Reitan Retail Statement according to the Norwegian Transparency Act
1. Responsible retailer
Reitan Retail is a leading 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 43,500 positive and proactive people and strong brands, including REMA 1000, Innom, 7-Eleven, Narvesen, R-kioski, Pressbyrån, Caffeine, Uno-X and YX We daily serve around two million customers with goods from all over the world with complex value chains.
Our unique franchise model is at the heart of our business, and the customer is our boss. We are part of everyday life – at home, on the go and on the road. We are close, simple and responsible.
We are a value-driven company. Our values are the foundation for making customers, employees and partners feel valuable, creating long-term financial value and conducting our activities with integrity. Conducting business in an ethical and transparent manner aligned with our values to inspire trust is essential for us. 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 at large.
Based on strong values, efficient operations, and local ownership, we share a common purpose:
1.1 Organisation
Reitan Retail AS is a fully owned subsidiary of REITAN AS, owned by the Reitan family. Odd Reitan, Ole Robert Reitan, and Magnus Reitan, with their respective families 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.
“Together we make everyday life a little bit easier and the world a little bit better”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 [Siter kilden din her.]
REMA DistribusjonNorge AS
Kolly AS
REMA IndustrierAS
REMA 1000Norge AS
REMA 1000Danmark A/S
ReitanRetail AS
GladengenDrift AS
ReitanConvenience AS
Norsk Kylling AS
Stanges GårdsprodukterAS(95%)
Kjeldsberg Kaffebrenneri AS(50%)
Grans Bryggeri AS(50%)
BARE (50%)
KolonihagenAS(82%)
REMA Etablering Norge AS Spekeloftet AS(50%)
Div. datterselskap
ReitanDistributionA/S
REMA Danmark Butik ApS
REMA Etablering A/S
Gramog Nybøl GodserA/S(49%)
ReitanConvenience Norway AS
ReitanConvenience SwedenAB
ReitanConvenience Denmark A/S
R-kioski Oy
NK IndustrieiendomAS(94%)
Div. datterselskap (33%-100%)
Vigo.dk ApS
Div. datterselskap (50%-100%)
Div. datterselskap (21%-59%)
SIA ReitanConveneience Latvia SIA Preses Serviss
ASReitanConvenience Estonia
UAB ReitanConvenience Lithuania
Div. datterselskap
Uno-X Mobility Norge AS
Uno-X Norge AS
Uno-X Forsyning AS
Uno-X E-Mobility Norge AS
Uno-X Smøreolje AS
Uno-X Sykkel AS
Uno-X Mobility AS
Uno-X Mobility Danmark A/S
Uno-X Danmark A/S
Uno-X E-Mobility Danmark A/S
Uno-X Smøreolie A/S
Uno-X KonceptdesignA/S 1)
Percentshowshareofownership.Companieswithoutpercentindicatesfullownership.
1)Uno-XKonceptdesignA/Sisnotincludedinthestatement.ThecompanywasacquiredinNovember2022
Please find REMA 1000 Norway’s statement according to Act with links to their subsidiaries’ report here.
Please find Reitan Convenience Norway’s statement according to Act here.
Please find Uno-X Mobility’s statement according to the Act with links to their subsidiaries’ report here.
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 a proud history as the pioneer of discount grocery offerings in Norway. REMA 1000 is the largest grocery banner 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.
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 stores 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 ecolabelled 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
Reitan Retail is a value-driven company, and our management philosophy is value-based leadership. Being value-driven is the foundation for making customers, employees and partners feel valuable, creating financial value and conducting our activities with integrity.
In Reitan Retail we have a decentralised structure, and we organise our activities in ways that make the distance between accountability, authority and operational execution as short as possible.
