Norwegian Transparency Act 2023

Snøhetta is committed to comply with the requirements set out in The Norwegian Act relating to enterprises' transparency and work on fundamental human rights and decent working conditions (the “Transparency Act”). This due diligence report covers the fiscal year of 2023, from 1 January to 31 December 2023. The report is prepared and provided by Snøhetta pursuant to Section 5 of the Transparency Act.

At the heart of all Snøhetta’s work lies a commitment to social sustainability, shaping the built environment in the service of humanism. We know that with well-conceived design we can help things run more efficiently, improve people’s well-being, and make life more enjoyable. To achieve this, Snøhetta creates generous designs that respect the character of each project’s unique preconditions such as climate, people, culture, and history.

This joint due diligence report is provided by and covers Snøhetta AS (reg. no. 998 597 013) ("Snøhetta AS"), Snøhetta Oslo AS (reg. no. 995 135 485) (“Snøhetta Oslo”), and Snøhetta Design AS (reg. no. 895 518 212) (“Snøhetta Design”). The board of directors of Snøhetta AS, Snøhetta Oslo AS and Snøhetta Design AS approved this report on 30 April 2024.

For the purpose of this report, all descriptions of "Snøhetta" refers to the corporate group of the abovementioned entities, whereas information regarding specific entities in the group is specified with separate subsections. Descriptions of “Snøhetta Group” refer to the entire corporate group of Snøhetta AS and its subsidiaries, as further described below. A description of planned due diligence efforts in Snøhetta AS' foreign subsidiaries is provided at the end of this report.

1. General information

Snøhetta Group is a transdisciplinary practice including architecture, landscape architecture, interior architecture, art, product design, graphic and digital design. Snøhetta AS is the parent company to all Snøhetta fully and partially owned subsidiaries, often referred to as studios, and has its home office in Oslo, Norway.

In addition to Snøhetta AS, Snøhetta Oslo and Snøhetta Design, the operations of which are further described under separate subsections below, the Snøhetta Group consist of:

• Snøhetta Studio Innsbruck – a studio with a broad multidisciplinary team within architecture, landscape architecture, interior architecture. This studio works in Austria, Northern Italy, Southern Germany and parts of eastern Europe. The studio is located in Innsbruck, Austria.
• Snøhetta Studio Paris – a studio with a multidisciplinary team within architecture and landscape architecture. The studio works in France, French Switzerland, and French Luxembourg. The studio is located in Paris, France.
• Snøhetta Studio Hong Kong – a studio with a broad multidisciplinary team within architecture, landscape architecture, interior architecture. The studio works across Asia and is located in Hong Kong, China.
• Snøhetta Studio Shenzhen - a studio with a broad multidisciplinary team within architecture, landscape architecture, interior architecture. The studio works in China.
• Snøhetta Studio Adelaide - a studio with a broad multidisciplinary team within architecture, landscape architecture, interior architecture, art curation and bespoke furniture design. The studio works across Australasia and is located in Adelaide with a branch office in Melbourne, Australia.
• Snøhetta Overseas – this company has partially been consolidated in Snøhetta Oslo. The studio holds contracts for ongoing work which is delivered by Snøhetta Oslo and will be closed once the contracts are fulfilled.

In addition, Snøhetta AS has a brand trademark agreement with Snohetta Architecture Design Planning P.C. in New York.

2. Snøhetta AS

Snøhetta AS functions as the ultimate holding company of the Snøhetta Group and manages the brand in addition to ensuring strategic and operational development of the studios. Apart from this, Snøhetta AS’ operations are primarily carried out through its operative studios, including Snøhetta Oslo and Snøhetta Design, which are wholly owned subsidiaries of Snøhetta AS. Snøhetta AS is located in Oslo, Norway, and has its registered office at Akershusstranda 21, 0150 Oslo, Norway.

3. Snøhetta Oslo AS

Snøhetta Oslo is based in Oslo and works in a wide variety of geographical regions, including in the Nordics, Europe, Africa, and the Middle East. Snøhetta Oslo is the largest studio in the Snøhetta Group and provides architectural services, including landscape and interior architecture, within a wide range of typologies, as well as product design services globally. The services offered by Snøhetta Oslo are architectural services usually delivered directly to the client from the early stages of a project and up until or including architectural services in the construction phase. As such, Snøhetta does normally not have a contractual relationship with the providers carrying out the construction work as these are normally contracted by the client. In larger projects Snøhetta typically has one or several subconsultants providing consultancy services within other areas of expertise such as engineering.

Snøhetta Oslo has its registered office at Akershusstranda 21, 0150 Oslo, Norway.

4. Snøhetta Design AS

Snøhetta Design is, like Snøhetta Oslo, based in Oslo, and operates globally, both on individual design-specific projects and as part of architectural projects run by the architectural studios within the Snøhetta Group.

