| A | B | C | D | E | F | G | H | I | J | K | L | M | N | O | P | Q | R | S | T | U | V | W | X | Y | Z | |
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1 | Company | Revenue | Source | Links | Time Period Covered | Length of Report | General Risks Indentied? | Specifc Risks Indentied? | Actions Taken or Planned to Prevent or Mitigate Specifc Risks? | Actual Adverse Impacts? | Actions taken to Cease, Prevent or Mitigate Actual Adverse Impacts? | Complaint Systems | Human Rights Complaints Reported | Consultant/Platform | ||||||||||||
2 | Equinor | $104.81 | 2023 Human Rights Statement | https://cdn.equinor.com/files/h61q9gi9/global/abad63a4e316dc251eef1d1eeedbd6407a2c640f.pdf?human-rights-statement-2023-equinor.pdf | 2023 | 11,678 words (47 pages) | Yes | The most severe findings relate to indicators of forced labour referenced by the 11 ILO Forced Labour Indicators. Although all such findings are concerning, our attention is directed firstly towards payment of recruitment fees, retention of identity papers and lack of freedom of movement, as the prevalence of these indicators knowingly increase the risk of forced labour. 61 persons have been identified to be subject to one or more forced labour indicators in contracts in execution in 2022 . South East Asia forced labor remedy project, Tanzania LNG site (with Shell), Angola, Argentina (HRDD showed no problems), Brazil Mendulbim solar project with Scatec (risks), Libya (JV in conflict zone), Responsible exit from Russia | In 2022, payment has been made to 1,791 previously identified workers, to the value of over USD 2 million, where Equinor contributed with approximately half the amount | Yes | Multiple references | The primary, global channel is our Ethics Helpline available for anyone involved in or affected by our activities to raise a concern, both employees and externals.To address human rights concerns in our own operations, we typically establish community-based grievance mechanisms (CGM). Where we are not the operator, we expect an equivalent grievance system to be in place by our business partner. Handling grievances in our supply chains As set out in our Human Rights Expectations of Suppliers, we expect our suppliers to provide appropriate mechanisms for raising complaints, and where necessary, provide remedy. This expectation is supported by specific compliance requirements related to remedy and grievance mechanisms within our templates for standard supplier contracts. In practice, and often because of site visits, we have seen there is a need to raise awareness of both individuals’ rights, as well as the mechanisms available to them. In certain cases, we might establish a site-level grievance channel managed by a specialist third party. Workers will in such cases typically be informed of how to use the channel and its purpose by the operators themselves, and are free to contact the operators via e.g., text or through phone calls in workers’ native language. | None | We engage with human rights specialist organisations such as Shift, Impactt, Triple R Alliance and Synergy Global Consulting | ||||||||||||
3 | Aker [Aker BP, Aker ASA , Aker Solutions] | bp 12.89 + ASA 5.41+Solutions 3.06=21.36 | Transparency Act Report | https://akerasa.ams3.cdn.digitaloceanspaces.com/images/Aker-ASA-Transparency-Act-Report-2022.pdf | 2022 | 4042 words (16 pages) | Yes | Oil and gas exploration and development in Ghana is subject to inherent risk of Adverse Impacts due to the country risk profile in general and weaker human rights protection. Industrial software has higher inherent risk of Adverse Impact in Saudi Arabia due to the country’s weaker protection of human rights and decent working conditions. | None | No | None | None | In 2022 Norway NCP received a complaint re Lundin Energy re Sudan in 1999-2003. | RepRisk | ||||||||||||