The Norwegian Transparency Act (the Act) has been on the Board of Director’s agenda and the compliance with the act lies with them and Reitan Retail’s CEO. The CEO is responsible for the day-to-day management of Reitan Retail AS in accordance with applicable legislation, and together with Reitan Retail’s executive management team (EMT), routines for complying to the Act have been established. Reitan Retail respects and actively protects workers’ right to fundamental human rights and decent working conditions.
The members of the EMT have a collective duty to safeguard and promote the corporate interest of Reitan Retail and to promote Reitan Retail’s strategic, financial, and other
objectives and targets. In addition, the role of the EMT is also to ensure that Reitan Retail is properly organised and that adequate steering, risk management and control systems are in place to provide a sufficient basis for an overview of risk exposure and compliance with applicable laws and regulations, also including the Act.
Responsibility and dedicated roles with respect to the Act have been delegated in many subsidiaries, and dialogue across business areas, subsidiaries, sectors, and geographical locations has been established. Reitan Retail circulated internal guidelines on the Act with expectations and steps on how to implement the comprehensive work. Multiple workshops have taken place, due diligence assessment methods, risk assessments tools, examples and findings have been shared by both Reitan Retail and the business areas. A structure for high level reporting has been implemented using existing financial reporting structure and system. Overall risks assessments and the evolution of identified risks are fixed discussion points at board meetings in Reitan Retail AS, our four business areas REMA 1000 Norway, REMA 1000 Denmark, Reitan Convenience, Uno-X Mobility and their respective subsidiaries.
Our strong culture, values and value-driven leadership philosophy 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 sets expectations for its suppliers, if necessary, based on sector and the markets in which it operates.
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.
Reitan Retail whistleblowing
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 Uno-X Mobility and REMA 1000 in Norway and Denmark:
Uno-X Mobility whistleblowing
REMA 1000 Norway whistleblowing
REMA 1000 Denmark whistleblowing
The notifier can choose to be anonymous or not. The whistleblowing channels are proceeded by a third party, PwC.
A training program in Motimate relating to whistleblowing and our code of conducts, including dilemma training was made available for both internal and external stakeholders in June 2023.
2. Human rights due diligence assessments
2.1 Conducting human rights due diligence
The framework for due diligence assessments in Reitan Retail is based on the UN's guiding principles on business and human rights (UNGP, 2011) and OECD due diligence guidance for responsible business conduct (2018). The 2023 update of the guidelines will be implemented in our assessments going forward.
It is Reitan Retail’s opinion that risk assessments and due diligence assessments are most beneficial when carried out at the operational level in our subsidiaries, where the detailed knowledge and experience of the supply chain lies. By embedding ownership for the Act in all levels of the organisation, we promote local responsibility for mitigating the risk of negative impact. Following the supply chain risk assessments, the subsidiaries prioritise allocation of resources where the greatest risk of adverse impact has been identified and mitigating actions should be implemented. The operational unit is responsible for risk assessments, prioritisation, mitigating actions and follow-up. Support is given by the business area’s management to which the subsidiary report. The business areas report to Reitan Retail and Reitan Retail management provides support to the business areas.
Reitan Retail's business areas with operation in Norway and Uno-X Mobility’s Danish organisation have evaluated their need to initiate processes to ensure compliance with the Act. Procedures for complying with the Act are established and embedded in the boards of the subsidiaries. These subsidiaries provide individual statements according to the Act (see chart 1) with ongoing findings being reported to Reitan Retail’s EMT meetings, which are conducted weekly.
The business areas REMA 1000 Denmark and Reitan Convenience assess risks of multiple factors in their value chain, and for 2023 Reitan Retail will ensure that their due diligence assessments are accounted for according to the Act and included in the aforementioned structure for high level reporting using existing financial reporting structure and system. Even if the process outlined in the Act is not fully implemented, findings on human rights and decent working conditions and critical concerns are raised internally to Reitan Retail EMT and the respective boards. Their work on due diligence assessments is outlined in this chapter.
