Transparency Act 2023

Our statement on the Transparency Act

Introduction: Transparency and accountability in practice

Nordic Steel is Norway's leading competence center within steel. We are a complete supplier of mechanical production within advanced plate processing, certified welding and assembly. We are located at Bryne in Rogaland, with administration and production departments, and we have our own sales offices in Ålesund and Oslo.

Nordic Steel is a certified Eco-Lighthouse company and we are certified according to ISO 9001. We supply customers in all industries, such as renewable energy, oil and gas, transport and infrastructure, aquaculture, construction, defense and aerospace, HVAC and piping.

For many years, we have taken responsibility for the environment and sustainability. We want to help reduce our customers' carbon footprint, while ensuring social conditions and basic human rights throughout our value chain.

Working life and social responsibility are closely linked to environmental responsibility. We divide our sustainable choices into three core areas: people, work life and the environment. These areas are all linked to the UN Sustainable Development Goals. We have selected three SDGs that we work with in particular, because this is where we can make an extra difference. These are the goals of good health and quality of life (no. 3), decent work and economic growth (no. 8), and to stop climate change (no. 13).

Collaboration is essential to achieve sustainability results. In recent years, it has become particularly clear that government, business and society must work together to find good solutions. Only then can we achieve sustainable development. Nordic Steel sees our sustainable choices and climate footprint as crucial to our future competitiveness.

Context and the industry

The UN Universal Declaration of Human Rights is the basic document in the international work for human rights. It consists of 30 articles and applies to all UN member states.

As an industrial company, it is important for us to lead the way, and we will have a profile that is sustainable and climate-friendly. We will do what we can to reduce climate emissions and promote human rights and democratic principles.

Børre Lobekk, President and CEO Nordic Steel Group

We care. There are no alternatives

Our position as Norway's leading center of expertise in steel obliges us to contribute to a more sustainable industry. We will be a leader in what is most forward-looking in our industry, in everything from environmental focus in our own operations, to delivering on environmental requirements from our customers, and to creating and maintaining a good and safe working environment.

The UN Sustainable Development Goals are the world's common work plan to eradicate poverty, fight inequality and stop climate change. The 17 SDGs will serve as a common direction for countries, businesses and civil society.

Human rights are the fundamental rights that all people have, regardless of race, gender, ethnicity, beliefs, nationality or where they live.

If we can help promote basic human rights and responsible working conditions in the production of our goods and delivery of our services, it is even more meaningful. We hope that transparency about us in Nordic Steel and our supply chain, and in the industry at large, helps to increase demand and requirements for a more sustainable industry.

For us, there are no alternatives.

Policies and procedures

Nordic Steel has conducted due diligence in line with the OECD Guidelines. We have identified potential and actual adverse impacts and significant risks regarding human rights and have the following documents to ensure and demonstrate compliance:

  • Human rights due diligence
  • Report on human rights
  • Analysis of sustainability goals
  • Sustainability and human rights strategy
  • KHMS policy and policy on social responsibility and human rights
  • Ethical guidelines
  • Staff handbook
  • Procedure for reporting misconduct
  • Procedure for approval and evaluation of suppliers
  • Supplier approval / evaluation form
  • Quality, environment and HSE handbook
  • Register of conformity assessment of laws and regulations

Actual negative consequences and significant risks identified in the due diligence assessment

Nordic Steel operates in Norway where human rights are controlled by law and well implemented in society. Based on our activities and size (over 120 employees), we have limited impact on society other than on our own employees and our suppliers.

Nordic Steel has no conflicts related to the UN Universal Declaration of Human Rights and will respect the rights and local laws wherever we work.

We have conducted a due diligence on the UN Universal Declaration of Human Rights and have identified areas where we may have a risk or opportunity to influence. We have implemented measures internally and among suppliers to limit the risk of negative consequences in some relevant areas.

