Transparency Act – Annual account for due diligence

The Transparency Act entered into force 1 July 2022, to promote enterprises’ respect for fundamental human rights and decent working conditions in connection with the production of goods and the provision of services.

According to the Transparency Act, Jotun is committed to carry out due diligence, provide information upon request and publish an account of the due diligence assessments each year. The following is to be considered Jotun’s annual account for due diligence pursuant to Section 5 of the Transparency Act for the period 1 January 2023 to 31 December 2023, approved by the Board of Directors and CEO 13 February 2024.


Jotun is a global company consisting of 67 companies in 46 countries worldwide. The company extends its reach to other countries through a network of subsidiaries, joint ventures, associated companies, sales offices and distributors. The parent company, Jotun A/S, is headquartered in Sandefjord, Norway. Of the Group’s operating revenue, approximately 8 per cent is related to activities in Norway, while the remaining 92 per cent is related to the rest of the global network.

Jotun’s business is organized into five regions: Europe and Central Asia (ECA), Middle East, India and Africa (MEIA), North East Asia (NEA), South East Asia and Pacific (SEAP) and Americas (AM).

Jotun’s product and service offerings are organized into two business areas: Decorative Paints and Performance Coatings, and four business segments: Decorative Paints, Marine Coatings, Protective Coatings and Powder Coatings. For more info –

Jotun’s commitment to human rights

Jotun has embedded the OECD Guidelines for Multinational Enterprises in its own Human Rights Policy.

Jotun’s social sustainability framework is based on the company’s Human Rights Policy. The policy is aligned with the United Nations Guiding Principles on Human Rights and the International Labour Organisation’s (ILO) Declaration on Fundamental Principles and Rights at Work. The company adheres to the United Nations Global Compact (UNGC) to contribute to the goal of creating a sustainable and inclusive global business with decent working conditions.

Jotun is committed to develop an organizational culture and a relationship with our business partners that respect internationally recognized human rights and seek to avoid human rights abuses. Jotun operates in 46 countries across all continents. We respect local laws and regulations in the countries where we operate. If local legislation differs from or conflicts with international human rights standards, Jotun complies with local law while implementing relevant measures to ensure respect for human rights and decent working conditions.

Jotun’s whistleblowing channel is open to both internal and external stakeholders who wish to report on suspected violations of Jotun’s Business Principles, policies, laws or regulations. Jotun encourages employees and external stakeholders to raise concerns if malpractices or wrongdoings are suspected, for the company to be able to follow up. Concerns can be reported openly or anonymously, and once a concern is logged, it is investigated and handled according to established procedures. All reports are handled confidentially and individuals are protected and treated respectfully. The whistleblowing solution is GDPR compliant.

Risk areas

With operations in 46 countries around the world, Jotun acknowledges that our activities may impact the fundamental human rights of our stakeholders. The risk varies between the different countries and regions in which Jotun is active. Jotun regularly conducts risk-based assessments of all companies as well as of our suppliers, with a particular focus on fundamental human rights and decent working conditions.

Based on the risk assessments, the following essential risk areas have been identified for own business and our suppliers:

Human Right


Right to safe and decent working conditions

·       Working hours

·       Injuries

·       Fires

·       Sick leave

·       Use of personal protection equipment


With production facilities and suppliers across the world, Jotun recognises the

inherent health and safety risks related to production environments, handling of heavy machinery etc.


Right to be treated fairly and without discrimination

·       Gender equality

·       Immigrant workers

·       Temporary workers


A global presence entails differences in culture, religion, nationality in the local units which may pose a risk.


Right to freedom of association and collective bargaining

·       Labour unions


This right is limited or forbidden by law in some countries where Jotun/our suppliers operate.


Mitigating actions – implemented and planned

Reviews and systems 

Through various audits and reviews, Jotun follows up human rights issues and potential breaches. Human rights are addressed in the regular Business Reviews and Compliance Reviews in all companies. Jotun has systems and regularly runs control reports on salary reviews, working hours, and gender pay equality measures, and ensure all employees have proper employment contracts in a language they understand. Reviews are followed up with actions according to findings.

Regular employee surveys are conducted, to obtain candid feedback from employees on satisfaction level on a variety of topics, included but not limited to diversity and inclusion, development opportunities, respect, recognition, pay and benefits. Findings from these surveys are followed up with action plans and feedback based on results.  

Gender equality - salary

To ensure compliance with guidelines for salary levels and gender pay equality in all companies, the process is about to be fully integrated into the global HR-system. The ambition is to have the overview of all countries by end of 2025. By this integration, Jotun can make reports based on actual salary levels and trends globally and plan necessary actions accordingly.