2.2 Direct subsidiaries of Reitan Retail with individual statement according to the Act
REMA 1000 Norway
REMA 1000 Norge AS is covered by the Act on an individual basis, and the account for human rights due diligence carried out in own operations and by its subsidiaries is detailed in own due diligence report, available on REMA 1000 Norway’s webpage under the section Vårt ansvar –Redegjørelser, here
REMA 1000 in Norway and its subsidiaries work continuously with human rights due diligence, in line with legal requirements and the OECD framework. Work on the Act is embedded in the respective boards and management and in the business area’s board and management. REMA 1000 Norway has several subsidiaries and in line with the Reitan franchise model, seeks to embed governance on the operational level. This is why REMA 1000 has had focus on assisting its subsidiaries in completing human rights risk assessments. Following the risk assessments and subsequent prioritisation of most significant risk, the responsibility of following up on identified risks and actual negative impact 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 pusued through an internally developed and integrated solution for supplier management and in-depth risk assessments.
The most significant risk in REMA 1000 Norway’s supply chain lies in the supply chain of products sold in REMA 1000 stores, that are characterised by a complex supply chain. To address this risk, suppliers are prequalified, made aware of REMA 1000 Norway’s ethical trade requirements which must be signed accordingly, and lastly compliance is followed up REMA 1000 Norway. 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 (2018). The 2023 update of the guidelines will be implemented in our assessments going forward.
Uno-X Mobility
Uno-X Mobility is covered by the Transparency Act on an individual basis, and the account for human rights due diligence carried out in own operations and its subsidiaries in Norway and Denmark is detailed in own due diligence report, available on Uno-X Mobility’s webpage under the Responsibility section, here.
The work relating to the Transparency Act has been embedded in the leadership and management of Uno-X Mobility, and guidelines and policies applicable to Uno-X Mobility and all its business areas have been established. Guidelines for supplier mapping, including human rights due diligence and risk assessments, have been implemented. Suppliers are categorised according to the implication in products sold by Uno-X Mobility.
The due diligence report covers the following subsidiaries:
- In Norway: Uno-X Mobility Norge AS, Uno-X Norge AS, Uno-X Sykkel AS, Uno-X Forsyning AS, Uno-X E-Mobility Norge AS and Uno-X Smøreolje AS
- In Denmark: Uno-X Mobility Danmark A/S, Uno-X Danmark A/S, Uno-X E-Mobility Danmark A/S, Uno-X Smøreolie A/S
2.3 Direct subsidiaries of Reitan Retail without individual statement according to the Act
REMA 1000 Denmark
As Reitan Retail’s subsidiary, REMA 1000 in Denmark is affected indirectly by the Act and the company does not account individually on the Act.
The section below covers:
- REMA 1000 Denmark A/S, Reitan Distribution A/S, REAM Danmark Butik ApS, REMA Etablering A/S and Vigo.dk ApS.
REMA 1000 Denmark work closely together with REMA 1000 Norway on subjects concerning responsible and sustainable trade. Through the sharing of experience, increased competence is gained. REMA 1000 Denmark follow the UN Guiding Principles on Business and Human Rights that set expectations of states and companies about how to prevent and address negative impacts on human rights by businesses. REMA 1000 Denmark also has its own policy on human rights. All workers in the supply chain should have decent working conditions, and the environment and surrounding communities should be protected and cared for during the production of the goods sold in our stores. REMA 1000 Denmark’s pledge is to deliver “discount with attitude” and the Act is a welcome driver in this ongoing work, taking REMA 1000 Denmark to the next level and enrolling suppliers into further ESG compliance.
Since 2018, REMA 1000 Denmark has had a risk-based approach in their value chain work, mapping risk across two verticals: ingredients and country. Amfori’s definition of risk countries is used for country-by-country risk assessments. Amfori’s list is based on an assessment from World Governance Indicators’ (WGI) and the six dimensions of governance: a) Voice and Accountability, b) Political Stability and Absence of Violence/Terrorism, c) Government Effectiveness, d) Regulatory Quality, e) Rule of Law, e) Control of Corruption.
