The Norwegian Transparency Act
1. The company´s report pursuant to the Transparency Act 2024
1.1 INTRODUCTION
This statement has been prepared in accordance with the requirements of Section 5 of the Norwegian Transparency Act concerning enterprises’ transparency and work on fundamental human rights and decent working conditions ("the Transparency Act").
Fjord Line AS is a limited liability company owned indirectly by Ferd AS, Kontrari AS and West Coast Invest AS. The company is a large enterprise with headquarter at Elganeveien 1, 4373 Egersund in Norway and with offices in Hirtshals, Bergen, Stavanger, and Kristiansand. Fjord Line provides services both within and outside of Norway. The provisions of the Transparency Act apply to Fjord Line. In line with the requirements of the Act, Fjord Line conducts due diligence assessments to identify potential and actual adverse impacts on fundamental human rights and decent working conditions.
This statement applies to Fjord Line AS, Fjord Lines parent company and Fjord Lines subsidiaries (referred to together as “Fjord Line”). Please see the appendix on page 15 for an overview of which companies are included. The statement encompasses the company’s own operations, suppliers, and business partners (referred to as suppliers hereafter). The statement covers the period from January 2024 to December 2024.
The statement is based on information collected from the company’s own operations, information from suppliers, and recognized publicly available sources.
The statement has been approved and signed by the members of the board of directors and Fjord Line Holding AS, Fjord Line AS and the group CEO of Fjord Line. The statement will be available on Fjord Line’s website and will be updated on an ongoing basis if there are significant changes to Fjord Line’s risk assessments. A reference to the statement is also included in Fjord Line’s 2024 annual report.
1.2 CONTACT INFORMATION
Any inquiries in connection with this report can be directed to: transparency@fjordline.com
In line with the requirements of the Act, Fjord Line conducts due diligence assessments to identify potential and actual adverse impacts on fundamental human rights and decent working conditions.
1.3 DUTY TO ACCOUNT FOR THE DUE DILIGENCE
The Fjord Line companies subject to reporting requirements are Fjord Line Holding AS and Fjord Line AS. All group companies are however included in the due diligence assessments to ensure a comprehensive evaluation. Only Fjord Line AS and Fjord Line Denmark A/S are operating companies with employees.
Fjord Line operates the cruise-ferry vessels MV Bergensfjord and MV Stavangerfjord, sailing between Bergen, Stavanger, Hirtshals, and Kristiansand, and HSC Fjord FSTR sailing between Kristiansand and Hirtshals. All vessels fly the Danish flag (DIS). Until October 2023 Fjord Line also operated the vessel MV Oslofjord between Sandefjord and Strömstad. MV Oslofjord was sold in May 2024.
Fjord Line's 642 employees transported 886.402 passengers and 48.562 freight units between Norway and Denmark in 2024. Being a link between Norway and Europe has always been important throughout Fjord Line’s history. We are proud of the role Fjord Line plays in society by providing services between coastal communities and in connecting Norway and Continental Europe.
2. About the company´s operations
2.1 THE COMPANY'S ORGANISATION AND AREA OF OPERATIONS
The company is organised as a Group with Fjord Line Holding AS as parent company, Fjord Line AS as commercial operating entity, Fjord Line Denmark A/S as shipping company and Danish subsidiaries as vessel owning companies. Organisational chart for the group is attached to this report.
As the second largest cruise ferry company in Norway, Fjord Line provides passenger and freight transport services between Norway and Denmark. The company operates a modern fleet of vessels powered by more sustainable fuel alternatives, including LNG (liquefied natural gas), and is committed to reducing emissions and promoting green maritime transport.
Fjord Line places a strong focus on safe and decent working conditions, fair labor practices, and environmental performance. As a company with complex maritime and international supply chains, Fjord Line is aware of the potential risks associated with procurement and subcontracting, particularly in areas involving manufacturing, shipbuilding, textiles, food and beverage supply, and technology. The company has implemented a due diligence framework aligned with the Norwegian Transparency Act, including supplier screening, risk prioritization, and preventive and corrective measures.
Fjord Line’s commitment to responsible business conduct is reflected in its sustainability policy, supplier code of conduct, and engagement with stakeholders to promote respect for human rights and decent labor standards throughout its operations and supply chain.
2.2 CODE OF CONDUCT
Fjord Line has established internal procedures for embedding respect for human rights and decent working conditions, in line with and anchored in the Fjord Line Code of Conduct, which is attached to this report. The Code of Conduct was revised and formally adopted by the company’s Board of Directors on 30 April 2025. It has been communicated to all employees and is readily accessible via the company’s intranet.
The Code of Conduct also contain information about the company's whistleblowing channels that are meant to uncover adverse impact on fundamental human rights and decent working conditions linked with the company's activities.
Fjord Line places a strong focus on safe and decent working conditions, fair labor practices, and environmental performance.
2.3 AMBITIONS AND PROGRESS
2.3.1 Overall ambitions and progress
Fjord Line works continuously on assessment of risks related to the company's activities and make use of our business contacts (suppliers and business partners) in this respect. Furthermore, the company works continuously on implementing measures to achieve the ambitions set by the company. See items 3 and 4 of the report for guidance on the work done in the reporting year.
2.3.2 Ambitions for the coming year
We have set several concrete ambitions for the future. For instance, there is an ongoing effort to further improve our due diligence process. As part of this work, we have developed customized questionnaires to be sent to selected business partners in order to collect additional information. Furthermore, we are continuously working to obtain signed Supplier Codes of Conduct from all key suppliers. We aim for exceptions to be made only if a supplier presents an equivalent and satisfactory Code of Conduct that we can rely on.
3. The due diligence
3.1 FOCUS FOR THE COMPANY’S DUE DILIGENCE
Fjord Line continuously makes assessments of the risk of adverse impact on fundamental human rights and decent working conditions linked with the company's activities and business relationships. The company continuously tracks any violations of human rights or violations of decent working conditions that is connected with the company's activities. The company’s activity refers to both the company’s own operations and the activities of its suppliers and business partners.
In the mapping work, Fjord Line utilizes a digital platform developed by Ignite Procurement AS. The platform simplifies the implementation of due diligence assessments in accordance with the requirements of the Transparency Act. Through the platform, Fjord Line has obtained a systematic overview of first-tier suppliers, business partners, and other known subcontractors. Based on this overview, the platform has conducted initial assessments of the risk of negative impact on fundamental human rights and decent working conditions. The steps in this assessment are explained in the following:
1. Based on supplier data obtained from Fjord Lines ERP system (Microsoft Dynamics), a complete overview of the company's firsttier suppliers is created. The company has manually added business partners and other known subcontractors in the platform. The overview of the company's first-tier suppliers is continuously updated through the platform.
2. In the platform, supplier information is enriched through thirdparty collaborations. The platform gathers information and financial details about the company's suppliers, such as industry codes (NACE) and company structure.
3. Through steps 1 and 2, the company obtains an overview of firsttier suppliers, business partners, and other known subcontractors, along with their corresponding supplier information.
4. The classification tool in the platform has conducted an initial risk classification of the company's first-tier suppliers, business partners, and other known subcontractors based on classification rules created within the platform. In the ignite tool the classification rules are as follows: industry risk, social risk and geography risk. In addition, Head of Procurement has included acceptance of Fjord Lines Supplier code of conduct as a parameter for the company’s assessment. Through the classification tool, suppliers that meet defined risk parameters are classified as having high, medium, or low risk of negative impact on fundamental human rights and decent working conditions.
Through the platform, Fjord Line has obtained a systematic overview of first-tier suppliers, business partners, and other known subcontractors.
5. Manual assessments and evaluations are conducted for suppliers which are considered high risk. The company can also use the platform to request documentation and certifications from firsttier suppliers, business partners, and other known subcontractors. This procedure is in process of being implemented.
