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Human Rights Due Diligence Norway

EY Norway, in collaboration with EY Finland, EY Denmark and EY Sweden, has initiated a Human Rights Due Diligence based on OECDs Guidance for Responsible Business Conduct. We acknowledge that human rights due diligence is a continuous process, and EY Nordics is constantly working to better understand and map its risks to fully integrate and implement required improvements.

The Due Diligence is a 6-step iterative process consisting of the following steps1:

  1. The business should embed responsible business conduct into policies and management systems
  2. Identify and assess adverse impacts in operations, supply chain and business relations
  3. Cease, prevent or mitigate adverse impacts
  4. Track implementation and results
  5. Communicate how impacts are addressed
  6. Provide for or cooperate in remediation when appropriate

How we are organized

EY Norway’s legal entity name is Ernst & Young AS and Ernst & Young AS owns 100 % of the Norwegian companies Bjørvika Konferansesenter AS, EY Skye Consulting AS and Ernst & Young Value Added Tax Services AS. In addition Ernst & Young AS controls Ernst & Young Advokatfirma AS.

EY Norway is part of the Nordic organization and our core business services are organized on a Nordic level.

Worldwide, EY member firms operate in more than 150 countries and share the commitment to building a better working world. As a member of the EY Global Network, the Norwegian firm operates as subcontractor to and for other member firms, which are all required to comply with the internal policies, and support the initiatives, set out by EY Global.

Step 1: Embed responsible business conduct

People are the most important and valued part of EY; they are EY; thus to pay close attention to their well-being, sense of belonging, safety, and decent conditions at work is important to us – This applies to our own operation, to our extended teams abroad, our supply chain and business relations.

In EY globally we draw our understanding of human rights from the Universal Declaration of Human Rights, its related treaties and declarations, and the broader ethical reasoning behind their development. Our approach to respecting and upholding human rights is based on the United Nations Guiding Principles on Business and Human Rights.

All EY member firms, including EY Norway, are committed to upholding the human rights of EY people. Specifically, we strive to respect the following human rights that we have identified to be most salient to EY people, in our work environment:

  • Health and safety — The right of all people to enjoy a physically and psychologically safe work environment
  • Labour rights — The right of all people to just and favorable terms of employment
  • Diversity, equity and inclusiveness — The right of all people to be respected and valued for their differences, with equitable opportunities and outcomes, in an inclusive environment where all can thrive.

EY's Supplier Code of Conduct sets out clear standards of business conduct and ethics that our suppliers must abide by. Suppliers must ensure that they and/or their subcontractors and suppliers shall respect the rights of their employees and comply with all relevant legislation, regulations and directives in the country or countries in which they operate. This includes all rights and minimum standards relating to:

  • Wages
  • Benefits and working conditions applicable across their entire workforce
  • No exploitation of child labour (under 14 years of age)
  • No exploitation of any vulnerable group (e.g., illegal immigrants)
  • Abide by all local laws, directives and regulations relating to the elimination of slavery and human trafficking.

Responsibility and approach for human rights can be found in:

Human Rights Statement
Our Global Code of Conduct
Supplier Code of Conduct
EY Global Executive (GE) Diversity, Equity and Inclusiveness Statement

To ensure responsible business conduct EY Norway, in collaboration with EY Finland, EY Denmark and EY Sweden, is strengthening a Nordic management system for Human Rights based on OECD’s guidelines on due diligence for responsible business. We have a dedicated team in place and are in the process of assessing human rights risks in our own operation, including vendors, and based on these results we plan to update necessary management documents.

Step 2. Identifying and assessing human rights impacts

We have assessed risk both in our own operation and our Supply chain:

Own Operation – Risk Assessment

We have conducted a risk assessment to identify the highest risks for our operation on a Nordic level. Based on the fundamental Human Rights Conventions (International Bill of Human Rights and the ILO Conventions), we have identified the degree to which these are relevant to EY and pose a risk to EY from a reputational and legal perspective. We identified the following three human rights that pose a high risk:

  • Right to not be subjected to slavery, servitude or forced labour
  • Right to equality before the law, equal protection of the law, and rights of non-discrimination
  • Right to enjoy just and favorable conditions of work

The result of EY Nordics risk assessment confirms the Human Rights that EY Global assessed as most salient to EY people in our work environment.

Supply Chain – Risk Assessment

To assess EY Norway’s vendors we have utilized an EY ESG analytics tool to check all vendors against risk based on: company name, location, sector and EY spend. The result is presented in a dashboard showing where EY has the most salient human rights risk in the supply chain.

We identified the following human rights risks:

In general, the majority (69%) of EY’s vendors pose a medium social risk, while 30% pose a high risk. High risk is mainly associated with labour rights (27%), while some vendors also pose a high risk in relation to indigenous & tribal rights (5%). Vendors of high social risk are mainly located in Norway, while there are also some vendors located in Sweden and Finland.

Certain sub-industries pose a high risk in relation to labour rights:

90%-100% of vendors in the following services: Security and alarm services, Diversified support services, Food retail, Home furnishings

80%-90% of vendors in the following services: Human resources & employment, Construction & engineering

70%-80% of vendors in the following services: Technology Hardware, storage, Trucking

The results of these assessments will guide us to which human rights and which vendors we should investigate further as part of a full due diligence. We expect to start up further work in the beginning of fiscal year 2023.

Step 3. Ceasing, preventing, and mitigating human rights impacts

EY’s Global culture and guidelines promotes a fair workplace and a positive work environment. The Code of Conduct sets clear responsibilities of which human rights are found to be most salient to EY. Employees are encouraged to speak up and report any potential human rights violations, and whistleblowing channels are in place to facilitate this. If you wish to report a concern, you can register a case via EY/Ethics Hotline. In EY Nordics we appreciate a culture of speaking up and most internal concerns are raised through counsellors or superiors. In FY22 there were no cases raised linked to human rights.

Step 4. Tracking implementation and results

In EY Norway the Corporate Sustainability Lead is responsible for the Human Rights management system and support the Board by monitoring and reviewing its practices and policies in this area, including regular reviews of progress.

Step 5. Communicating how impacts are addressed

EY Norway communicates its human rights impact focus in the Annual Report and on its webpage and plans to issue a separate report on human rights impacts to fulfil its reporting obligations under the Norwegian Transparency Act.

Step 6. Grievance mechanisms and remediation

The EY culture promotes openness and transparency in all its activities and all employees and business partners are encouraged to report any violations of the Code of Conduct or other policies.

All cases raised through EY Ethics hotline or other internal channels are managed by EY Nordics risk responsible through a standardized process. In Fiscal year 2022 there were no reported cases relating to Human Rights.

Access to information requests

As per section 6 of the Transparency Act, any person has the right to information from an enterprise regarding how the enterprise addresses actual or potential adverse impacts in accordance with the Act. This includes both general information and information relating to a specific product or service offered by the enterprise.

Such requests may be presented to Marita Hagerup Vogt.

1]  http://mneguidelines.oecd.org/OECD-Due-Diligence-Guidance-for-Responsible-Business-Conduct.pdf