
DNO Annual Report 2025 39
Policies related to value chain workers
DNO has a clear governance framework by which we conduct
our affairs related to our value chain workers. We have a
Business Partner Code of Conduct that applies to all suppliers
and customers, which requires commitment to comply with
DNO’s environmental and safety requirements and
internationally recognized employment practices, including, but
not limited to, prevention of modern slavery, child labor,
harassment or discrimination and acceptance of freedom of
association, whilst promoting decent working hours and living
wages set in accordance with applicable laws. We have
dialogue with our suppliers to assess and improve their
performance, including with respect to the environment. We
use risk assessments to identify the frequency and level of
detail of such dialogue. The supplier risk assessment is based
on the type of services provided, geographic location, incident
reports, contract size and operational location. For suppliers
with an increased risk profile, DNO assesses documented
policies and practices of suppliers and implements preventive
and mitigating measures with continuous tracking and when
necessary, DNO takes corrective actions. We also audit
selected suppliers to ensure compliance with relevant
regulations and DNO’s standards, including with respect to
ESG standards. In addition to the Business Partner Code of
Conduct, DNO has embedded HSSE requirements in all of its
contracts with suppliers. The Head of Compliance is
accountable for the policy and the General Managers of each
business unit are responsible for implementation aided by
DNO’s supply chain and compliance functions. As we set the
same expectations for our business partners as for ourselves,
the Diversity and Inclusion policy and the Major Accident
Prevention policy are also considered relevant for our value
chain workers. All of these, including the HSSE requirements,
reduce the risk of major accidents and disparity (e.g., based on
gender) in our value chain. The Business Partner Code of
Conduct is available on DNO’s website and other relevant
policies are made available to the supplier workers, as
required.
DNO acknowledges and respects internationally recognized
human and labor rights standards. Our human rights
commitments have UN Global Compact as a reference for
responsible business conduct, as set out in the Code of
Conduct. Additionally, DNO conducts an annual assessment of
its own operations and its value chain, based on the principles
of the OECD Guidelines for Business Enterprises. This
assessment aims to identify and address significant risks and
adverse impacts on human rights and decent working
conditions. Our Business Partner Code of Conduct does not
explicitly mention engagement with value chain workers;
however, we regularly evaluate and modify our Code of
Conduct, policies and procedures, as risks are ever evolving.
DNO did not identify any actual adverse impacts on human
rights and decent working conditions in 2025 related to our
value chain.
Process of engaging with value chain workers about
impacts
At our operated sites, DNO’s business partners are expected
to ensure that value chain workers are subject to the same
standard as our own employees and are expected to report on
matters relevant to working conditions. Informational flyers are
available, highlighting key aspects of the Code of Conduct and
other essential procedures. DNO conducts a risk assessment
prior to contract signing, which is described within the actions
below. This risk assessment includes dialogue with
representatives for the supplier, particularly for suppliers with a
higher risk profile. As part of the ERM, DNO can and does
conduct audits of its suppliers against the requirements set out
in the Business Partner Code of Conduct, including but not
limited to HSSE standards and the working conditions of value
chain workers. Apart from this, DNO does not currently have in
place any formalized processes to engage with value chain
workers, but the Group is assessing whether any measures
should be implemented.
DNO’s partner-operated sites in the North Sea are in highly
regulated countries with established legal frameworks and
experienced operators. The regulatory environments set clear
requirements for worker rights and safety. DNO verifies
through existing mechanisms, including direct engagement
with our operators and participation in joint venture
governance processes.
Process to remediate negative impacts and channels for
value chain workers raise concerns
We encourage workers in the value chain or those with
concerns regarding our workers in the value chain to raise
these through our confidential channel for reporting concerns,
which is described in more detail within section 4.1 Business
conduct. Workers in the value chain are made aware of such
channels for raising concerns through the Code of Conduct
available on the Group’s website. DNO is currently exploring
ways to ensure the effectiveness of the channel and assess
awareness and trust in using it to raise concerns.
All processes and actions with regards to providing remedy in
instances where DNO has caused or contributed to actual
material impacts would be determined on a case-by-case
basis. The individual circumstances would be assessed in
order to determine appropriate follow-up and remedial
measures.
Actions related to value chain workers
In order to prevent and mitigate negative impacts related to
workers in the value chain in operated activities, DNO has
established a group-wide risk assessment system to gain
insights into the working conditions across our value chain.
The supplier risk assessment is based on credible proxies for
engagements and analyzes the type of services provided,
geographic location, incident reports, contract size and
operational location. For suppliers with an increased risk
profile, DNO assesses documented policies and practices of
suppliers, as well as implementing preventive and mitigating
measures with continuous tracking and, when necessary, we
take corrective actions.
The risk assessment is conducted ahead of contract signing
and periodically afterwards to ensure that suppliers meet
DNO's ethical behavior and business conduct standards. The
Head of Compliance has the responsibility of ensuring that the
process is conducted. DNO has a robust supply chain process
and management team working with nearly 1,000 suppliers
worldwide.
When DNO enters into new contracts, the Group underscores
the importance of respect for human rights and decent working
conditions in DNO’s Business Partner Code of Conduct.
Concerning our suppliers, we aim to implement improved risk
assessment tools to better visualize our supply chain risks,
including but not limited to supplier employee wages.
The results of our risk assessment process described above
determine further actions DNO takes related to our suppliers,
such as providing or enabling remedies concerning material
impact on workers in the value chain. The Group has sufficient