Right to freedom of association

Jotun operates in some countries where the right to freedom of association and collective bargaining is limited or forbidden by law. In this context, employee surveys and audits play an important role to ensure issues are voiced and addressed. Other mitigating actions include regular meetings between employees and local management to ensure that employees can voice their opinions, as well as welfare/ethics committees and/or communications teams, to secure open communication between employees and management.

Health, Safety, Environment and Quality (HSEQ)

Jotun’s HSEQ management system defines the requirements for how to operate worldwide with regards to health, safety, environment and quality to ensure the security of people and operations. The comprehensive system provides a structure to track and manage 15 elements related to HSEQ. More information can be found on our website. Jotun reports annually on sick leave, incidents (lost time injuries), working hours, fires and potential fires.

Extensive internal HSEQ audits are conducted regularly in all production companies. According to findings, the companies initiate necessary actions to comply with requirements and to continuously improve the HSEQ standard, ensuring a safe work environment for all. Starting from 2024, Jotun will also audit sales companies (non-producing units) on relevant HSEQ measures.


Jotun’s Insurance Scheme includes all employees, and covers injuries or loss during business travels, medical treatment, invalidity, disablement related to employment and death (regardless of cause). Currently, Jotun is mapping local pension schemes in all companies to obtain a full overview. The mapping will be followed up with actions according to findings.

To support gender equality, promoting a work-life balance is proven to be important. In Jotun, the “Penguin Care” programme was launched in 2022, contributing to health, welfare and work/life balance. The programme entails paid parental leave for both new mothers and fathers in all Jotun companies, as well as paid caregiver leave in support of employees caring for sick, injured or elderly relatives. For 2024, the programme will be extended with a professional counselling service offering support to individuals on a variety of health and welfare topics.

In several countries where Jotun operates, employers are required to provide housing for immigrant workers. Jotun has chosen to build and manage accommodation houses internally, ensuring a good standard of living conditions for these employees.

Training and awareness

Awareness campaigns are conducted regularly on various topics. Each year Jotun arranges global campaigns across all companies on the following topics: International Women’s Day, Diversity, Human Rights and Mental Health. The global campaign on Mental Health was launched in 2023.

Jotun’s “I Care”-concept is an awareness campaign related to Health, Safety and Environment, requiring all companies to run three relevant I Care campaigns each year. One is initiated on a global level, while the other two are local and should be based on local incidents, challenges or risks. In 2023 global focus was put on the campaign “Speak Up”, promoting a culture where people feel comfortable expressing their opinions, concerns and ideas without fear of negative consequences. Planned campaign for 2024 is “Ignition sources”, as the number of potential fires is still too high.

After an upturn of Lost Time Injuries in 2022, this area was addressed in 2023. Through training and security measures, for example safety interlocks, the number of Lost Time Injuries decreased during the year.

All employees received mandatory training on “Diversity and Inclusion” in 2023, increasing knowledge and awareness of the topic to ensure the culture of inclusion Jotun expects. All managers with reporting lines received the additional training “Inclusive hiring”, with the goal to identify and minimize unconscious bias in recruiting process, learn to create job adverts that widen the applicant pool and implement inclusive hiring techniques in the interview and selection process.

Supplier Integrity

Jotun sets clear requirements for suppliers and business partners, and has developed a Supplier Integrity declaration, aligned with the United Nations Guiding Principles on Human Rights and the International Labour Organisation Declaration on Fundamental Principles and Rights at Work. The declaration covers a broad range of topics including child labour, the right to organize, diversity and inclusion, anti-corruption, and safe working environments. The declaration is distributed to suppliers, and Jotun expects all suppliers to support the principles in this declaration and to implement the same standards at their suppliers and subcontractors.

Looking ahead, Jotun plans to implement a new supplier management solution. This will provide better system support on assessments, as well as regular follow-up and distribution of relevant requirements/tasks and reminders.

EcoVadis is the world’s largest and most trusted provider of business sustainability ratings, delivered sustainability assessments to Jotun since 2022. More details about the assessments can be found on EcoVadis’ web pages. Jotun’s suppliers are subject to EcoVadis assessments and supplier audits, and based on score they are placed in different categories:

  1. Pass: Always give feedback to suppliers with areas for improvements based on the audit result. The agreement with the supplier will continue.
  2. Temporary pass: Feedback to supplier with areas for needed improvement. Suppliers are given 6-12 months to document improvement to meet “pass”.
  3. Fail: Feedback to supplier with areas for improvements. If the supplier fails to document sufficient improvement in a short time, Jotun will terminate the contract.

Status assessments and audits as per end 2023: 98 per cent of our purchased raw material is from suppliers covered by EcoVadis and/or internal/external audits.  

For more information regarding our organization and business, please refer to our website and the Group report.