Transparency Act
Our commitment to human rights
and decent working conditions
The Norwegian Transparency Act (Åpenhetsloven) is designed to ensure that companies respect fundamental human rights and decent working conditions in connection with the production of goods and the delivery of services. The Act also aims to strengthen the public's access to information about how companies manage risk and adverse impacts in these areas.
Isfjord Norway AS is classified as a larger enterprise under the Act and is therefore fully subject to its requirements. This means the company must conduct due diligence assessments in accordance with the OECD Guidelines for Responsible Business Conduct, which provide guidance on how companies can identify, prevent, and manage negative impacts on people, society, and the environment.
Our operations are anchored in the values of respect, environment, quality, and collaboration, and we have a clear ambition to conduct responsible business that serves people, society, and the environment. This statement describes how Isfjord Norway AS approaches due diligence assessments and the measures we have implemented in response to our identified risk areas. The statement covers the reporting year 2025.
Download statement (Norwegian, PDF)Our Business and Area of Operations
Isfjord Norway AS is a seafood producer based in Orkanger. The company processes approximately 15,000 tonnes of salmon and trout annually and offers a broad range of products, including fillets, portions, smoked and cured products, and various marinated varieties. Raw materials are primarily purchased on the spot market.
Isfjord's entire business concept is built on the sustainable utilisation of raw materials, with the goal of minimising food waste. Through processing methods designed to utilise the whole fish, high utilisation of all raw materials is achieved. For parts that cannot be used for food, the company ensures responsible handling and further use — including as fishmeal. Isfjord Norway AS today has a broad and diverse customer base that includes grocery chains, restaurants, hotels, and wholesalers, both nationally and internationally.
Governance, Responsibility & Management
Isfjord Norway AS is committed to conducting its business responsibly, with respect for human rights and decent working conditions. This is embedded in the company's policies and guidelines, and forms the basis for the due diligence work under the Transparency Act.
The Chief Quality Officer / sustainability coordinator oversees risk assessments and the statement. The management team reviews and monitors assessments and measures, supported by subject-matter experts within HR, HSE, environment, finance, and quality. The statement is approved by the CEO and the Board.
To report concerns or raise questions related to the Transparency Act, external enquiries can be directed to: aapenhetsloven@isfjordnorway.no
Risk Assessment
Isfjord Norway AS has conducted an overall risk assessment of actual and potential negative consequences for fundamental human rights and decent working conditions in its own operations and supply chain.
The work is based on the OECD Guidelines for Responsible Business Conduct and forms the basis for prioritising further measures. The risk assessment is updated when there are significant changes in the company's operations, including the sourcing of goods from new countries, development of new products, or the establishment of new business relationships.
Method and approach
Isfjord Norway AS has mapped its suppliers using data from its accounting system, combined with relevant information about each individual supplier. Due to the large number of suppliers, the work has been limited based on purchase volume, as well as industry and geographic affiliation, with a primary focus on the suppliers the company trades with most frequently. The prioritisation also takes into account the company's ability to influence and where it is most appropriate to direct efforts.
The assessments are based on internal experience, industry knowledge, supplier reputation, and relevant external sources. Based on this, certain risk areas and supplier categories have been prioritised for further follow-up under the Transparency Act. In 2025, particular attention has also been directed at raw materials, staffing, and transport, with a primary focus on the largest suppliers.
External sources used include, among others:
- Corruption Perception Index (CPI)
- ITUC Global Rights Index
- UNEP FI guidance tool
- DFØ's high-risk list
- Companies' own reports
Identified Risk Areas
Own operations — HSE and working conditions
Isfjord Norway AS operates production where employees use machinery and perform physical work. This involves risk related to health, environment, and safety (HSE). The company therefore focuses on assessing risk in work tasks, preventing injuries, and ensuring good training and follow-up of employees. Systems have also been established for reporting deviations and improvements. Since the company has employees from various backgrounds and languages, challenges related to communication and understanding can arise. This is addressed through tailored information and training.
