The Norwegian Transparency Act entered into force on 1 July 2022, obliging large and mid-size companies to conduct fundamental human rights and decent working conditions due diligence throughout their supply chain and with their business partners. 

The Transparency Act covers services and products in a broad sense. Under this Act, consumers, organisations, trade unions, journalists, and the general public will be entitled to request information from companies, and the Norwegian consumer authority may issue injunctions and fines for non-compliance. 

Though it is a Norwegian initiative, we see similar initiatives such as Germany’s Supply Chain Due Diligence Act or the UK’s Modern Slavery Act in other European countries.

Who does the Act apply?

The Act applies to companies registered in Norway, and foreign companies that must pay taxes in Norway. These must meet at least two of the three criteria below:

  • At least 50 full-time employees (or equivalent annual man-hours)
  • An annual turnover of at least NOK 70 million (£5.9 million)
  • A balance sheet sum of at least NOK 35 million (£2.95 million)

Integrating environmental aspects and granting access to justice for victims of corporate abuse are two crucial outstanding tasks for the Norwegian legislation. The European Commission is expected to address them under its Sustainable Corporate Governance initiative, as demanded by an overwhelming majority of respondents to the relevant public consultation.

The Norwegian Consumer Agency is the supervisory body for the Transparency Act, while the Market Council will act as the appeal body for appeals against the Norwegian Consumer Agency’s decisions. These bodies will be able to review the companies’ reports to confirm they fulfill the reporting obligation.

Complying with the Act

Managers of enterprises should become familiar with the Transparency Act and its requirements so they can ensure that sufficient resources are allocated for compliance with the Act. They need to establish systems internally that enable them to answer requests within the three-week deadline.

Existing policies and risk assessment forms that form the basis for the due diligence assessment also need to be updated. These policies must cover the requirements of fundamental human rights and decent working conditions. The risk assessment should the enterprise itself, its supply chain, and business partners. Enterprises can turn any potential business risks into a competitive advantage by allocating sufficient resources to the Transparency Act.


We can help with Due Diligence

The CRI Group has developed a highly specialised assessment solution for Corporate Due Diligence and Third-Party Risk Management to assist organisations in accurately identifying, preventing, mitigating and addressing actual and potential adverse impacts of affiliating with global partners and complies with all EU mandates.

From enhanced due diligence to identify non-compliance of the regulatory framework and damaging environmental allegations to investigating company (or stakeholder) human rights violations related to labour laws, child labour or human trafficking, CRI Group experts help determine the legal compliance, financial viability, and integrity levels of outside partners and suppliers affiliated with your company’s value chain.

The Benefits of Compliance

Recent studies have demonstrated a positive correlation between the extent to which companies implement environmental, social and good governance policies, and their overall economic performance, all while contributing to a more stable global marketplace. Such responsible business conduct will:

  • Enhance protection for workers
  • Improve access to justice for victims
  • Safeguard the environment
  • Ensure fair products for consumers

Further, apart from general compliance with EU mandates, such organisations will benefit from:

  • Reduced overall liability risks
  • Improved stakeholder protection
  • Lower costs resulting from conflicts
  • Improved company transparency
  • More profound knowledge of the value chain
  • Enhanced reputation in the market &
  • Improved social standards for workers

CRI Group’s corporate due diligence and accountability solutions can help your organisation comply with a growing list of global regulations and mandates related to human rights and the environment while acting as an integral part of your business decision-making and risk management systems. 

Contact the CRI Group to learn more about our Corporate Due Diligence and Accountability solutions and stay one step ahead of the pending EU mandates. We look forward to assisting you.



About CRI Group™

Based in London, CRI Group™ works with companies across the Americas, Europe, Africa, Middle East and Asia-Pacific as a one-stop international Risk ManagementEmployee Background ScreeningBusiness IntelligenceDue DiligenceCompliance Solutions and other professional Investigative Research solutions provider.

We have the largest proprietary network of background screening analysts and investigators across the Middle East and Asia. Our global presence ensures that no matter how international your operations are, we have the network needed to provide you with all you need, wherever you happen to be. CRI Group™ also holds BS 102000:2013 and BS 7858:2012 Certifications, is an HRO certified provider and partner with Oracle.

In 2016, CRI Group™ launched the Anti-Bribery Anti-Corruption (ABAC™) Center of Excellence – an independent certification body established for ISO 37001:2016 Anti-Bribery Management SystemsISO 37301 Compliance Management Systems and ISO 31000:2018 Risk Management, providing training and certification.

ABAC® operates through its global network of certified ethics and compliance professionals, qualified auditors and other certified professionals. Contact ABAC™ for more on ISO Certification and training.