6. Based on the findings in points 4 and 5, the company has assessed which actions should be taken to investigate potential negative consequences for fundamental human rights and decent working conditions. The prioritization is aligned with the company's connection to and responsibility for the risk and should be proportionate to the size, nature, and context of the business.
7. The company has involved stakeholders, suppliers, and business partners in the implementation of actions.
In the analysis tool within the platform (interactive dashboard), analyses of the supply chain have been developed based on supplier data, the outcome of risk classification, and gathered information from the supply chain. In section 3.2, the following information generated by the analysis tool in the platform is provided:
a. The number of first-tier suppliers, business partners, and other known subcontractors.
b. Further classification of the company's first-tier suppliers, business partners, and other known subcontractors based on risk profiles high, medium, and low.
Relevant factors for the due diligence related to the company's activities and business conditions include, among other things:
• The context of the company’s operations
• The company's business model
• The company’s position in the supply chain
• The type of product and services
We have in 2024 not identified any significant risk of adverse impact on human rights or decent working conditions nor uncovered violations of human rights or decent working conditions through the company's due diligence assessments.
3.2 THE DUE DILIGENCE ASSESSMENTS OF THE COMPANY'S OWN OPERATIONS
In its own operations, Fjord Line has identified individual cases of discrimination and harassment (including sexual harassment). As a result, equality and anti-discrimination work has been intensified and continues to be prioritized internally in the company.
Through a whistleblowing case, specific cases related to safety at work have also been assessed in 2024. External advisors found no basis for action.
3.3 THE COMPANY'S SUPPLY CHAIN AND BUSINESS PARTNERS
The company has commercial relationships with 1061 direct suppliers and business partners in the reporting year. The company's suppliers are located in the following country/geographic area:
The classification tool in the platform displays the following classification of the company's first-tier suppliers, business partners, and other known subcontractors:
i. 1061 suppliers evaluated based on Country, VAT ID & NACE
a. Majority of suppliers evaluated through Ignite tool, remaining manually by the Head of Procurement
ii. 1 supplier is rated as High risk
iii. 400 suppliers as Medium risk
iv. 660 suppliers as Low risk
3.4 THE RESULT OF THE DUE DILIGENCE ASSESSMENT
Fjord Line operates a complex supply chain encompassing multiple industries and tiers. While many of our direct suppliers are based in regions traditionally considered low-risk—such as the Nordics, Western Europe, and Central Europe—potential risks emerge further down the value chain. These risks primarily relate to sub-suppliers and raw material producers, especially in sectors historically associated with labor rights and human rights challenges.
Identified Risk Areas:
• Fuel: The global fuel supply chain presents several inherent risks related to labor rights and human rights. These risks stem from the geographical complexity of the industry, the nature of extraction and refining processes, and the regulatory environments in which many suppliers operate.
• Food and Beverage Products: Raw materials like coffee, tea, cocoa, fruit, and sugar carry known risks of forced labor, child labor, and inadequate health and safety standards at the production level.
• IT Equipment: Manufacturing in certain Asian countries raises concerns about labor conditions, including low wages, excessive overtime, misuse of student labor, and limited union rights.
• Furniture: Component production in parts of Asia and Eastern/ Southern Europe may involve child labor, forced labor, and poor working conditions. Union suppression, low pay, and unpaid overtime are additional concerns.
• Office Supplies: Products such as pens, staplers, paper goods, and disposable items have been identified as high-risk categories for potential human rights violations throughout their life cycle.
• Textiles: Items like uniforms, bedding, towels, and interior fabrics can pose risks across various production levels—from assembly to raw material sourcing—including child labor and serious safety and health deficiencies. Risks also extend to laundry and maintenance services.
• Tobacco Products: Items such as cigarettes and snus carry known risks at the agricultural level, including child labor, low wages, and inadequate safety conditions.