The main driver for risk-based approach was to identify and understand value chain risk and REMA 1000 Denmark has also developed and implemented a responsible supply chain program, according to the six steps in OECDs guidelines which is widely integrated into our business.
REMA 1000 Denmark focus their efforts where they have the most influence and impact, and hence the starting point for their responsible supply chain programme, is private label products. They ask suppliers for documentation, such as BSCI reports and other relevant standards, which is uploaded in their Scanmarket system. The data is used to assess all suppliers starting from our risk matrix.
Regarding follow-up on sourcing in branded goods REMA 1000 Denmark experience less possibilities for significant impact due to minimal information. EU’s Corporate Sustainability Due Diligence Directive will drive transparency in this area. Nevertheless, all suppliers,
including branded goods are asked to sign the SCoC, in order to comply with the due diligence process.
In 2023, REMA 1000 Denmark plan to include Fruit and Vegetable in the responsible supply chain programme. Most of the cases with actual or potential risks of violations on human rights and decent working conditions are related to Fruit and Vegetables in high-risk countries.
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 2022 on their webpage 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 webpage under the section Ansvarlighed here.
Reitan Convenience AS
Reitan Convenience AS’s subsidiaries outside Norway is affected indirectly by the Act and for 2022 the following subsidiaries are covered in the section below:
- Reitan Convenience Sweden AB, Reitan Convenience Denmark A/S, R-kioski Oy, SIA Reitan Conveneience 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 and Northland and is covered by the Act on an individual basis, and the 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 webpages.
As a business area, Reitan Convenience AS has over the past couple of years taken important steps 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, and environmental ones such as deforestation and associated biodiversity loss.
The due diligence assessment process for commodities, though ongoing and in need of further improvement, is already providing crucial insights into supply chain dynamics and assists Reitan Convenience in prioritising improvement work with first-tier suppliers. Over the past years, they have built a shared system for the seven-country organisation where they collect and store product sustainability data, including data on origin countries for risk commodities. The mapping is conducted on a product level rather than on any aggregated level such as category, which both means better data quality and enables more specific responses. Thus, the potential measures range from fixing overall problematic tendencies in the assortments to acting on one specific product from one specific supplier. Finally, all the analyses we make are connected to our sales data, which means that we can prioritise sustainability actions with the biggest impact.
In parallel, their joint SCoC have been sharpened, to ensure their strong position on risk commodities is clear to all suppliers. Reitan Retail AS’s SCoC is implemented in all Reitan Convenience subsidiaries.
In 2023, all Reitan Convenience-countries will have implemented a whistleblowing system that is externally available. In the meantime, there is always the possibility to report cases in Reitan Retail's whistleblowing system, which is available on Reitan Retail's webpage.
Across the seven countries Reitan Convenience operates within, mapping for any given risk commodity generally reveals that sourcing origins are somewhat centralised. For example, while Reitan Convenience has numerous confectionery suppliers, palm oil is almost exclusively derived from Indonesia and Malaysia. This was expected as these countries are the two largest palm oil exporters globally. Nonetheless, it is relevant for Reitan Convenience to have this information on a product level as it enables us to get to know our assortment on a deeper level and measure progress from a variety of parameters.
Below is an extract of the business intelligence tool used by Reitan Convenience in which the sourcing origins are visualised for palm-oil, cocoa, and coffee. These three commodities are deemed as high-risk in regards of human rights and decent working conditions in Reitan Convenience’s vale chain.
Figure1- Current view of the sourcing origins of cacao, coffee, and palm oil in Reitan Convenience’s sustainability-focused business intelligence tool. Colour intensity corresponds to the count of articles containing any of these. The data is provided by first tier suppliers and is not yet complete for all assortments across Reitan Convenience but is likely quite representative.
