Reitan Retail Statement according to the Norwegian Transparency Act
2023 in review
• About 9,300 suppliers and productions facilities have been risk assessed, accounting for 74 percent of all suppliers and production facilities reported in our operations.
• There are 1,342 suppliers and production facilities identified with high or very high risk, primarily within the food/non-food sector, IT hardware, software and manufacturing.
• Reitan Retail companies conducted 29 on-site visits and initiated dialogue to collaborate in ensuring secure and satisfactory working conditions.
• 716 self-assessments and direct dialogues were carried out with suppliers after initial risk assessments.
• Based on our due diligence efforts, 96 cases required further action. 77 uncovered minor non-compliance whilst 19 resulted in improved conditions, most of them concerning safety and hygienic conditions, working hours and social management system in China, Greece, India, Indonesia, Thailand and Vietnam
• Two contracts in REMA 1000 Norway were terminated after assessment and repeated inquiries regarding SCoC. The suppliers work in the construction services sector and manufacture non-food products.
• 40 inquiries about the origin of products and due diligence procedures were received and addressed.
• The development of our Policy on responsible procurement, endorsed by the Board of Directors in February 2024, encompasses both direct and indirect procurement across all business areas and subsidiaries.
• The responsible procurement policy integrates due diligence into our decisionmaking, risk management, and responsible procurement practices.
Transparency act §5 a. A general description of the enterprise's structure, area of operations, guidelines and procedures for handling actual and potential adverse impacts on fundamental human rights and decent working conditions.
1. Responsible together
Reitan Retail is a retail company, committed to responsible retail in the Nordic and Baltic region with operations in discount grocery, convenience, fuel and mobility across seven countries.
We are a family of 45,000 positive and proactive people with strong brands, including REMA 1000, Narvesen, R-kioski, Pressbyrån, 7-Eleven, Caffeine, Norsk Kylling, Kolly and Uno-X Mobility. Together, we encounter 2 million customers every day, offering products sourced from across the world.
Our unique franchise model is at the heart of our business, and the customer is our boss. Our ambition is to take a leading sustainability position by making it easier to make good choices – at home and on the go.
We are a value-driven company, and our value-based culture is the cornerstone of our operations throughout all companies. It is the basis for creating financial value and conducting activities with integrity and responsibility. Being a value-driven company, we depend on trusting each other throughout our organisation, and we are dependent on trust from our customers, suppliers, partners, owners, authorities and from society Transparency in how we conduct business and report on our actions are key elements to gain trust.
Based on strong values, efficient operations, and local ownership, we share a common purpose:
“Together we make everyday life a little bit easier and the world a little bit better”
1.1 Organisation
Reitan Retail AS is a fully owned subsidiary of REITAN AS, which is owned by the Reitan family. Odd Reitan, Ole Robert Reitan, and Magnus Reitan with his family, each own 33.3 percent of the shares in REITAN AS through their individually owned holding companies.
Reitan Retail is organised with a parent company, Reitan Retail AS, responsible for overall corporate governance. Subsidiaries that are defined as core business areas are referred to as business areas. These are REMA 1000 Norway, REMA 1000 Denmark, Reitan Convenience and Uno-X Mobility. The Transparency Act (the Act) applies to all subsidiaries in Reitan Retail.
The chart on next page gives an overview of Reitan Retail’s business areas with respective subsidiaries, assembled based on operational structure.
Operational structure chart of Reitan Retail
Norsk Kylling AS
Uno-X
Percent shows share of ownership. Companies without percent indicates full ownership. 1) REMA Distribusjon Import AS is included in the statement
2) Ipart ApS was acquired by Uno-X Mobility in 2022. The company restructured in 2023 and further downsizing of operations has recently been decided for 2024 due to market challenges and low orders. Ipart ApS has not conducted supplier evaluations in accordance with the transparency law for 2023.
Companies with individual statement according to the Act
Companies accounted for in Reitan Retail's statement Companies accounted for in REMA 1000 Norway's statement Companies accounted for in Uno-X Mobility's statement
REMA 1000 Norway’s statement according to Act with links to their subsidiaries’ report Reitan Convenience Norway’s statement according to Act Uno-X Mobility’s statement according to the Act
1.2 Sectors, markets and products
Reitan Retail has operations in the discount grocery, convenience, fuel and mobility sectors through our four business areas.
REMA 1000 Norway has since the opening of the first REMA store in 1979 been a significant contributor to the maturity of the discount grocery segment in Norway. The company distributes and sells typical grocery goods within food and non-food categories through REMA 1000 sales outlets run by franchisees in Norway. The distribution activities within REMA 1000 also include external customers, which in 2022 was expanded to include deliveries to the HoReCa market (hotels, restaurants and catering companies). In addition, REMA 1000 Norway
has ownership in selected companies producing a range of private labels, including the chicken producer Norsk Kylling.
REMA 1000 Denmark distributes and sells typical grocery goods within food and non-food categories through REMA 1000 sales outlets run by franchisees in Denmark. REMA 1000 Denmark also distributes and sells goods to several convenience stores, including the 7-Eleven sales outlets in Denmark, operated by Reitan Convenience Denmark.