• Maritime-Related Goods and Services: Shipbuilding and related services, particularly at certain shipyards, present significant risks due to the potentially severe consequences of poor occupational health and safety standards.
4. Measures to cease, prevent or mitigate the adverse impact
Fjord Line is committed to addressing these risks through its due diligence process:
• Supplier Engagement: We actively gather information from suppliers based on risk assessments and will engage in dialogue to address identified issues. We also assess suppliers own transparency reporting if available.
• Origin: We take a deliberate approach to ensuring traceability and responsible sourcing of our products. For example, we have contractually secured that LNG deliveries originate from Norwegian gas production and are converted to LNG in Norway.
• Code of Conduct: Acceptance of Fjord Line’s Supplier Code of Conduct is required for all suppliers (exceptions are primarily made for suppliers with their own code of conduct which is satisfactory), requiring them to ensure equivalent standards among their sub-suppliers.
• Centralized Procurement: Our procurement department has standardize purchasing processes to enhance oversight.
• Whistleblower Mechanism: An external whistleblower channel has been established in collaboration with a legal firm, allowing for confidential reporting of concerns.
• Internal Initiatives: We continue to focus on equality and diversity within our organization, utilizing system tools to monitor and promote a safe and inclusive work environment.
• Stakeholder Engagement: Regular dialogues with organizations and stakeholders are conducted as part of our sustainability efforts.
Through these measures, Fjord Line strives to uphold and strengthen our commitment to human rights and decent working conditions across our supply chain, aligning with the principles of the Norwegian Transparency Act.
Fjord Line strives to uphold and strengthen our commitment to human rights and decent working conditions across our supply chain
5. Communication with affected stakeholders and rights-holders
Apart from what is outlined in section 3.2 above, the company has not uncovered any violations of human rights or decent working conditions in the reporting year. Nor has the company uncovered any significant risk of violations as mentioned.
6. Remediation and compensation
The company has not uncovered any cases requiring remediation in the reporting year.
Egersund, 27.06.2025
Fjord Line Holding AS
Jan Erik Sivertsen Board member
Hans Jakob Collett Humlevik Board member
Dag Magne Vedvik Board member
Kristian Eikre Board member
Peter Frølich Chairman
Fjord Line AS
Brian Thorsted Hansen Group CEO
Heidi Nag Flikka Board member
Christian Fredrik Grønli Board member
Appendix
This report applies for the following companies:
• Fjord Line AS
• Fjord Line crewing AS
• Fjord Line Holding AS
• Fjord Line Denmark A/S
• Hirtshals LNG A/S
• Fjord Skibsholding I A/S
• Fjord Skibsholding II A/S
• Fjord Skibsholding III A/S
• Fjord Skibsholding IV A/S
• Fjord Skibsholding V A/S
FJORD LINE HOLDING AS Elganeveien 1, 4373 Egersund, Norway Org. nr. 928 026 329
Fjord Skibsholding II AS Dalsagervej 9, 9850 Hirtshals, Denmark Org. nr. 31089824
Fjord Skibsholding I AS Dalsagervej 9, 9850 Hirtshals, Denmark Org. nr. 30826434
Fjord Line Danmark AS Dalsagervej 9, 9850 Hirtshals, Denmark Org. nr. 28870515
Fjord Skibsholding III AS Dalsagervej 9, 9850 Hirtshals, Denmark Org. nr. 33040644
Fjord Skibsholding V AS Dalsagervej 9, 9850 Hirtshals, Denmark Org. nr. 38594877
Fjord Line Crewing I AS Elganeveien 1, 4373 Egersund, Norway Org. nr. 924 445 785
Hirtshals LNG AS Dalsagervej 9, 9850 Hirtshals, Denmark Org. nr. 35643265
Fjord Skibsholding IV AS Dalsagervej 9, 9850 Hirtshals, Denmark Org. nr. 33040695
FJORD LINE AS Elganeveien 1, 4373 Egersund, Norway Org. nr. 928 026 329
