Human Rights, Modern Slavery & Norwegian Transparency Act Policy
Last updated: June 2026
Din Bemannings Partner AS (“DB Partner”, “we”, “us” or “our”) is committed to respecting human rights, preventing modern slavery and human trafficking, and supporting decent working conditions in our own operations, business relationships and supply chain.
The Norwegian Transparency Act, known in Norwegian as Åpenhetsloven, requires companies to work systematically with human rights and decent working conditions, carry out due diligence, publish annual information, and respond to information requests.
This policy explains DB Partner’s commitments and how we work to identify, prevent, reduce and address risks related to human rights, modern slavery and decent working conditions.
1. Our commitment
DB Partner has zero tolerance for forced labour, child labour, human trafficking, debt bondage, unlawful recruitment fees, document retention, discrimination, harassment, retaliation and exploitation.
Employment must be freely chosen. Workers must keep control of their own identity documents, receive clear information about their work, receive correct pay, and have access to safe reporting channels.
We are committed to treating employees, agency workers, candidates, suppliers, clients and business partners with dignity, fairness and respect.
2. Who this policy applies to
This policy applies to DB Partner’s own operations and relevant business relationships, including:
- employees and agency workers;
- candidates and applicants;
- administrative staff and managers;
- staffing clients and customer worksites;
- suppliers, landlords, transport providers and service providers;
- recruitment, technology, payroll, accounting, occupational health, hosting and AI service providers;
- other business partners where human rights or decent working conditions may be affected.
3. Our main risk areas
DB Partner’s work focuses especially on areas where human rights or decent working conditions may be affected, including:
- recruitment and onboarding of EU/EEA workers;
- manual labour in seafood, food production, aquaculture, manufacturing, logistics and related operations;
- working time, timesheets, pay and payroll preparation;
- health, safety and working environment at customer sites;
- language, information and understanding of rights and duties;
- worker accommodation and transport where arranged by DB Partner;
- harassment, discrimination, threats or other objectionable conditions;
- suppliers and business relationships;
- privacy, data protection and responsible use of technology and AI-assisted tools.
Identifying a risk area does not mean that a negative impact has occurred. It means that DB Partner considers the area important enough to monitor, document and control.
4. Recruitment and employment standards
DB Partner does not charge recruitment fees to candidates or workers. DB Partner is paid by clients, not by candidates.
Workers keep their own passports, identity documents and personal documents. DB Partner may check and store copies of required documentation where legally necessary, for example identity checks, right-to-work documentation, D-number, police certificate or other required onboarding documents. Such documentation is handled through approved systems and according to privacy rules.
Workers receive employment contracts and assignment information digitally, normally through RecMan. Contracts and renewals are stored in the system and made available to the worker.
Workers are free to resign in accordance with their employment contract and applicable law.
5. Pay, working time and equal treatment
DB Partner is committed to correct and timely pay, transparent timesheet routines, lawful salary deductions, correct overtime handling, and compliance with applicable Norwegian employment rules.
Workers must receive clear information about pay, working time, assignment conditions, reporting routines and who to contact with questions.
DB Partner supports equal treatment and does not accept discrimination based on nationality, gender, age, religion, language, ethnic background, disability, sexual orientation, gender identity, political opinion or other protected characteristics.
6. Housing and accommodation
Where DB Partner assists with accommodation, housing must be safe, decent and suitable.
Workers must receive information about available accommodation, rent and relevant conditions. Rental agreements must be documented. If rent is deducted from salary, the deduction must be lawful, documented and visible through payroll routines.
Housing must have appropriate fire safety, sanitation, heating, cleaning standards and reasonable privacy. Workers may report housing concerns to DB Partner, the property manager or through the complaints/whistleblowing process.
7. Health, safety and working environment
DB Partner provides workers to environments that may include physically demanding work, machinery, wet or cold areas, hygiene requirements, shift work and production pressure.
Health and safety must always come first. Workers must receive relevant information and follow customer workplace rules, safety instructions and required use of protective equipment.
DB Partner cooperates with clients on health, safety and working environment matters and follows up workers during assignments.
8. Suppliers and business relationships
DB Partner expects suppliers and business partners to respect human rights, decent working conditions, lawful employment, safe working environments, anti-corruption standards, privacy and responsible business conduct.
Relevant suppliers and business relationships may be assessed using risk-based due diligence. Higher-risk relationships may require additional documentation, corrective actions or follow-up.
DB Partner may require suppliers and business partners to follow DB Partner’s Supplier Code of Conduct.
9. Technology, privacy and AI-assisted tools
DB Partner uses digital systems and approved technology providers to support recruitment, staffing, payroll preparation, communication, compliance and operations.
AI-assisted tools may support administration, drafting, summaries, recruitment support and internal workflows, but they must not replace human responsibility or make final employment, hiring, pay, disciplinary, legal or health decisions.
DB Partner applies privacy, access control and human oversight safeguards when using systems that process employee, candidate or worker data.
10. Due diligence process
DB Partner’s due diligence process is practical, proportionate and risk-based.
The process includes:
- identifying relevant operations, suppliers, clients and business relationships;
- assessing actual and potential risks;
- prioritising higher-risk areas;
- implementing controls and preventive measures;
- documenting evidence and actions;
- tracking improvements and remediation;
- publishing an annual transparency statement;
- responding to information requests.
Internal records are maintained in DB Partner’s compliance archive, including risk logs, supplier assessments, client audit records, remediation records and action plans.
11. Reporting concerns and remediation
Employees, agency workers, candidates, suppliers, clients and other stakeholders may report concerns about human rights, working conditions, harassment, discrimination, pay, housing, health and safety, privacy, AI misuse or other serious matters.
Reports can be made to a DB Partner contact person, manager or compliance contact.
DB Partner will assess concerns, protect people who report in good faith from retaliation, and take corrective or remedial action where appropriate.
12. Information requests
Any person may request information about how DB Partner handles actual and potential adverse impacts on fundamental human rights and decent working conditions under the Norwegian Transparency Act.
Requests should be sent to:
Please describe the information requested as clearly as possible. DB Partner will register and assess the request and respond within the applicable legal deadline.
13. Related documents
This policy should be read together with DB Partner’s related public and internal documents, including:
- Annual Transparency Statement;
- Code of Conduct;
- Supplier Code of Conduct;
- Employee Handbook;
- Whistleblowing, Complaints & Grievance Procedure;
- Privacy Policy;
- GDPR & Data Protection Policy;
- AI Transparency Notice;
- Candidate AI Transparency Notice.
14. Review
DB Partner reviews this policy at least annually, or when laws, operations, suppliers, systems or risk areas change.
Contact
For questions about this policy, human rights, decent working conditions, the Norwegian Transparency Act, compliance or information requests, contact:
Din Bemannings Partner AS
Falkenborgvegen 9
7044 Trondheim
Norway
Email: compliance@db-partner.no
General contact: info@db-partner.no