Both REMA 1000 in Norway and Denmark have a broad selection of private labelled products and products from unique suppliers who only deliver to REMA 1000. For these goods, we have a particularly large responsibility for overseeing fundamental human rights and decent working conditions in the associated value chain.
Reitan Convenience holds a proud more than 100-year-long history in convenience retailing. The convenience retail operations aim to meet consumer demand for convenient solutions “on the go” with focus on food to go, hot and cold beverages, and bakery. A limited selection of the goods sold are private labelled products. Reitan Convenience also offers services such as sale of transportation tickets, lottery, parcel pick-up. With limited exceptions, the portfolio is based on franchising and with sales outlets in Norway, Sweden, Denmark, Finland, Latvia, Estonia and Lithuania. Reitan Convenience aims to make convenience sustainable and sustainability convenient.
Uno-X Mobility has operations in liquid fuels, lubricants, Nordic Swan ecolabel car wash and ultrafast EV charging in Norway and Denmark. Uno-X Mobility’s mission is to develop and promote solutions for sustainable mobility. Uno-X Mobility also owns and operates Uno-X Pro Cycling Team to promote more everyday cycling as an important measure for sustainable mobility.
1.3 Value-driven culture embedded in governing documents
We strongly believe in the shared responsibility of sustainability and advocate for collaboration to address this urgency. We strive to have a sustainable business practice that respects people, society, and the environment. The greatest risks of negative impact are often found in the supply chain of the goods we sell, which is why we are committed to responsible procurement and supply chain management, ensuring traceability and responsible production
Our supply chain is complex, often with numerous layers of sub-suppliers, agents, cooperatives and production facilities involved, making the cascading of efforts downstream challenging. While direct communication within the supply chain is essential, it is often difficult and pose significant challenges in numerous cases.
At Reitan Retail, our decentralised structure ensures that accountability, authority, and operational execution are closely linked. With around forty companies located in the Nordics and Baltics, each company has a deep understanding of their markets, suppliers, employees, and customers, enabling them to conduct business effectively and responsibly.
Our strong culture, value-based trust leadership and values guides us in our everyday operations. As also outlined in Reitan Retail’s Code of Conduct (CoC) and Supplier Code of Conduct (SCoC) and Anti-Corruption and Anti-Money Laundering Policy, Reitan Retail is committed to respecting internationally recognised human and labor rights in our own operations and throughout the value chain. The Codes outline a minimum set of requirements and ethical principles relating to human rights that we expect our business areas, and their subsidiaries to adhere to, including the safeguard of environmental and human rights
defenders. Additionally, each business area set additional expectations for their suppliers, based on sector and the markets in which they operate.
The Board of Directors of Reitan Retail is responsible for the overall governance of Reitan Retail, including upholding the Norwegian Transparency Act. The CEO of Reitan Retail, together with the other members of the Corporate Management Board (CMB) are accountable for the daily operations of Reitan Retail. The CMB collectively hold the responsibility to protect and advance the corporate interests of Reitan Retail, as well as to support its strategic, financial, and operational goals. Moreover, the CMB's role encompasses ensuring the proper organisation of Reitan Retail, implementing effective steering, risk management, and control systems to facilitate a comprehensive understanding of risk exposure and adherence to laws and regulations, including the Act.
1.3.1 Responsible procurement policy
The Responsible Procurement Policy outlines the requirements and practices we anticipate our business areas to adhere to. Its aim is to ensure a sustainable and enduring supply chain while aligning with our mission, objectives, and sustainability strategy.
The policy, together with our Code of Conduct, Supplier Code of Conduct and associated internal processes and routines, forms the basis for our work on labour and human rights, climate, environment, animal welfare, anti-corruption, and other forms of financial irregularities such as money laundering, in our procurements. The policy was developed in 2023 and adopted by the Board of Directors in February 2024. It covers direct and indirect procurement for all business areas and their affiliated companies. During 2024 the business units will align their procurement practices, including supplier code of conduct, supplier agreements, and internal procedures, with the principles outlined in the policy.
The CEO of each business area is responsible for the implementation and compliance of the policy. Managers of relevant units are responsible for ensuring that employees under their management and relevant third parties have understood the contents of the policy and established processes that ensure compliance with the policy, integrating due diligence in company decision-making, risk management, and responsible procurement.
The policy aligns with relevant legislation of procurement practices, and international principles for sustainable business practices and ethical trade in global supply chains. Among others it includes the UN Sustainable Development Goals, the Norwegian Transparency Act, the EU Deforestation Act, the EU Due Diligence Directive, the ILO conventions and the EU Corporate Sustainability Reporting Directive. It follows the OECD Guidelines for Multinational Enterprises and the UN Guiding Principles on Business and Human Rights that set expectations for preventing and addressing adverse impacts on human rights, the environment, and animals.
Responsible procurement policy
1.4 Grievance mechanisms and whistleblowing
Reitan Retail’s internal control and systems for risk management aim to ensure compliance with the corporate values, ethical guidelines, and guidelines for corporate social responsibility.
The company’s CoC and SCoC describe Reitan Retail’s ethical commitments and requirements related to business practice and personal conduct. If employees, suppliers, or any other stakeholders experience situations or matters that may be contrary to rules and regulations or the Code of Conducts, they are urged to raise their concerns with their immediate superior or another manager or through the whistleblowing function.
