Introduction

The SSN considers sustainable business practices to be a prerequisite for sustainable development, which means that current generations have their needs met without destroying the ability of future generations to meet their needs (1). We have therefore prepared this policy document, which aims to describe how we will operate the SSN in a responsible and sustainable manner. The document, which includes our 13 principles for sustainable business practices, forms the basis of our sustainability work.

Through membership of Ethical Trade Norway, we have committed ourselves to working actively on due diligence for sustainable business practices (2). The SSN works with due diligence in order to respect and safeguard human and labour rights in our own operations and throughout the supply chain in accordance with the Transparency Act. We have also chosen to include the environment and animal welfare in our due diligence. We expect our suppliers and partners to adopt the same approach.

The policy is a description of the expectations and requirements we have for ourselves, our suppliers and other business partners, as well as how we work to follow this up. It forms the basis of what we look for when assessing and seeking to manage and improve our impact in our supply chains. The policy contains guidelines covering basic requirements for human rights, labour rights, climate and the environment, animal welfare and anti-corruption.

Our work is based on the principles and guidance in the UN Guiding Principles on Business and Human Rights (UNGP, 2011) and the OECD’s Due Diligence Model for Responsible Business Conduct (OECD, 2018). These frameworks are based on the UN Sustainable Development Goals, the Universal Declaration of Human Rights, the International Labour Organisation's (ILO) core conventions on fundamental principles and rights at work and other relevant guidelines for the environment and climate, in which the Paris Agreement and the 1.5 degree target are key.

The policy will be reviewed annually on the basis of the due diligence that the SSN conducts and the findings and information it collects. We will work continuously to update and strengthen the document, as well as add more policy documents in key risk areas that we uncover.

Requirements relating to own business

The SSN recognises that its business practices may have potentially negative impact on people, society, the environment and animal welfare. It also sees its potential to contribute to positive developments in the supply chain. Based on this, it has drawn up the following requirements for its own business:

Due diligence

The SSN shall conduct due diligence for sustainable business practices, i.e. conduct its own risk assessment of its negative impacts on people, society and the environment and animal welfare and stop, prevent and reduce such impacts. The measures shall be monitored and their effects assessed, and they shall be communicated to the affected parties. Where our activities cause or contribute to a negative impact on people, society, the environment or animal welfare, we shall stop this activity and seek to remedy the damage. If a supplier is responsible for causing negative impact/damage, they are also responsible for remedying the situation (3).

Responsible purchasing practices

The SSN considers responsible purchasing practices to be one of its most important tools in its work towards sustainable business practices. The SSN will adapt its own purchasing practices so that it strengthens, and not undermines, its suppliers' ability to deliver on the requirements it sets to ensure good conditions for people, society, the environment and animal welfare. The SSN will strive for long-term supplier relationships with suppliers who show a clear willingness and ability to work with positive developments in the supply chain.

Free Trade unionism and workers' representation

The SSN supports the right to free trade unionism and other forms of democratically elected workers' representation. It will involve workers' representatives and other relevant stakeholders in its work towards sustainable business practices.

Supplier development and partnerships

Through dialogue with suppliers, the SSN will, if necessary, consider contributing relevant skills enhancement or resources that enable its suppliers to comply with its requirements for conditions in the supply chain. In this way, it will lay the foundation for good cooperation with suppliers who show particular willingness and ability to work with positive development for people, society and the environment in the supply chain.

Anti-corruption

The SSN, including all employees, shall never offer or receive illegal or improper monetary gifts or other remuneration in order to obtain business or private benefits for its own part or benefits to customers, agents or suppliers.

Countries under trade boycott

The SSN, including its suppliers and partners, shall avoid trading partners who operate in countries that are subject to trade boycotts by the UN and/or Norwegian authorities.

Requirements relating to conditions in the supply chain

We expect our suppliers and partners to work purposefully and systematically to comply with our Supplier Guidelines, including principles for sustainable business practices, which cover fundamental requirements for human rights, labour rights, anti-corruption, animal welfare and the environment. Our suppliers must:

• Follow our supplier guidelines (add link) including our 13 principles for sustainable business practices.
  

