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First Transparency Act report published

September 4 2023

Fulfilling requirements on reporting of due diligence framework for human rights risks in value chains

The Norwegian Transparency Act, which requires enterprises to have in place a due diligence framework for human rights risks in their supply chains, entered into force on 1 July 2022. The Act requires enterprises to annually report on their due diligence activities and provide information to the public on request. The first reporting deadline was 30 June 2023. 

During the reporting period, Storebrand Asset Management has mapped and assessed human rights risks in sectors ranging from renewable energy, to oil and gas, textile, and food and agriculture. We have implemented measures to stop, prevent, or limit negative consequences in our portfolios for the following risks: 

  • living wages and decent working conditions in supply chains
  • forced labour
  • gender, diversity, and inclusion
  • employee rights, including the right to participate in trade unions
  • children's rights
  • local community rights in the green transition
  • indigenous peoples' rights
  • human rights in high-risk countries and conflict areas 

We have used active ownership strategies such as exclusions, reactive and proactive dialogue with companies, and observation lists as part of our due diligence framework. 

These strategies helped avoid including at least eleven problematic companies from high-risk countries in our portfolios. We have also decided to exclude thirteen companies after evaluating the human rights risks as aligned with our due diligence framework. 

We have also had a proactive dialogue with over fifteen industries, mainly through collaboration in various investor initiatives, and have voted on over 195 social shareholder proposals at general meetings in 2023. 

In addition to the Norwegian Transparency Act, we have also reported on the EU Sustainable Finance Disclosure Regulation (SFDR). We have focused on principle adverse impacts such as violations of UN Global Compact and OECD Guidelines for Multinational Enterprises, unadjusted gender pay gap, board gender diversity, and exposure to controversial weapons. 

For more details on our human rights due diligence process, as well as a list of excluded and engaged companies, see our recently published report

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