DNB and human rights

DNB places great emphasis on human rights and decent working conditions, and strives every day to make sure that these rights are respected. Fundamental human rights and decent working conditions are relevant for DNB in a number of ways; primarily in connection with our role as employer, supplier of banking and financial services, and purchaser of goods and services, as well as in our lending and investment practices, but also in connection with our role as a key player in society.

Fundamental human rights are the internationally recognised human rights that are enshrined, among other places, in the UN International Covenant on Economic, Social and Cultural Rights of 1966, the UN International Covenant on Civil and Political Rights of 1966 and the ILO core conventions on fundamental principles and rights at work.

The responsibility to safeguard fundamental human rights lies primarily with the individual nation states. Through national legislation, states have imposed independent duties on the business sector to ensure that these rights are upheld. The Working Environment Act, the Equality and Anti-Discrimination Act and the Transparency Act are examples of Norwegian legislation to this end.

The picture is more complex in a global context, as not all countries have equally well-developed legislation and the degree to which it is enforced varies. However, such national variations do not exempt the business community from responsibility. The UN Guiding Principles for Business and Human Rights (UNGP) and the OECD Guidelines for Multinational Enterprises clearly set out companies’ responsibility to respect fundamental human rights and decent working conditions globally. DNB has made a commitment to comply with both of these, and they also form the basis for our Code of Conduct and Group policy for sustainability. The principles are also included in our ethical guidelines for business partners, observed in our ethical investments as an important part of DNB’s exercise of ownership rights, and incorporated in our principles for responsible lending. DNB has also undertaken to comply with the Equator Principles, which clarify our obligations to respect fundamental human rights in connection with project financing.

The Transparency Act sets out requirements for large enterprises domiciled in Norway that offer goods and services in or outside Norway. It also applies to large foreign enterprises that offer goods and services in Norway, and that are liable to pay tax in Norway. The Transparency Act applies to DNB. The requirements imposed on enterprises covered by the Act are that due diligence must be performed and accounted for. Our first Transparency Act report and a Q&A of how we work with our due diligence assessments relating to human rights and decent working conditions are available below. The reports are however, only available in Norwegian.

On this page you can read more about how DNB ensures compliance with the requirements set by the Transparency Act, and who to contact for more information.

DNB’s governing documents set out that we are required to perform risk-based due diligence in our value chain, regardless of whether this relates to loans, investments or purchases. Here are links to key governing documents, describing how we promote human rights and decent working conditions throughout our value chain.

» DNB’s ethical guidelines – Code of Conduct
» Group policy for sustainability
» Group standard for responsible investments
» Group standard for corporate responsibility in DNB Bank ASA’s credit activities
» DNB’s ethical guidelines for business partners
» DNB Asset Management’s expectation document for human rights

Performing due diligence is a key part of DNB’s efforts to respect fundamental human rights. Due diligence is a process implemented to identify, prevent, reduce and document our handling of any negative impact on fundamental human rights and decent working conditions.

When DNB is to perform due diligence focusing on human rights, it is important to stress that the risks considered in these assessments are not risks for the company, but for the person(s) affected.

We must be proactive and prevent violations of human rights. Should DNB be directly involved in human rights violations, we must help rectify the situation and ensure that compensatory measures are implemented. In such cases, we will communicate how we dealt with the situation to the affected beneficial owners.

Our business operations are based on trust. In order to maintain that trust, we must act professionally and with integrity in all situations, not just in our own operations, but also by setting requirements for our partners and customers. This applies at all times, not just when we are the focus of public attention.

An estimated 9 000 companies must comply with the Transparency Act. Many of them are DNB customers. DNB takes a risk-based approach to following up our customers’ compliance with the Transparency Act. As part of our know-your-customer process, thorough customer due diligence is performed based on assessments of the customer’s inherent risk of money laundering, corruption and other potential negative impacts of their business operations. The customer’s country of origin, industry and products used in DNB are key drivers of inherent risk. Using internet searches and information tools, we investigate whether the customer has been involved in controversial incidents, including actual or potential violations of human rights or decent working conditions.

