Norwegian Transparency Act 2024

Snøhetta is committed to comply with the requirements set out in The Norwegian Transparency Act relating to enterprises' transparency and work to respect fundamental human rights and decent working conditions (the “Transparency Act”) in own operations and in our value chain. This due diligence report covers the fiscal year of 2024, from 1 January to 31 December 2024. 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.

This due diligence report is provided by and covers Snøhetta AS (reg. no. 998 597 013) ("Snøhetta AS") and Snøhetta Oslo AS (reg. no. 995 135 485) (“Snøhetta Oslo”), both of which are subject to the Transparency Act.

In addition, the report includes the following subsidiaries of Snøhetta AS: Snøhetta Design AS (reg. no. 895 518 212) (“Snøhetta Design”), Snohetta Studio Innsbruck ZT GmbH (reg. no. 414572s) (“Snøhetta Innsbruck”), Snohetta Studio Paris SaS (reg. no. 834146623) (“Snøhetta Paris”), Snohetta Studio Hong Kong LTD (68672491) (“Snøhetta Hong Kong”), Snohetta Studio Shenzhen LTD (reg. no. 91440300MA5HEFUP4J) (“Snøhetta Shenzhen”) and Snohetta Australasia PTY LTD (reg. no. 74612295735) (“Snøhetta Australasia”).

The board of directors of Snøhetta AS and Snøhetta Oslo approved this report on 5 May 2025. The report is signed by Snøhetta AS’ and Snøhetta Oslo's board of directors.

For the purpose of this report, “Snøhetta Group” refer to the entire corporate group of Snøhetta AS and its subsidiaries, as further described below. 

Snøhetta Group is a transdisciplinary practice including architecture, landscape architecture, interior architecture, art, product design, graphic and digital design. Snøhetta AS is the parent company to all Snøhetta fully and partially owned subsidiaries, often referred to as studios, and has its home office in Oslo, Norway. The majority of services offered by Snøhetta are architectural building, landscape and interior services usually delivered directly to the client from the early stages of a project and up until or including architectural services in the construction phase. As such, Snøhetta does normally not have a contractual relationship with the providers carrying out the construction work as these are normally contracted by the client. In larger projects Snøhetta typically has one or several subconsultants providing consultancy services within other areas of expertise such as engineering.

Snøhetta Group consists of:

• Snøhetta AS functions as the ultimate holding company of the Snøhetta Group and manages the brand in addition to ensuring strategic and operational development of the studios. Apart from this, Snøhetta AS’ operations are primarily carried out through its operative studios. Snøhetta AS is located in Oslo.
• Snøhetta Oslo AS is based in Oslo and works in a wide variety of geographical regions, including in the Nordics, Europe, Africa, and the Middle East. Snøhetta Oslo is the largest studio in the Snøhetta Group and provides architectural services, including landscape and interior architecture, within a wide range of typologies, as well as product design services globally.
• Snohetta Studio Innsbruck ZT GmbH is based in Innsbruck, Austria. The studio has a broad multidisciplinary team within architecture, landscape architecture, interior architecture. This studio works in Austria, Northern Italy, Southern Germany and parts of eastern Europe. 
• Snohetta Studio Paris SaS is located in Paris and works in France, French Switzerland, and French Luxembourg. The studio has a multidisciplinary team within architecture and landscape architecture.
• Snohetta Studio Hong Kong LTD is located in Hong Kong and works across Asia. The studio has a broad multidisciplinary team within architecture, landscape architecture, interior architecture.
• Snohetta Studio Shenzhen Ltd is located in Shenzhen and works in China. The studio has a broad multidisciplinary team within architecture, landscape architecture, interior architecture.
• Snohetta Studio Adelaide (Snohetta Australasia PTY LTD) is located in Adelaide with a branch office in Melbourne, Australia and works across Australasia. The studio has a broad multidisciplinary team within architecture, landscape architecture, interior architecture, art curation and bespoke furniture design.
• Snøhetta Overseas Architecture AS – this company has partially been consolidated in Snøhetta Oslo. The studio holds contracts for ongoing work which is delivered by Snøhetta Oslo and will be closed once the contracts are fulfilled.
• Snøhetta Design AS is based in Oslo, and operates globally, both on individual design-specific projects and as part of architectural projects run by the architectural studios within the Snøhetta Group. Snøhetta Design offers consultancy services alongside graphic production and product delivery, including preparing files for printing or digital distribution, as well as designing and developing digital and graphic products and services. Projects include corporate branding, logo design, and other visual communication, design of printed materials like books, magazines, posters, and packaging, as well as wayfinding/signage systems, and digital projects such as web design and TV graphics.

