Norway’s Transparency Act

Overview

Enforced on July 1, 2022, Norway’s Transparency Act requires companies to conduct and publicly report due-diligence assessments related to human rights and working conditions throughout their supply chains.

Specific Due Diligence Obligations

The Supply Chain Transparency Act lists eleven specific due diligence obligations that a company must comply with:

  • Due Diligence: The duty to carry out due diligence to identify and assess actual and potential adverse impacts on human rights and decent working conditions in companies and their supply chains.
  • Report on Due Diligence: The duty to publish an annual account of the due diligence process by 30 June each year.
  • Right to information: the duty to respond to requests from the public on how a company addresses actual and potential adverse impacts on human rights and decent working conditions.
  • To come within the scope of the Act, the enterprises must offer goods and services.
  • Enterprises must also conduct human rights due diligence assessments.
  • Enterprises must publicly report on findings and measures resulting from the due diligence.
  • Companies must provide information about due diligence upon request.
  • Enterprises covered by the Act must account for their due diligence assessments.
  • The Act indicates that "everyone" is entitled to information from a subject enterprise regarding how it addresses actual and potential adverse impacts on fundamental human rights and decent working conditions.
  • If an enterprise is in violation of the Act, the Norwegian Consumer Authority can invoke orders and prohibitions (essentially mandating compliance or imposing injunctive relief).
  • The Act does not place particular obligations on an enterprises board, other than the requirement to sign the annual public statement.