Business and responsibility
KONGSBERG respects all internationally recognised human rights, as set out in our Code of Ethics and Business Conduct. Violations of human rights shall not occur at KONGSBERG.
Our requirements for our business operations and our supply chain are established in our Code of Ethics and Business Conduct approved by our Board of Directors, together with our Supplier Conduct Principles and our governing documents for risk assessment and risk mitigating measures in our own operations, which have been adopted by our Group Management.
KONGSBERG endorses and will strive to comply with the intentions laid down in:
- The UN Universal Declaration of Human Rights
- The UN Convention on the Rights of the Child
- The ILO conventions
- The UN Guiding Principles on Business and Human Rights (UNGP).
- The OECD Guidelines for Multinational Enterprises
- The UN Global Compact
- Reporting requirements according to Global Reporting Initiative (GRI)
UNGP is a prevailing international standard concerning how businesses should approach human rights. KONGSBERG will strive to comply with UNGP and is committed to continuous improvement of our human rights risk assessment and reporting. We acknowledge that we have an independent responsibility to respect human rights and that this applies regardless of where we are operating; it is particularly important in states which do not safeguard human rights.
KONGSBERG complies to the UNGP by:
- Comply to applicable laws and regulations in the countries we have operations.
- Be familiar with and use UNGP and OECD’s guidelines in development of strategies for responsible business conduct, when relevant.
- Conduct risk assessment for Human Rights adapted to our operations.
- Follow the principle for ”follow or explain” and principle of materiality.
KONGSBERG has identified the following areas that need special focus with regards to Human Rights:
- A good, safe and secure working environment.
- Avoidance of child labour and compulsory labour.
- Non-discrimination based on gender, ethnicity, religion, sexual orientation etc.
- Acceptable working hours and wage conditions.
- Freedom of association and the right to collective bargaining, or the freedom to elect their representatives.
- Respect for human rights in the communities in which we operate. This entails respecting the human rights of people outside of our organisation, that might be affected by our business activity.
Under these areas, KONGSBERG will identify the Salient Human Rights Issues, which will be at the core of our annual Human Rights assessments and -reporting. KONGSBERG will continually carry out risk assessments relating to human rights, and implement preventive or risk-mitigating measures to avoid causing or contributing to serious human rights violations.
The occurrence of a Severe Human Rights Impact, or the finding of a high risk of such impact, shall be reported to Line Management and to the Business Area’s Compliance Officer, and handled on a case-by-case basis.
KONGSBERG will report annually on Human Rights, as part of our Sustainability reporting. Reporting will include:
- A statement of KONGSBERG’s Salient Human Rights Issues.
- Reporting on Severe Human Rights Impacts related to the salient issues, in own business units and in the supply chain.
- Actions taken to prevent or mitigate potential impacts related to each salient issue.
KONGSBERG’s governance system is designed to capture a broad range of risks related to our business, including risks related to political and military instability, as well as conditions that deviate from our Code of Ethics and Business Conduct.
Corporate approval of significant offers, contracts and framework contracts
All bids entailing risks as described above will undergo extensive risk assessment, including an independent assessment of Human Rights risks by the compliance organisation, and require approval by the Executive Steering Group of the Business Area. Bids that have material risks associated with compliance will also need approval by the Corporate Board of Directors.
We expect our suppliers to keep the same standard as us, and have implemented our requirements in our “Supplier Conduct Principles” which are part of our supplier agreements. We conduct audits in our supply chain that also include human rights. We have been paying attention to the risk of human rights violations in our supply chain during 2020 due to the COVID-19 situation, no discrepancies or incidents have been reported.
Communication with our stakeholders
We have had meetings with some of our major financial partners in 2020, with focus on human rights. We have annual meeting with our major owner, the Ministry of Trade, Industry and Fisheries, with sustainability and ESG issues on the agenda, including human rights. We have engaged with the Coalition for Responsible Business (KAN) which is a broad association of business, trade union, civil society and other movements that support a Norwegian Human Rights Act for business.
Our subsidiaries and employees engage locally where we operate, e.g. in India where a CSR committee is established for support and contribution to local initiatives and organizations for education, to end poverty, and projects with a particular focus on education for girls.
KONGSBERG delivers a broad spectre of world leading technology, including marine robotics and seaborne transportation, complex integrated defence- and communication systems, space and surveillance technology and digital ecosystems. Our business is diverse and dynamic, and so are the associated risks. KONGSBERG will work continuously to identify and mitigate emerging risks and is committed to preventing risks of illicit practices related to our products.
Compliance with trade and export regulations
KONGSBERG’s defence systems and military equipment are included under the Norwegian export control regime, meaning they are subject to strict regulations by the Norwegian government. The Ministry of Foreign Affairs (MFA) include the following considerations when granting export licenses1):
- The risk of military equipment being used for internal oppression.
- The risk that export could provoke, prolong or aggravate existing armed conflicts.
- Knowledge that the military equipment could be used to commit genocide, crime against humanity or other war crimes.
- High probability that the military equipment will lead to breach of international provisions on terrorism or transnational organised crime.
- Risk of the military technology or equipment being sold illegally in the buying country.
- Risk of the export contributing to serious gender-based violence or other violence against women and children.
KONGSBERG considers the Norwegian export control regime an integrated part of our Human Rights Risk Assessment. Compliance with Norwegian, as well as international, export regulations are considered top priority. KONGSBERG has established specific routines and control mechanisms in this regard and will work continuously to build and maintain a culture of export compliance across the organisation.
We will follow up the Norwegian government’s proposed new legislation, which aims to ensure that Norway can implement the EU’s restrictive measures in Norwegian law. This includes the EU’s new sanctions regime against serious human rights abuses.
1) Guidelines for the Ministry of Foreign Affairs’ processing applications for export and defense equipment, as well as technology and services for military purposes (22 February 1992; reviewed 28 November 2014)
Goals and activities
No breaches of human rights shall occur in our operations
Goals for 2020 – what did we say?
- KONGSBERG shall have a framework for human rights in accordance with the laws and guidelines in force at all times.
- KONGSBERG will reduce the risk of human rights breaches within its own organisation and in our supply chain by:
- Conduct risk assessments regarding human rights within our own organisation and implement mitigation measures as and when necessary.
- Carry out Due Diligence regarding suppliers.
- Monitor our suppliers in accordance.
- Monitor and ensure that our acquired companies integrate our requirements and procedures.
- Carry out targeted skills development and training of personnel.