The Transparency Act applies to
Businesses of the Accounting Act § 1-5, or which exceed the limit for two of the following three conditions:
Sales revenue of 70 million
Total assets of 35 million
Employed an average of 50 full-time employees in the financial year
The Transparency Act is a relatively new law which aims to promote businesses' respect for basic human rights and decent working conditions, and ensure the public's access to information.
The Act imposes, among other things, a duty to provide information and a duty to carry out due diligence assessments, which must be explained in a report that is submitted.
The obligation to provide information applies from the law's entry into force on 1 July 2022
The Act imposes the following obligations on businesses:
Carry out due diligence assessments of own business activities, the supply chain and business relationships continuously and regularly
Handle inquiries about access/requirements for information after 1 July 2022
Reporting of the due diligence assessment on 30 June each year, or in case of significant changes, and for the first time 30 June 2023
The following must be done:
The board must anchor compliance with the Openness Act
2. Appoint a responsible person in the company who follows up the due diligence assessments that are carried out, as well as follows up and responds to inquiries within 3 weeks.
- Enter the responsible person under Key Personnel
3. Get an overview of suppliers
- Add these to Service Providers
4. Make a risk assessment of each individual supplier on the basis of geography, industry, products and any other risk
- Enter these risks in the Risk Assessment module, and add each individual supplier as an Action
5. Send the Code of Conducts to suppliers and partners. Here, a requirement for compliance with the Transparency Act should be specified and a confirmation that they take responsibility for this in their own business and their supply chain.
- Add these to the Service Provider module by pressing Add report under each provider
6. If any of the suppliers have an extra high risk, we recommend a mini-due-diligence in the form of a form with some relevant questions.
- This can also add on relevant suppliers in the Service Provider module
7. When entering into new contracts or renewing old ones, the contracting party's responsibility in accordance with the Openness Act must be anchored.
- The template from DFØ can be used here.
Provide available information on your website about the status of the due diligence assessments and update this continuously.