The Transparency Act

The Norwegian Transparency Act (Åpenhetsloven) aims to promote businesses’ respect for fundamental human rights and decent working conditions, while ensuring public access to information on how we address potential negative consequences on fundamental human rights and decent working conditions.

Our Approach

Småkraft is a leading renewable energy company specialized in generating renewable energy through small hydropower plants. As a company with long-term ambitions, we develop, build, and operate hydropower plants in Norway and Sweden. In a normal year, we produce 2TWh of renewable hydropower, and our goal is to increase this to 3TWh by 2027. Småkraft’s operations center is located in Bergen, but we also have a presence in Oslo, Flatanger, Hamar, Nittedal, Sandnes, Harstad, and Uppsala in Sweden.

Since 2017, Småkraft has prepared and published an annual sustainability report. In 2022, we also incorporated the requirements of the Transparency Act as a fundamental premise for our sustainability work and started implementing these requirements in our governing documents.

This document summarizes the due diligence assessment we conducted in connection with the implementation of the requirements of the Transparency Act. Detailed information about our requirements for safe behaviour and awareness of social responsibility in the communities around our power plants can be found in Chapter 2 of the sustainability report, available on the company’s website. In Chapter 4 of the same document, you can find comprehensive information about our assessment of various risk factors related to our operations.

These requirements apply not only to our own employees but also to our suppliers and external parties with whom we collaborate in the construction and operation of our power plants. The sustainability report for 2022 was presented and approved by the board of Småkraft AS on March 28, 2023.

Due Diligence Assessment

Since 2020, Småkraft has conducted a risk assessment of all aspects of our operations. This assessment is updated annually based on external requirements such as laws and regulations, as well as demands from owners or investors and internal standards outlined in our quality handbook, including requirements related to human rights and decent working conditions. Each risk element is classified based on both probability and consequence and covers our own employees, suppliers, and partners.

Based on the identified risks, we conduct due diligence assessments that identify how we address negative consequences related to violation of fundamental human rights. Especially in connection with procurement related to the construction of new power plants but also required procurement for regular operations, there is an inherent risk of non-compliance with our requirements for social behaviour, which requires special attention. This is followed up through regular supplier monitoring, participation in construction meetings, and follow-up of deliveries.

Additionally, because of the implementation of the Transparency Act, we have sent letters to our suppliers clarifying our requirements for environmental and social considerations, including human rights and anti-corruption efforts. We have also obtained signed confirmation from the suppliers that they comply with these requirements in their own operations and will ensure that their subcontractors do the same.

As part of the implementation of the Transparency Act, we have also developed ethical guidelines for our employees, which have been reviewed and signed by all employees during the annual appraisal. No breaches or negative consequences related to Småkraft’s operations or our suppliers’ operations were uncovered in 2022.

To further reduce the risk, we will work towards further integrating the requirements into our work processes in 2023 and ensure their implementation and compliance within the organization.

In 2023, we will also conduct a re-evaluation of our risk elements to ensure that we adapt to changing conditions and internal and external demands on the business.

On our website, we have established a procedure for handling notifications of breaches of our obligations, guidelines, and ethical standards. Småkraft did not receive any such notifications in 2022.