A very long time ago, when I started out in the law, Swiss law had a unitary concept of public policy, and it was called – public policy. By now, all kinds of further words are added to the expression, and then it means different things each time.

 

Let me start with the judicial review of arbitral awards rendered by international arbitral tribunals having their seat in Switzerland. This is covered by article 190 subsection 2 of Switzerland's Federal Private International Law Statute which reads as follows:

 

2. Der Entscheid kann nur angefochten werden:

 

2 Elle ne peut être attaquée que:

 

2 Il lodo può essere impugnato soltanto se:

 

2 The award may only be set aside: