Transparency Act
Statement on due diligence assessments.
Prepared under section 5 of the Norwegian Transparency Act (åpenhetsloven) for Dark Design Group AS and its subsidiaries. Considered and approved by the board for the 2025 financial year.
This is a translation. The Norwegian statement approved by the board is the authoritative version.
Introduction
This statement sets out how Dark Design Group AS and the group’s subsidiaries work to identify, prevent, mitigate and follow up actual and potential adverse impacts on fundamental human rights and decent working conditions — in our own operations, in the supply chain and among business partners.
The statement is updated and published annually.
About the business
Dark Design Group AS is one of Norway’s leading architecture and design groups, with operations in architecture, landscape architecture, planning, urbanism and design — including Dark Arkitekter AS and the other subsidiaries.
The group has around 145 employees across offices in Norway and Poland. The business is partner-owned and provides services to both public and private clients in the development of buildings, cities and communities.
How the work is organised
The board and group management hold overall responsibility for the work on human rights, decent working conditions and compliance with the Transparency Act. The Chief Executive Officer holds operational responsibility for implementation, while managers at every level are responsible for compliance within their own areas. The work is anchored through:
Policies and procedures
Dark Design Group works actively for responsible business conduct through compliance with Norwegian employment legislation, equal treatment and non-discrimination, safe working conditions and a good working environment, respect for internationally recognised human rights, and zero tolerance for corruption and improper advantages. All employees are covered by the group’s code of ethics.
New suppliers are assessed before an agreement is entered into and must accept the group’s ethical requirements. Suppliers may be asked to document their procedures relating to human rights, working conditions and corporate governance.
Due diligence assessments
The assessments follow the OECD Guidelines for Responsible Business Conduct and the requirements of the Transparency Act.
They cover our own operations, suppliers, business partners, and geographic and sector risk.
The supplier base consists mainly of businesses in Norway and other EU/EEA countries. This is generally assessed as presenting a low to moderate risk of breaches of fundamental human rights and decent working conditions.
At the same time, the group recognises that certain purchases may be linked to global supply chains where the risk is higher.
Identified risk areas
ICT
Computers, mobile phones, servers and other electronic equipment are often produced in global supply chains outside Europe. This can involve risk relating to working conditions, raw material extraction and sub-supplier tiers.
Office equipment and furnishings
Furniture, technical equipment and office supplies may contain components produced in countries with a higher risk of human rights breaches.
Third-party services
When using external consultants and other specialised services, we assess the risk of non-compliance with employment legislation and requirements for decent working conditions.
Outcome of the assessments
During the reporting period, Dark Design Group has not identified any actual adverse impacts or material breaches of human rights or decent working conditions in its own operations, or among the suppliers subject to closer follow-up.
Measures carried out in 2025
Planned measures for 2026
Whistleblowing and requests for information
Employees, clients, suppliers and other stakeholders can raise concerns relating to human rights, working conditions or ethical matters through the group’s established whistleblowing channels. Dark Design Group also handles requests for information under the Transparency Act in accordance with the provisions of the Act.
Enquiries can be directed to post@dark.no or (+47) 23 13 12 00.
Approval
The statement has been considered and approved by the board of Dark Design Group AS and applies to the 2025 financial year.
Oslo, 30 June 2026
Geir Gustav Hantveit
Chief Executive Officer, on behalf of the board of Dark Design Group AS