• Work actively with due diligence, i.e. carry out own risk assessment of negative impacts on people, society and the environment, and stop, prevent and reduce such impacts. The measures shall be monitored and their effects assessed, and they shall be communicated to the affected parties. If a supplier is responsible for causing negative impact/damage, they are also responsible for remedying the situation (4).
  

• Demonstrate a willingness and ability for continuous improvement for the sake of people, society and the environment and animal welfare through cooperation.
  

• At the SSN's request, they must be able to document how they, and any subcontractors, work to comply with the guidelines.
  

• Have a system in place for handling complaints related to human rights, labour rights, animal welfare, the environment and corruption.
  

• Avoid trading partners who operate in countries that are subject to trade boycotts by the UN and/or Norwegian authorities.
  

If, after repeated inquiries, a supplier does not show a willingness or ability to comply with the supplier guidelines, the contract may be terminated.

Principles of sustainable business practices (Code of Conduct)

These 13 principles of sustainable business practices are based on UN and ILO conventions and set minimum and not maximum standards. The legislation at the production site must be respected. Where national laws and regulations cover the same topic as these guidelines, the highest standard shall apply. This also applies in cases where our Code of Conduct conflicts with national legislation. Our Supplier Code of Conduct specifies minimum and not maximum requirements. If a supplier uses subcontractors to fulfil a contract, the supplier is responsible for ensuring that these requirements apply throughout the supply chain.

1. Forced labour/slave labour (ILO Convention No. 29 and 105)

1.1. There shall be no form of forced labour, slave labour or involuntary labour.
1.2. Workers shall not be required to submit deposits or identity papers to their employer and shall be free to terminate their employment by submitting a reasonable notice period.

2. Trade union organisation and collective bargaining (ILO’s core conventions nos. 87, 98, 135 and 154)

2.1. Workers shall without exception have the right to join or establish trade unions at their own request and to negotiate collectively. The employer shall not interfere with, obstruct or oppose trade unionisation or collective bargaining.
2.2. Trade union representatives shall not be discriminated against or prevented from carrying out their trade union work.
2.3. Where freedom of association and/or the right to engage in collective bargaining are limited by law, the employer must facilitate, and not hinder, alternative mechanisms for free and independent organisation and negotiation.

3. Child labour (UN Convention on the Rights of the Child, ILO Convention Nos. 138, 182 and 79, ILO recommendation no. 146)

3.1. The minimum age of workers shall not be less than 15 years and shall be in line with the national minimum age for employment, or the minimum age for compulsory schooling, and the highest age shall apply. If the local minimum age is set at 14 years in accordance with the exception in ILO Convention 138, this may be accepted.
3.2. The new recruitment of child workers in violation of the aforementioned minimum age shall not take place.
3.3. Children under the age of 18 shall not perform work that is detrimental to their health, safety or morals, including night work.
3.4. Action plans shall be established for the rapid phasing out of child labour that is in contravention of ILO Conventions 138 and 182. The action plans shall be documented and communicated to relevant staff and other stakeholders. Support schemes shall be facilitated in which children are given the opportunity to study until they are no longer of school age.

4. Discrimination (ILO Convention No. 100 and 111 and the UN Convention on the Elimination of Discrimination against Women)

4.1. There must be no discrimination when it comes to employment, remuneration, training, promotion, termination or retirement based on ethnic affiliation, caste, religion, age, disability, gender, civil status, sexual orientation, trade union work or political affiliation.
4.2. Protection shall be established against sexually intrusive, threatening, abusive or exploitative behaviour, and against discrimination or dismissal on unjustifiable grounds, e.g. marriage, pregnancy, parenthood or HIV status.

5. Cruel treatment (Universal Declaration of Human Rights/UDHR)

5.1. Physical abuse or punishment, or the threat of physical abuse, is prohibited. The same applies to sexual or other abuse and other forms of degrading treatment.

