
S1-2: Processes for engaging with own workforce and
workers’ representatives about impacts
In Norway, employee engagement surveys and performance
and development reviews are both conducted semi-annually. In
Poland, performance reviews and development interviews are
both conducted once a year. Poland also has fewer formal
platforms for engaging with employees, where they can voice
their opinions and questions. The employee engagement
surveys and performance and development reviews provide
platforms for all employees to offer input and feedback on
workplace conditions.
Performance reviews and development interviews are crucial
for development, motivation, and sharing thoughts and
feedback. They cover well-being, work tasks, goal setting,
development, and other relevant topics. We also encourage
more frequent one-to-one conversations between managers
and employees.
The employee engagement survey in Norway, which is
anonymous and presented at an aggregated level, includes
questions on employee engagement, inclusion and diversity,
the psychosocial and physical work environment, and
adherence to our values. It also features open-ended questions
for general feedback. After each employee engagement
survey, we evaluate the results and establish action points
based on employee feedback. We also review and adjust the
survey questions as needed. Engagement with our workforce is
otherwise followed up on an ongoing basis. The HR Director is
responsible for ensuring that engagement happens and that
results inform our approach.
In Norway, every office has a safety representative, and we
also have a main safety representative and an employee
representative. These representatives serve on the Working
Environment Committee (WEC) alongside two management
representatives. The WEC addresses matters related to the
working environment, including HSE issues, safety inspections,
and preventive measures. The committee meets four times a
year, with additional meetings as needed. Employees can bring
matters to the WEC through their safety representative.
By law in both Norway and Poland, we do not collect data on
origin, religion, disability, or similar characteristics. In Poland, a
person with certain level of disability has a right to additional
days of holiday. To be able to use this right, the employee must
deliver specific confirmation to the employer. However, the
employer cannot ask that question at any stage. Our statutory
statement on equality and anti-discrimination in Norway details
our work on equality, diversity, and inclusion, and includes
goals for gender balance at various position levels, especially
in top management. There is no equivalent report on this
demanded in Poland.
S1-3: Processes to remediate negative impacts and
channels for own workforce to raise concerns
Our whistleblowing routine, which is statutory for Norwegian
and Polish companies, allows employees to raise concerns
through a dedicated channel.
In Norway, the whistleblowing channel is available in the
employee handbook and via a link in our HR system. The
details of this routine are described in the employee handbook.
The HR Director is the sole receiver of concerns raised through
dedicated digital forms. Reports can also be submitted in
writing to an employer representative, safety representative,
union representative, or lawyer. The recipient ensures the
report is followed up and managed by the HR Director, who
investigates within a reasonable time and informs the
whistleblower of the outcome. If the investigation takes longer
than what is considered a reasonable time, the whistleblower is
notified. Once the case is fully processed, the concerned
individual(s) are informed of the outcome. If the whistleblower
is anonymous, they will not be informed.
The Personal Data Act is observed in processing all personal
data, and confidentiality rules are strictly followed. The
employer ensures the traceability of the whistleblowing
process, including preparing minutes from interviews. All
documentation is deleted in accordance with the Personal Data
Act once it is no longer necessary.
In addition to the whistleblowing channel, we have regional
HR personnel, safety representatives, and a Working
Environment Committee (WEC) in Norway. Employees can
always speak to their regional HR person if they have
questions regarding workplace conditions
In Poland, the whistleblowing channel and routine is available
on the intranet, where there is a link to the forms where an
employee, intern or contractor can report a violation. The
procedure is based on the EU Whistleblowing Directive (EU
2019/1937) through the Whistleblowers Protection Act of 14
June 2024, which also expands the scope of reportable issues
beyond the EU Directive to include corruption, matters
involving state financial interests, and violations of
constitutional rights. The routine mainly describes how and in
which areas employees can report a violation, the steps taken
by the employer to clarify the situation, who is a part of the
committee which will investigate the report and how the
employee is protected. The investigating committee consists
of three managers or top-level resources, in addition to two
potential members in case of the absence of one of the three
others. If the violation report refers to any of the committee’s
members, it will be passed to proxy who will nominate another
member. It is forbidden that the committee members are
proxy, or member of the board, a whistle-blower, his/her direct
manager or subordinate. Whistleblowers are protected from
retaliation, and the Act applies broadly to employees, former
employees, contractors, job candidates, interns, volunteers,
shareholders, and others working under the supervision of
contractors or suppliers.
S1-4: Taking action on material impacts on own
workforce and approaches to mitigate material risks and
pursuing material opportunities related to own workforce
and effectiveness of those actions
Fluctuating workload
In our industry, it is well known that the workload can increase
during the annual reporting season. While this fluctuating
workload can create opportunities for employees to earn
more, it can also put pressure on work-life balance during
these periods. We have several routines and measures in
place to address fluctuating workloads.
Managers in Norway are responsible for reviewing and
approving their team’s timesheets on a weekly basis. This
provides a clear overview of each employee’s workload and
makes it easier to identify and address potential overloads or
idle time. We have organized most of our workforce in Norway
into portfolios based on core competencies and industry
expertise. Portfolio managers have regular meetings to
discuss workloads and redistribute capacity when needed.
In Norway, we also conduct a semi-annual employee survey,
which includes a question about perceived workload. The HR
department monitors these results and implements
appropriate measures when necessary. Our employee
handbook in Norway includes our insurance scheme. We
have better insurance coverage than what is required by law.
The scheme includes private medical insurance, which can
help employees with repetitive strain injuries, that could be a
result of workload.
In Poland, workload is managed by managers on an ongoing
basis – we monitor capacity, redistribute tasks within teams,
and move resources between teams when needed to ensure
efficiency and continuity. Workload is actively monitored
through monthly flexi worksheets and regular discussions with
managers. We pay particular attention to per-employee
workload indicators that may signal risk of overload and act
when needed. We also monitor vacation usage regularly to
support sustainable work patterns and help employees
maintain a healthy work-life balance.
In recruitment processes in both countries, our approach is to
recruit based on specific needs in each portfolio or team,
which also supports resource allocation and can reduce
unwanted high workloads and prevent idle time for new
employees.