The Norwegian Transparency Act

The Norwegian Transparency Act came into effect on July 1, 2022, and applies to "larger" businesses in Norway. Do you have it in place?

The law covers public limited liability companies, listed companies, and other entities that meet two of the following three criteria on the balance sheet date:

• Sales revenue of NOK 70,000,000
• Balance sheet total of NOK 35,000,000
• Average number of employees equivalent to 50 full-time positions

All businesses directly covered by the Transparency Act are required to publish a statement outlining the due diligence assessment conducted. The deadline for this  statement was June 30, 2023. 

According to the Transparency Act, the covered businesses are obligated to conduct a due diligence assessment of their operations and supply chain, following the OECD Guidelines for Multinational Enterprises. The focus of the assessment is the business's respect for fundamental human rights and decent working conditions, as well as those of their suppliers.

The due diligence assessment consists of six steps, although this overview simplifies the process:

1.  Accountability under the Transparency Act should be embedded in the company's policies and management systems.
2.  Actual and potential negative impacts on fundamental human rights and decent working conditions must be identified. This applies to the company's own operations as well as those of its business partners.
3.  Measures to stop, prevent, and mitigate the negative impacts identified in step 2 must be implemented.
4.  These measures should then be continuously monitored and followed up.
5.  The measures and assessments should be disclosed to stakeholders.
6.  If actual negative impacts are discovered, they should be remediated or replaced

Also read: The Norwegian Transparency Act

If you don't have the statement under the Transparency Act in place the consequences of failing to report in compliance with the law can be significant.

Also read: Compulsory fines and violation fees for companies that do not comply with the Norwegian Transparency Act

If you would like more information on how to work with the Transparency Act leading up to the deadline, feel free to contact us for a conversation.

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