To address these challenges, we will proceed to map the full assortment while also continuing and strengthening partnerships with suppliers to accelerate the transformation of these value
chains towards ethical, sustainable practices. These issues call for open communication and partnerships with stakeholders, which also helps build accountability and trust. In parallel each Reitan Convenience subsidiary is sharpening their positions on all risk commodities with suitable boundary conditions and quantitative targets. In the case of palm oil, for example, these range from by phasing it out altogether in some country organisations in the coming years, to limiting use and moving towards RSPO-certified options only in other countries.
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 2022 on reitanretail.no under the section Our responsibility-Reports and here.
Reitan Convenience Norway
Reitan Convenience Norway AS operates the brands Narvesen, 7-Eleven and Northland and is covered by the Act on an individual basis, and the 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 webpages.
The work relating to the Act has been embedded in the leadership and management of Reitan Convenience Norway, and guidelines and policies applicable to Reitan Convenience Norway and all its brands have been established.
Reitan Convenience Norway has conducted assessment of risk of negative impact on human rights and decent working conditions in its supply chain. The purchase of goods sold in Reitan Convenience Norway’s sales outlets are mostly done through the REMA 1000 Norway subsidiary Kolly AS. Kolly’s due diligence assessments on human rights and decent working conditions are covered by REMA 1000 Norge AS’s statement according to the Act. For other suppliers, with operations in Norway, it has been assessed that the risk of negative impact is low. The risk related to suppliers is also assessed as low.
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 with much more for Reitan Retail employees.
Gladengen Drift AS is included in Reitan Retail’s whistleblowing policy and channel. The whistleblowing channel, described in the Codes of Conduct and in the whistleblowing policy is available on reitanretail.no, and allows employees, suppliers, or any other stakeholder to report experienced or suspicion of unacceptable behavior in violation of Reitan Retail’s values, ethical guidelines or regulations, without fear of retaliation against the whistleblower.
In the due diligence on human rights Gladengen Drift mapped and categorised their 144 suppliers based on services and goods provided and conducted risk assessments. A review of risk factors together with personal knowledge of their suppliers indicated which suppliers had potentially high-risk for fundamental human rights and decent working conditions.
25 suppliers from whom they needed more information was approached in writing with requests to provide information according to the transparency act together with Reitan
Retail’s SCoC. The approached suppliers provide goods such as furniture, hardware and packaging and services such as cleaning and carpentry. Gladengen Drift AS received positive response from all suppliers, some called to ask questions, others sent emails and open communication was established with the suppliers in high-risk category. As a result, the SCoC was signed by all and additional information regarding internal processes and policies was received from multiple suppliers specifying how they approach human rights due diligence according to the transparency act.
No actual negative impact has been uncovered by Gladengen Drift AS. All new suppliers will be risk assessed according to the Act to ensure joint understanding of the law.
The work of risk evaluation of suppliers in Gladengen Drift has been time-consuming, but in a good way. The company was happy to learn that most of the approached suppliers had already started their due diligence assessments and gathering necessary data. The communication was positive and seemingly the aim of the transparency act was welcomed and taken seriously.
Questions about Gladengen Drift’s work on the Act can be directed to Kristine Kvakkestad kristine.kvakkestad@gladengendrift.no
2.4 Identified negative impact
The following negative impact has been identified in the REMA 1000 Norway’s supply chain:
• Solar panels: This has been identified as a product category with significant risk. In depth risk assessment and supply chain mapping have been completed, indicating that the REMA 1000 supply chain does not include products connected to the high-risk Xinjiang region in China.
• Production site in Thailand with low BSCI audit score: REMA 1000 Norway is working with the supplier on implementing measures to improve the situation.
• Supplier report of significant risk relating to production site in Vietnam: An identified potential negative impact on migrant workers from Myanmar was identified at production site in Vietnam, with suspected practice of recruitment fees. This was followed up on by an on-site audit, and after dialogue with the production site, they have abandoned the recruitment fee practice.
