The Norwegian Transparency Act

Codex has adopted a policy for compliance with the Norwegian Transparency Act. Based on this policy, Codex has also developed ethical guidelines for suppliers and business partners.

Codex sets high standards relating to human rights and decent working conditions within its own operations. We also require suppliers and business partners to impose corresponding requirements on their own suppliers and business partners. These requirements are based on Codex’s ethical guidelines.

Codex’s guidelines are based, among other things, on the Norwegian Working Environment Act, the UN International Covenant on Economic, Social and Cultural Rights, the UN International Covenant on Civil and Political Rights, the European Convention on Human Rights, and the ILO core conventions on fundamental rights and principles at work.

Codex expects suppliers and business partners to commit to complying with our ethical guidelines and to be able to document such compliance.

The Norwegian Transparency Act requires companies to identify and assess actual and potential adverse impacts on fundamental human rights and decent working conditions that the company has either caused or contributed to, or that are directly linked to the company’s operations, products or services.

Codex carries out due diligence assessments in accordance with the requirements set out in Section 4 of the Norwegian Transparency Act and the OECD Due Diligence Guidance.

Codex has reviewed and carried out an overall assessment of all suppliers and business partners, with the exception of trivial contributions, provided that the relevant party does not fall within predefined high-risk sectors. These assessments are based on the severity and likelihood of breaches of human rights and decent working conditions. The assessments take into account the countries in which the supplier or business partner, and/or its supply chain, is located, as well as the type of products or services delivered to Codex.

In our assessments, we have, among other things, used the Norwegian Agency for Public and Financial Management’s list of high-risk product categories, Økokrim’s National Threat Assessment for 2022, and Transparency International’s Corruption Perceptions Index, which provides an overview of corruption levels across countries. Codex’s own knowledge of specific actors has also been taken into account.

The scope of the risk assessments also reflects assumptions relating to Codex’s ability to influence, based on the percentage of the supplier’s turnover represented by Codex and/or the frequency of contact with the supplier or business partner. Based on the risk assessments, Codex has carried out further investigations of certain actors in order to identify any relevant concerns.

This forms the basis for assessing whether specific measures should be implemented in relation to individual suppliers and business partners, or whether further investigations should be carried out. This work is ongoing, and we continuously seek to identify and address any risk of breaches of human rights and decent working conditions.

Codex provides legal services, and purchases related to our business operations consist primarily of services. Codex’s suppliers and business partners are, for the most part, based in Norway, where the general risk of serious breaches of human rights and decent working conditions in connection with the services purchased is considered low. However, Codex has identified excessive overtime, unequal pay for equal work and discrimination as potential risk areas among our suppliers’ subcontractors.

In addition, the cleaning industry is generally considered high-risk. Økokrim’s 2022 threat assessment indicates that this sector involves an increased risk of vulnerable workers being exploited.

The above is based on general information relating to the services involved, as well as the geographical location of the relevant actors, gathered from publicly available sources. At present, Codex has no specific concerns relating to individual suppliers, but does not exclude the possibility that such breaches may occur based on the publicly available information referred to above. Codex works actively to identify any circumstances that may give rise to concern.

Codex expects suppliers and business partners to commit to complying with applicable laws, relevant guidance and Codex’s ethical guidelines, and encourages them to contact Codex if they are uncertain about how these requirements should be implemented.

If a supplier or business partner is unwilling to comply with Codex’s requirements, Codex will consider other measures and, as a last resort, terminate the relationship.

Codex has not received any reports or other information indicating that Codex’s requirements relating to human rights and labour rights have not been complied with. Codex will continue to monitor the situation in order to assess whether further measures should be implemented, either generally or in relation to specific actors.

Codex has established an email address, apenhetsloven@codex.no, for enquiries and reports from suppliers, business partners, stakeholders and third parties. These parties are encouraged to report any suspected breaches, or risks of breaches, of Codex’s ethical guidelines or applicable law. The email address may also be used for requests for information.

Codex also has an internal whistleblowing system for employees. All employees are encouraged to report matters of concern.

Where harm is identified, Codex will cooperate with relevant stakeholders on remediation, depending on the extent of our involvement in the harm.