In addition, Snøhetta AS has a brand trademark agreement with Snohetta Architecture Design Planning P.C. in New York.

Our efforts related to the Transparency Act are anchored with the board of directors of Snøhetta AS, 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, we have established policies, guidelines, and tools to ensure our commitment to respect and promote fundamental human rights and decent working conditions throughout the group. The routines are similar for all entities but are tailored to reflect the individual risk factors relevant for each company.

Within Snøhetta's own operations, we primarily work office based as architects and designers, in addition to support and administrative functions. As such, the risk of adverse impact on human rights and decent working conditions in our own operations is limited. 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. Snøhetta also has a variety of other 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 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. Our third-party code of conduct is communicated to our suppliers and clients setting out the minimum requirements that Snøhetta expects all third parties to meet to ensure that the third parties’ actions are consistent with Snøhetta’s values and ethical standards. This is further ensured through appropriate contract clauses, urging the suppliers to assess and mitigate the risk in their own operations and supply chains. Snøhetta has implemented routines for risk assessments of our supply chain, including background checks and appropriate follow up measures. The routines and process for the due diligence assessment of suppliers were updated and strengthened in 2024, including onboarding of a new third-party platform for conducting risks assessments of the suppliers and documenting the follow up measures such as self-assessment questionnaires and documentation of signed Third-Party Code of Conduct.

Further, Snøhetta has an online whistleblower portal on our website allowing individuals to report incidents or concerning behavior through an external platform. The platform is secure and allows whistleblowers to opt for complete anonymity. Any reports will be handled by Snøhetta AS, who will follow up confidentially. The whistleblower will have the opportunity to communicate with the case handlers in Snøhetta and provide more details about the incident throughout the process.

The management teams of Snøhetta AS, Snøhetta Oslo, Snøhetta Design, Snøhetta Innsbruck, Snøhetta Paris, Snøhetta Australasia, Snøhetta Hong Kong and Snøhetta Shenzhen are responsible for ensuring that the due diligence assessment relating to human rights and labor conditions in Snøhetta's operations and supply chain is performed. Risk assessment, evaluations, mitigating measures and tracking of suppliers and business partners are conducted on a continuous basis and followed up throughout Snøhetta’s projects and in our operations.

The risk factors applicable to Snøhetta in general are closely tied to the risks inherent to the architecture and design industry. In our projects, Snøhetta procures various architectural, engineering, consultancy and other specialist services, which are professions with typically reduced risk of labor violations, poor working conditions, and less physical labor. 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’s supply chain risks typically depend on the geographical location of the project. The risk of adverse impact on fundamental human rights and decent working conditions is considered most prominent for projects in Asia, Middle East and Southeast Europe. There is also a risk of financing with Russian funds, which is particularly relevant for suppliers in Eastern Europe and the Middle East. For relevant projects, we seek to mitigate this risk by conducting due diligence reviews and requiring confirmations from clients and suppliers that they are not subject to any applicable sanctions. Our due diligence process also includes a screening against sanction lists (EU, UN, OFAC, HM treasury), state ownership and several warning lists. Further, the security situation in the Middle East due to the ongoing war in Gaza and in Europe following the Russian invasion of Ukraine increases the risk for projects in these regions. Extended due diligence is carried out for potential projects in affected regions as well as in regions where there is a risk of funding from individuals, countries, and companies under sanctions.

The routine for due diligence is the same for all Snøhetta entities but is tailored to the relevant risk factors in each company. In 2024 we have updated the due diligence routine and implemented a new tool and is now using a third-party software platform to perform the risks assessment. Using a third-party tool for this reduces the risk of biases and individual dependency and ensures the credibility and objectivity of our assessments. The tool assesses risks based on their country of operations, industry, product risks and sanction lists.

