Norwegian Transparency Act

Last updated: 30 June, 2025

1 Introduction

The Norwegian Transparency Act entered into force on 1 July 2022. Businesses that are covered by the Act are required to perform due diligence of business partners and their supply chain to prevent negative consequences for basic human rights and decent working conditions. Businesses are also required to publish an account of their due diligence assessments.

This report identifies risks, examines potential negative consequences, outlines mitigation measures in place or planned, and evaluates their effectiveness. The findings in this report covers the period from 1 January, 2024 to 31 December, 2024, but reflects due diligence measures up to the date of publication.

2 About the Hagland group

Established in 1872, Hagland is a group of family-owned companies with heritage in the maritime industry. The group’s parent company R.G. Hagland AS offers shipbroking services within the dry cargo, offshore and tanker markets as well as fishing/aquaculture. The shipbroker services are carried out under the brand name Hagland Shipbrokers, which also includes part-owned companies in Esbjerg, Hamburg and Aberdeen. The parent company R.G. Hagland AS also provides services to other companies in the group related to shipping operations and administrative support such as accounting and secretarial services. Hagland Agency provides ship agency services to ships calling the Haugesund region.

At the end of 2024, the group’s shipping business Hagland Shipping comprised a fleet of 12 self-discharging bulk carriers of approx. 3,700-4,900 DWT. The ships operate on contracts of affreightment and in the spot marked, servicing industrial companies in Northern European.

The real estate business Hagland Eiendom includes the purchase, operation and sale of properties and participation in other companies with similar purposes. The real estate activities of the company, including subsidiaries, comprise over 20 properties/buildings with totalling approx. 33,500 square meters which are predominantly commercial properties for rent, in addition to land areas under development for commercial and/or residential purposes. The group’s properties are primarily located in the Haugesund region.

The business Hagland Finans comprises accounting services and business management for companies within the Hagland group and a range of external customers. Hagland Finans AS is registered as an approved accounting company by the Norwegian Financial Supervisory Authority (“Finanstilsynet”).

The company Storm & Bull Shipping AS is agent for a number of international shipyards and service companies, and acts as an intermediary between these yards and shipping companies operating in/from Norway.

3 Our Commitment to Human Rights

Hagland will consistently adhere to all applicable national and international laws, conducting business in accordance with globally recognised standards, including the OECD guidelines, United Nations conventions and ILO conventions, covering human rights, health and safety, labour rights, environmental protection, anti-corruption and fair business practices.

4 Our Stakeholders

OWNERS AND BOARD OF DIRECTORS

As a family-owned company, Hagland’s owners take an active role in overseeing and supporting all of the company’s human rights initiatives, demonstrating a strong commitment to ethical and responsible business practices. Furthermore, The Hagland group’s Board of Directors and Management are dedicated to upholding compliance with the Transparency Act and implementing necessary measures identified through risk assessments and audits to promote human rights.

CUSTOMERS

As a service provider, Hagland is dependent on its reputation and trust among customers, clients and others. Good business ethics and honesty are crucial for our competitiveness and implies that we strive to act in an appropriate and ethical manner in all contexts.

SUPPLIERS

Our choice of suppliers reflects what we ourselves stand for. We therefore expect our suppliers and business partners to act in a similar manner. All our suppliers receive our Supplier Code of Conduct and are expected to adhere to it.

EMPLOYEES

The foundation of Hagland lies within our people. Their contributions have been instrumental in shaping Hagland’s success thus far and will continue to drive our future growth. The wellbeing of our employees is therefore of utmost importance to us. We prioritise a safe and healthy work environment, stable working conditions, fair compensation, equal opportunities, well-defined routines and policies, and, above all, ensuring that everyone returns home safely.

SOCIETY AT LARGE

Society at large refers to all other stakeholders and the general public such as authorities, banks and insurance companies, environmental organisations, media, local communities, associations and certification bodies. Hagland is committed to comply with all regulatory requirements required to operate responsibly.

5 Due Diligence Process

In line with the Norwegian Transparency Act and fundamentally the OECD’s guidelines, Hagland has established a due diligence system and process to identify, assess and manage actual and potential risks and impact on fundamental human rights and decent working conditions, both in Hagland’s operations and its supply chain. The due diligence process is continuous, with regular monitoring of adverse impacts and significant risks. The management remains actively engaged to ensure effective oversight and accountability.

The due diligence process is prioritised based on risk and probability. Our review covers all suppliers from the past three years, categorising them based on actual spend. Suppliers below a certain spend threshold are classified as low-risk and therefore excluded from further analysis. Next, we assess suppliers based on industry-specific risks and geographical factors.

Suppliers that are considered small, are categorised as low risk and are not followed up in more detail. Furthermore, we identify suppliers based on risk factors such as geographical operation and industry related risk factors. Geographic location is also evaluated in light of The International Trade Union Confideration’s (ITUC) Global Rights Index.

For the remaining suppliers, we assess our ability to influence and exert impact. Suppliers identified as medium or high risk are contacted directly and must undergo a comprehensive follow-up process.

6 Findings

A handful of suppliers were assessed regarding their efforts in upholding human rights and maintaining effective systems and practices for working conditions. Through our due diligence assessment, there have not been uncovered or brought to Hagland’s knowledge any objectionable conditions relating to basic human rights and decent working conditions. However, we acknowledge that there are areas within our supply chain with higher risk of breaches.

From a group perspective, the various businesses have significant differences in organisation and operation, which also imply significantly different probabilities for potential negative consequences regarding basic human rights and decent working conditions. On a risk-based approach, it is the shipping business Hagland Shipping which is deemed to entail the highest probability of any negative conditions.

Shipbroking, ship agent and shipyard representation activities are all characterised by the fact that the services provided are as an intermediary between shipping companies and/or port/terminal/shipyard. Although these may not be considered suppliers or business partners in the usual sense (i.e. in relation to the Transparency Act), it is nevertheless important to Hagland that all the parties with whom we conduct business respect and live up to the same expectations when it comes to basic human rights and working conditions. At the same time, it is relevant to note that the majority of these companies are themselves large Norwegian and international businesses that have established similar guidelines for their own operations.

Although our due diligence process has not identified any breaches, we recognise that there is heightened risk in some areas of our supply chain. Of particular relevance are suppliers that involve a large workforce, for example involving crewing services, shipyards and service repair companies. Relevant mitigating factors will typically be certifications, for example documenting compliance with the Maritime Labour Convention (MLC).

7 Measures

In carrying out our due diligence work, we have gained increased awareness on fundamental human rights and decent working conditions. We have strengthened our existing procedures, including our supplier evaluation system and internal policies. Examples of the latter include our Code of Conduct, Supplier Code of Conduct, Anti-Bribery and Corruption Policy, Health and Safety Policy, Environmental Policy and Whistleblowing Policy. Hagland will continue to improve our due diligence system and supplier evaluation in addition to further raise awareness among our own employees, suppliers, business partners and other interested parties about our requirements and expectations.