In Reitan Retail we want a low threshold for speaking up about misconduct in the workplace or in our value chain. The whistleblowing channel, described in the Codes of Conduct and in our whistleblowing policy that is available on our webpage, allows our employees, suppliers, or any other stakeholder to report experienced or suspicion of unacceptable behavior in violation of our values, ethical guidelines, or regulations, without fear of retaliation against the whistleblower.
In addition to Reitan Retail’s whistleblowing policy and channel, issues can be raised directly to REMA 1000 Norway, REMA 1000 Denmark, the respective Reitan Convenience country companies and Uno-X Mobility
Whistleblowing channels
Reitan Retail
REMA 1000 Norway
REMA 1000 Denmark
Reitan Convenience Norway
Reitan Convenience Sweden
Reitan Convenience Denmark
Reitan Convenience Finland
Reitan Convenience Latvia
Reitan Convenience Estonia (implementation 2024)
Reitan Convenience Lithuania (internal only)
Uno-X Mobility
The notifier can choose to be anonymous. The whistleblowing channels are proceeded by a third party, PwC. When a case is reported, representatives from Reitan Retail become involved in further assessments according to our governing document - whistleblowing process.
In 2023, a total of 96 cases were reported by internal and external stakeholders and were subsequently addressed, mostly concerning violations of laws and regulations, discrimination and harassment and other unethical or illegal conduct We want to encourage more use of our whistleblowing function. The cases reported offer valuable insights to help mitigate negative impacts. Our goal is to extend the application of lessons learned from remediation and risk assessment throughout Reitan Retail.
Digital training programs relating to whistleblowing and our Code of Conducts, including dilemma training were made available for both internal and external stakeholders in 2023.
business areas
REMA 1000 Norway
REMA 1000 Norge AS is subject to the Transparency Act on an individual basis. The company provides a detailed account of human rights due diligence conducted in its own operations and by its subsidiaries in its due diligence report. This report can be found on REMA 1000 Norway’s website under the section Vårt ansvar – Redegjørelser, here.
REMA 1000 Norway AS and its subsidiaries work continuously with human rights due diligence, in line with legal requirements and the OECD framework. The efforts related to the Act are integrated into the board and management structure, with the Head of Sustainable Sourcing at REMA 1000 Norway AS overseeing the process and implementation, including conducting overarching risk assessments and subsequent prioritastion of the most significant risks.
Following the risk assessments and subsequent prioritisation of most significant risk, the responsibility for addressing identified risks and actual negative impacts lies with the subsidiaries for their respective supply chains.
The due diligence report covers the following subsidiaries:
REMA Distribusjon, Kolonihagen, Spekeloftet, Kjeldsberg Kaffebrenneri, Norsk Kylling, Stange Gårdsprodukter, Grans Bryggeri, BAMA/BaRe and Kolly.
REMA 1000 Norway use a platform to identify and track risk of negative impact on human rights and decent working conditions. The follow up is based on consolidated procurement categories for REMA 1000 Norway and its subsidiaries. Risks identified is pursued through an internally developed and integrated solution for supplier management and in-depth risk assessments.
The most significant risks in REMA 1000 Norway’s supply chain are linked to the products sold in REMA 1000 stores, characterised by complex supply chains in addition to supply chains for packaging, textile (uniforms), construction supply and IT, amongst others. To address these risks, suppliers undergo a prequalification process, receive information about REMA 1000 Norway's ethical trade standards which they must agree to, and REMA 1000 Norway has policies and routines that support our work with due diligence assessments. The framework for due diligence assessments in Reitan Retail, and hence REMA 1000 Norway is based on the UN's guiding principles on business and human rights (UNGP, 2011) and OECD due diligence guidance for responsible business conduct (2023).
Questions about REMA 1000 Norway’s work on human rights and decent working conditions in the value chain can be directed to Christina Skogmo Fuglesang, christina.fuglesang@rema.no
REMA 1000 Norway’s statement according to the Act
REMA 1000 Denmark
As Reitan Retail’s subsidiary, REMA 1000 Denmark A/S is affected indirectly by the Act and the company does not account individually on the Act.
This section covers the companies:
REMA 1000 Denmark A/S, Reitan Distribution A/S, REMA Danmark Butik ApS, REMA Etablering A/S and Vigo.dk ApS.
The business area REMA 1000 in Denmark is a discount retailer offering food and non-food products through their more than 400 stores in Denmark The headquarter is in Horsens, with distribution centres in Horsens, Vejle, and Avedøre employing more than 17,000 people.
REMA 1000 Denmark has procurement procedures, with the Head of private label being the responsible party overseeing daily operations and system follow-up. Head of private label is supported by a staff member who handles supplier inquiries regarding responsible supplier management. REMA 1000 Denmark, in partnership with Reitan Retail, has identified risk areas that serve as the foundation for their approach to responsibility. In 2023, all private label suppliers underwent due diligence as outlined below.
