Below is KBN’s report on the work it carried out in 2022, as required by Section 5 of the Act.
Embedding and organisation
During the year, the duties imposed by the Transparency Act to carry out due diligence and to report on this work, were incorporated into KBN’s general guidelines for sustainability. The guidelines were approved by the Board of Directors of KBN.
The Chief Executive Officer of KBN is responsible for the conduct of KBN’s work on sustainability. The CEO determines the detailed guidelines for sustainability, the organisation of the work and the allocation of responsibility within the management structure.
Work carried out in 2022
Over the course of 2022, appropriate procedures were developed for the practical implementation of the due diligence requirements, including how the due diligence will be carried out, what information will be required, the need for routine monitoring, the need for channels/procedures for receiving and processing enquiries, and procedures for carrying out remedial measures.
KBN has carried out due diligence assessments of its suppliers and business connections. This work has identified that KBN, as a financial institution serving customers in the Norwegian local government sector, is exposed to only a small extent to suppliers of products and services that might represent material risk of breaches of employment rights and human rights in general.
KBN has in any case implemented a number of measures to ensure compliance with employment rights and human rights by participants in its supply chains. KBN’s General guidelines for procurement include a stipulation that “Procurement processes must be arranged so that they contribute to promoting KBN’s goal of sustainable business operations in accordance with the general guidelines for sustainability. This means that procurement must contribute to reducing damaging environmental impacts and to promoting climate-friendly solutions where relevant. Procurement must promote respect for fundamental human rights and employment rights, equality and diversity, ethical conduct and social responsibility. KBN will not use suppliers that are involved in corruption or money laundering. Procurement must be carried out in such a way as to ensure that KBN has reasonable oversight into the use of subcontractors by suppliers and their subcontractors, and that KBN’s sustainability objectives are promoted throughout the supplier chain”.
KBN’s standard terms and conditions for its contracts with suppliers incorporate a number of requirements relating to employment rights and human rights. These contracts impose duties on our suppliers which include:
- Recognising their social responsibility, including their responsibility in respect of the climate and environment, diversity and equality and social responsibility, not only for their own company but also for their subcontractors and business partners.
- Respecting fundamental human rights and ensuring decent working conditions.
- Undertaking, whether in the supplier’s own right or through a middleman, not to offer any person an improper advantage or service in order to achieve an advantage or influence a public sector employee or any other third party in carrying out their duties.
- Working actively to reduce their climate footprint.
- Being transparent about paying taxes and other payments to the authorities in every jurisdiction in which the supplier carries out business.
- Reporting annually on their work on social responsibility
In addition, KBN has produced a separate statement setting out its expectations of suppliers which stipulates that KBN expects all suppliers of goods or services to KBN to work systematically with sustainability, and contribute to solving society’s social, economic and environmental challenges.
KBN has established an internal procedure to receive and process any requests for information it may receive in order to comply with its duty to provide information. The “Contact us” section of KBN’s website provides information on the email address to be used for any enquiries pursuant to the Transparency Act. KBN received two enquiries in 2022, and it replied to both of these in accordance with the stipulated timetable.