Snøhetta Design offers consultancy services alongside graphic production and product delivery, including preparing files for printing or digital distribution, as well as designing and developing digital products and services. Projects include corporate branding, logo design, and other visual communication tasks, design of printed materials like books, magazines, posters, and packaging, as well as wayfinding/signage systems, and digital projects such as web design and TV graphics.

Snøhetta Design has its registered office at Akershusstranda 21, 0150 Oslo, Norway.

Our efforts related to the Transparency Act are anchored with the board of directors of Snøhetta AS, Snøhetta Oslo and Snøhetta Design, setting the "tone from the top" within each entity as well as establishing it as a prioritized area for Snøhetta. To ensure that social sustainability is implemented in our operations, Snøhetta AS, Snøhetta Oslo and Snøhetta Design have established various policies, guidelines, and tools to ensure our commitment to respect and promote fundamental human rights and decent working conditions. The routines are similar for all three companies but are tailored to reflect the individual risk factors relevant for each company.

Within Snøhetta's own operations, we primarily work office based as architects and designers. As such, the risk of adverse impact on human rights and decent working conditions in our own operations is limited. However, we are committed to ensure a safe and healthy working environment. This is enforced through our health and safety policies, whistle blower channel, code of conduct and other relevant measures. Snøhetta also has a variety of other policies and statements in place, communicating our commitment and approach to collaboration; environment; equality, diversity, and inclusion; quality management; and sustainability. Further, Snøhetta has adopted a human rights policy which stipulates our ambition and commitment to ensure respect and promotion of fundamental human rights and working conditions in our operations, supply chain and business relationships.

In relation to our supply chain, Snøhetta has established an internal third-party management routine which sets out the procedure for how Snøhetta seeks to ensure control over our supply chain and mitigate the risk of breach of fundamental human rights and decent working conditions. Our third-party code of conduct is communicated to our suppliers and clients setting out the minimum requirements that Snøhetta expects all third parties to meet to ensure that the third parties’ actions are consistent with Snøhetta’s values and high ethical standards. This is further ensured through appropriate contract clauses, which require the suppliers to assess the risk in their own supply chains. Snøhetta has also implemented routines for risk assessments of our supply chain, including background checks and appropriate follow up measures and audits during the contractual relationship.

Further, Snøhetta has implemented an online whistleblower portal on our website allowing individuals to report incidents or concerning behavior through an external platform. The platform is secure and allows whistleblowers to opt for complete anonymity. Any reports will be handled by Snøhetta AS, who will follow up confidentially. The whistleblower will have the opportunity to communicate with the case handlers in Snøhetta and provide more details about the incident throughout the process.

The management teams of Snøhetta AS, Snøhetta Oslo and Snøhetta Design are responsible for performing assessment of risk relating to human rights and labor conditions in Snøhetta's operations and supply chain. Risk assessment, evaluations, mitigating measures and tracking of suppliers and business partners are conducted on a continuous basis and followed up throughout each of Snøhetta’s projects.

The risk factors applicable to Snøhetta in general are closely tied to the risks inherent to the architecture and design industry. In our projects, Snøhetta procures various architectural, engineering, consultancy and other specialist services from highly skilled companies and highly educated professionals within their respective fields. This reduces the risk in our supply chain. Additionally, most of our services are carried out in the early phases of a project, further reducing risk in the supply chain.

Snøhetta’s supply chain risks typically depend on the geographical location of the project. The risk of breach of fundamental human rights and decent working conditions is considered most prominent for projects in the Middle East and Southeast Europe. There is also a risk of financing with Russian funds, which is particularly relevant for suppliers in Eastern Europe and the Middle East. We seek to mitigate this risk by conducting due diligence reviews and requiring confirmations from clients and suppliers that they are not subject to any applicable sanctions. Further, the security situation in the Middle East due to the ongoing war in Gaza and in Europe following the Russian invasion of Ukraine increases the risk for projects in these regions. Extended due diligence is carried out for potential projects in affected regions as well as in regions where there is a risk of funding from individuals, countries, and companies under sanctions.

Snøhetta AS, Snøhetta Oslo and Snøhetta Design conduct due diligence of our own operations and supply chain. The routine for such due diligence is similar for all three companies but is tailored to the relevant risk factors in each company. For the due diligence review of Snøhetta’s suppliers we are mapping our supply chains through a risk classification tool. The tool is used to assess the risk related to suppliers based on factors such as the supplier’s nationality, industry, operating risk, use of sub-contractors, and internal routines.

