Humanrights
Human rights are fundamental rights that apply to all people worldwide.
Basic human rights and decent working conditions
Human rights and decent working conditions are something DNB has a major focus on and the company strives every day to ensure these rights are respected. For DNB, fundamental human rights and decent working conditions are relevant in several ways; this applies primarily to our role as an employer, provider of bank and financial services, purchaser of goods and services and in connection with our lending and investment practice and also in our role as a key player in Norwegian society.
Fundamental human rights refers to the internationally recognised human rights that result from, among other things, 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 the ILO core conventions on fundamental principles and rights at work.
The responsibility for securing fundamental human rights ultimately lies with the individual national states. Through national legislation, the states have imposed independent obligations on the business sector to ensure that these rights are safeguarded. Examples of such Norwegian legislation are the Working Environment Act, the Equality Act and the Transparency Act.
In a global context, the picture is more complex, as not all countries have as well-developed legislation and because its enforcement varies. However, such national differences do not exempt businesses from liability. The UN Guiding Principles on Business and Human Rights (UNGP) and the OECD’s guidelines for multinational companies clarify which responsibilities businesses have for respecting fundamental human rights and decent working conditions globally. DNB has committed to both of these and they are also guidelines of our Code of Conduct and Corporate Policy on sustainability. The principles are also included in our Ethical Guidelines for Business Partners, our ethical investments as an important part of DNB’s exercise of ownership rights, and for our principles for responsible lending. DNB has also committed to complying with the Equator principles, which among other things clarify our obligations to respect fundamental human rights in connection with project financing.
DNB and the Norwegian Transparency Act
The Norwegian Transparency Act sets requirements for larger businesses domiciled in Norway that offer goods and services within or outside Norway. The law also applies to larger foreign businesses that offer goods and services in Norway and which are tax-liable to Norway. The Transparency Act applies to DNB. The requirements imposed on the businesses covered by the law are that due diligence assessments must be carried out and that these must be reported.
On this page you can read more about how DNB ensures that we comply with the requirements of the Transparency Act and where you can ask for more information if you’d like it.
Corporate governance
DNB's governing documentation states that we are obliged to make risk-based due diligence assessments in our value chain. This could be through loans, investments or purchases. Here you’ll find links to key governing documents describing how we promote human rights and decent working conditions in our value chain.
Due diligence assessments
At the heart of DNB’s efforts to respect fundamental human rights is the implementation of due diligence assessments. Due diligence assessments are a process that is implemented to identify, prevent, reduce and document how we handle any negative impact on fundamental human rights and decent working conditions.
When DNB is conducting due diligence in the area of human rights, it is important to emphasise that the risk involved in these reviews is not the risk to the company, but to the affected person or people.
We must be precautionary and prevent breaches. If DNB is directly involved in breaches of human rights rights, we must contribute to correcting the situation and ensure compensatory measures are put in place. Here we will communicate with affected rights holders about how we have handled the situation.
Our business is based on trust. Maintaining this trust requires us to act professionally and with integrity in all contexts, not only when it comes to our own business, but also in the demands we place on partners and customers. This applies at all times, not only when we have the spotlight on us.
Corporate customers
It is estimated that 9,000 companies will comply with the Transparency Act. Many of these are DNB customers. DNB has a risk-based approach to how we monitor our customers’ compliance with the Transparency Act. As part of our Know-your-Customer process, thorough customer checks are made based on assessments of the customer’s inherent risk of money laundering, corruption and other potential negative impact they may cause through their business. Important drivers of inherent risk are the country, the industry and the products the customer uses at DNB. Through Internet search and by using information tools, we examine whether the customer has been involved in controversial events, including actual or potential violations of human rights and decent working conditions.
Loans and provision of capital
In our group standard for corporate responsibility in the credit business, we explain our requirements and expectations of customers for whom we provide credit or facilitate capital market-based financing. All of DNB’s customers must observe applicable laws and regulations in their home country/country of domicile, as well as applicable laws and regulations in countries where they conduct their business. Our customers must also act in accordance with relevant international conventions and guidelines adopted by international organisations, such as the UN and the Organisation for Economic Cooperation and Development (OECD). Compliance with laws and guidelines for accountability is monitored using a proprietary 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 severe conditions are found, this will affect the final ESG risk classification and decision level for credits. Customer dialogue about the conditions will be initiated, while follow-up and impact on customers to prevent or reduce damage through action plans will also be carried out.
