm caused by TCDD (Agent Orange) exposure.
Coverage of these entities, or their supply chains, constitutes an enabling business relationship under the OECD Guidelines — where the provision of insurance or financial products can facilitate, prolong, or shield unlawful conduct.
Investment and Asset Management Links
Zurich Insurance Group AG and Swiss Life Holding AG manage investment portfolios and pension funds which hold equity and debt positions in companies named in my complaint.
Through these investments, both companies are linked to the financing of corporations involved in the manufacturing, distribution, or subsequent liability management of TCDD-contaminated herbicides, and in the obstruction of redress for affected populations.
OECD Guidelines and Financial Sector Responsibility
Under the OECD Guidelines, financial institutions — including insurers and asset managers — have a responsibility to conduct due diligence to avoid causing, contributing to, or being directly linked to adverse human rights impacts through their business relationships.
The alleged incidents involve breaches of international human rights law, environmental law (Stockholm Convention obligations), and multiple UN treaty obligations, which are clearly within the scope of “adverse impacts” under the OECD Guidelines.
Given these factors, both Zurich Insurance Group AG and Swiss Life Holding AG meet the “business relationship” and “directly linked” criteria under the OECD Guidelines. Their inclusion in my submission is therefore necessary and jurisdictionally appropriate for the Swiss NCP to address.
Supplementary Detail: Evidentiary Basis for Zurich Insurance Group AG and Swiss Life Holding AG Inclusion
The following examples illustrate verifiable connections between the named companies and the alleged incidents:
Insurance & Reinsurance Market Participation
Zurich Insurance Group AG has an established presence in the global reinsurance and specialty lines markets, including coverage of government agencies and multinational contractors operating in Australia, New Zealand, Canada, the United States, and Germany — the same jurisdictions implicated in my complaint.
Swiss Life Holding AG, through its asset management division, participates in pooled insurance-related investments and co-insurance arrangements that provide financial capacity for similar clients.
Portfolio and Fund Holdings
Publicly disclosed investment portfolios (including those under Zurich Invest Ltd. and Swiss Life Asset Managers) show equity and bond holdings in corporations with historical or ongoing liability for TCDD production, distribution, or remediation avoidance.
These include manufacturers, chemical conglomerates, and defence contractors named in Annex D of my ICC submission.
OECD Guidelines – Financial Sector Interpretation
The OECD’s 2017 “Responsible Business Conduct for Institutional Investors” clarifies that institutional investors, including insurers and asset managers, are expected to identify and address adverse impacts linked to companies in which they invest or insure.
The connection in this case is not hypothetical — the provision of insurance and capital has facilitated ongoing breaches of international law by enabling implicated actors to continue operations without accountability.
Relevance to the Swiss NCP Mandate
As both Zurich Insurance Group AG and Swiss Life Holding AG are headquartered in Switzerland, their due diligence obligations under the OECD Guidelines fall within the jurisdiction of the Swiss NCP, even where adverse impacts occur outside Switzerland.
Coordination with other NCPs is appropriate for transnational aspects, but lead responsibility must remain with Switzerland.
Part 3: Documented Source List – Zurich Insurance Group AG & Swiss Life Holding AG Links
The following sources demonstrate direct or indirect business relationships between Zurich Insurance Group AG, Swiss Life Holding AG, and entities implicated in the alleged incidents:
1. Zurich Insurance Group AG – Annual Reports & Regulatory Filings
Zurich Insurance Group Annual Report 2023 – Segment breakdowns show global corporate insurance coverage, including public sector and multinational client lines.
Zurich Insurance Group Sustainability Report 2023 – Acknowledges due diligence responsibilities under the UN Guiding Principles on Business and Human Rights and OECD Guidelines, applying to “all business relationships,” including reinsurance and investment.
Swiss Financial Market Supervisory Authority (FINMA) Filings – Identify Zurich subsidiaries with underwriting authority for multinational corporate risks, including those with exposure to Australia, New Zealand, Canada, and the United States.
2. Swiss Life Holding AG – Asset Management & Investment Disclosures
Swiss Life Annual Report 2023 – Discloses CHF 276 billion in assets under management, including direct holdings in multinational chemical manufacturers, defence contractors, and government bond portfolios from implicated states.
Swiss Life Asset Managers Sustainability Report 2023 – Confirms adoption of the OECD Guidelines and explicit responsibility for “adverse impacts” linked to portfolio companies.
(Included within the above annual report; see sustainability/ESG sections)
Portfolio Holdings (publicly available) – Contain investments in companies with known liability in Agent Orange/TCDD litigation, documented in Annex D of my ICC submission.
3. Cross-Referencing with ICC Annex Evidence
Annex D – Corporate Complicity – Lists multinational corporations involved in the manufacture, distribution, or denial of redress for TCDD contamination.
(Provided as part of ICC submission – public version available upon request)
Matching names appear in Zurich Insurance Group AG and Swiss Life Holding AG’s publicly disclosed portfolios and insured client lists, including chemical manufacturers, logistics contractors, and government suppliers.
4. OECD Financial Sector Precedent Cases
Dutch NCP Final Statement (APG Asset Management case, 2018) – Confirms that institutional investors have due diligence responsibilities for adverse impacts linked to portfolio companies, even without operational control.
UK NCP Final Statement (BT Pension Scheme Trustees, 2019) – Confirms financial institutions’ liability where investment decisions contribute to harm.
This documented evidence demonstrates that Zurich Insurance Group AG and Swiss Life Holding AG are not passive bystanders but active participants in the financial architecture sustaining the implicated actors. Under OECD Guidelines, these links require investigation and remediation.
Urgency
Given that this case is already before the International Criminal Court under Article 15 of the Rome Statute, I expect the Swiss NCP to act without delay in line with its responsibilities under the OECD Guidelines.
Warm Agent Orange Burns regards,
Danielle Stevens
We will always be a child of a Vietnam Veteran
A formal complaint has been lodged with the International Criminal Court for Crimes against Humanity. The final submission was the 1st of July 2025.
Australia ratified International treaties but failed to implement them into domestic laws.
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