Transparency Law

Reporting
- Companies must document steps taken to prevent and limit risks of human rights violations in their supply chains and report on cases of severe risk or harmful incidents
- Report on potential negative consequences of their operations
- Reports are submitted to authorities and be available in the company’s website
- There is no duty to inform on production sites
Due Diligence
- Baseline for obligations stems from the UNGPs and OECD Guidelines for Multinational Enterprises
- Assessment for the entire supply chain and with business partners
- Provide or cooperate to ensure remedies

Human Rights
- Including decent work and the right to information for stakeholders/consumers
Environment
- Will be revised by the Parliament in the upcoming evaluation
Other Social Matters
Broad ranging

Own Operations
Subsidiaries
Direct Suppliers
- Including business partners, defined as any party that supplies goods or services directly to the enterprise (even if not part of the supply chain)
Indirect Suppliers
- The law covers the entire supply chain, defined as any party in the chain of suppliers and sub-contractors
Full Value Chain
- Covers all suppliers and subcontractors in the entire global supply chain, including business partners supplying goods or services directly to the company
- Uncertain if it includes both upstream and downstream obligations

Large Companies
- Companies domiciled in Norway and foreign companies providing services or selling products in Norway
- Covers around 8800 companies
SMEs
- Only applies only to medium sized companies
- The Norwegian Accounting Act defines company size: companies must meet two of three criteria to be covered by the law:
  at least 50 man-years
  turnover of at least 70 million NOK
  balance of at least 35 million NOK
All sectors

Monitoring
- Enforcement of the law is at the hands of the Norwegian consumer authority
Administrative Sanctions
- The Norwegian consumer authority may issue injunctions and fines for non-compliance
- Fines can be imposed on the company itself as well as on the responsible individual

Civil Liability
Facilitating Access to Justice
Other
- Monitoring: citizens are entitled to request information from companies concerning their due diligence plan and in relation to a specific item or service offered by the company