4 | Hydro | $18.34 | 2023 Annual Report, pages 118-126, 157 | https://www.hydro.com/en/global/investors/reports-and-presentations/annual-reports/annual-report-2023/ | 2023 | 5643 words (23 pages) | Yes | Yes, multiple, see pages 125 and 126 | The deployment of fatality prevention procedures and associated life-saving rules and behaviors continued in 2023, which contributed to a continued reduction in the number and rates of high-risk incidents with the potential to be fatal or life changing. Key initiatives include a self-assessment process for critical programs, monthly deep-dive incident data analyses to support continuous improvement through root cause and use identification, and defining actions to prevent incidents from recurring. Quarterly health, safety, security and environment network meetings are used to connect specialists from all business areas to discuss findings and actions taken from high-risk incidents, and to share best practice and innovative solutions. Hydro also increased its emphasis on installing engineering controls to prevent High Risk Incidents from occurring. | No | None | Hydro uses an internal grievance mechanism, AlertLine. | Claims of harassment and discrimination 106, confirmed cases 37 | Ecovadis, Moody's Grid integrity risk tool | ||||||||||||
5 | Yara International | 13.94 | Yara Integrated Report 2023, see sections referred to on p. 207 | https://www.yara.com/siteassets/investors/057-reports-and-presentations/annual-reports/2023/yara-integrated-report-2023.pdf | 2023 | 7999 words (32 pages) | Yes | None | None | No | None | Accessibility to grievance channels in local languages has been improved. We continue our work to raise the general awareness of grievance processes and will initiate an evaluation of our grievance channels against the effectiveness criteria under the UN Guiding Principles on Business and Human Rights in 2024 | None | EcoVadis | ||||||||||||
6 | Storebrand | 9.26 | 2023-Redegjørelse-etter-åpenhetsloven-Storebrand-Asset-Management-AS en | https://www.storebrand.no/en/sustainability/sustainability-library/_/attachment/inline/c64c2e5f-622a-4170-97dc-fcc3645deb30:1d0ebdc279acc5b547bab45b6d13354ae7cefc78/2023-Redegj%C3%B8relse-etter-%C3%A5penhetsloven-Storebrand-Asset-Management-AS.pdf | 2023 | 2620 words (10 pages) | Yes | None | This work has also made it possible to avoid investing in companies with a significant risk of human rights violations. This work has resulted, among other things, in the exclusion of 13 companies based on our criteria for human rights and international humanitarian law, and reduced the risk human rights violations in our investments. In addition, we excluded 11 companies linked to high-risk countries prior to the time of investment. | No | None | A shared compliance framework for the Transparency Act has been established across the Storebrand Group, and Storebrand Asset Management AS follows the established guidelines and procedures. The group has systems for complaints and whistleblowing, which allow employees to report internally or through an external third-party channel. Complaints can also be submitted through Storebrand’s website or by contacting the customer service center. | None | |||||||||||||
7 | DNB | 7.88 | DNB and human rights (web page) | https://www.dnb.no/en/about-us/csr/human-rights.html | 2023 | 1795 words (7 pages) | None | None | No | None | None | None | Ecovadis | |||||||||||||
8 | Telenor | 7.63 | Annual Report 2022, pages 12 and Sustainability Report p. 49 | https://www.telenor.com/investors/reports-and-information/annual/annual-report-2022/ | 2022 | 3633 words (15 pages) | Yes | None | None | No | None | Grievances are to be reported through Telenor’s whistleblowing Integrity Hotline. The Integrity Hotline is a confidential whistleblowing channel intended for related questions and reported concerns about possible breaches of Telenor’s Code of Conduct, including relevant laws, regulations and Governing Documents. The service is accessible to both employees and external stakeholders on the internet and is thus available 24 hours a day, seven days a week. It can accommodate reports in the local languages of all Telenor’s markets. Any query or report made will be treated confidentially and respectfully. Telenor encourages employees, business partners and other stakeholders to speak up through the Integrity Hotline. | 660 Concerns reported in 2022 3 Reported concerns classified as human rights incidents | BSR did gap analysis on law. Human Rights Due Diligence e-learning developed by Amnesty International with Telenor support.Telenor’s Human Rights Due Diligence Toolkit, initially developed by BSR in 2017, was updated. | ||||||||||||