In the Group standard for corporate responsibility in credit activities, we explain what we demand and expect from customers for whom we provide credit or facilitate capital market-based financing. All DNB customers must comply with applicable laws and regulations in their home country/country of origin, in addition to applicable laws and regulations in countries where they conduct business operations. Our customers must also act in accordance with relevant international conventions and guidelines set out by international organisations, such as the UN and the OECD. Compliance with legislation and guidelines for accountability is followed up in a separate ESG risk assessment tool, including our customers’ follow-up of their suppliers’ and business partners’ accountability and respect for human rights and decent working conditions. If serious violations are uncovered, this will affect the final ESG risk classification and decision level for credit. A customer dialogue on the matter will be initiated, and customers will be followed up and influenced to prevent or reduce the harm through action plans.

Due diligence performed by DNB Asset Management AS (‘DAM’) on suppliers/partners is described below. For DAM as an asset manager, the risk of actual or potential negative effects on fundamental human rights or decent working conditions may also be linked to companies we invest in on behalf of our customers. DNB’s Group Instructions for Responsible Investments integrates the OECD Guidelines for Multinational Enterprises, for example, into the Group’s requirements for responsible investment practices. What we demand and expect from companies in terms of upholding human rights and workers’ rights is further explained in our expectation document on human rights.

As part of the due diligence process for companies we invest in on behalf of customers, the investment universe is regularly screened, e.g. for potential and actual negative impacts on social, environmental and ethical criteria based on internationally recognised guidelines and principles. On the basis of this screening and an internal assessment, as well as alerts about incidents, the potential negative consequences are identified and mapped. An external consultant helps us to do this, and also gathers information and provides analyses for our assessments. Depending on the severity of the negative impacts, various appropriate measures are taken, to begin with often in dialogue with the company. However, actual negative consequences may lead to the company being excluded, if our attempts to influence the company do not produce the desired results, see: Exclusions | Responsible investments | Sustainable finance | Sustainability from A to Å - DNB. More information about our due diligence process can be found in our statement on Principle Adverse Indicator Statement. An account of our human rights initiatives, including initiatives relating to workers’ rights, can be found in our annual report on responsible investments.

For DNB Livsforsikring AS (DNB Liv) as a capital owner, the risk of actual or potential negative impacts on fundamental human rights and decent working conditions is related to the companies we invest in. DNB’s Standard for responsible investments integrates the OECD Guidelines for Multinational Enterprises, for example, into the Group’s requirements for responsible investment practices. The standard provides guidance for DNB Liv as a capital owner and for everyone who manages funds on behalf of DNB Liv.

As part of the due diligence process for companies we invest in, the investment universe is regularly screened, e.g. for potential or actual negative impacts on social, environmental and ethical criteria, based on internationally recognised guidelines and principles. On the basis of this screening and an internal assessment, as well as alerts about incidents, the potential negative consequences are identified and mapped. DNB Asset Management (DAM) manages most of DNB Liv’s investments. Read more on how DAM conducts due diligence in the DNB Asset Management section.

DNB purchases goods and services worth around NOK 10 billion every year. The main purchasing categories are IT solution development and operation, marketing and consulting services, and goods and services related to properties and office equipment. Most of our suppliers are in the Nordic countries, Western Europe and North America.

DNB’s commitment to safeguard human rights and perform risk-based due diligence when working with suppliers is based on DNB’s Group policy for sustainability, and is integrated into our internal procurement guidelines. In addition, what is expected of the supplier is expressed in DNB’s Code of Conduct for business partners, which is part of the supplier contract. All companies that supply goods and services to DNB are assessed for risk, including sustainability risk and human rights risk, in DNB’s third-party risk management system. Suppliers from industries or countries with a higher risk of human rights violations, among other things, are subjected to a more in-depth analysis. Our best chance of exerting an influence is by working with our direct suppliers. This is done in various ways, mainly through follow-up via the EcoVadis platform, dialogue on specific topics, thematic inspections (e.g. ‘see-to-it duty’) or broader on-site sustainability audits. The decision on which measures to implement is based on an assessment of risk and severity, DNB’s connection with the risk, and the type of delivery/how close to our business operations the supplier is, which is often also a factor in our ability to exert an influence.

If you have any questions about how DNB Bank ASA and its subsidiaries work to safeguard fundamental human rights and decent working conditions, please send an email to apenhetsloven@dnb.no.

If you have any questions regarding DNB Næringseiendom AS’s approach to the same topic, please contact servicesenter@dnb.no.