Human rights
Business strategy, business model and core values.
Accountability is entrenched at the highest level of management in the Hafslund Group, and “Responsible” is one of Hafslund’s core values.
Hafslund is dependent on suppliers and partnerships and is committed to maintaining the good relationship the Group has with its other key stakeholders. Hafslund having a system which contributes to reducing the risk of human rights violations in its own activities and in the value chain is crucial for this.
Impact, risks and opportunities
“Human rights” are an important topic for Hafslund, and risk is the most important driver of the materiality analysis. All of Hafslund’s business areas are involved in complex global supply chains that are, in many cases, characterised by an absence of transparency and openness. Hafslund has not uncovered actual negative consequences, but recognises that the Group operates in certain value chains where there is an inherent risk of negative impacts.
Hafslund sets clear requirements for its suppliers within all product and service areas. All suppliers and their subcontractors shall conduct their activities in accordance with nationally and internationally recognised principles and guidelines relating to human and workers’ rights, corruption, and health, safety and the environment. In addition to being risk-mitigation measures, Hafslund also believes that these are measures that have a positive impact on the employees in Hafslund’s supply chains.
Assessing the risk of violations of worker and human rights is an ongoing process at Hafslund. The risk landscape changes in line with changes in the Group’s business areas. It has been established tools for conducting risk assessments in each business area, which also facilitates a risk-based approach in the Group’s follow-up of suppliers and assists in prioritising measures. Risk tools and methodologies have been developed and adopted, and further implementation and development are currently in progress. The risk mapping process involves a review of Hafslund’s suppliers, and the Group uses recognised sources of country and category risk to classify the suppliers. This provides Hafslund with an overview of the risk landscape in the Group’s supply chains.
Conditions that define risks associated with suppliers that perform work and services for Hafslund and the Group’s companies include the type of work, the employees’ employment agreements, employee accommodation and the use of subcontractors. Conditions that define risk when purchasing input factors for production and production equipment include complex global value chains, countries of origin and market access.
The table below summarises the Group’s most significant risks and opportunities related to the important sustainability topic of “Human rights”:
| Risks | Opportunities | ||
|---|---|---|---|
| Violations of human rights | Setting requirements either alone or in cooperation with the industry/sector | ||
| Violations of decent working conditions | Close industry cooperation | ||
| Stakeholder dialogue |
Hafslund Eco Vannkraft
For Hafslund Eco Vannkraft, suppliers in the following industries are considered to have the greatest risk of adverse consequences for fundamental human rights and decent working conditions:
- Building and construction
- Construction or property management
- Complex materials
- Transport and logistics
The risk within each of these categories depends on the nature of the work, employment agreements, employee accommodation, the use of subcontractors and the complexity of the value chain.
The greatest risk is related to labour market crime in connection with operation and maintenance contracts for hydropower plants in Norway. Breaches of pay and working conditions by suppliers and subcontractors are considered the greatest risk.
Hafslund Oslo Celsio
For Hafslund Oslo Celsio, providers of maintenance at facilities during production stoppages, global fuel suppliers and waste customers have been identified as the greatest risk of potential violations of human rights and decent working conditions:
- Operation and maintenance contracts for facilities in Norway are carried out by European suppliers and subcontractors. It is particularly in connection with production stoppages at incineration plants that there is an identified risk of labour market crime and violations of pay and working conditions on the part of suppliers and subcontractors who perform work for us.
- Purchases of input factors for incineration plants (for example biofuel, pellets etc.) and waste customers may have complex, unclear and not very transparent value chains.
Hafslund Vekst
For Hafslund Vekst, the greatest risk of there being an absence of basic human rights and decent working conditions is linked to suppliers of solar and wind power plants.
The supply chains for input factors to solar and wind power plants are unpredictable, complex and characterised by high demand. There is considered to be a high risk of human rights violations associated with the supply chain, which extends all the way from the extraction of raw materials and production of individual components to finished solar panels and wind turbines.
There is a shortage of architects, technical advisers and resources for the installation of solar panels. Building and construction companies that install solar panels often rely on hiring tradespeople from countries where there is an inherently higher risk of labour market crime.
Policy/guidelines
Principles in the Group sustainability policy that are directly related to the important sustainability topic of “Human rights”:
- Hafslund shall respect human rights in its own business activities and exert its influence over suppliers and business partners to ensure that respect for human rights is safeguarded.
- Hafslund shall engage in business activities that are consistent with the UN Guiding Principles on Business and Human Rights and the Ten Principles of the UN Global Compact.
- Due diligence shall be carried out with regard to human rights and employee rights in connection with entering into new partnerships and the Group’s procurement practices. Due diligence must be conducted in a manner that is systematic and appropriate. This should be an integral part of how Hafslund works.