Internal risks and opportunities

1. There is a risk that injuries and strain injuries can occur, and we work continuously to ensure the safety and well-being of our employees (HR3)

Initiated measures: Health, safety and environment is the most important thing we work on, every single day. All employees receive training before they start so that they have the best possible skills to do their jobs and understand the company's work processes. Important routines at our company relate to protective equipment, chemicals, machinery, lifting, transportation and the working environment. We have regular safety inspections, a risk-based system, work in accordance with Norwegian law and conduct working environment surveys.

Further measures planned: HSE is a continuous effort, we work on improvements, have regular risk assessments and involve employees in safety rounds.

2. There is a risk that employees feel uncertain about joining trade unions (HR23 and HR20)

Measures taken: Norwegian law and the staff handbook describe that staff are free to join the trade union of their choice.

3. There is a risk that personnel do not receive equal pay for equal work (HR23)

Measures taken: We follow the established salary matrix in the production departments.

Further measures planned: A report on gender equality and what is being done to fulfill the activity obligation (cf. the activity and reporting obligation) will be included in the annual report.

Supplier risk

1. There is a risk that logistics companies do not comply with driving and rest time regulations and have an acceptable standard of living (HR24 and HR25)

Measures taken: We have agreements with logistics companies that confirm that they are in compliance with the law and we verify this. Supplier evaluation is updated to include requirements and confirm that they have no conflict with the UN Universal Declaration of Human Rights.

Further measures planned: We conduct annual audits of companies and spot checks of drivers.

2. There is a risk that steel wholesalers and steel mills supply materials and components produced in countries that do not respect human rights

Initiated measures: We have mapped our suppliers' potential risk. Our wholesalers are mainly located in Norway and subject to Norwegian law, but we deal directly with the steel mills from abroad. Our supplier evaluation has been updated to include human rights compliance requirements and our suppliers must confirm this.

Further measures planned: We conduct an annual audit of the company

3. There is a risk that suppliers of workwear receive materials and components produced in countries that do not respect human rights

Actions taken: The supplier evaluation has been updated to include requirements and confirm that they have no conflict with the UN Universal Declaration of Human Rights.

Further measures planned: We conduct an annual audit of the company

Responsible business: Integrity and environment


At Nordic Steel, we have a Code of Conduct that clearly emphasizes the values we stand for and what our rights and obligations are.  

We shall avoid conflicts of interest, bribery or improper benefits, in order to obtain or retain improper benefits. This is very important to us, our customers and business partners. In all circumstances, we will promote honesty, integrity, loyalty and fairness.


Nordic Steel is a sustainability leader in our industry - and sustainability is at the heart of our organization. We have an environmental management system and strict procedures for emissions, transportation and recycling of waste, to name a few. Our direct CO2 emissions are low, with energy-efficient buildings and machinery. We have no emissions to air or water. An important mission is to reduce indirect emissions. We do this by challenging customers and partners to make more environmentally friendly choices and to meet environmental requirements. As the first in Norway, we can offer the world's most sustainable stainless and acid-resistant steel to our customers, Circle Green from Outokumpu.

Responsible business protects human rights. That's what Nordic Steel does. It is important to us that our partners do the same.

No business partner risks related to human rights have been identified.

Strengths and weaknesses (SWOT analysis)


  • Well-implemented HSE system
  • Good legislation in Norway
  • Good working environment


  • No direct follow-up of wholesalers' steel suppliers abroad


  • Contribute to a better working day for more people


  • Losing key employees if this is not taken seriously

The way forward

Nordic Steel works strategically with working conditions, working environment and human rights with employees and suppliers. We will continue to do so.

By being open about internal risks and opportunities regarding human rights, it can help to contribute to better working conditions throughout the industry. We think that's very positive.

Our report on the Transparency Act (§5) is anchored in Nordic Steel's Board of Directors.

Get the Transparency Act 2023 in PDF

Download Report on the Transparency Act 2023

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