REMA 1000 Denmark has implemented the OECD's "The 6 steps" guidelines for due diligence and maintains regular communication with suppliers in high-risk areas. This is accomplished through the establishment of a supplier registration system that collects information such as the geographical location of production sites supplying private label products to REMA 1000 Denmark. Suppliers using production sites in high-risk areas must provide a valid third-party certification or audit approved by REMA 1000 Denmark. The company specifies acceptable certifications/audits that address social responsibility aspects, including management systems, human rights, labour rights, safety and hygiene, working conditions, and wages. If a supplier fails to comply in these areas, they are required to submit a corrective action plan and follow up on the proposed measures.
Since 2018, REMA 1000 Denmark has had a risk-based approach in their value chain work, mapping risk across two verticals: ingredients and country of origin. When evaluating food and non-food items, assessments by Amfori are utilized, while for fruits and vegetables, the risk countries assessment by GLOBALG.A.P is employed. A questionnaire has been created based on these risk assessments and is completed by suppliers of own-brand and private label products. This process ensures transparency regarding product origins. In high-risk countries, valid and approved certifications such as Amfori BSCI, SEDEX SMETA, or SA8000 are required for food and non-food items, while Fairtrade or Rainforest Alliance certifications are necessary for fruits and vegetables.
Data is obtained through our supplier platform, where certifications and audits are consistently updated as they expire. In the event of non-compliance identified during an audit, it is essential to implement a Corrective Action Plan. This plan should outline the noncompliant issues at the production site, the corrective actions to be taken, and the anticipated timeline for resolution. For instances of critical or major non-compliance, REMA 1000 Denmark works closely with the supplier to monitor the status and improvements at the production site.
In 2023, REMA 1000 Denmark conducted a detailed assessment of social conditions at product and raw material production sites for items containing a higher proportion of risk materials. Dialogues were initiated with suppliers handling raw materials like coffee, cocoa, soy, palm oil, and wood, all falling under the EU Regulation on Deforestation-free Products (EUDR). For products with these materials, REMA 1000 Denmark aims to request third-party certifications from organisations ensuring adherence to social, environmental, and ethical standards. Collaboration with independent and approved third-party organisations is crucial to validate compliance with standards and confirm proper production practices.
Questions about REMA 1000 Denmark’s work on human rights and decent working conditions in the value chain can be directed to Gunhild Nørgaard, gun@rema1000.dk.
Additional information on how REMA 1000 Denmark collaborates with suppliers can be read in their sustainability report 2023 on their website under the section Ansvarlighed here, and policies on deforestation, animal welfare, biodiversity, ethical trade, Employee relations, climate and environment, responsible soy and palm oil and responsible supplier management can be found on their website under the section Ansvarlighed here.
Reitan Convenience AS
Reitan Convenience AS’s subsidiaries outside Norway is affected indirectly by the Act and for 2023 the following subsidiaries are covered in the section below:
Reitan Convenience Sweden AB, Reitan Convenience Denmark A/S, R-kioski Oy, SIA Reitan Convenience Latvia, SIA Preses Serviss, AS Reitan Convenience Estonia, Lehepunkt OU, UAB Reitan Convenience Lithuania, UAB Coffee Point and UAB Press Express
Reitan Convenience Norway AS operates the brands Narvesen, 7-Eleven, Northland and Innom (2024), and is subject to the Act on an individual basis. Their account for human rights due diligence carried out in own operations is detailed in its own due diligence report, available on Narvesen and 7-Eleven websites.
As a business area, Reitan Convenience AS has over the past couple of years had a strong focus on both social and environmental sustainability issues. Working towards value chain transparency has been a core objective and important steps have been taken in mapping the origins of risk commodities in the assortment such as palm oil, cocoa, coffee, soy, and animal products. These commodities present significant sustainability challenges - both social ones such as the risks for child labour, unsafe workplace environment, misuse of migrant workers, insufficient living wage, but also environmental ones such as deforestation and associated biodiversity loss. There are also important animal welfare issues to consider.
Reitan Convenience has developed a data system for the seven-country organisation enabling them to gather and retain a variety of important sustainability data related to products. This information encompasses over 7,000 products sourced from more than 600 suppliers within the organisation, constituting 70 percent of sales in edible product categories
The system of important sustainability data contains information about the countries of origin for high-risk commodities in 1,730 products. Presently, the breakdown of origin data coverage by country is as follows:
Reitan Convenience Norway 35%
Reitan Convenience Sweden 13%
Reitan Convenience Denmark 28%
Reitan Convenience Finland 11%
Reitan Convenience Latvia 81%
Reitan Convenience Estonia 18%
Reitan Convenience Lithuania 12%
Enhancing coverage will be a key focus going forward. Nevertheless, the data is likely to be representative since most suppliers are included.
The mapping is carried out on a product level where each ingredient is accounted for This approach allows for targeted follow-up, ranging from adjusting the balance between different categories to address overarching issues in product assortments e.g., increasing fresh food and reducing pre-packaged items to reduce the use of palm oil to addressing specific issues with individual products from specific suppliers (such as the absence of a credible certification for a popular chocolate bar). The assortment teams in all seven countries actively work with the origins risk data and results of these assessments are covered in supplier dialogues.