Hafslund has established a governing document with a routine for compliance with the Transparency Act. The routine will contribute to the Hafslund Group’s business activities and cooperation with suppliers and business partners promoting the objectives of the Transparency Act. It involves respect for fundamental human rights and decent working conditions in connection with the production of goods and the provision of services, and ensures public access to information about how businesses manage negative consequences for fundamental human rights and decent working conditions. The routine provides guidance for compliance with the duties stipulated in the Transparency Act, and defines basic principles, appetite for risk, and roles and responsibilities for compliance with the Transparency Act. The Executive Vice President Corporate Development is responsible for ensuring that this routine is approved by the companies in the Hafslund Group that are governed by the Transparency Act. The main principles of this governing document are:
- The companies in the Hafslund Group that are governed by the Transparency Act shall conduct due diligence in line with the OECD Guidelines for Multinational Enterprises.
- The Group parent company, Hafslund AS, shall prepare and publish a due diligence report for the Hafslund Group.
- The Group parent company, Hafslund AS, shall handle requests for information pursuant to the Transparency Act.
The report for the Transparency Act is published on Hafslund’s website by 30 June each year. The report is signed by the CEO and the Board of Hafslund AS. The CEO and the respective boards of Hafslund Eco Vannkraft AS, Hafslund Vekst AS and Hafslund Oslo Celsio AS sign the parts of the report that concern their individual companies.
Hafslund’s “Ethical guidelines and requirements for suppliers” sets requirements for the Group’s suppliers. These were updated in 2023 and are based on the principles of the UN Global Compact initiative. Hafslund expects suppliers to actively work to achieve the UN Sustainable Development Goals. Hafslund uses the International Labour Organization’s (ILO) core conventions and the Oslo Model as a basis for its activities. Hafslund’s suppliers must respect fundamental human rights and ensure decent working conditions and refrain from contributing to any form of human rights violations.
The Oslo Model
The Group has implemented the Oslo Model, which is a collective term for a number of good practice provisions that are incorporated into contract terms for the purchase of goods and services, and building and construction. Hafslund sets clear requirements for its suppliers within all product and service areas. All suppliers and their subcontractors shall conduct their activities in accordance with nationally and internationally recognised principles and guidelines relating to human and workers’ rights, corruption and health, safety and the environment.
Actions
In autumn 2022, the Hafslund Group commenced an important project to strengthen the work on human rights and compliance with the Transparency Act. This work continued in 2023. The project’s working group comprises sustainability and compliance functions at Group level, as well as representatives from each individual subsidiary that include legal expertise, procurement functions and other key persons to ensure broad-based involvement. In 2023, Hafslund employed a human rights advisor.
The focus areas during this period included:
- Updating the management system, and ensuring establishment in governing documents and with management.
- Adapting the division of roles and responsibilities and assessing internal expertise.
- Adapting reporting routines, including managing of requests for information.
- Assessing the potential and actual risk of violations of worker and human rights in own operations and supply chains.
Hafslund’s work on compliance with the Transparency Act is based on the due diligence work in Hafslund’s guidelines and management systems. Routines for risk mapping and supplier follow-up have been updated during this process. This lays the groundwork for Hafslund’s efforts to stop, prevent and reduce potential or actual negative impact.
Hafslund has developed and established risk tools that are designed in such a way that the Group can prioritise suppliers for follow-up with a risk-based approach, create action plans and follow up implementation. The risk tool is used across the Group’s business areas. The work of obtaining an overview of the Group’s supply chain is ongoing. In 2022 and the start of 2023, Hafslund prioritised obtaining a sufficient overview for being able to formulate a comprehensive risk landscape. The assessments and findings from the due diligence conducted shall be actively used in future due diligence processes so that Hafslund can address potential risks related to human rights and decent working conditions in a good and structured manner. Preventive work in the high-risk areas was a prioritised focus area during the final half of 2023 and has continued at the start of 2024. Based on the risk mapping, relevant suppliers are followed up and improvement measures are implemented when necessary. Work is underway to prepare key indicators for measuring due diligence implementation and results.
The Group aims to select the right suppliers. Hafslund endeavours to reduce risk by having good processes before entering into agreements and active follow-up after agreements are entered into by using measures that include monitoring and audits. Hafslund’s guidelines provide the option of setting ethical requirements and checking compliance through, among other things, random checks of employment agreements, rotation arrangements and timesheets, as well as non-conformance management of undesirable incidents and improvements that also include contracted activities.
At Group level, the work with human rights and the Transparency Act is rooted in the management system and governing documents. Below are descriptions of some of the company-specific measures that were implemented or commenced in 2023.
Whistleblowing channel:
In order to assist in identifying potential and actual negative consequences, Hafslund has a whistleblowing channel that is available to internal and external stakeholders. This is available on the Group website via https://hafslund.no/varsling. The whistleblowing channel is further described in the chapter relating to the important sustainability topic of “Ethical business operations”.
Hafslund Eco Vannkraft
In 2023, notification was received from another power company about improper working conditions at one of their suppliers. Hafslund also uses this supplier. With the aim of contributing to the supplier changing its routines and controls for working conditions, dialogue was established with this supplier and control measures were implemented by Hafslund to reduce the risk of similar incidents occurring in Hafslund’s projects.
