Code of Conduct

At Norrøna Sport AS (hereafter referred to as Norrøna) we promote decent working conditions and environmental standards in our supply chain. Norrøna commits to upholding the principles and standards contained in the OECD Guidelines for Multinational Enterprises on Responsible Business Conduct (OECD Guidelines), and as a member of Fair Wear, we commit to Fair Wear Code of Labour practices and standards.

Fair Wear Code of Labour Practices form the basis of our collaboration. It outlines the minimum standards expected of our suppliers and business partners. By applying Fair Wear Code of Labour Practices, suppliers must comply with national and other applicable laws. Where the provisions of the laws and Norrønas Code of Conduct address the same subject, the provision that gives the workers greater protections prevails.

The Norwegian Transparency Act which came into force on 1 July 2022. The Act makes it mandatory for large and medium sized companies to conduct human rights due diligence (HRDD) throughout their supply chain, in accordance with the OECD Guidelines for Multinational Enterprises. This requires that Norwegian companies, such as Norrøna, commit to responsible business practices and embed this responsibility into policies and management systems; this includes identify and assess adverse impacts in our operations, supply chains and business relationships; cease, prevent or mitigate these adverse impacts; track implementation and results of the measures; communicate how impacts are addressed; and provide for, or cooperate in remediation when appropriate.

This Code of Conduct reflects our expectations and requirements of our business partners, and our commitment to respect and promote internationally agreed standards covering human rights, workers’ rights, corruption and protection of the environment and animal rights.

Norrøna’s suppliers are to supply goods and services that are produced in compliance with this Code of Conduct. Moreover, the suppliers are to communicate the code of conduct to their sub suppliers, and to monitor implementation.

Norrøna is dependent on our close relationships and transparency with our partners to ensure this, and we must obtain credible documentation of the whole supply chain.

• A supplier must be able to document compliance with the Code of Conduct at Norrøna’s request. Such documentation may take the form of self-declaration, follow-up meetings, and/or inspections of the working conditions at production sites. The supplier will be obliged to name and provide contact information for any sub-supplier that Norrøna wishes to inspect.
• Norrøna believes in co-operation and in cases of non-compliance with the requirements, and will always seek collaboration in order to achieve the standards of this Code of Conduct. Both in cases where the minimum standards cannot be met immediately, and in cases where these are already met, the supplier should work to continuously improve, and communicate openly about this with Norrøna.
• The supplier must immediately report all incidences and violations / breaches of the Norrøna Code of Conduct to the CSR responsible in Norrøna by email or phone.
• Remediation must take place within a reasonable period of time. The contract will only be terminated if the supplier remains unwilling to remedy the breach following repeated enquiries and if corrective action is not taken within the agreed limit.

The Code of Conduct is based on key UN international regulation set by the International Labour Organisation( ILO) and the UN Universal, Declaration of Human Rights, and the Code of Labor Practices by Fair Wear Foundation

(ILO Conventions Nos. 29 and 105)

1.1 There shall be no forced, bonded or involuntary prison labor.

1.2 Workers shall not be required to lodge deposits or identity papers with their employer and shall be free to leave their employer after reasonable notice.

(ILO Conventions Nos. 87, 98, 135 and 154)

2.1 Workers, without distinction, shall have the right to join or form trade unions of their own choosing and to bargain collectively. The employer shall not interfere with, or obstruct, the formation of unions or collective bargaining.

2.2 Workers representatives shall not be discriminated against and shall have access to carry out their representative functions in the workplace.

2.3 Where the right to freedom of association and/or collective bargaining is restricted under law, the employer shall facilitate, and not hinder, the development of alternative forms of independent and free workers representation and negotiations. The identity and contact details of the representative can be requested by Norrøna.

(ILO Conventions Nos. 138, 182 and 79, and ILO Recommendation No. 146)

3.1 The minimum age for workers shall not be less than 15 and comply with i) the national minimum age for employment, or; ii) the age of completion of compulsory education, whichever of these is higher. If the local minimum is set at 14 years in accordance with developing country exceptions under ILO Convention 138, this lower age may apply.

3.2 There shall be no recruitment of child labour defined as any work performed by a child younger than the age(s) specified above.

3.3 No person under the age of 18 shall be engaged in labour that is hazardous to their health, safety or morals, including night work.

3.4 Policies and procedures for remediation of child labour prohibited by ILO conventions no. 138 and 182, shall be established, documented, and communicated to personnel and other interested parties. Adequate support shall be provided to enable such children to attend and complete compulsory education.

(ILO Conventions Nos. 100 and 111 and the UN Convention on Discrimination against Women)

4.1 There shall be no discrimination at the workplace in hiring, compensation, access to training, promotion, termination or retirement based on ethnic background, religion, age, disability, gender, marital status, sexual orientation, union membership or political affiliation.