• Kolonihagens kaffefond: Challenges connected to the payout to farmers of profits raised through the fund, lead to the decision to certify coffee products with Rainforest Alliance.
•
More information about the uncovered negative impact and implemented measures can be found in the REMA 1000 Norway’s statement according to the Transparency Act here
Due diligence assessments, including human rights are ongoingly revised, improved and implemented in Reitan Retail. As a result of the last quarters’ retrieval of data from suppliers on human rights due diligence, thoroughly mapping the origin of raw materials and systemising external certifications of production facilities among further criterions, we are reminded that both the complexity and responsibility are of great magnitude.
Besides clarifications needed and dialogue with risk suppliers no actual negative impact was uncovered by Uno-X Mobility, Reitan Convenience, Reitan Retail directly, or for the subsidiaries accounted for by Reitan Retail. This outlies that we currently do not manage to identify all areas with actual and potential negative impact in our value chain. We are progressing on the
work and aim for our subsidiaries to have fully structured system for following up suppliers in the years to come.
2.5 Risks identified, prioritisation and aggregated data
Risks identified through high-level risk assessments in our business areas
With operations in the sectors food, agriculture, fuel and mobility, our supply chains are global, complex, and exposed to climate change. Challenges linked to forced labour, child labour, corruption, freedom of association, discrimination, living wage and environmental destruction are significant in these sectors and with the expected consequences of several factors such as climate change and geopolitical conflicts are set to worsen in the years to come.
As a result of workshops led by Reitan Retail, conversations on risk management across the business areas, annual reporting of suppliers being screened and the subsidiaries' due diligence assessments, Reitan Retail have identified two main risk areas for the goods we sell in our stores and for the fuel and energy suppliers in Uno-X Mobility. Additionally, other highrisk supplier categories for the products and services that are vital for our daily operations are identified for the overall business.
To main risk categories for the goods we sell
1) Foodandnon-food
The substantive part of our suppliers are connected to the goods we sell in our 3,000 discount grocery stores and convenience sales outlets. There is a high risk for violations of human rights in the raw material market, risks are also present in the product manufacturing stage.
a) Riskrelatedtorawmaterialsandgeographicorigin
Child labour and forced labour are especially widespread and well-documented in the supply chains of tea, coffee, cocoa, cane sugar and tropical fruit. There are also documented cases of migrants working under slave-like working conditions for products produced in Europe1. The agricultural sector, especially in developing countries, is characterised by informal labour. There are also health risks linked to the use of pesticides2. Given this risk assessment, both raw materials and geographical production location are prioritised risk areas.
High-riskrawmaterialsandgeographicallocationidentified
• Palm oil, Soy, Scampi, Tuna fish, Cocoa, Coffee and tea, Hazelnuts and Cashew nuts
• Bangladesh, China, Malaysia, Morocco, Pakistan, Philippines, Sri Lanka, Thailand, Tunisia, Turkey and Vietnam.
The above-mentioned raw materials are followed up in REMA 1000 Norway and Denmark by using a dedicated raw material risk tool, and they are addressed by leveraging certifications (Fairtrade, RFA, MSC, a.o.). For the same high-risk raw materials, both REMA 1000 in Norway and Denmark have internal policies which are approved by their boards and anchored in REMA 1000's management team as well as the management team of the Category and Purchasing departments. In addition, mandatory training courses have been developed for everyone working with purchase of goods and with supplier contact.
1 Direktoratet for forvaltning og økonomistyring
2 OECD-FAO Guidance for Responsible Agricultural Supply Chain
b) Risksrelatedtoproductmanufacturing
Reitan Convenience Norway conducted factory audits in Italy, Lithuania and Latvia, covering working conditions, and no negative impact was uncovered. It has been profiled that there may be a risk of negative impact on human rights and decent working conditions at five other production sites, based on geographical risk. Reitan Convenience Norway is in dialogue with these suppliers, and audits and follow-up of these sites to further assess risk and potential negative impact is planned for 2023.
