Norwegian Transparency Act 2022

Due diligence report

1 Introduction

Snøhetta is committed to comply with the requirements set out in The Norwegian Act relating to enterprises' transparency and work on fundamental human rights and decent working conditions (the “Transparency Act”). This due diligence report covers the fiscal year of 2022, from 1 January to 31 December 2022. The report is prepared and provided by Snøhetta pursuant to Section 5 of the Transparency Act.

At the heart of all Snøhetta’s work lies a commitment to social sustainability, shaping the built environment in the service of humanism. We know that with well-conceived design we can help things run more efficiently, improve people’s well-being, and make life more enjoyable. To achieve this, Snøhetta creates generous designs that respect the character of each project’s unique preconditions such as climate, people, culture, and history.

2 Reporting entities

This joint due diligence report is provided by and covers Snøhetta AS (reg. no. 998 597 013) ("Snøhetta AS"), Snøhetta Oslo AS (reg. no. 995 135 485) (“Snøhetta Oslo”), and Snøhetta Design AS (reg. no. 895 518 212) (“Snøhetta Design”). The board of directors of Snøhetta AS, Snøhetta Oslo AS and Snøhetta Design AS approved this report on 15 June 2023.

For the purpose of this report, all descriptions of "Snøhetta" refers to the corporate group of the three abovementioned entities, whereas information regarding specific entities in the corporate group is specified with separate subsections.

3 Corporate structure and operations

1. General information

Snøhetta is a transdisciplinary practice including architecture, landscape architecture, interior architecture, art, product design, graphic and digital design. With studios in Oslo, New York, San Francisco, Paris, Innsbruck, Hong Kong, Shenzhen, Adelaide and Melbourne, Snøhetta employs approximately 350 employees.

Snøhetta AS, Snøhetta Oslo and Snøhetta Design all have their registered office at Akershusstranda 21, 0150 Oslo, Norway.

2. Snøhetta AS

Snøhetta AS functions as the ultimate holding company of the Snøhetta group. Snøhetta AS’ operations are primarily carried out through its operative subsidiaries, often referred to as studios, including Snøhetta Oslo and Snøhetta Design, which are wholly owned subsidiaries of Snøhetta AS.

3. Snøhetta Oslo AS

Snøhetta Oslo is based in Oslo but operates globally and has ongoing projects in a wide variety of geographical regions, including in the Nordic region, Europe and the Middle East. Snøhetta Oslo provides architectural services within a wide range of typologies, as well as product design services globally.

4. Snøhetta Design AS

Snøhetta Design is, like Snøhetta Oslo, based in Oslo, but operates globally. Snøhetta Design offers design services to customers, either directly or as part of projects run by the architectural studios in the Snøhetta group.

4 Governance framework

Our efforts related to the Transparency Act are anchored with the board of directors in Snøhetta AS, Snøhetta Oslo and Snøhetta Design, setting the "tone from the top" within each entity as well as establishing it as a prioritized area for Snøhetta. To ensure that social sustainability is implemented in our operations, Snøhetta AS, Snøhetta Oslo and Snøhetta Design have established various policies, guidelines, and tools to ensure our commitment to respect and promote fundamental human rights and decent working conditions. The routines are similar for all three companies but are tailored to reflect the individual risk factors relevant for each company.

Within Snøhetta's own operations, we primarily work office based as consultants. The risk for adverse impacts on human rights and decent working conditions in our own operations is limited. However, we are committed to ensure a safe and healthy working environment. This is enforced through our health and safety policies, whistle blower channel, code of conduct and other relevant measures. Snøhetta also has a variety of policies and statements in place, communicating our commitment and approach to collaboration; environment; equality, diversity, and inclusion; quality management; and sustainability. Further, Snøhetta has adopted a human rights policy which stipulates our ambition and commitment to ensure respect and promotion of fundamental human rights and working conditions in our operations, supply chain and business relationships.

In relation to our supply chain, Snøhetta has established an internal third-party management routine which sets out the procedure for how Snøhetta seeks to ensure control over our supply chain and mitigate the risk of breach of fundamental human rights and decent working conditions. Requirements are communicated to all our suppliers through our third-party code of conduct which sets out the minimum requirements that Snøhetta expects all third parties to meet to ensure that their actions are consistent with Snøhetta’s values and high ethical standards. This is further ensured through appropriate contract clauses, which require the suppliers to assess the risk in their own supply chains. Snøhetta has also implemented routines for risk assessments of our supply chain, including background checks and appropriate follow up measures and audits during the contractual relationship.

5 Risk factors and risk management

The management teams of Snøhetta AS, Snøhetta Oslo and Snøhetta Design are responsible for performing assessment of risk relating to human rights and labor conditions in Snøhetta's operations and supply chain. Risk assessment, evaluations, mitigating measures and tracking of suppliers and business partners are conducted on a continuous basis and followed up throughout each of Snøhetta’s projects.

