The Norwegian Transparency Act: An Assessment of Supply Chain Human Rights Due Diligence

The Norwegian Transparency Act, adopted in 2021, requires companies to undertake due diligence regarding human rights in their operations and global supply chains and disclose their efforts publicly. The authors assess compliance with the Transparency Act through a granular analysis of the mandatory accounts of due diligence published by a sample of 50 Norwegian consumer goods companies. Coding information from these accounts, the authors construct three indexes: minimum compliance, supply chain risk analysis, and due diligence program elements, to provide a descriptive analysis of corporate reporting under the Transparency Act. They find company performance is, at best, mediocre, and suggest that these accounts of due diligence do not provide enough information regarding risks to human rights in supply chains. The implications for improving compliance are discussed.