NOAH's report on due diligence assessment
NOAH is covered by the Act on Business Transparency and Work with Basic Human Rights and Decent Working Conditions, also called the Transparency Act. The Openness Act shall contribute to ensuring that our business safeguards basic human rights and has decent working conditions, and that we demand accountability towards our suppliers and other business relationships.
This report covers the entire NOAH group, including operating companies and subsidiaries, but does not include Morrow Batteries. The statement applies to the period 01.01.-31.12.2023. We also refer to the sustainability report and NOAH's website for information on our business og the organization.
NOAH's work with the Transparency Act
A working group organizes the work on the transparency act in NOAH. This is ongoing work that encompasses the entire group. It is emphasized that the work with the Transparency Act should be included in our existing routines and work processes to the greatest extent possible.
Measures taken when implementing the Transparency Act:
- Anchoring in NOAH AS's board on 13.06.2022 June XNUMX.
- NOAH's environmental policy changed its name to sustainability policy and received a new point on human rights and decent working conditions and responsibility towards suppliers.
- Obligation to provide information according to the Transparency Act has been included in the procedure for external communication.
- Quality assurance of ethical guidelines for employees.
- Major revision of self-declaration for suppliers, previously called "Ethical guidelines for suppliers". This was approved by NOAH AS's board on 21.03.2023 March XNUMX.
- Introduced separate points about the Transparency Act in the form used for supplier audits.
- Systematics around due diligence assessments have been implemented in the method description for risk assessments.
- Revised notification procedure and notification form on the website so that the notification system also includes conditions under the Transparency Act.
- Revised checklist for new suppliers and contract templates for suppliers.
- The purchasing procedures have been revised.
- Employees are informed about the new requirements and measures via the intranet and our general meeting "Free minute".
Mapping of prominent human rights
In connection with carrying out a materiality analysis, a survey of prominent human rights was carried out in the autumn of 2022. This was carried out by Position Green Advisory through interviews with various stakeholders, both internal at various levels in the organisation, customers and critical suppliers. This was the result of the analysis, where the tick shows the prominent human rights:

The analysis shows that health, safety and working conditions are the most prominent human rights, both internally and among suppliers/collaboration partners. Carriers are singled out as particularly important among our suppliers, and discrimination is also singled out as a prominent human right. This overview is used in the further work with due diligence assessments.
Due diligence assessments in own business
For the work with health, safety and working conditions in your own business, there are existing, good routines, including:
- HSE manuals, personnel manual, ethical guidelines and quality system with procedures, tools for follow-up and documentation. NOAH AS and NOAH Solutions AS are certified according to ISO 9001 and ISO 14001, and have been assessed for conformity according to ISO 45001.
- Annual employee survey with themes such as motivation, well-being, cooperation, workload, bullying/harassment, HSE and competence.
- Annual employee interviews with follow-up of the individual employee.
- Risk assessments at 1-3 year intervals, both at group level, location level and the individual workplace.
- Safety rounds with mapping of the physical working environment and safety.
- This week's HSE theme, some only for Langøya in NOAH Solutions AS and some for the entire group.
- Compliance assessments to verify that the quality system complies with framework conditions.
- System for deviations and suggestions for improvement, which is followed up by a quality and improvement committee.
- Audit group that carries out internal audits and supplier audits.
- Notification procedure and a notification committee.
- Working environment committee (AMU) in NOAH Solutions AS. Rekefjord Stone AS has AMU from 01.01.2024.
- Three main safety representatives and several safety representatives.
- Several active trade unions.
- Annual chemical rounds at all operating locations and a separate chemical selection in NOAH Solutions AS.
In addition, there is a corruption manual and a competition manual, as well as an annual compliance course with a lawyer.
The measures are documented and followed up in our quality system Landax.
The deviation system is actively used for deviations/unwanted incidents and suggestions for improvement. There is a low threshold for using the deviation system, and the system is actively used in the improvement work. In 2023, 882 incidents, deviations and improvement proposals were registered.
All personal injuries are followed up with root cause analyses, while for incidents with the potential for high risk, a learning meeting is held and a learning note is created which is shared on the intranet. For two incidents, an investigation has been carried out in 2023.
There were no injuries to employees in Engadalen or at office locations. At the operating locations on Langøya and in Rekefjord there have unfortunately been personal injuries, with a total of seven absenteeism injuries among our own employees and contracted/external employees. This is a significantly higher number of claims than in previous years, and is related to a high level of activity with large projects and many hired workers.
There have been three absenteeism injuries among our own employees, one in Rekefjord and two in Langøya. The injuries have been hands in a pinch, falling down the stairs on a ferry and inhaling gas during welding. Measures implemented have included changing crushers, signage with "Use the guardrail" on the ferry, updated procedure for hot work (stricter requirements for cleaning at the front) and a new type of respiratory protection, with training.
