The Supplier Code of Conduct describes the main principles for how the company's suppliers should comply with the requirements of applicable laws and regulations. Deliveries to JOHAN GISKEØDEGÅRD AS must be compatible with the described requirements.

This policy applies to the company's suppliers and partners, as well as their subcontractors. 

Relation to national laws and regulations

The supplier's activities shall in all respects be lawful. The supplier shall keep itself informed of, and comply with, the laws, regulations and decisions applicable to the Supplier's activities at all times. Deliveries to JOHAN GISKEØDEGÅRD AS must fulfil and be compatible with the terms described.

Suppliers to JOHAN GISKEØDEGÅRD AS shall comply with the Group's ethical guidelines for suppliers, internationally recognized conventions and relevant national legislation. Deliveries to JOHAN GISKEØDEGÅRD AS must be compatible with the requirements stated below. The requirements specify minimum standards. In cases where internationally recognized conventions and national laws and regulations deal with the same topic, the highest standard shall always apply, as far as this is within the legislation of the country concerned.

We have guidelines for food safety, quality and sustainability, and deliver our goods and services in accordance with national legislation and international standards for food safety and environmental management.

Our partners and customers who are directly or indirectly involved in our activities shall be made aware of our goal of complying with applicable regulations and requirements in the standards that form the basis for our production. This applies to sustainability, food safety and traceability, as well as good and dignified conditions for our employees.

Privacy and data security

All Partners shall have routines and systems that ensure that privacy is safeguarded and that there is no improper acquisition, use or sharing of data, information or material.  Treat all confidential information in an ethical manner and at all times within the agreed framework and applicable regulations. Deviations and suspected nonconformities must always be reported.

Environment and climate

All partners shall work with and towards relevant national environmental goals and international environmental commitments. The supplier must have a "precautionary principle" related to pollution, environmental risk and other environmental and climate challenges.

Human rights

All Partners shall respect the internationally recognized human rights, dignity, privacy and personal rights of all people. 

Labor standards

Labor standards
Freedom of association and the right to collective bargaining
Partners shall 

  • ensure and recognize the right to freedom of association, and facilitate collective bargaining if a substantial part of the employees agree to this. 
  • do not discriminate against representatives of workers or members of trade unions, but facilitate the ability of these persons to perform their functions in the workplace.

In cases where freedom of association and collective bargaining are restricted by national law, the supplier shall allow employees to freely choose their own representatives within the legislation.

 shall not use any form of coercion in connection with employment or in employment relationships. The supplier shall ensure that the working relationship between the employee and the supplier is based on voluntary participation and without threats of any kind. It is stated that all employees are free to terminate their employment after having communicated this in a reasonable manner. Employees shall not have to deposit money, identity papers or the like for the purpose of being employed or maintaining an employment relationship.

under the age of 18 shall not perform work that endangers health or safety, including night work. Children under the age of 15 or of school age shall not perform work that may be detrimental to their education.

Partners shall work to avoid direct or indirect discrimination based on ethnicity, religion, age, disability, gender, marital status, sexual orientation, trade union membership or political affiliation, and shall promote equality in employment relationships, and shall not tolerate any form of sexually intrusive, threatening, abusive or exploitative behaviour. 

Partners shall provide remuneration that meets any national legal standard for minimum wage. The salary must be agreed in writing and transferred to the employees at the agreed time.

Partners must ensure that working hours are not disproportionately long and that, as a minimum, they are within the limits set out in relevant laws and regulations.  Respect individual employees' need for restitution and ensure that all employees are entitled to satisfactory vacation with pay.

Labour law and labour legislation in which production takes place must be complied with.

Ensure that statutory working time regulations are complied with and that all employees receive written employment contracts describing the employment relationship in a language that the employee understands.

Partners shall ensure that all employees have a healthy and safe working environment in accordance with internationally recognised standards, laws and regulations. 

To control occupational risks and establish measures to prevent accidents and occupational diseases, including taking out all statutory insurance. If necessary, employees shall be equipped with appropriate personal safety equipment and trained in its use.

Provide regular training to ensure that employees have adequate skills related to health and safety issues.

When employees are offered lodging, the supplier must ensure that this is clean, secure and that it meets the basic needs of the employee and, if applicable, his or her family.

Business methods

Business Partners shall comply with laws and regulations relating to bribery, corruption, fraud and all other illegal business activities. The Supplier shall not offer, promise or provide any undue advantage, service or incentive to public officials, international organisations or other third parties for the purpose of obtaining personal or business benefits. This applies regardless of whether this benefit is offered directly or indirectly through an intermediary.

The Supplier shall not, directly or indirectly, offer gifts or benefits to JOHAN GISKEØDEGÅRD AS's  employees, which go beyond profile articles and simple attentions. Courtesy gestures such as social events, meals or entertainment can be offered if there is a business aspect involved and the cost is kept at a reasonable level.

Partners must distance themselves from all forms of money laundering and shall establish measures to prevent the company's financial transactions from being used for money laundering
Partners shall not cause or be part of any breach of competition law, such as illegal cooperation on pricing, illegal market cooperation or other forms of conduct that result in violations of competition law.