Investing
DNB Asset Management
Due diligence assessments DNB Asset Management AS (“DAM”) carried out by suppliers/partners are described below. For DAM as the asset manager, the risk of actual and potential negative consequences for fundamental human rights and decent working conditions can also be linked to the companies we invest in on behalf of our customers. DNB’s Group instructions integrate, among other things, the OECD’s guidelines for multinational companies into the requirements for responsible investment practices. Furthermore, our requirements and expectations for companies regarding the safeguarding of human and employee rights are elaborated in our expectation document on human rights.
As part of the due diligence on companies we invest in on behalf of customers, the investment world is regularly screened for potential and actual negative consequences on social, environmental and ethical criteria based on internationally recognised guidelines and principles. Based on screening, and internal assessment, as well as reports of incidents, potential negative consequences are identified and mapped out. For this work, we are supported by an external consultant, who also contributes information gathering and research for assessments. Depending on the degree of severity, various reasonable measures are implemented, often in dialogue with the company in the first instance. However, actual negative consequences can result in exclusion, Exclusions | Responsible investments | Sustainable finance | Sustainability from A to Z - DNB, by the company if the impact does not produce the desired results. More information about our due diligence process is available in our Principle Adverse Indicator Statement. An account of the human rights work, including employee rights, is covered in our annual report for responsible investments.
DNB Livsforsikring
For DNB Livsforsikring AS (DNB Liv) as the asset manager, the risk of actual and potential negative consequences for fundamental human rights and decent working conditions is linked to the companies we invest in. DNB’s Standard for responsible investments integrate, among other things, the OECD’s guidelines for multinational companies into the requirements for responsible investment practices. The standard provides guidelines for DNB Liv as the asset owner and for everyone who manages assets on behalf of DNB Liv.
As part of the due diligence on companies we invest in, the investment world is regularly screened for potential and actual negative consequences on social, environmental and ethical criteria based on internationally recognised guidelines and principles. Based on screening, and internal assessment, as well as reports of incidents, potential negative consequences are identified and mapped out. DNB Asset Management (DAM) manages most of DNB Liv’s investments. Read more about how DAM conducts due diligence in the DNB Asset Management section.
Purchasing
DNB purchases goods and services worth around NOK 10 billion a year. Important procurement areas are the development and operation of IT solutions, marketing and consultancy services, as well as goods and services related to properties and office equipment. Most suppliers are from the Nordic countries, Western Europe or North America.
DNB’s commitment to safeguarding human rights and conducting risk-based due diligence when working with its suppliers is based on DNB’s overarching sustainability policy, and is integrated into internal purchasing guidelines. Furthermore, the supplier’s expectations are expressed in DNB’s Ethical guidelines for business partners, which is part of the supplier contract. All businesses that supply goods and services to DNB are assessed for risks, including sustainability and human rights risk, in DNB’s system for Third Party Risk Management. Suppliers from industries or countries with a higher risk of, among other things, human rights breaches undergo a more in-depth analysis. Our biggest opportunity for impact is working with our direct supplier. This is done through various measures, primarily through the EcoVadis platform, dialogue on specific themes, thematic audits (e.g. duty of care) or broader local sustainability audits. The measures initiated are based on an assessment of risk and severity, DNB’s connection to risk, and type of delivery / how close to the business the supplier is, which often also has a connection with our ability to influence. Read more about DNB and responsible purchasing in DNB’s annual report for 2022.
Contact points
If you have any questions about how DNB and our subsidiaries work to secure fundamental human rights and decent working conditions, please send an email to this address: apenhetsloven@dnb.no.
If you have any questions directed to DNB Real Estate Investment Management (DNB REIM) on this subject, please contact servicesenter@dnb.no.