The ongoing risk assessment of high-risk commodity origins is already providing crucial insights into supply chain dynamics This aids Reitan Convenience in prioritising improvement efforts with first-tier suppliers. While numerous relevant insights are gained from this mapping, several common trends emerge. Reitan Convenience's suppliers source a significant amount of coffee from Latin and South America (Ecuador, Colombia, Brazil), cocoa from West Africa (Ivory Coast, Ghana, Nigeria), and palm oil from Indonesia and Malaysia. These three commodities are considered high-risk in terms of human rights and working conditions. Due to their significant presence in convenience settings, there is cause for concern, prompting indepth dialogues with suppliers across all Reitan Convenience countries.
Reitan Convenience is expanding risk assessments to cover all procurements, also covering non-food suppliers. Details on risk assessment and due diligence are included in key policy documents like the SCoC and sustainability strategy, aiming for full functionality by end of 2024. The systematic approach for dealing with all procurements related risk assessments and due diligence is estimated to be fully functional by the end of 2024.
Questions about Reitan Convenience’s work on human rights and decent working conditions in the value chain can be directed to Malin Eklund, malin.eklund@reitanconvenience.no.
Additional information on how Reitan Convenience collaborates with suppliers can be read in their sustainability report 2023 on reitanretail.no under the section Our responsibility-Reports and here.
Uno-X Mobility
Uno-X Mobility AS is subject to the Transparency Act on an individual basis. The company provides a detailed account of human rights due diligence conducted in its own operations and subsidiaries in Norway and Denmark in its due diligence report. This report can be accessed on Uno-X Mobility's website under the Responsibility section, located here
Uno-X Mobility offers liquid fuels and biofuels, ultrafast EV charging for cars and heavy-duty transport and car wash from over 800 self-service outlets in Norway (526) and Denmark (297) Uno-X Mobility also owns and operates fuel storage facilities in Norway and Denmark. In Norway, the company owns and operates fuel storage facilities at Sjursøya in Oslo, Mo i Rana, and Stavanger. In Denmark, the company owns and operates a fuel storage facility in Rønne on Bornholm, as well as having a 50% ownership in Samtank A/S, which operates several fuel storage facilities in Denmark.
Human rights issues are central within the oil and gas industry Consequently, we predominantly procure goods from major oil and gas suppliers based in Scandinavia, known for their stringent human rights policies and thorough supply chain oversight The risk of changes in land use related to bio components in biofuels can lead to negative impacts The EU's deforestation directive, effective from 2024, mandates the sourcing of biofuels from regions not at risk of deforestation. Uno-X Mobility, therefore, refrains from using palm oil and soy in its purchased biofuels. Sustainability certificates are provided for all biofuel purchases in compliance with legal mandates in Norway and Denmark.
Uno-X Mobility procures items from suppliers across different nations, impacting society both directly and indirectly through product value chains. It is crucial for the company to minimize any potential adverse social and environmental effects through collaborative efforts with suppliers.
The ethical guidelines for suppliers employ a risk-based approach in line with the Norwegian Transparency Act. Management and key personnel in the companies have received training in the Transparency Act.
Due diligence assessments of suppliers are an ongoing task in daily operations and the statement according to the Transparency act covers the following subsidiaries:
In Norway: Uno-X Mobility AS, Uno-X Mobility Norge AS, Uno-X Mobility Cycling AS, Uno-X E-Mobility Norge AS, Uno-X Smøreolje AS and YX Betjent AS
In Denmark: Uno-X Mobility Danmark A/S, Uno-X E-Mobility Danmark A/S, Uno-X Smøreolie A/S, Ipart ApS
While there were clarifications required and discussions held with risk suppliers, Uno-X Mobility did not discover any actual negative impacts as of December 31, 2023. This highlights that we are currently unable to pinpoint all areas with actual or potential negative impacts within the supply chains. The ongoing efforts to establish a responsible procurement policy with accompanying due diligence processes will aid us in detecting negative impacts moving forward.
Questions about Uno-X Mobility’s work on human rights and decent working conditions in the value chain can be directed to Jacob Berner, jacob.berner@unox.no.
Uno-X Mobility’s statement according to the Act
Gladengen Drift AS
Gladengen Drifts AS is the office management provider for Reitan Retail’s rented head office building in Gladengveien 2, Oslo. Gladengen Drift is fully owned by Reitan Retail and provides services such as canteen, reception, events, meeting facilities, cleaning in addition to maintaining the head office suitable as a daily workspace with desks, light, functioning elevator, fresh plants and much more for Reitan Retail employees.
Gladengen Drift AS is covered by Reitan Retail's whistleblowing policy and channel. The whistleblowing channel, outlined in the Code of Conduct and the Whistleblowing policy, can be accessed on reitanretail.no. It enables employees, suppliers, and other stakeholders to report instances or suspicions of misconduct that contravene Reitan Retail's values, ethical standards, or regulations, without the whistleblower having to fear facing retaliation.
Each year, Gladengen Drift AS assesses its suppliers, considering type of contracts, whether they are regular suppliers or not, environmental certifications, and costs. Additionally, they evaluate whether current suppliers are at risk of not fulfilling fundamental human rights and decent working conditions. Currently, Gladengen Drift AS is contemplating switching one main service provider. The abovementioned steps will precede the selection of new suppliers.