Based on the mapping we categorize our suppliers as either low, medium, or high-risk suppliers. The classification determines whether further investigations should be carried out prior to the contractual relationship, and how Snøhetta approaches its relationship with the respective supplier. The assessments are carried out on a continuous basis and applies to both existing and new suppliers. Local suppliers of office materials, cleaning services, food services and other administrative services for Snøhetta’s offices in Oslo apply to Snøhetta AS, Snøhetta Oslo and Snøhetta Design. In addition, each Snøhetta company has a particular supply chain connected to its operating activities as described below.

1. Snøhetta AS

Snøhetta AS' operations is managing and developing the Snøhetta brand, its overall operations, and the company's subsidiaries. Its supply chain is limited, consisting mainly of administrative support functions and subscriptions of joint technical solutions.

2. Snøhetta Oslo AS

Snøhetta Oslo primarily operates in the architecture industry, an industry in which the risk varies in the different phases of a project. The risk of negative impact on human rights and working conditions is considered most prominent in the construction phase, whereas the risk is significantly lower in the design phase. The actual construction is not a service supplied to Snøhetta, but directly to the client/owner of the relevant development.

Snøhetta Oslo mainly procures professional services from suppliers. The main consultancy services that Snøhetta Oslo procures from are engineering, architectural, design, acoustics, landscape, and IT services. As stated above, there is an increased risk related to suppliers in certain geographical regions. As we are almost exclusively dealing with professional services and service providers, the risk of negative impact on human rights in our supply chain is, however, relatively limited also in such regions.

3. Snøhetta Design AS

The risk of negative impact on human rights and working conditions is generally considered to be limited for Snøhetta Design. The industry is considered to generally carry low risk across project phases.

Snøhetta Design mainly procures professional services from suppliers. The main consultancy services that Snøhetta Design procures from are design, printing, digital development, and IT services. As for Snøhetta Oslo, Snøhetta Design’s supply chain risk is also tied to the region in which the suppliers are located, and we experience increased risk with suppliers in the Middle East, Southeast Europe, and the Asia Pacific.

As of the date of this report, Snøhetta has not identified any actual adverse impacts in the due diligence review of our suppliers. Snøhetta acknowledge that the risk of breach of fundamental human rights and decent working conditions is considered most prominent for projects in the Middle East and Southeast Europe. The most prominent risk in these regions, as well as in Snøhetta’s other markets, include risk related to i) health safety and environment (including work related accidents and injuries), ii) compliance with working time regulations, iii) ensuring workers receive an acceptable wage and iv) work-related crime. We continue our efforts to carefully carry out due diligence reviews for potential suppliers in these regions, and new suppliers in other regions. In addition to this, Snøhetta aims to improve the due diligence processes throughout the supply chain.

Tools:

Snøhetta implements appropriate measures on a risk-based approach and based on the principle of proportionality. We want to use our position and our influence to ensure and promote respect for fundamental human rights and decent working conditions. Based on the outcome of the risk analysis we will implement the measures we consider necessary and appropriate based on any actual and potential risk identified.

As the due diligence review of our supply chain is being conducted on a continuous basis, we will concurrently assess whether and to what extent measures should be implemented towards our suppliers. Such measures may include dialogue with suppliers, background checks, audits, signing of our third-party code of conduct and contract clauses, consultation of internal key functions and external advisors, further due diligence reviews and obtaining additional information and documentation from the suppliers. If significant risk or breach of human rights and decent working conditions is identified, measures may also include termination of the contractual relationship with the respective supplier. The measures will set clear expectations to the conduct of Snøhetta's suppliers, as well as increase Snøhetta's control over the supplier and discretion to implement relevant measures.

Measures implemented in 2023:

Since the last reporting date, we have included our third-party code of conduct in new supplier agreements, an effort that will continue going forward. Other measures implemented in 2023 include implementation of the online whistleblower portal, publishing the third-party code of conduct on our website and including it in our general terms and conditions, which illustrates Snøhetta’s commitment to respect and promote fundamental human rights and decent working conditions. Requirements to adhere to the Norwegian Transparency Act has been implemented into our standard subconsultant agreements. Although it is challenging to get foreign organizations to bind themselves to Norwegian laws they are not familiar with, we find that given enough time it is possible in most instances.

As the human rights due diligence is an ongoing operation, our efforts will continue towards the next reporting date. We hope to make a positive impact on our own operations and our supply chain and contribute to ensure human rights and decent working conditions.

The Norwegian entities in the Snøhetta Group have been prioritised due to a risk-based approach and to secure a best possible implementation of our due diligence procedures. It is Snøhetta's intention to extend the due diligence procedures to Snøhetta's foreign subsidiaries. Snøhetta is currently preparing for EU’s Corporate Sustainability Reporting Directive (CSRD), and we are planning to implement due diligence procedures in Snøhetta’s foreign subsidiaries as part of this work. We consider our work and routines in relation to the Transparency Act as a solid base and natural bridge to the more comprehensive reporting that will be required under CSRD