Suppliers and business relationships
Most of Isfjord Norway AS's suppliers are registered in Norway and comply with Norwegian laws and regulations. Many of these are also subject to the Transparency Act, which contributes to reducing the risk of violations of human rights and decent working conditions in the supply chain. At the same time, the company has some suppliers in countries categorised as having particular risk, which leads to increased attention around compliance with fundamental rights and working conditions in these areas.
Raw materials
Isfjord Norway AS primarily purchases raw materials through traders, as well as some directly from fish farming companies. This means the supply chain may consist of several tiers, and fish farming facilities are often one to several steps removed from the company's direct suppliers. Traceability is therefore limited, and Isfjord primarily engages in dialogue with and sets requirements for its direct suppliers. The suppliers are established actors, and the risk is assessed as moderate to low. At the same time, Isfjord requires compliance with, among other things, a Supplier Code of Conduct to contribute to accountability in the supply chain.
Transport
Transport is a central part of the business, and deliveries are mainly carried out by road. The transport industry is considered an area of elevated risk, particularly related to working conditions, rights, and the environment. This has therefore been identified as a priority area for further follow-up.
Staffing companies
Isfjord Norway AS uses staffing companies as part of its operations. Hired workers have the same pay and working conditions as permanent employees, in line with applicable collective agreements, which contributes to reducing the risk of violations of human rights and decent working conditions in the company's own operations. Any risk factors are more likely to be related to conditions internal to the staffing agencies, but this is assessed as manageable and with low to moderate risk of unreported deviations. Isfjord Norway monitors staffing agencies through requirements in the "Supplier Code of Conduct" and imposes requirements on employment contracts and equal treatment. Staffing is thus considered an area that is monitored, but not as a high-risk area in the company's due diligence work.
Procurement from China and Poland
Isfjord Norway AS has some suppliers in countries with higher general risk, which may lead to increased risk of violations of human rights and decent working conditions. The risk varies between suppliers, but is related to factors such as freedom of association, working conditions, and wage levels. Isfjord Norway AS sets clear requirements for its suppliers through the company's "Supplier Code of Conduct", and will going forward monitor more closely suppliers in high-risk areas.
How We Work to Prevent, Reduce and Stop Negative Consequences
Isfjord Norway AS is well underway in establishing internal guidelines within sustainability and responsible business practices.
In the course of 2025, we have implemented several measures to strengthen our work on human rights, decent working conditions, and the environment:
- We have established an external whistleblowing channel via email (aapenhetsloven@isfjordnorway.no) for the safe reporting of critical matters.
- Employees are regularly informed of the opportunity to raise concerns, and are encouraged to speak up and make improvement suggestions.
- Follow-up of staffing agencies has been strengthened.
- We collaborate with Orkanger municipality and external consultants to improve the management of emissions and the development of treatment facilities.
- An HSE manager has been appointed to strengthen work on health, environment, and safety.
The Way Forward
Isfjord Norway AS will in the further work prioritise measures aimed at areas with elevated risk, particularly related to transport, the use of staffing companies, and suppliers in high-risk countries. At the same time, the company acknowledges that this is comprehensive and long-term work. Isfjord Norway AS considers that good progress has been made in the due diligence work, but that significant work remains in the years ahead. Measures will therefore be introduced gradually and adapted to the company's ability to influence through dialogue, supplier follow-up, and contractual requirements.
The aim is to reduce identified risk and contribute to improved working conditions both in our own operations and in the supply chain, as an integrated part of the ongoing work with due diligence assessments under the Transparency Act and in line with the OECD Guidelines.
Isfjord Norway AS will also further develop its systems for due diligence assessments, including through increased expertise, clearer routines, and strengthened follow-up of prioritised suppliers and business partners.
The company will also continue to fulfil the requirements of the Transparency Act by publishing annual statements and responding to public information requests within the applicable deadlines. Enquiries related to this work can be directed to the CEO of Isfjord Norway AS.
This statement has been approved by the Board of Isfjord Norway AS.
Signed: Orkanger, 30 June 2026 · Daniel Lund (Chair), Lars Krogh (Board Member), Lisa Ludvigsen (Board Member)