6. Health, safety and the environment (ILO Convention no. 155 and recommendation no. 164)

6.1. Efforts shall be made to ensure workers a safe and healthy working environment. Hazardous chemicals and other substances must be handled responsibly. Necessary measures shall be taken to prevent and minimise accidents and damage to health as a result of, or related to, workplace conditions.
6.2. Workers must receive regular and documented training in health and safety, including new employees and relocated workers. Health and safety training shall be repeated for new employees and relocated workers.
6.3. Workers must have access to clean sanitary facilities and clean drinking water. Where relevant, employers must also provide access to facilities for the safe storage of food.
6.4. If employers offer accommodation, such accommodation must be clean, safe, adequately ventilated and provide access to clean sanitary facilities and clean drinking water.

7. Wages (ILO Convention no. 131)

7.1. Workers’ wages for a normal working week shall, as a minimum, be in line with the national minimum wage regulations or industry standards, the highest of which shall apply. Wages must always be sufficient to cover basic needs, including some saving.
7.2. Pay conditions and payment of wages must be agreed in writing before work commences. The agreement must be understandable for the worker.
7.3. Deductions from wages as a disciplinary measure are not allowed.

8. Working hours (ILO Convention nos. 1 and 14)

8.1. Working hours must be in line with national laws or industry standards and shall not exceed the working hours laid down in current international conventions. Normal weekly working hours must not normally exceed 48 hours.
8.2. Workers must have at least one day off per seven days.
8.3. Overtime must be limited and voluntary. The recommended maximum overtime is 12 hours per week, i.e. total working hours of 60 hours per week. Exceptions to this may be accepted if regulated by collective agreement or national law.
8.4. Workers shall always be paid extra for overtime in excess of normal working hours (see item 8.1 above) in accordance with applicable laws as a minimum.

9. Regular employment

9.1. Obligations towards workers, in line with international conventions, national laws and regulations on regular employment, shall not be circumvented through the use of short-term contracts (such as contract workers, casual workers and day workers), sub-contractors or other labour relations.
9.2. All workers are entitled to an employment contract in a language that they understand.
9.3. Apprenticeship programmes must be clearly defined with respect to duration and content.

10. Marginalised population groups

10.1. The production and use of natural resources shall not contribute to destroying the resource and income base for indigenous peoples or other marginalised population groups, for example, by seizing large areas of land, or the irresponsible use of water or other natural resources on which the population groups depend.

11. Environment

11.1. Negative environmental impact shall be reduced throughout the value chain. In line with the precautionary principle, measures shall be implemented to continuously minimise greenhouse gas emissions and local pollution, the use of harmful chemicals, pesticides and to ensure sustainable resource extraction and management of water, oceans, forests and land, and the conservation of biodiversity.
11.3. National and international environmental legislation and regulations must be complied with, and relevant emission permits must be obtained.

12. Corruption

12.1. All forms of bribery are unacceptable, such as the use of alternative channels to ensure illegitimate private or work-related benefits to customers, agents, contractors, suppliers or their employees, and government officials/women.

13. Animal welfare

13.1. Animal welfare must be respected by safeguarding the five freedoms for animal welfare: freedom from hunger and thirst, freedom from discomfort, freedom from pain injury or disease, freedom to express normal behaviour and freedom from fear and (chronic) distress (Brambell Commission, 1965). Measures shall be taken to minimise negative impacts on the welfare of farmed animals and working animals.
13.2. National and international animal welfare legislation and regulations must be complied with.




1) The Brundtland Commission, "Our Common Future", 1987. 2) UN OHCHR, Guiding Principles on Business and Human Rights (UNGP)", 2011; OECD, "Due Diligence Guidance for Responsible Business Conduct", 2018. 3) OECD Contact Point for Responsible Business Conduct, "OECD Guide for Due Diligence for Responsible Business Conduct – an Introduction", 2018. 4) OECD Contact Point for Responsible Business Conduct, "OECD Guide for Due Diligence for Responsible Business Conduct – an Introduction", 2018.