During this years’ due diligence Gladengen Drift AS mapped and classified their 133 suppliers according to the services and products they offer and carried out risk assessments. A review of risk factors and leveraging on own knowledge of the suppliers, they identified 28 with a potentially high risk of violating fundamental human rights and decent working conditions. None of which are new in 2023. The identified suppliers provide goods such as furniture, hardware and packaging and services such as cleaning and carpentry. Questionnaires with
requests of information were provided in writing in 2022/2023 and ongoing dialogue is in place ensure joint understanding of the law.
There have been no alterations to the risk assessments of current suppliers in 2023 and no actual negative impacts have been uncovered by Gladengen Drift AS.
Questions about Gladengen Drift’s work on human rights and decent working conditions in the value chain can be directed to Kristine Kvakkestad, kristine.kvakkestad@gladengendrift.no
2.3 Identified negative impacts
The following negative impacts have been identified throughout supply chains in Reitan Retail:
• A whistleblower raised concerns about unfair wages, unpaid overtime and the use of temporary contracts instead of permanent ones at a food sub supplier in Norway. Following constructive dialogue with the tier 1 supplier, the issues raised in the complaint were addressed, wages were refunded, and changes were made regarding the contract types.
• Despite continuous communication and multiple requests to a non-food production facility in China regarding responsible trading irregularities, our supplier has not observed any change in behavior or received any indications of improvement. As a result, the contract with the production facility has been terminated
• A whistleblowing complaint was made concerning unfair wages and extended working hours for berry pickers employed by a sub supplier in Sweden was raised Despite a due diligence investigation conducted without adequate evidence, our supplier plans to continue monitoring and addressing the situation in 2024.
• Production site in Thailand with low BSCI audit score: REMA 1000 Norway is working with the supplier on implementing measures to improve the situation.
• A supplier raised concerns about negative impacts at a food production site in Thailand, where migrant workers were charged high recruitment fees upon hiring. Stakeholder engagement and collaboration with Etisk Handel led to the production site discontinuing the recruitment fee practice. A Sedex audit is scheduled for 2024.
• One non-compliance involved a producer in Bulgaria who submitted a certificate with numerous errors and deficiencies.
• One production site in Thailand transitioned from an Amfori BSCI score of B to D. D-score is unacceptable, and a new audit was immediately requested
• A producer in Thailand faced challenges regarding the employment of migrant workers. Upon becoming aware of the issues, immediate action was taken to address the problems, and a reaudit was requested.
• Numerous cases of significant non-compliance are linked to "Working hours," particularly in China. Production facilities struggle to retain skilled workers unless they offer substantial overtime opportunities with double pay compared to regular hours.
• A situation involving drivers not being paid their salaries and the absence of contracts with a Norwegian private driver company was highlighted in the media. This led to dialogue, the signing of our SCoC, and ongoing follow-up in 2024.
While there were clarifications required and discussions held with categorised risk suppliers, Reitan Convenience and Uno-X Mobility did not discover any actual negative impacts. This highlights that we are currently unable to pinpoint all areas with actual or potential negative impacts within our supply chains. The ongoing efforts to establish a responsible procurement policy with accompanying due diligence processes will aid us in detecting negative impacts moving forward.
2.4 Risks identified, prioritisation and aggregated data
Risks identified through high-level risk assessments in our business areas
Operating within the food, agriculture, fuel, and mobility sectors, our supply chains span globally, are intricate, and face exposure to climate change. Significant challenges related to forced labor, child labor, corruption, freedom of association, discrimination, fair wages, and environmental harm exist within these sectors. Anticipated consequences from various factors like climate change and geopolitical conflicts are expected to intensify these challenges in the future.
By engaging in discussions on risk management throughout the business areas in 2023, conducting annual supplier screenings, and performing due diligence assessments on subsidiaries, two primary risk categories have been identified for the products sold in our stores and for the fuel and energy suppliers at Uno-X Mobility. Additionally, other high-risk supplier categories for the products and services that are vital for our daily operations are identified for the overall business.
Conflicts in the world around us lead to inquiries from employees and customers concerning our stance on products from Israel and Palestine and Russia for example. We do not take a stance in specific conflicts but adhere to current trade agreements and comply with sanctions lists and the trade regulations established by authorities locally and regionally. We specify the origin of all products.
The classification of risk categories (below), established in 2022 has remained unchanged as of June 30, 2024, following an evaluation of our operations within the global context.
Two main risk categories for the goods we sell
1) Food and non-food
The substantive part of our suppliers and production facilities are directly linked to the products sold in our 2,800 discount grocery stores and convenience sales outlets. There is a significant risk of human rights violations in the raw material market, with additional risks present during the product manufacturing phase.
a) Risk related to raw materials and geographical origin
According to third party sources, child labour and forced labour are especially widespread and well-documented in the supply chains of tea, coffee, cocoa, cane sugar and tropical fruit1. There are also documented cases of migrants working under slave-like working conditions for products produced in Europe2. The agricultural sector, especially in developing countries, is characterised by informal labour. There are also health risks linked to the use of pesticides3. Given this risk assessment, both raw materials and geographical production location are prioritised risk areas.
