The Norwegian Transparency Act
In the materiality analysis from 2022, human rights and workers’ rights were identified as important areas for Hafslund and the Group’s stakeholders. In our important topics, these are included in “responsible procurement practices” and “attractive and developing workplace”, for our suppliers and our employees respectively. We want to be an actor that contributes to responsible working conditions, both internally and in our supply chains. Several projects were initiated in autumn 2022 to improve the Group’s internal routines and processes.
A key project was to strengthen our due diligence work in line with the new Transparency Act, which entered into force on 1 July 2022. The purpose of the Act is to promote companies’ respect for fundamental human rights and decent working conditions in connection with the production and delivery of goods and services. This applies to our own business activities, suppliers and business partners. Hafslund’s ongoing improvement work shall ensure that the entire Group works with due diligence in accordance with the requirements of the Transparency Act, the United Nations Guiding Principles on Business and Human Rights and the OECD’s guide for due diligence. For 2022, and the first half of 2023, Hafslund has chosen to focus on an overall approach to the three business areas of Hafslund Eco Vannkraft, Hafslund Oslo Celsio and Hafslund Vekst.
As part of this improvement work, we have focused on:
- Updating the management system, and ensuring establishment in governing documents and with management.
- Adapting the division of roles and responsibilities and assessing internal expertise.
- Adapting reporting routines, including managing of requests for information.
- Assessing the potential and actual risk of violations of worker and human rights in own operations and supply chains.
Assessing the risk of violations of worker and human rights is an ongoing process at Hafslund. The risk landscape changes in line with changes in our business areas. It is our preliminary assessment that there may be risks in the following areas, which will be prioritised for further assessment and measures in 2023:
Hafslund Eco Vannkraft:
- Operations and maintenance contracts for hydropower plants in Norway, with a risk of labour market crime such as violations of pay and working conditions, etc. on the part of suppliers and their subcontractors who perform work for us.
Hafslund Oslo Celsio:
- Operations and maintenance contracts for facilities in Norway. This particularly applies to production stoppages at incineration plants, where there is a risk of labour market crime, violations of pay and working conditions on the part of suppliers and their subcontractors who perform work for us.
- Purchase of input factors for incineration plants (for example, biofuels, pellets, etc.) that have associated global value chains.
Hafslund Vekst:
- Safeguarding human rights in the production of solar and wind power plants, with complex global value chains linked to the production of solar panels, wind turbines, components in products and extraction of raw materials.
- Operations and maintenance contracts for facilities, with a risk of labour market crime, such as violations of pay and working conditions on the part of suppliers and their subcontractors.
As part of the risk assessments, we have started planning frameworks for risk classifications of third parties and prioritising follow-up of high-risk suppliers. The improvement work for strengthening our due diligence assessments, and our understanding of the risk landscape, will be presented in more detail in our due diligence report by 30 June 2023, here.