Based on the risk assessment 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. If an elevated risk is identified, appropriate follow-up measures are initiated, including dialog, requesting further information of documentation from the supplier, and/or additional contractual obligations.

Some supplier categories such as local suppliers of office materials, cleaning services, cantina services and other administrative services are consistent for all of Snøhetta’s entities. In addition, the different entities’ supply chain varies and is connected to its operating activities and regions as described below.

1. Snøhetta AS
   Snøhetta AS' operations involve 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, Snohetta Studio Innsbruck ZT GmbH, Snohetta Studio Paris SaS, Snohetta Studio Hong Kong LTD, Snohetta Studio Shenzhen LTD and Snohetta Australasia PTY LTD
   
   The entities (Snøhetta Oslo AS, Snøhetta Studio Innsbruck ZT GmbH, Snøhetta Studio Paris SaS, Snøhetta Studio Hong Kong LTD and Snøhetta Studio Shenzhen LTD and Snohetta Australasia PTY LTD) primarily operate in the building, landscape and interior 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 project. We do acknowledge our responsibility to promote ethical business practices and expect our clients to follow similar standards to ethical procurement as those we follow in our own operations and expect from our suppliers.
   
   The studios mainly procure professional and advisory services from suppliers. The main consultancy services are engineering, architectural, design, acoustics, landscape, legal and IT services. As stated above, there is an increased risk related to suppliers in certain geographical regions, mainly Middle East, Southeast Europe and Asia. As we are almost exclusively dealing with professional services and service providers, the risk of negative impact on human rights or labor rights in our supply chain is, however, relatively limited also in such regions.
   
3. Snøhetta Design AS
   The risk of negative impact on human rights and working conditions is generally considered limited for Snøhetta Design. The industry is considered to generally carry low risk across project phases. The main services that Snøhetta Design procures are design, printing, digital development, and IT services. Similarly to the other studios, 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.

Risks of adverse impacts:

With the implementation of a new tool and process for our supply chain due diligence, including supplier risk assessments, we have identified a greater number of potential adverse impacts in our supply chain than compared to previous years. This increase is due to a stricter risk assessment methodology in place and because we have extended the process to all of Snøhetta AS’s subsidiaries, while we in previous years have performed the due diligence process for our Norway based entities.

1. Snøhetta AS
   We have not identified any risk of adverse impact in Snøhetta AS own operations or supply chain.
   
2. Snøhetta Oslo AS
   The majority of identified risks are linked to suppliers supporting Snøhetta Oslo AS’s projects in high-risk countries, particularly in the Middle East and Eastern Europe. While the risks associated with the industry, products, and services are considered low, the suppliers are flagged as high risk due to the regions in which they operate. We acknowledge that 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 and that we will not always be able to identify and mitigate the risk. The most prominent risk in these regions, as well as in Snøhetta’s other markets, include risk related to i) health, safety and environment (including work related accidents and injuries), ii) compliance with working time regulations, iii) ensuring workers receive an acceptable wage and iv) work-related crime.
   
   For our suppliers supporting our daily operations and offices, we have identified risks related to cleaning services for our office. In addition we have identified risks relating to certain construction activities, primarily relating to renovations that happened in our office building in Oslo.
   
   As a result of the increased number of suppliers that carry risk of adverse impact, follow-up measures have been implemented for a greater number of suppliers than in previous years, with a particular focus on dialogue, increasing the number of suppliers required to complete self-assessment questionnaires and sign our Third-Party Code of Conduct. 
   
3. Snohetta Studio Innsbruck ZT GmbH, Snohetta Studio Paris SaS, Snohetta Studio Hong Kong LTD, Snohetta Studio Shenzhen LTD and Snohetta Australasia PTY LTD
   
   As we have expanded the scope of our due diligence to include suppliers from our entities outside of Norway, some suppliers are automatically flagged as high risk due to the risk related to the supplier’s country of origin. The majority of high-risk suppliers for our non-Norwegian entities are in Asia. The risk related to industry, products and services provided is considered low. For our suppliers supporting our daily operations and offices, we have identified risks related to cleaning services for our offices.
   