The risk factors applicable to Snøhetta in general are closely tied to the risks inherent to the architecture and design industry, as further described below.

Snøhetta’s supply chain risks typically depend on the geographical location of the project. The risk of breach of fundamental human rights and decent working conditions is considered most prominent for projects in the Middle East and Southeast Europe. There is also a risk of financing with Russian funds, which is particularly relevant for suppliers in Eastern Europe. Further, the security situation in Eastern Europe following the Russian invasion of Ukraine increases the risk for projects in this region.

In our projects, Snøhetta procures various architectural, engineering, consultancy and other specialist services from highly skilled companies and highly educated professionals within their respective fields. This reduces the risk in our supply chain. Additionally, most of our services are carried out in the early phases of a project, further reducing risk in the supply chain.

Snøhetta AS, Snøhetta Oslo and Snøhetta Design conduct due diligence of our own operations and supply chain. The routine for such due diligence is similar for all three companies but is tailored to the relevant risk factors in each company. For the due diligence review of Snøhetta’s suppliers we are mapping our supply chains through a risk classification tool. The tool is used to assess the risk related to suppliers based on factors such as the supplier’s nationality, industry, operating risk, use of sub-contractors, and internal routines.

Based on the mapping we categorize our suppliers as either low, medium, or high-risk suppliers. The classification determines whether further investigations should be carried out prior to the contractual relationship, and how Snøhetta approaches its relationship with the respective supplier. The assessments are carried out on a continuous basis and applies to both existing and new suppliers. Local suppliers of office materials, cleaning services, food services etc. apply to all companies. In addition, each company has particular supply chain connected to its activities.

1. Snøhetta AS

Snøhetta AS' operations is managing and developing the Snøhetta brand, its overall operations and the company's subsidiaries. Its supply chain is limited, consisting mainly of administrative support functions and subscriptions of joint technical solutions.

2. Snøhetta Oslo AS

Snøhetta Oslo primarily operates in the architecture industry, an industry in which the risk varies in the different phases of a project. The risk of negative impact on human rights and working conditions is considered most prominent in the construction phase, whereas the risk is significantly lower in the design phase. The actual construction is not a service supplied to Snøhetta, but directly to the client/owner of the relevant development.

Snøhetta Oslo mainly procures professional services from suppliers. The main consultancy services that Snøhetta Oslo procures from are engineering, architectural, design, acoustics, landscape, and IT services. As stated above, there is an increased risk related to suppliers in certain geographical regions. As we are almost exclusively dealing with professional services, the risk of negative impact on human rights in our supply chain is, however, relatively limited.

3. Snøhetta Design AS

The risk of negative impact on human rights and working conditions is generally considered to be limited for Snøhetta Design. The industry is considered to generally carry low risk across project phases.

Snøhetta Design mainly procures professional services from suppliers. The main consultancy services that Snøhetta Design procures from are design, printing, digital development, and IT services. As for Snøhetta Oslo, Snøhetta Design’s supply chain risk is also tied to the region in which the suppliers are located, and we experience increased risk with suppliers in the Middle East, Southeast Europe and the Asia Pacific.

6 Identified adverse impacts and mitigating measures

As of the date of this report, Snøhetta has not identified any actual adverse impacts in the due diligence review of our suppliers.

Snøhetta implements appropriate measures on a risk-based approach and based on the principle of proportionality. We want to use our position and our influence to ensure and promote respect for fundamental human rights and decent working conditions. Based on the outcome of the risk analysis we will implement the measures we consider necessary and appropriate based on the actual and potential risk identified.

As the due diligence review of our supply chain is being conducted on a continuous basis, we will concurrently assess whether and to what extent measures should be implemented towards our suppliers. Such measures may include dialogue with suppliers, background checks, audits, signing of third-party code of conduct and contract clauses, consultation of internal key functions and external advisors, further due diligence reviews and obtaining additional information and documentation from the suppliers. If significant risk or breach of human rights and decent working conditions is identified, measures may also include termination of the contractual relationship with the respective supplier. The measures will set clear expectations to the conduct of Snøhetta's suppliers, as well as increase Snøhetta's control over the supplier and discretion to implement relevant measures.

7 Going forward

As the human rights due diligence is an ongoing operation, our efforts will continue towards the next reporting date. We hope to make a positive impact on our own operations and our supply chain, and to contribute to ensure human rights and decent working conditions.

It is Snøhetta's intention to strengthen the due diligence procedures in Snøhetta's foreign subsidiaries. For the fiscal year of 2022, the Norwegian entities in the Snøhetta company group were prioritised due to a risk-based approach and to secure a best possible implementation.

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