With external parties who have carried out work on Langøya, there have been four absenteeism injuries. A fall injury when handling a hand-held remote control unit, an injury while driving a wheel loader, crushing injury to the foot and crushing injury to the hand. The incidents have been reviewed with the businesses involved, and several measures have been implemented. Among other things, better routines have been established (including a one-point lesson for bag unloading), improved unloading solution elements, HSE as a topic at several meetings and more HSE points on the checklist for regular inspection rounds. There is an increased focus on the safety standard of external suppliers/contractors and hirers, including through even closer follow-up and involvement in the week's HSE theme.
The employee survey in spring 2023 showed good well-being, high motivation and that the HSE culture is perceived as good. Each department has worked on its results, and there have also been some joint areas of focus for the entire group, including broader anchoring of the strategy, increased recognition of milestones and achievements, increased exchange of experience/hosting, group day for increased cross-functional cooperation, information at the general meeting. Friminutt" about HSE work and the HSE theme of the week on bullying/harassment.
Due diligence assessments for suppliers and other business partners
In order to get an overview of all suppliers and other business partners, the aim is to collect all of these in the supplier module in Landax (NOAH's quality system). Most of the suppliers are now entered in Landax, and an automatic link to the Brønnøysund register has been established, in order to obtain industry affiliation. Those who have not had deliveries in the last two years have been set as inactive.
NOAH has 1446 suppliers who have delivered goods or services in the past two years, ranging from a small single delivery to suppliers who are critical to our business. A large proportion of the suppliers used the most are large players who are themselves covered by the Transparency Act.
In the supplier module, a rough analysis of most of the suppliers has been carried out, and work is underway to carry out this for the last suppliers who have been transferred to the system. The rough analysis emphasizes factors such as country affiliation, type of industry and possibility of influence. Based on this, an overview is formed of the suppliers that must be assessed more thoroughly. NOAH has chosen not to use a standardized questionnaire as part of the due diligence assessment, but the suppliers are further surveyed through obtaining explanations/information, dialogue and/or supplier audits. This is work that is ongoing and will continue as a key priority. Follow-up of suppliers and the requirements of the Transparency Act have been identified as an important task for the specialist area of procurement.
The largest share of NOAH's suppliers is from Norway (92%), see figure. Priority is given to using local suppliers in the local communities where we are active.

At NOAH, we have assessed that it is our suppliers in the transport sector, both on land and at sea, who represent the greatest potential for negative consequences in the field of human rights and working conditions. Companies in the transport sector compete on flexibility and quick adaptability, which can result in strong pressure on workers through reduced wages and worse working conditions (rest breaks, working hours, overtime pay, access to facilities, etc.). The transport sector is particularly exposed to health and safety risks as a result of being a highly competitive industry.
The transport sector is a group for which we have good follow-up routines, both through supplier meetings, supplier audits and ongoing contact. On Langøya is there an employee who follows up on drivers and their compliance with, among other things, safety routines. We have carried out supplier audits for several of our carriers in recent years, and some are also on the schedule this year. Working conditions and human rights are the subject of all supplier audits.
Other important supplier groups are contractors and craftsmen. Both on Langøya and in Rekefjord, contracted contractors carry out a large and important part of the production work, and also have some of the work operations that involve the highest risk, such as rock drilling, blasting and loading/unloading of boats. There are weekly collaboration meetings with the contractors - with HSE on the agenda - they carry out regular risk assessments and report if any unwanted incidents occur. Deviations that may affect safety are registered in NOAH's deviation system, and are followed up in collaboration with the supplier. The contractors are also followed up with regular supplier audits.
With some suppliers, there have previously been challenges with the use of subcontractors, but fewer subcontractors are now used than previously. In new contracts, NOAH places restrictions on the use of subcontractors, in that these must be pre-approved by NOAH.
So far, no serious violations of human rights or decent working conditions have been uncovered, but some areas for improvement have been found. At some of the suppliers, a lack of follow-up of the Transparency Act has been discovered, and this is being followed up.
Notification channel
NOAH has integrated notification under the Transparency Act into the same system as notification under the Working Environment Act. It can, among other things, be notified via our websites, both for employees, hired or external. We encourage you to fill in contact information, but it is also possible to report anonymously. See more about this on our websites.
Goals for the coming year
- Clarify the role of supplier manager and ensure that all important suppliers have a dedicated supplier manager.
- Further work with the new procurement routines and implementation of changes.
- Improve the due diligence assessment system for new suppliers.
Running goals
- Reduce the number of suppliers.
- Ongoing rough analysis of new suppliers.
- Due diligence assessment of suppliers, with particular focus on significant supplier groups.
Questions about this report can be directed to Quality Advisor Tone Berit Pedersen, contact information tone.Pedersen@noah.no or +47 909 27 182.