Roles and responsibilities

All Partners are obliged to respect the requirements set out in this document in their own activities.  The supplier is obliged to continue corresponding provisions against all subcontractors and contract assistants. JOHAN GISKEØDEGÅRD AS may require this work to be documented within a reasonable time in the following ways:

a) Self-declaration from the supplier and/or

b) Follow-up conversations with JOHAN GISKEØDEGÅRD AS

JOHAN GISKEØDEGÅRD AS may at any time require documentation to be submitted for or check whether the requirements are met.  Contact information is treated confidentially.

Partners can choose to document follow-up of the requirements by adequately certifying the enterprise.

Due Diligence

Statement of due diligence according to the Transparency Act

Valderøya, 14th June 2023            


The new Norwegian Transparency Act imposes a duty to publish a statement regarding their due diligence assessments. It is Johan Giskeødegård AS’ understanding that the following is in accordance with this duty in the Transparency Act.            

Who are we?

Johan Giskeødegård AS is a Norwegian company and we are subject to Norwegian law. The company har 25 employees distributed in the administration and factory, situated on Valderøya in Giske munincipality. We have been operating since 1938.

Johan Giskeødegård AS mainly does business with purchasing and selling wet salted and dried salted fish, in addition production of the same products in our own factory. We largely buy our raw materials on auctions in Norwegian fish salesteams, or from fish suppliers along the coast. In addition some products/raw materials are purchased from suppliers outside of Norway.

 The company has in the later years actively focused on human rights and decent working conditions in accordance to the OECD principles, and this has been anchored through our internal procedures and routines. We have developed general demands to all our suppliers that convey our expectations connected to ethical trading. In addition we have developed our own Code of Conduct as a means in the follow-up of those of our suppliers where there is a risk of breach in human rights and/or decent working conditions.

 Due diligence assessments have been introduced as a continous process in our business. Through this process we try to identify, avoid/prevent, reduce and assess negative effects on human rights and decent working conditions happening in our supplier chain or our partners.


Our supplier chain

 Raw materials are mainly purchased through auctions at Norwegian fish salesteams and fish suppliers. The fish is mainly delivered by Norwegian fishing vessels to fish suppliers all along the Norwegian coast. We use largely Norwegian transport companies, but we also have transporters outside of Norway, i.e Denmark. Suppliers of processed products are situated, in addition to Norway, in The Faroe Islands and Iceland.


 From an overall assessment of our supplier chain we can see that in the industry there will be a higher risk in our supplier chain in connection to

  • The fishery    
  • Transport
  • Processing of raw materials

 For our transport companies we have on the basis of our reporting duties already implemented routines in connection to the follow-up of salary – and working terms with our suppliers.

In relation to the countrieswhere we operate we can see from an overall mapping that there will be a consideraterisk with suppliers situated in

-         Russia (Raw materials)

-         China (Equipment for production and packing)

 In some sales transactions we use agents and/or sales representatives. These have been assessed on the same level as our raw material suppliers. Based on our knowledge of hired workers, there will also be a risk of breach in suppliers situated in Norway.

Mapping and risk assessment

Johan Giskeødegård AS has mapped our supplier chain and our partners. We make assessments of human rights and decent working conditions in accordance to OECDs guidelines.

 We have classified our business connections in accordance to who we consider our suppliers, and who we consider our business partners. Our businesspartners are considered to not pose a risk in the assessments we are to undertake by the Transparency Act. For our suppliers we have assessed the risk further down the supplier chain and requested information from our main suppliers where we have considered that there is a risk. We have not received any reiterations from all of our main suppliers and these will be followed more closely.

We use the OECDs contact pointself-assessment to evaluate the ongoing process.

Mapping and risk-assessment of our business connections have been made through a classification in the following manner: 


Red        –       suppliers and businesspartnerswhere we conside the risk high

Orange  –       suppliers and businesspartners wherewe conside the risk medium

Green      –     suppliers and businesspartners where we consider the risk low


Those of our suppliers and businesspartners who are considered to be in category orange and red, will be asked to sign the companysself-declaration form, which in general describes our demands and expectations connected to basic human rights and decent working conditions.

 We think that dialogue and close communication with our suppliers and businesspartners is an important part of this process to classify them all correctly, and to contribute to raise the awareness level in every aspect of this area.

 Johan Giskeødegård AS has so far in this work, not discovered any actual breaches on humans rights or working conditions.


Our own business

We execute our business in accordance to Norwegian law, including the Norwegian working environment law. Our main focus is that all our employees should have equal rights and a good working environment. We have not had any cases in our business connected to a negative working environment or breach of human rights.


The mapping and risk assessment work of our suppliers will be an ongoing work in our business. In addition to the follow-upof existing suppliers we have implemented routines connected to mapping and assessing all new suppliers.

 For the future we will have am extra focus on the close follow-up and dialogue with the suppliers where we consider the threat of a breach of human rights and/or decent working conditions as real.

 We will continously assess the need to implement other measures with other suppliers.



Should you request more information as to how Johan Giskeødegård AS is handling the actual and potential negative consequences for a breach on basic human rights or decent working conditions in accordance to the Transparency Act § 6, you are most welcome to do so via e-mail:

Reactions and follow-up in the event of a breach of the guidelines

Violation of the provisions of this document implies a breach of all or part of the contractual relationship. Repeated breaches of ethical guidelines or lack of follow-up, after JOHAN GISKEØDEGÅRD AS has pointed out the circumstances, are always regarded as significant breaches of contract.