   We continue our efforts to carefully carry out due diligence reviews for suppliers in all regions. As of the date of this report, we have not identified any risk of adverse impact in our own operations in Snohetta Studio Innsbruck ZT GmbH, Snohetta Studio Paris SaS, Snohetta Studio Hong Kong LTD, Snohetta Studio Shenzhen LTD or Snohetta Australasia PTY LTD

Actual adverse impacts:

1. Snøhetta AS
   We have not identified any actual adverse impact in Snøhetta AS’ own operations or supply chain.
   
2. Snøhetta Oslo AS
   With the implementation of a new system and routine for due diligence, a greater number of Snøhetta Oslo AS’ suppliers have been requested to complete self-assessment questionnaires. Through these questionnaires, we have identified a few instances of violations related to the ILO Convention concerning the right to paid holidays. In response, we are implementing mitigation actions, which include engaging in dialogue with the suppliers and communicating our expectations to them as one of our business partners. We believe that open dialogue and clearly communicating our expectations can raise awareness and build knowledge among suppliers, encouraging them to take action toward aligning with international standards and our expectations. We also recognize that this is a long-term process, and meaningful change takes time, commitment, and ongoing engagement. As of the date of this report, Snøhetta Oslo AS has not identified any actual adverse impacts in our own operations.
   
3. Snohetta Studio Innsbruck ZT GmbH, Snohetta Studio Paris SaS, Snohetta Studio Hong Kong LTD, Snohetta Studio Shenzhen LTD and Snohetta Australasia PTY LTD
   
   We have not identified any actual adverse impact in the supply chain or own operations of Snohetta Studio Innsbruck ZT GmbH, Snohetta Studio Paris SaS, Snohetta Studio Hong Kong LTD, Snohetta Studio Shenzhen LTD or Snohetta Australasia PTY LTD.

Tools and routines: 

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 respect and promote fundamental human rights and decent working conditions. Based on the outcome of the risk assessments we implement the measures we consider necessary and appropriate based on the risk of adverse impact or actual adverse impact 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, signing of our third-party code of conduct and contract clauses, consultation of internal key functions and/or 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 and discretion to implement relevant measures.

Measures implemented in 2024:

Since the last reporting date, Snøhetta Group has, as previously mentioned in this report, updated its routines and tools for performing the due diligence of suppliers. In previous years, we have followed a due diligence process and routine in our Norway based companies and in 2024 we implemented the process for all Snøhetta AS’ subsidiaries. With the implementation of the due diligence routine in all entities we have taken a risk-based approach and started performing the due diligence on the largest procurements and purchases. We have included our third-party code of conduct in new supplier agreements, an effort that will continue going forward. Although it is challenging to get foreign organizations to bind themselves to Norwegian laws that they are not familiar with, we find that given enough time it is possible in most instances. With the updated routine, tool and process for conducting supplier due diligence we have also taken steps to raise awareness on ethical procurement internally and conducted trainings on the new routine and process. Updated routines and tools have enabled the identification of more risks of and actual adverse impact in our supply chain, which are now being addressed. The implementation of third-party code of conduct in all our studios, along with increased awareness of Norwegian regulatory requirements, is expected to influence and improve practices abroad, both in our own operations and among our suppliers.

As the due diligence process is an ongoing operation, our efforts will continue towards the next reporting date. We aim to improve the due diligence process of our own operations and supply chain and contributing to the promotion of human rights and decent working conditions. Particularly, we will focus on mitigating the risk of adverse impacts for suppliers in high-risk countries, as identified through our risk assessment.

Until 2024 the Norwegian entities in the Snøhetta Group were prioritised due to a risk-based approach and to secure a best possible implementation of the due diligence procedures. With these procedures being extended to Snøhetta's foreign subsidiaries in 2024, there will be a strong focus on these entities going forward, particularly on continued training and awareness on the new routines both internally and externally to ensure proper compliance. By continuously refining our due diligence processes, we expect to enhance both the effectiveness and reach in promoting human rights and decent working conditions.