REMA 1000 use production sites in high-risk countries. The geographical risk is addressed by gathering information about suppliers and productions sites, in order to map the provenance of ingredients in all products.
2) Fuelandbiofuel
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.
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 labour3 .
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 process4
Manufacturing– 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. Risks of forced labour and possible slavery of indigenous people in Xinjiang province in China halted the rollout and intensified the due diligence assessment of the suppliers. Description on the process can be found in REMA 1000 Norway’s statement according to the Act, on their webpage under the section Vårt ansvar – Aktsomhetsvurderinger, here.
IT – hardware,softwareandservices- 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 products5. 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 6
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 accidents7
Aggregated quantitative reporting on due diligence assessments and findings
Reitan Retail operates in seven countries, within different sectors, and our value chains spans all over the world with related complexity. In the journey to understand this magnitude Reitan Retail developed a reporting format for quantitative data relating to the Act. The reporting format was distributed all our Norwegian subsidiaries, as well as Uno-X Mobility’s Danish operations. The collected data, reported as per February 2023, gave us valuable context and relevant information to determine processes going forward. Foremost, the quantitative reporting will be implemented in international subsidiaries for the 2023 reporting to provide context on supplier categorisation.
Quantitative data collected relating to the Norwegian Transparency Act
• Around 4,800 suppliers have been risk assessed, equaling around 67 percent of all suppliers reported from our Norwegian subsidiaries and Uno-X Mobility in Denmark. Priorities have been made and the reasons for suppliers not being fully risk assessed includes transaction size, relevance to the subsidiary’s operation, determined low risk etc.
• 542 suppliers and production facilities are assessed to have high or very high risk. These suppliers are mainly in the categories food/non-food and manufacturing.
• In 2022, Reitan Retail conducted 65 on-site visits and initiated dialogue with the aim of collaboration to secure satisfactory conditions.
• 633 initiated conversations, dialogues and self-assessments were carried out with suppliers after risk assessments.
• Due diligence assessments in REMA 1000 Norway indicated need for action beyond dialogue in four cases. Descriptive information can be found in part 2.2 in this statement, and in REMA 1000 Norway’s statement according to the Act which can be read on their webpage under the section Vårt ansvar – Aktsomhetsvurderinger, here
3. Measures, results and actions
3.1 Measures to mitigate risks
Reitan Retail has so far focused on embedding human rights due diligence in the organisation and our business areas, as detailed earlier in the report in part 2.3.
An integral part of this work has been to establish internal reporting lines, whereby the business areas are reporting regularly on their human rights due diligence efforts in both qualitative and quantitative measures. This allows for accountability and tracking of implementation. See section Quantitative data collected relating to the Norwegian Transparency Act.
As the operational responsibility for conducting human right due diligence lies with the business areas and their respective subsidiaries, risk mitigation activities are carried out by them individually. For a detailed account on all activities to prevent, reduce or mitigate human rights and labor risks we refer to the reports of:
• REMA 1000 Norge AS
• REMA Distribusjon Norge AS
• REMA Industrier AS
• Norsk Kylling AS
• Stanges Gårdsprodukter AS
• Kjeldsberg Kaffebrenneri AS
• Grans Bryggeri AS
• Reitan Convenience Norway AS
• Uno-X Mobility AS
To illustrate the efforts conducted throughout the business areas, we are highlighting some key 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 framework agreement with the supplier code of conduct is signed, production sites are certified according to GFSI and have Sedex/BSCI membership, suppliers carry out human rights due diligence, they have access to information, REMA 1000 policies for high-risk raw materials are implemented, and that suspected or actual breach of the supplier code of conduct is reported.
