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:

01The group’s code of ethics
02Procedures for supplier follow-up
03Internal whistleblowing and reporting channels
04Annual due diligence assessments
05Ongoing assessment of supplier and partner relationships

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

Obtained information about suppliers’ work on human rights and working conditions
Required compliance with the code of ethics in new supplier agreements
Continued risk-based supplier assessments
Strengthened documentation and follow-up of the supply chain
Continued internal procedures for whistleblowing and reporting
Delivered training and awareness-raising on ethics, responsibility and the Transparency Act

Planned measures for 2026

Better systematisation of supplier mapping
Increased use of risk classification of suppliers
Further development of reporting and documentation
Ongoing training of managers and employees
Regular review of the code of ethics and procurement procedures

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