9 | Orkla | 6.61 | Annual Report 2022, page 113 | https://www.orkla.com/wp-content/uploads/sites/3/2023/06/230614_Orkla_Annual-Report_FINAL.pdf https://www.orkla.com/the-norwegian-transparency-act/#:~:text=Orkla's%20work%20related%20to%20human,partners%20and%20in%20supply%20chains | 2022 | 431 words (2 pages) | Yes | The sourcing of raw materials such as cocoa, palm oil, and hazelnuts unfortunately carries a risk of child labour in their respective supply chain. The Child Labour Monitoring and Remediation System (CLMRS) is used in segments of our supply chain where child labour has been identified as an inherent risk. we have the target of sourcing 100% Rainforest Alliance-certified cocoa by 2025. The cocoa sector in West Africa, particularly the Ivory Coast, faces serious challenges in the form of poverty, low productivity, human rights violations, and environmental degradation. Palm oil also has human rights risks, They are RSPO members. Cashews lack tracability and haver Human Rights risks, they are grown in West Africa and processed in Vietnam. Hazel nuts have risks in child labor and working conditions. Wild berry picker working conditions risks in Scandinavia related to workers from Thailand. | None | No | None | None | None | Sedex, SAI Platform | ||||||||||||
10 | Var Energy | 7.38 | Annual Report 2023 page 171 | https://varenergi.no/wp-content/uploads/2024/03/Var-Energi-Annual-Report-2023.pdf | 2023 | 6,773 words (27 pages) | Yes | None | None | No | None | The fundamental element in the Human Rights Due Diligence Program is the risk and impact assessment. This approach enables Vår Energi’s senior leaders to take holistic business decisions, and to incorporate effective mitigating measures and risk re-assessments. In this way, human rights risk can be regularly reported to management and the Board of Directors as part of the internal risk reporting process. The output of the exercise can also be used to document the already existing preventing or detecting controls at Vår Energi. (page 84) | ||||||||||||||
11 | Sparebank | (Sparebanken Vest) .67 (Sparebank .57) (Sparebanken Sor .35) (Sparebanken More .22) = 1.81 | Human Rights and Decent Work: Our Responsibility | https://www.sparebank1.no/content/dam/SB1/bank/sr-bank/om-oss/Samfunn/SpareBank1SR-Bank_TransparencyAct2023.pdf | 2023 | 8689 words (35 pages) | Yes | None | None | No | None | In 2023, a new and improved whistleblowing procedure was established, along with a special review group made up of representatives from HR, Risk Management and Group Legal. This will ensure that employees have access to a mechanism for reporting matters of concern which is even more secure and easily accessible. The incidents database has also been further improved, helping to strengthen employee protection and whistleblowing channels. The database is constantly monitored, with an in-depth review every 14 days in an interdisciplinary forum (the HSE forum). | Among the incidents raised, three cases were reported in the “psychosocial working environment” category and six in the “physical working environment” sub-category, along with four near-misses and hazardous situations, three accidents and personal injuries, and five other HSE-related incidents | |||||||||||||
12 | Mowi | 6.02 | Transparency Act Statement | https://mowi.com/wp-content/uploads/2024/06/Transparency-Act-Statement-2023.pdf | 2023 | 4805 words (19 pages) | Yes | None | None | No | None | Our whistleblower channel facilitates the reporting of concerns about potential compliance issues related to laws, regulations and our Code of Conduct. Concerns received are reported to the Board of Directors Audit committee on a quarterly basis. Reports of concerns can be made verbally or written. They can be addressed to a Manager, Grandfather, Union Representative, to Group Management, Human Resources or directly to Mowi’s independent whistleblower channel. The whistleblower channel is managed by an independent third party. Notifications may be done anonymously and are handled confidentially | 46 cases in 2023 where all notices were investigated and handled, they found none had actual negative consequence on human rights or decent working conditions. Employee Engagement Survey showed 86% s aid their work environment was safe | |||||||||||||