High-risk raw materials identified
• Palm oil, soy, Scampi, tuna fish, cocoa, coffee and tea, hazelnuts, cashew nuts, paper and wood
High-risk geographical location identified
• Bangladesh, Brazil, China, Hungary, India, Indonesia, Malaysia, Maldives, Morocco, Pakistan, Paraguay, Philippines, Sri Lanka, Thailand, Turkey and Vietnam. 1
b) Risks related to product manufacturing
At Reitan Retail, we procure products globally, including from countries identified as high-risk by external risk analysis firms. Risk mitigation efforts include measures such as mandating Sedex membership for production sites outside the Nordic region, performing audits, and certifying high-risk raw materials.
2) Fuel and biofuel
Human rights issues are central within the oil and gas industry. As a result, we trade goods mainly from large oil and gas suppliers located in Scandinavia having strict human rights policies and close monitoring of their supply chains. Biofuel on the other hand is prone to risk related to land use change. The EU's deforestation directive will enter into force in 2024 and necessitates ensuring that biofuels do not come from areas at risk of deforestation.
Health, safety and environment (HSE) are inherent risks for the industry of Uno-X Mobility and a prioritised risk for the company. Health, safety and environment risk assessments are carried out continuously. Most employees work in office spaces, but there is a particular risk connected to self-service gas stations and tank facilities. Compliance with HSE regulations is followed up on a continuous basis, and several relevant ISO certifications are maintained.
Other supplier categories with high risk
Textiles – The textile industry is highly concentrated in Asia. Uniforms are part of our day-today operations with main origin in Bangladesh, a country subject to poor working conditions, especially excessive use of overtime, unsatisfying safety and use of child labour4
Packaging – Most end-products require packaging. The production of plastic products risk is therefore high in the sector, especially in countries where the labour market is not regulated or regulated to a lesser extent. The cardboard and paper industry also involves the use of chemicals that can be harmful to workers in the production process5.
Fixed assets – Building materials, inventory, office supplies etc. originate from all over the world. Due diligence assessments are carried out in the operational level of the organisation, where detailed knowledge and experience of the supply chain allow for qualified assessments. Within this category, solar panels are identified with very high risk. Solar panels are installed on several of our distribution and industry sites to reduce the carbon footprint of our operations, and additional locations have been screened for further rollout.
IT – hardware, software and services - All our points of sales, administration offices, distribution companies and industry companies are highly dependent on IT, technical solutions and electronics. The electronics market is experiencing high pressure, widespread use of subcontractors and environmental problems associated with the products6. The mineral industry is part of the supply chain for IT products, where the main risks include unsafe working environment, use of forced and child labour, impact on local communities when developing new mining areas and financing of military/paramilitary groups
Transportation – Growth in international trade has led to pressure in the transport and logistics sector. Global competition has led to lower wages and a high degree of informal work, especially in road transport. Workers in the sector are also exposed to a high HSE risk, related to long shifts, manual work and traffic accidents8.
Aggregated quantitative reporting on due diligence assessments and findings
Reitan Retail operates in seven countries, within different sectors, and our value chains span all over the world with related complexity. In the journey to understand the scale of our operations, Reitan Retail gathers quantitative data concerning the Act. All four business areas, along with their respective subsidiaries, have submitted reports as of February 2024. This valuable information provides context and relevant insights to guide future processes.
Due
20232022
The 97 percent increase in suppliers undergoing risk evaluation in 2023 compared to 2022 is primarily due to the inclusion of subsidiaries located outside of Norway.
In 2023, REMA 1000 Denmark focused on assessing suppliers and production sites engaged in producing their private-labelled products. All business areas and their subsidiaries will continue to enhance their due diligence assessment processes and include more suppliers and production facilities in the current year and beyond.
Transparency act §5 c. Information regarding measures the enterprise has implemented or plans to implement to cease actual adverse impacts or mitigate significant risks of adverse impacts, and the results or expected results of these measures.
3. Measures, results and plans
3.1 Measures to mitigate risks
Dedicated raw material risk tools are utilized for monitoring high-risk raw materials identified in section 2.4, with a focus on leveraging certifications such as Fairtrade, RFA, MSC, among others. Both REMA 1000 in Norway and Denmark have internal policies in place for these highrisk raw materials, approved by their respective boards and anchored with the management teams and category and purchasing departments. Furthermore, mandatory training programs have been established for all staff involved in purchasing and supplier interactions. In November 2023, Reitan Retail made the decision to cease the sale of food products containing palm oil to combat deforestation. The use of palm oil in food products will be phased out by the end of 2028.
In 2023, Reitan Retail has made considerable efforts to develop a comprehensive policy on responsible procurement for all business areas. See section 1.3.1. Through working groups and workshops, the company has focused on sustainable procurement, increasing knowledge about responsible procurement, including due diligence. Each business area has created a first draft of an action plan based on a survey of existing practices. Reitan Retail has also developed its own action plan for responsible procurement, which will be reviewed annually. By building knowledge, raising awareness of due diligence, and establishing follow-up routines, we aim to integrate due diligence into overall decision-making, risk management, and responsible procurement.
