Åpenhetsloven

The Transparency Act

Our Approach to the Transparency Act

The Transparency Act, which entered into force on 1 July 2022, aims to reduce the risk of human rights violations and ensure decent working conditions in our own operations, in the supply chain and among business partners. In addition, the Act is intended to promote transparency and access to information.

Akershus Eiendom's Business

Akershus Eiendom was established in 1992 and is a leading company within commercial real estate advisory in Norway. The company has approximately 40 employees and offers brokerage services within transactions, including purchase, sale and letting of commercial properties, valuation and analysis, and tenant advisory.

The company is based in Oslo but offers services nationwide. The customers are mainly professional and larger, well-known actors, including industrial real estate companies, property owners and various financial actors such as syndicates or funds. Akershus Eiendom’s clients are primarily professional actors operating within a commercial context.

Structure and Corporate Governance

The company is organised into five operational units:
(1) Transactions
(2) Letting
(3) Valuation
(4) Analysis
(5) Tenant advisory / Project management (PM)

The purpose of the business is to provide real estate brokerage services in accordance with applicable laws and regulations. The business shall be conducted in an ethically responsible manner. The framework for operations is governed by requirements under the Companies Act, the Real Estate Brokerage Act, the Anti-Money Laundering Act, etc. Circulars from the Financial Supervisory Authority of Norway and, where relevant, from the Norwegian Association of Real Estate Agents and the Forum for Commercial Real Estate Brokerage complement the formal regulatory framework. The company is also subject to the Transparency Act.

The company has structured its work related to the Transparency Act by updating and embedding routines and guidelines in governing documents, and by allocating roles and responsibilities related to implementation and compliance.

The Board of Directors determines the company’s strategy, goals, guidelines and procedures.
The Managing Partner is responsible for effective organisation and compliance with laws and regulations, and the daily work related to ongoing risk assessments under the Transparency Act is delegated to the company’s administration.

The responsibility for monitoring compliance lies with the Head of Compliance.

Due Diligence Assessments

Akershus Eiendom has initiated the process of implementing a system to ensure respect for human rights and decent working conditions in our supply chain.

The due diligence assessment follows the OECD due diligence framework by:
(1) Anchoring responsible business conduct in company policies and management systems
(2) Identifying and assessing actual or potential negative impact on responsible business conduct
(3) Ceasing, preventing or mitigating such impact
(4) Tracking implementation and results
(5) Communicating how the impact has been addressed
(6) Enabling or providing remediation where required

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In addition to risk assessment during the onboarding of new suppliers (in accordance with the company’s procurement procedures), the company has established a Supplier Code of Conduct, which can be downloaded from our website.

Given our profession as a provider of services in a regulated market, we have relatively few suppliers in our supply chain but many business partners. Many of these relationships are long-term, and the parties are well known to us. Regardless, the company conducts an annual review of all suppliers in accordance with its defined risk criteria.

Where increased risk is identified under the Transparency Act, the company will assess concrete measures.

Results of the assessment and evaluation of negative impact

We consider certain providers of marketing services to be part of our supply chain.

The risk related to these actors is particularly linked to the right to privacy and the use of personal data in marketing.

Most suppliers to Akershus Eiendom are defined as business partners. These consist of various types of support functions and other providers who do not deliver direct input to the services we provide to our clients.

Our assessments have identified three groups of business partners where there may be increased risk of breaches of decent working conditions: transport, catering and cleaning. All these industries are associated with elevated risks concerning working conditions, especially health, safety and environment (HSE) and social dumping, including wage levels. All current suppliers in these categories are based in Norway but operate in industries with generally elevated risk levels.

Akershus Eiendom has, as of now, not uncovered any actual violations or negative impact on human rights or decent working conditions, neither within our own business nor in our supply chains.

Measures and next steps

Internal measures implemented in 2024

Updated internal ethical guidelines to strengthen the foundation for work under the Transparency ActDeveloped ethical guidelines for suppliers (Supplier Code of Conduct), ensuring compliance with necessary regulationsCreated a questionnaire for follow-up with suppliers and business partnersAdjusted the whistleblower channel on our website to allow use by third parties outside the companyEstablished a routine where risk assessment of suppliers is integrated with the accounting system and the existing supplier list


Further work in 2025:

  • Follow up business partners in high-risk sectors to ensure decent working conditions, including obligations under the Regulation on Information and Monitoring Duties
  • Ongoing monitoring of our supply chain, with the aim of identifying risks and exercising our influence where possible. This includes both privacy compliance among marketing suppliers and their work on human rights and decent working conditions in their own supply chains

The work with the Transparency Act is a continuous process. The ambition is that Akershus Eiendom will implement the measures before the next reporting cycle. Responsibility for implementation lies with the company’s administration, represented by the Head of Finance and Administration.

Compliance oversight remains with the Head of Compliance.
The Managing Partner holds ultimate responsibility for the company’s compliance with the Transparency Act.

The statement for 2023 is published on this website.

Supplier Code of Conduct - Norsk

Supplier Code of Conduct - English