13 | Wallenisu Wilhelmsen | 5.24 | Account of due diligence pursuant to Section 5 of the Transparency Act (Appendix 5 of Annual Report) | www.wilhelmsen.com/globalassets/investor-relations/annual-report/wilhelmsen-group---transparency-act---disclosure-statement-2023.pdf | 2023 | 3132 words (13 pages) | Yes | None | None | No | None | Wilhelmsen has a whistle-blowing channel that may be used by employees and external parties, including clients, suppliers, business partners and other representatives of Wilhelmsen, to raise concerns for non-compliance including situations where Wilhelmsen has contributed to direct or indirect, actual or potential adverse effects on human rights and decent working conditions. The channel is accessible on our website, written in plain English, and guarantees confidentiality and offers proper protection for stakeholders. For employees and other individuals within Wilhelmsen, the company intranet also provides direct access to the portal. | 16 complaints related to human rights, including discrimination, working conditions, bullying, harrassment, and sexual harrassment. In six of the cases allegations were confirmed with appropriate mitigating actions taken. | |||||||||||||
14 | Austevoll Seafood | 3.32 | Statement For 2023 Regarding the Work of the AUSTEVOLL SEAFOOD ASA GROUP to Promote Fundamental Human Rights and Decent Working Conditions under the Transparency Law | https://www.auss.no/media/1591/redegjoerelse-for-2023-vedroerende-konsernet-auss-sitt-arbeid-for-aa-fremme-grunnleggende-menneskerettigheter-og-anstendige-arbeids.pdf | 2023 | 3591 words (14 pages) | Yes | None | None | No | None | AUSS has an external whistleblowing service at group level, and several companies in the AUSS group have implemented the same scheme. The whistleblowing service allows for both internal and external reporting, as well as anonymous reporting. Austral has a reporting service where reports can also be submitted by external parties. The ethics hotline is open to employees, suppliers, customers, and local communities. The ethics hotline is also available to external parties. | None | |||||||||||||
15 | Gjensidige Forsikring | 4.07 | Our Compliance wiht the Transparency Act (webpage) 2023 Annual Report page 350-353 | https://www.gjensidige.com/files/content-innhold/konsern-filer/annual-reports/Annual%20report%202023%20Gjensidige.pdf | 2023 | 2451 words (10 pages) | Yes | None | None | No | None | If anyone suspects human and labour rights violations, they can report it through our external notification channel: Gjensidige (mittvarsel.no) | None | EcoVadis | ||||||||||||
16 | Kongsberg Gruppen | 4.45 | Human Rights Report 2023 | https://www.kongsberg.com/globalassets/kongsberg-asa/5.-investor-relations/1.3.-reports-and-presentations/1.3.4.-other-reports-and-presentations/2023/kog_humanrights_23_290524.pdf | 2023 | 7845 words (31 pages) | Yes | None | None | No | None | If you identify a concern regarding KONGSBERGs business, you can raise it though our whistleblowing hotline. | None | IntegrityNext | ||||||||||||
17 | Veidekke | 3.99 | Partially addressed in Annual Report 2023 p. 131 workers rights and in the document on its website call Veidekke's Work on human rights | https://mb.cision.com/Main/17348/4036732/2997986.pdf https://www.veidekke.com/siteassets/om-veidekke/styrende-dokumenter/engelsk/no-po-01-03.01-veidekkes-arbeid-med-menneskerettigheter_en-002.pdf | 2023 | 2872 words (11 pages) | No | None | None | No | None | Veidekke has established a whistleblowing mechanism for employees and others to report censurable conditions of any kind. See pages 138 and 141. | None | Veidekke uses services provided by Dow Jones to screen suppliers for negative media coverage concerning breaches of workers’ rights. Veidekke has used Ignite Procurement in its work on the Norwegian Transparency Act. | ||||||||||||
18 | AF Gruppen | 2.85 | 2023 Annual Report | https://www.afgruppen.com/4a1e6b/siteassets/investor-en-dokumenter/annual-reports/af_annual_report_2023.pdf | 2023 | 789 words (3 pages) | Yes | None | None | No | None | "Reports can be submitted to the line manager, to a more senior manager, via email to the whistleblowing committee (varsling@afgruppen.no) or using the reporting form available at www.afgruppen.com/ notification. The whistleblowing committee conducts a preliminary investigation of all written and documented reports that are received and investigates the facts if necessary. If a case permits it, the whistleblower will be informed of how AF is handling the matter and its outcome." They use HMSREG to simplify inspections. | None | StartBank | ||||||||||||