Furthermore, ongoing efforts are being made to enhance existing frameworks for due diligence. The operational responsibility for conducting human rights due diligence rests with the business areas and their respective subsidiaries, which are individually engaged in risk mitigation activities. For an overview of all efforts to prevent, reduce, or mitigate human rights and labor risks, we recommend referring to section 2.2, and the individual statements of:
• REMA 1000 Norge AS
• REMA Distribusjon Norge AS
• Kolly AS
• Norsk Kylling AS
• Stanges Gårdsprodukter AS
• Kjeldsberg Kaffebrenneri AS
• Grans Bryggeri AS
• Reitan Convenience Norway AS
• Uno-X Mobility AS
To exemplify the efforts carried out across the business areas, we are showcasing some examples:
REMA 1000 in Norway has a particular focus on mitigating risks for their private label products. For suppliers in this category, REMA 1000 Norway works to ensure that their Supplier Code of Conduct is signed, production sites are certified according to GFSI and have Sedex or BSCI membership, human rights due diligence are carried out, access to information, REMA 1000’s policies for high-risk raw materials are implemented, and that suspected or actual breach of the Supplier Sode of Conduct is reported.
In 2022, systematic risk assessments began with a focus on the non-Nordic supply chain due to perceived lower risks in the Nordic region. By 2023, higher risks were found in supplier chains in Norway regarding decent working conditions. Challenges such as unfair wages, unpaid overtime and contract types were revealed through a whistleblowing case, prompting efforts to enhance relationships with suppliers in Norway.
Pre-qualification of new suppliers is an important risk reduction measure. REMA 1000’s requirements for responsible sourcing are made clear to new suppliers during contract negotiation. During the pre-qualification of production sites, if improvement areas are identified, we establish an action plan for enhancements with deadlines for implementation.
REMA 1000 Denmark identified instances of non-compliance with three high-risk suppliers and production facilities, two occurring at existing sites and one at a new site. One case involved a Bulgarian producer who provided a certificate with numerous errors and deficiencies, prompting the scheduling of a new audit. In Thailand, one production site's Amfori BSCI score dropped from B to D, which is unacceptable, leading to an immediate order for a new audit. Another Thai producer faced issues related to the employment of migrant workers, prompting swift action to address the problems and a subsequent reaudit.
The primary issue of non-compliance often centers around "Working hours," particularly in China. Production facilities struggle to retain skilled workers when they are restricted from working substantial overtime. Overtime hours are said to be compensated at nearly double the standard rate, leading to workers being enticed by extra hours. Suppliers face challenges in recruiting workers, forcing production sites to extend their employees' working hours to meet demand. Similar difficulties are reported by other retailers in the Danish market.
Reitan Convenience Norway has identified potential risks of negative impacts at five production sites associated with critical items for our operations. This includes the production of lighting, store fixtures for refrigeration and freezing, and uniforms. These production sites are all sub suppliers, and we will be monitoring them along with our suppliers through 2024
3.2 Results and plans
Reitan Retail has two main ambitions to secure that we offer responsibly produced products to our customers:
1) keep high moral standards and hold our suppliers accountable to our rigorous ethical Code of Conduct
2) integrate the OECD Due Diligence Guidelines for responsible business conduct into our risk management processes and screen 100 percent of our suppliers based on environmental and social criteria. Reitan Retail has a zero- tolerance approach to any breach of human rights, and we strive to minimise our environmental impact across the value chain.
74 percent of our suppliers have been risk assessed, accounting for about 9,300 suppliers and production facilities. The efforts to enhance human rights due diligence, develop internal
guidelines, and report on human rights risk evaluations have led to a deeper understanding of responsible procurement practices. This has also led to more defined structures and expectations for our business areas and subsidiaries. Moreover, Reitan Retail has ensured that work has been done on operational level to implement risk mitigating or corrective measures as we organise our activities in ways that make the distance between accountability, authority and operational execution as short as possible.
In 2024, all Reitan Retail units will harmonise their procurement practices with policy principles. Each business area's CEO is responsible for implementing the policy, which includes establishing processes for compliance and integrating due diligence into company decisionmaking.
Reitan Retail has discovered synergies and common needs across business areas, such as the need for common positions on specific raw materials, education and capacity building, and risk assessments of raw materials. To implement and monitor our policy, key performance indicators (KPIs) will be developed, based on the policy, regulation and our sustainability strategy to make sure we follow up on our suppliers and producers in the most relevant way. The KPIs will be implemented starting in 2024 and introduced during the coming years.
Main results from due diligence assessments in our business areas in section 2.2.
4. Information, contact, approval
4.1
Information
This statement is accessible on our website, reitanretail.no. A reference to our work is also located in the annual and sustainability report for 2023 – “Responsible together” on our website or upon request. The statement will be revised as necessary by the Act, in accordance with significant changes in the overall risk assessments and no later than June 30, 2025.
4.2
Contact
For general inquiries regarding how Reitan Retail complies with the transparency act or for information about a specific product or service provided by the company, please get in touch with us.
Reitan Retail AS Gladengveien 2 0661 Oslo post@reitanretail.no
For questions about this statement contact Sandy Schrøder, sandy.schroder@reitanretail.no
4.3
Approval
Reitan Retail’s statement according to the transparency act was approved by the company’s Board of Directors and CEO in June 2024
Rune Bjerke, Chairman of the board
Magnus Reitan, Board member
Eilert Hanoa, Board member
Annika Marie Sigfrid, Board member
Ole Robert Reitan, CEO
+47 24 09 85 55
post@reitanretail.no reitanretail.no
Gladengveien 2 0661 Oslo