4.2 Measures shall be established to protect workers from sexually intrusive, threatening, insulting or exploitative behavior, and from discrimination or termination of employment on unjustifiable grounds, e.g. marriage, pregnancy, parenthood or HIV status.

5.1 Workers shall be treated with respect and dignity. Physical abuse or punishment, or threats of physical abuse, sexual or other harassment and verbal abuse, as well as other forms of intimidation, is prohibited.

(ILO Convention No. 155 and ILO Recommendation No. 164)

6.1 The working environment shall be safe and hygienic, bearing in mind the prevailing knowledge of the industry and of any specific hazards. Hazardous chemicals and other substances shall be carefully managed. Adequate steps shall be taken to prevent accidents and injury to health arising out of, associated with, or occurring in, the course of work, by minimising, so far as is reasonably practicable, the causes of hazards inherent in the working environment.

6.2 Workers shall receive regular and documented health and safety training, and such training shall be repeated for new or reassigned workers.

6.3 Access to clean toilet facilities, to potable water and, if appropriate, sanitary facilities for food storage shall be provided.

6.4 Accommodation, where provided, shall be clean, safe and adequately ventilated, and shall have access to clean toilet facilities and potable water.

6.5 Access to clean eating areas shall be provided. If the factory provides food for its workers, the canteen, in which the food is stored and prepared, must be located separately from the production area and also be clean and in a good condition.

(ILO Convention No. 131, ILO Convention No.95 )

7.1 Wages and benefits paid for a standard working week shall at minimum meet national legal standards for industry benchmark standards, whichever is higher. Wages should always be enough to meet basic needs, including some discretionary income.

7.2 All workers shall be provided with a written and comprehensible contract outlining their wage conditions and method of payments before entering employment.

7.3 Deductions from wages as a disciplinary measure shall not be permitted.

7.4 Deductions from wages shall be permitted only under conditions described in ILO convention No.95

7.a Living wage

All workers should earn a living wage. Where compensation does not meet workers’ basic needs and provide some discretionary income, Norrøna is committed to working towards implementing a living wage for the workers within our supply chains. We also expect our partners to join us in this collaborative effort to ensure fair compensation for all workers.

(ILO Convention No.1 and 14)

8.1 Working hours shall comply with national laws and benchmark industry standards, and not more than prevailing international standards. Weekly working hours should not on a regular basis be more than 48 hours.

8.2 Workers shall be provided with at least one day off for every 7 day period.

8.3 Overtime shall be limited and voluntary. Recommended maximum overtime is 12 hours per week, i.e. that the total working week including overtime shall not exceed 60 hours. Exceptions to this are accepted when regulated by a collective bargaining agreement.

8.4 Workers shall always receive overtime pay for all hours worked over and above the normal working hours (see 8.1 above), minimum in accordance with relevant legislation.

9.1 Obligations to employees under international conventions, national law and regulations concerning regular employment shall not be avoided through the use of short term contracting (such as contract labour, casual labour or day labour), sub-contractors or other labour relationships.

9.2 All workers are entitled to a contract of employment in a language they understand.

9.3 The duration and content of apprenticeship programs shall be clearly defined.

10.1 Production and the use of natural resources shall not contribute to the destruction and/or degradation of the resources and income base for marginalized populations, such as in claiming large land areas, use of water or other natural resources on which these populations are dependent.

11.1 Measures to minimize adverse impacts on human health and the environment and nature shall be taken throughout the value chain. This includes minimizing pollution, and promoting an efficient and sustainable use of resources, including energy and water, forest and land. The local environment at the production site shall not be exploited or degraded.

11.2 We expect our partners to measure, share data and minimize greenhouse gas emissions in production and transport, and work actively to transform from fossil fuel to cleaner energy.

11.3 National and international environmental legislation and regulations shall be respected and relevant discharge permits obtained. 11.4 Our manufacturers and suppliers must follow the REACH regulations (EU) Nr. 1907/2006,and as well as agree to and strictly adhere to the Bluesign Restricted Substance List(BSRSL).

11.5 We define sustainable materials according to the Norrøna Purchasing terms guide and Norrøna Roadmap.

12.1 Corruption in any form is not accepted, including bribery, extortion, kickbacks and improper private or professional benefits to customers, agents, contractors, suppliers or employees of any such party or government officials.

13.1 Norrøna is strongly against mistreatment of any animals. Ethical aspects such as traceability, sustainability, safety, animal welfare, and labor and farm conditions will be taken into account when choosing suppliers of animal fibers.