In order to increase the scope and carry out more systematic follow-up, the procurement function at the company has been strengthened and professionalised by employing more people who will work in positions dedicated to responsible procurement. Hafslund expects that further development of the procurement and project process together with increased capacity for systematic follow-up work will reduce the risk that Hafslund Eco Vannkraft’s activities result in potential negative incidents related to fundamental human rights and decent working conditions.
Hafslund Eco Vannkraft includes ethical guidelines for suppliers in all major agreements. To ensure that suppliers comply with the guidelines, the following controls has been implemented:
- Random checks of employment agreements and rotation arrangements.
- Random checks of timesheets.
- Non-conformance management of undesirable incidents and improvements that also include contracted activities.
Hafslund Oslo Celsio
Requirements and documentation for procurements:
- Requirements are set in operation and maintenance contracts for suppliers to comply with the Working Environment Act and to submit staffing plans as part of their tenders. This is done to ensure that suppliers have understood the provisions relating to working hours and have staffing plans that are in accordance with reported capacity.
- There is an adapted supplier qualification process for fuel and waste contracts. Ethical guidelines and requirements for suppliers are also stipulated for these suppliers and customers. Regular visits to production partners are also carried out.
During the past year, Hafslund Oslo Celsio has conducted a series of collaborative meetings with the principal maintenance providers, as well as with suppliers engaged during production stoppages at the incineration plants. This work has been continued with an emphasis on further improvements to the process, as well as the establishment of tools for supplier evaluation.
Hafslund Vekst
The following measures have been implemented or are planned to be implemented in connection with the procurement of a supplier of solar panels:
- Close dialogue with the supplier relating to requirements under the Transparency Act.
- Physical visits to subcontractors of Hafslund’s principal supplier.
The following measures have been implemented or planned to be implemented in connection with the procurement of a supplier of offshore wind turbines:
- A separate section relating to the follow-up of requirements in accordance with the Transparency Act was added to the client’s specification of requirements. This applies to both the main supplier and subcontractors. This is followed up with physical and digital meetings to ensure there is understanding and compliance.
- Evaluation of tender documents and weighting of sustainability requirements, including a section relating to human rights and decent working conditions.
Hafslund Vekst is also an active participant in the Norwegian Solar Energy Cluster (Solenergiklyngen) and Norwegian Offshore Wind, where industry guidelines are created based on existing and new regulations. The Norwegian Solar Energy Cluster is part of the association Solar Power Europe, where it contributes a focus on responsible value chains.
Metrics and targets
Hafslund has clear guidelines related to the topic of “Human rights”. To comply with these guidelines, the following metrics and targets have been defined:
| Metrics and targets | Result 2023 | Result 2022 | Comments |
|---|---|---|---|
| No instances in which Hafslund causes, contributes to or is directly linked to human rights violations. | - | - | No known violations |
| All suppliers must sign ethical guidelines and requirements for suppliers. | - | - | Work is being done to establish a system for registration in parts of the Group. |
Indicator table
Incidents, complaints and serious violations of human rights
| Incidents, complaints and serious violations of human rights in the value chain | Unit | 2023 | 2022 | Comment |
|---|---|---|---|---|
| Number of known serious violations of human rights or workers' rights in the value chain | Number | 0 | 0 | Two potential suppliers with various violations that were discovered after due diligence and on-site audits. Contract not yet signed. |
| Number of suppliers that have signed ethical guidelines (CoC) for suppliers - Hafslund Oslo Celsio | Per cent | 20 | - | New indicator. Value makes up 51% of spend. |
| Number of suppliers that have signed ethical guidelines (CoC) for suppliers - Hafslund Vekst | Per cent | 40 | - | New indicator. |
| Number of suppliers that have signed ethical guidelines (CoC) for suppliers - rest of the Group | Per cent | - | - | Data not available. Work is being done to establish a system for measurement. |
| Number of supplier audits conducted, which includes sustainability issues | Per cent | 21 | - | New indicator. |
| Number of known corruption cases | Per cent | 0 | - | New indicator. |
| Number of reported incidents in the whistleblowing channel related to violations of basic human rights and decent working conditions in the value chain | Per cent | 0 | - | New indicator. |
| Incidents, complaints and serious violations of human rights in own operations | Unit | 2023 | 2022 | Comment |
|---|---|---|---|---|
| Number of cases of discrimination, including harassment, reported | Number | 0 | - | New indicator. |
| Number of cases of discrimination or harassment that have been processed and an action plan established | Number | 0 | - | New indicator. |
| Number of cases reported through channels for raising concerns (including whistleblowing channel channel) | Number | 2 | 0 | Two incidents of unacceptable behaviour in a social context were reported directly to the manager and followed up with the immediate manager, HR and those involved. |
| Total amount for fines, penalties and compensation for damages as a result of any incidents and complaints related to discrimination | Number (NOK) | 0 | - | New indicator. |
| Total amount for fines, penalties and compensation for damages as a result of any incidents and complaints related to violations of human rights | Number (NOK) | 0 | - | New indicator. |