Policies and guidelines form the foundation of REMA 1000 Norway’s work on due diligence assessments and constitute the following documents:
- Policy for sustainable business practices
- Policy for risk-exposed raw materials
- Policy against child labour
- Policy against modern slavery
- Policy for good animal welfare
- Policy against food crime
- Routine for due diligence assessments and
r responsible procurement
- Routine for recovery
Uno-X Mobility takes a strong stance towards no soy and palm oil in their purchased products and acquire sustainability certificates from certified institutes on all purchases of biofuels, further verified by a third party in accordance with official requirements in Norway and Denmark in order to mitigate this potential risk. Furthermore, given the inherent risks in the oil and gas industry risk, Uno-X Mobility uses suppliers with strict internal guidelines, and who monitor their supply chains closely. Suppliers are expected to adhere to the Uno-X Mobility supplier code of conduct.
Reitan Convenience Norway enters framework agreements including its supplier code of conduct with all suppliers. The company communicates its expectations on ethical trade and compliance with the Act in engagement with suppliers and is planning to further strengthen the integration of the expectations of the Act in supplier processes in 2023.
3.2 Actions and plans
The work on embedding human rights due diligence, establishing internal guidance and reporting on human rights risk assessments, has resulted in clearer structures and expectations for the work in 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.
Overall, we have obtained a good overview of risks of negative impact to human rights and decent working conditions in our value chain As a result of the last quarters’ retrieval of data from suppliers on human rights due diligence, thoroughly mapping the origin of raw materials and systemising external certifications of production facilities among further criterions, we are reminded that both the complexity and responsibility are of great magnitude.
Besides clarifications needed and dialogue with risk suppliers no actual negative impact was uncovered by Uno-X Mobility, Reitan Convenience, Reitan Retail directly, or for the subsidiaries accounted for by Reitan Retail. This outlies that we currently do not manage to identify all areas with actual and potential negative impact in our value chain. We are progressing on the work and aim for our subsidiaries to have fully structured system for following up suppliers in the time to come.
Increased effort will continue in 2023, with resource allocation on technical systems for information gathering on suppliers, production facilities and commodities in products. Among the subsidiaries, dedicated personnel work across departments to integrate systemic thinking and managing operations to prevent human rights violations. Further in 2023 and going forward we will continue onboarding the international part of our business areas on the same reporting expectations as outlined in the Act. The experience from our Norwegian subsidiaries will serve as a foundation for our follow-up and support to international subsidiaries.
One of Reitan Retail's values is that we talk with each other, not about each other. We try to live up to this both internally and in collaboration with customers, suppliers and all other stakeholders. In 2023, Reitan Retail’s collaboration with Nobel Peace Center will enhance our communication on the importance of dialogue and work on human rights. We believe that conflicts can be avoided, and that the world becomes a better place with open and good dialogue.
Additionally, environmental risks, animal welfare, corruption and tax risks are equally important as human rights, and we will investigate implementation of multi-dimensional ESG risk management going forward for all business areas and subsidiaries.
4. Information, contact, approval
4.1 Information
This statement is available on our webpage, reitanretail.no. A reference to our work can also be found in the annual and sustainability report for 2022 – responsible retail on our webpage or upon request. The statement will be updated as required by the Act, in line with material changes in the overall risk assessments and at the latest by 30 June, 2024.
4.2 Contact
For general information about how Reitan Retail apply to the transparency act or information relating to a specific product or service offered by the company, please contact us. post@reitanretail.no
Reitan Retail AS
Gladengveien 2
0661 Oslo
For questions about this statement contact Sandy Schrøder, sandy.schroder@reitanretail.no
4.3 Approval
Reitan Retail’s statement according to the transparency act as per May 2023 was approved by the company’s Board of Directors and CEO in June 2023
Rune Bjerke, Chairman of the board
Magnus Reitan, Board member
Eilert Hanoa, Board member
Ole Robert Reitan, CEO