19 | Atea ASA | 3.11 | Rєdєgjørєlsє Åpєnhєtslovєn 2024 | https://www.atea.no/media/1mjd04ts/redegjørelse-a-penhetsloven-2024.pdf?v=638795718378241394 | 2024 | 6159 words | Yes | None | None | No | None | An agreement has been entered into with an external law firm that handles the whistleblowing channel so that it provides complete anonymity for the whistleblower. This law firm has no other business connection to Atea and will follow up whistleblowing reports discreetly andconfidentially with the relevant person in Atea's organization. Atea will not tolerate sanctions against whistleblowers who in good faith report concerns regarding behavior in Atea. | In 2023, a total of 16 concerns were reported, where all but one were submitted anonymously. Among these were concerns related to the same circumstances, a total of 13 different concerns. Five of these reported concerns were classified as actual whistleblowing, while the remaining were categorized as HR cases. Throughout the year, all cases received were investigated and handled appropriately within the Atea Group and no cases were open at the end of the year. | Using third-party solutions such as EcoVadis Sustainability intelligence Suite and RBA-Online SAQs, manual analysis of publicly available sustainability information and insights from our supplier dialogues, Atea can assess suppliers based on both qualitative and quantitative data. | ||||||||||||
20 | Elkem | 2.96 | Annual Report 2023, pages 154 - 157 | https://www.elkem.com/globalassets/corporate/documents/annual-report/Elkem-Annual-Report-2023.pdf | 2023 | 2016 words | Yes | None | None | No | None | Elkem's grievance mechanism, accessible on the company’s website, is designed for stakeholders providing feedback or expressing concerns about our global operations. Elkem also has a secure speak-up channel for both internal and external parties, detailed in the chapter on responsible business practices. | 1 Case reported through grievance mechanism (in 2023, 6 in 2022 and 2 in 2021). | |||||||||||||
21 | Leroy Seafood Group | 2.93 | Transparency Act Report 2023 | https://www.leroyseafood.com/globalassets/02--documents/english/the-transparency-act-report/transparency_act_report_2023/ | 2023 | 4972 words | Yes | None | None | No | None | Whistleblowing channel for employees and third parties | None | |||||||||||||
22 | Norwegian Air Shuttle | 3.07 | Transparency Act Due Diligence Report 2023 | https://www.norwegian.com/globalassets/ip/documents/about-us/company/investor-relations/reports-and-presentations/sustainability-reports/the-transparency-act---due-diligence-report-2023.pdf | 2023 | 5173 words | Yes | None | None | No | None | The Grievance reporting system is used when an employee has personally been treated poorly. This poor treatment could involve a breach of individual employment rights, or bullying or harassment, and the complainant is seeking redress or justice for themselves. The person making the complaint therefore has a vested interest in the outcome of the complaint and for this reason is expected to provide evidence to prove their case. Whistleblowing is used when raising a concern about danger or illegality that affects others, for example customers, members of the public, the environment or Norwegian. The person blowing the whistle is usually not directly or personally affected by the danger or illegality. Safety Net is the reporting system used for actual or potential health and safety issues in the context of aviation safety, as well as other HSE hazards or concerns that can impact Norwegian’s operations | None | EcoVadis IQ Plus and EcoVadis Ratings | ||||||||||||
23 | SalMar ASA | 2.51 | Report in Accordance with the Transparency Act Section 5 for 2023 (translated) | https://www.salmar.no/wp-content/uploads/2024/06/Redegjorelse-iht-Apenhetsloven-2023.pdf | 2023 | 2669 works | Yes | None | None | No | None | None | None | Ignite Procurement | ||||||||||||
24 | Archer Unlimited | 1.25 | Transparency Act Report 2023 | https://archerwell.com/wp-content/uploads/2024/03/Transparency-Act-Report-A4.pdf | 2023 | 1853 words | No | None | None | No | None | Whistleblower Hotline: Available to all persons via Archer’s website or internally, to advise of any instances where conduct is in breach of the Code of Conduct or any applicable laws, including those relating to Human Rights. | None | We developed an internal IT system named “Cascade” to structure input digitally from suppliers through Archer Questionnaires for QSHE, ESG, Norsok S-006 and Human Rights. The Cascade system has also been designed to evaluate the supplier self-assessment response to the Questionnaires specifically to assess supplier risk related to Human Rights and structure Archer follow up where more information is required and if adverse findings are identified. | ||||||||||||
