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Transparency Act
Responsible Business

Transparency Act

Statement · June 2025

Our commitment to human rights
and decent working conditions

This statement is published in accordance with the Norwegian Transparency Act (Åpenhetsloven), which requires larger companies to conduct due diligence assessments on human rights and decent working conditions, and to make the results publicly available.

Isfjord Norway AS is committed to responsible business practices across our own operations and throughout our supply chain. We conduct regular assessments and take concrete steps to prevent and address any adverse impacts on people and working conditions.

1. About Isfjord Norway

Isfjord Norway AS is a seafood producer based in Orkanger, Norway. The company processes approximately 18,000 tonnes of salmon and trout annually and offers a wide range of products including fresh, frozen, smoked, cured, and marinated varieties. Sustainability is a core pillar of our market position.

The company was established in Trondheim in 2006 and has grown to over 270 employees. In 2024, revenue was just under NOK 1.4 billion, with approximately 60% from international export markets. Our customers span retail, restaurants, hotels, and wholesalers across the Nordic region and beyond.

Isfjord Norway has long been committed to responsible and sustainable business — focused on reducing environmental impact, upholding human rights, and maintaining decent working conditions throughout our value chain. In line with the Transparency Act, we conduct regular due diligence assessments to identify, prevent, and address actual and potential adverse consequences on fundamental human rights and working conditions.

2. Due Diligence Assessments

Isfjord Norway conducts regular due diligence assessments in line with the Transparency Act and the OECD Guidelines for Responsible Business Conduct. The purpose is to identify, prevent, and limit actual and potential adverse consequences on fundamental human rights and decent working conditions — both within our own operations and in our supply chain.

Our assessments are structured around the following steps:

  1. 1Accountability embedded in leadership and governance
  2. 2Identifying actual and potential adverse impacts
  3. 3Taking action to stop, prevent, or mitigate adverse impacts
  4. 4Monitoring the effectiveness of measures and results
  5. 5Communicating to affected parties how impacts are addressed
  6. 6Ensuring or cooperating in remediation where required
  7. 7Annual review and update of the assessments

2.1 Risk Areas Identified

Based on our assessments, Isfjord Norway has not identified any confirmed adverse consequences to date. However, we have identified certain areas with potential risk, particularly related to:

Agency and contract workers

Use of hired labour may involve varying practices around wages and working conditions that require closer monitoring.

Shift work and overtime

In production, there may be a need for closer follow-up on reward structures and the distribution of shift work.

Raw material sourcing

Purchasing from suppliers in global seafood markets where working conditions and wages may be constrained.

Third-party production

Production in countries with elevated risk of non-compliance with labour rights and human rights standards, particularly outside Scandinavia.

3. Measures Implemented

Isfjord Norway has implemented a range of measures to prevent and reduce the risk of violations of human rights and decent working conditions — in our own operations and throughout the supply chain:

  • Development and implementation of an ethical code of conduct for suppliers, with clear requirements related to human rights, working conditions, environment, and anti-corruption.
  • Mapping of the supplier chain using the UN Human Development Index (HDI) to identify geographic risk levels.
  • Collection of additional documentation from high-risk suppliers, including declarations of adherence to core labour rights.
  • Ongoing monitoring and documentation review of supplier practices, including evaluation of health, safety, and environment (HSE) standards.
  • Continuous improvement of supply chain control through structured audit and review processes.

Measures are reviewed and updated regularly to ensure they remain effective and are adapted to changes in the market and risk landscape.

4. Whistleblowing & Transparency

Isfjord Norway has established reporting channels that enable employees, suppliers, and other stakeholders to raise concerns about unacceptable conditions — anonymously and safely. Reports can be submitted via our internal ERP system, through employee representatives, or directly to a line manager.

In accordance with the Transparency Act, Isfjord Norway provides access to information about our risk assessments and due diligence work on human rights and decent working conditions. Information can be shared with interested parties upon request, in accordance with the rules on transparency and access.

5. Planned Actions & Future Work

In the course of 2025 and 2026, Isfjord Norway will continue to strengthen and develop our responsible business practices through the following initiatives:

  • Annual review and update of the risk base for human rights and working conditions across our own operations and supply chain.
  • Strengthening internal controls and documentation routines in categories with elevated risk.
  • Increased focus on training and awareness of ethical guidelines — both internally and among our suppliers.
  • Systematic measurement and reporting of the effect of implemented measures to ensure continuous improvement.

Isfjord Norway is working purposefully to ensure that both our own operations and our suppliers contribute to a more fair and responsible value chain — where production is safe, sustainable, and carried out with respect for people and the environment.

Signed: Orkanger, 23 June 2025 · Daniel Lund (Chair), Lisa Ludvigsen (Board Member), Lars Krogh (Board Member)

Request Information

Requests for further information on our due diligence work can be directed to:

Grønørveien 30, 7300 Orkanger, Norway