13.2 Leather products shall be manufactured using only the skins of utility animals such as pigs, sheep, goats and cows, where the animals have been originally slaughtered for the meat market.

13.3 Down shall be picked from dead birds only which are by-products from the food industry. And all down or feathers used in Norrøna products should be either recycled or certified in accordance with Responsible Down Standard (RDS).

13.4 Norrøna will not allow any use of fur, from animals, in the production of Norrøna products.

13.5 The use of unethical and inhumane production processes such as mulesing is prohibited. Norrøna does not accept clips as an alternative to mulesing.

13.6 Norrøna does not allow animal testing.

The management system is the key to the implementation of the code of conduct. Norrøna emphasizes the importance of suppliers having systems that support such implementation. Norrøna’s expectations in this regard are summed up in the following measures:

• The supplier must conduct human rights due diligence. This involves; conducting risk assessments to identify potential negative impact on people, society and the environment and to stop, prevent and reduce such impact. The measures put in place must be monitored and their effect evaluated. The measures taken must be communicated to those affected by your actions. If the supplier is responsible for the negative impact/damage, they are responsible for providing remedy.
• The supplier should make a centrally placed employee responsible for the implementation of the code of conduct in the supplier’s business. The supplier must make the code of conduct known in all relevant parts of its organisation.
• The supplier must obtain Norrøna’s consent prior to outsourcing production or parts of production to a sub-supplier/contractor.
• The supplier must provide details about the entire value chain, including the supplier's name, used in our production supply chain, and country of origin, through Norrøna Material Information Sheet (MIS) or an equivalent template intended for this purpose.
• The suppliers are to provide scope certificates across the full value chain for each relevant production process of which the supplier is responsible.

The supplier is required to maintain an efficient management system for addressing complaints related to human rights, workers' rights, environmental concerns, and corruption. It is essential that both workers and external stakeholders, such as local communities and civil society organizations, have the ability to lodge complaints.

As a member of Fair Wear, we mandate that all our tier 1 suppliers make the Fair Wear code of labor practices and Fair Wear helpline accessible and known to workers. This ensures that workers have a reliable channel through which they can report any grievances or concerns.

Norrøna reserves the right that we, or representatives appointed by Norrøna will have free access to the production plant, with or without prior notification. Such representatives must document a signed approval from Norrøna. Audit standards and methods will be carried out in accordance with Norrøna Code of Conducts, and Fair Wear Code of Labour Practices. Suppliers to Norrøna are strongly encouraged to report annually through the Higg Facility Environmental Module (Higg FEM) and the The Facility Social & Labor Module (FSLM)reporting system.

• The factory shall have an assigned person with health and safety responsibility.
• Medical kits shall be available at the production site within a reasonable distance and each floor or workshop shall have at least one medical kit. In each factory location there shall be a person trained in basic first aid.
• The factory shall have routines for handling serious injuries requiring outside medical attention.
• There shall be sufficient numbers of fire extinguishers in the premises. Fire extinguishers and fire hoses shall be maintained and in proper working order. They shall be easily visible and accessible to all workers.
• The factory shall have a sufficient number of exits for an emergency, and these shall remain unlocked and free from obstruction in case of a fire or other emergency situation.
• Machines shall have satisfactory safety devices which are properly maintained.
• Workers shall be equipped with personal safety gear at no personal cost; this includes ear protection in areas with high noises.
• The lightning must be sufficient so as to ensure a safe working environment.
• Factories shall have proper ventilation, windows, fans, air conditioning and/or heating in all workplaces, so that the circulation, ventilation and temperature requirements are met.
• The factory shall ensure the noise level is acceptable and the lightning adequate.

• Dormitories shall be single sex unless premises for families are available.
• Workers shall have their own single beds or sleeping pads. The space for each worker must be in compliance with local laws.
• Everyone shall have their own lockable storage facility for clothes and personal belongings in relation to their sleeping area.
• There must be a sufficient number of toilets and showers (single sex). These must be maintained, easily accessible, safe, hygienic and located separately from the dormitories. There shall be washing facilities within a reasonable distance.
• Fire extinguishers shall be in proper working condition and maintained. They shall be easily visible and accessible for all workers. There shall be sufficient number of exits, and these shall remain unlocked and free from obstruction in case of a fire or other emergency situation.
• There shall be proper ventilation, windows, fans and/or air conditioning/heating apparatus in all dormitories so as to ensure proper circulation, ventilation and temperature.
• Those living on the premises must be able to come and go as they please in their own time, within reasonable limits due to security and comfort.
• Cost for the workers using the dormitories shall be reasonable according to the standard of the premises and salary.
• The dormitories shall have adequate lighting.
• Washing facilities shall be available for workers living on the premises.