25 | BEWI ASA | 1.12 | 2022 Statement on management of human rights and decent working conditions | https://bewi.com/wp-content/uploads/2023/06/2022-BEWI-ASA-Transparency-act-statement.pdf | 2022 | 3860 words | Yes | None | None | No | None | None | None | |||||||||||||
26 | Bonheur ASA | 1.35 | Bonheur ASA Transparency Act Statement | https://bonheur.no/media/qj3heamf/bonheur-asa-transparency-act-statement.pdf | 2023 | 1180 words | Yes | None | None | No | None | None | None | |||||||||||||
27 | DOF Group | 1.01 | DOF Transparancy Act Statement | https://cdn.prod.website-files.com/629f1b36bee3b058907852a0/668f8e568775f591edf27592_DOF%20Transparency%20Act%20Statement%202024%20DOFG%20V1.00%20-%20SIGNED.pdf | 2023 | 2614 words | Yes | None | None | No | None | DOFs third-party managed ‘Ethics Helpline’ gives all stakeholders a 24/7-hour accessible tool to report serious concerns. The report can also be submitted anonymously. The helpline can be found and used from our webpage.DOF has numerous channels for workers to raise their concerns. These include escalating concerns directly to a vessel’s onshore contact, through a vessel’s chain of command, or through our confidential Ethics Helpline. | None | |||||||||||||
28 | Elopak ASA | 1.26 | Human and Labor Rights Transparency Statement 2023 | https://www.elopak.com/app/uploads/2024/06/Human-and-labor-rights-transparency-statement-2023.pdf | 2023 | 3843 words | Yes | Multiple, page 7 | Yes, multiple, page 7 | No | None | Concerns of misconduct or grievances are reported through defined internal channels or through our whistleblower helpline. The whistleblower helpline can be publicly accessed through our webpage and is available for our suppliers and other external stakeholders. The helpline is hosted by an independent external service provider and is confidential, anonymous, and available in multiple languages. | None | |||||||||||||
29 | Hoegh Autoliners | 1.4 | Transparency Act Report 2023 | https://s202.q4cdn.com/916237373/files/doc_financials/2023/ar/Höegh-Autoliners-Transparency-Act-Report-2023.pdf | 2023 | 2550 words | Yes | Yes | None | No | None | The Group has a reporting system which the vessels use to report deviancies regarding breaches in its ethical standards, including human rights and labour rights. All staff on shore and onboard have access to the system and are trained and encouraged to use the system.Höegh Autoliners also has a third-party whistleblowing hotline for anonymous reporting of concerns accessible for anyone on the Company’s website. | None | |||||||||||||
30 | Schibsted | 1.23 | Due Diligence Report 2023 on Fundamental Human Rights and Decent Working Conditions | https://cdn.schibsted.com/wp-content/uploads/2024/04/10151626/Transparency-Act-Report-2023.pdf | 2023 | 2664 words | No | None | None | Yes | In 2023, Schibsted Distribusjon Vest AS was part of a major inspection by A-krim (inter-agency cooperation to combat workrelated crime) in Bergen. The result of the inspection showed that the existing routines and internal control were not fully adhered to and as a result of this, contractors were subject to indecent working conditions. The incident has led to an increased focus on the routines and internal control. To ensure clear employment contracts and ensure decent working conditions a process to hire previously self-e mploy ed worker s dire Distribusjon Vest is now initiated. | None | None | |||||||||||||
31 | TGS | 1.01 | 2023 Sustainability Report (Transparancy Act Reporting in III.B. and IV.E. | https://www.tgs.com/hubfs/Sustainability%20Web%20Page%20Content/Sustainability%20Report/2023%20TGS%20Sustainability%20Report_final.pdf | 2023 | 1143 words | No | None | None | No | None | Employees are empowered to let the offender know their inappropriate behavior is not tolerated and are to report the violation to the Compliance Department, HR Department, TGS Compliance hotline (anonymously if preferred) or their manager. TGS provides multiple avenues for internal and external stakeholders to report potential discrimination and harassment concerns or seek advice, including the TGS publicly available compliance hotline, which allows for anonymous reporting. In accordance with the TGS Whistleblower Policy and Code of Conduct, | None | |||||||||||||
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