The Norwegian Transparency Act 2022

As of 1 July 2022, the Transparency Act entered into force in Norway. The purpose is to promote companies’ respect for basic human rights and decent working conditions with business partners and in supply chains. An essential part of the law is to ensure the public’s access to information regarding these conditions and how businesses handle them. Together with other measures, the legal requirement will contribute to Norway’s work to meet and comply with the UN’s sustainable development goal no. 8 on decent work and economic growth (SDG8), as well as SDG12 on responsible consumption and production. The core of the law involves a duty to carry out and account for due diligence assessments. Due diligence assessments mean that businesses must map possible negative consequences for human rights and decent working conditions related to production and supply chains, implement improvement measures, follow up and report.

Due diligence assessments – what does Orkla do?

Orkla has a policy for human and labour rights which addresses respect for human rights in own organization and in the supply chain. The policy is based on the UN Guiding Principles for Business and Human rights and describes the main principles for how the Orkla companies shall handle the human and workers’ rights that are most relevant to day-to-day operations. In the policy, we describe how we want to carry out due diligence assessments and work with improvement measures both in our own businesses and in the supply chain. Furthermore, we describe what we expect from the Orkla companies when it comes to implementing the policy in a good way.

Orkla’s expectations for the companies’ work with due diligence assessments are also described in the document “Sustainability and Responsible Business Practices“, see especially pages 6, 7, 14 and 16.

Orkla has more than 25,000 direct suppliers and many sub-suppliers. We require all our direct suppliers to sign Orkla’s Supplier Code of Conduct. The Supplier Code of Conduct describes our supplier requirements related to human rights and other topics within sustainability. This means that the supplier agrees to carry out its production in accordance with internationally recognized standards relating to human rights, working conditions, the environment and anti-corruption.

The Orkla companies make a thorough assessment of all new suppliers when entering into a contract. In addition to this, the companies have a risk-based approach to the work with human rights in the supply chain, focusing their efforts on the supply chains where we consider the risk of human rights violations to be the highest.

Human rights due diligence report for 2022

Orkla’s annual and sustainability report for 2022 includes an account of our approach to due diligence, important human rights risks, measures implemented during the year and the plans for the coming period.

The following information is particularly relevant in relation to the requirements of the Transparency Act $5:

• Information on organization and operating area: p 9, p 11-19
• Information on segments: 197-203
• Sustainability strategy and governance: pp. 42, 87-88, 92-93, 96-97
• Human rights policy, routines, reporting channels: pp 92-93, 111-113
• Negative consequences and risks, measures: pp. 111-123, 158-159

The report covers all companies in which Orkla had more than 50% ownership as of 31 December 2022, with the exception of companies aquired after 1 July 2022. The information in the report on human rights policy, impact and risks, as well as procdures for due diligence assessments, supplier follow-up and complaints, applies to all Orkla’s companies. Risk conditions and measures related to Orkla’s Norwegian companies are discussed on the following pages:

Orkla Foods Norway: pp. 111-115, 116-117, 119-120

Orkla Confectionery & Snacks Norway: pp 111-117,

Orkla Home and Personal Care: pp. 111-115

Orkla Health: 111-115, 119-120

Orkla House Care: pp. 111-115

Lilleborg: pp. 111-115

Pierre Robert Group: pp. 111-115, 120-121

Idun Group: pp. 111-115

Orkla ASA and several of Orkla’s Norwegian companies are members of Ethical Trade Norway, and prepare an annual progress report based on Ethical Trade Norway’s requirements. The reports are available on Ethical Trade Norway’s website https://etiskhandel.no/vare-medlemmer/

The following Orkla companies are members of Ethical Trade Norway: Lilleborg, Orkla Confectionery & Snacks Norway, Orkla Foods Norway, Orkla Home and Personal Care, Orkla House Care, Pierre Robert Group.

Read more

Orkla’s annual and sustainability report

Orkla’s expectations for its own companies

Orkla’s human rights policy

Orkla Supplier Code of Conduct