1. Sustainability Reporting in Norway An Assessment of Non- Financial Disclosures by the 100 Largest Firms Irja Vormedal and Audun Ruud

2. Structure of presentation Methodology Results: Legally mandated and voluntary reporting Summary of main results and tendencies

3. Methodology Legally mandated reporting – Board of Directors Report The Accounting Act - 3 legal reporting requirements: 1) external environment, 2) working environment and 3) gender equality Voluntary reporting – Annual Reports and Separate Reports 4 indicators assessed by a scoring systems of 5 categories

4. 5 Variables - Content description General Corporate Responsibility (CR) Reporting on key policies, strategies and management practices in the CR field, including information on company performance with respect to set targets. Environment: e.g. energy consumption, waste, recycling, discharges, emissions, biodiversity and transport Social responsibility: e.g. working environment, employee satisfaction and training, health and safety, gender equality (internal issues); stakeholder dialogue, civil society (NGO) collaboration, community liaison, philanthropy and human rights (external issues) Economy: economic impact on stakeholders and business ethics, corporate governance, anti-corruption Management Systems Reporting on environmental, social and economic management systems and control mechanisms in place to ensure that CR is sufficiently monitored in the company Codes of Conduct Reporting on the implementation of environmental, social and economic codes of conduct (established guidelines) in the firm Supply Chain Management Reporting on the company’s environmental, social and economic requirements towards suppliers on CR issues.

5. Scoring System Category 0: “Not mentioned” Neither of the relevant non-financial themes are mentioned in the report. Category 1:“Mentioned” The information provided is minimal and generalised. Furthermore, the information appears isolated from the traditional activity (policy and operations) of the firm in question. Alternatively, the themes are dismissed as irrelevant. Category 2: “Insufficient” The non-financial information provided is linked to the operations of the firm, but the reporting has major deficiencies with respect to content and presentation, and lacks sufficient detail. Category 3: “Satisfactory” Sufficient provision of relevant non-financial information. The theme is described and analysed within the context of the firm’s operations. Central problems, challenges and solutions are candidly considered. The content and presentation of the information provided, however, is somewhat deficient. Category 4: “Very satisfactory” The company’s efforts and achievements with respect to the themes in question is analysed systematically and comprehensively, and in an integrated manner.

6. Results – Board of Directors Reports

7. Results – Annual Reports

8. Results – Separate Reports

9. Summary – Main Results and Tendencies Legally mandated reporting: Minority of “law-abiding” companies Voluntary reporting: Majority of firms fail to report satisfactorily. Few forerunners, many laggards Notably weak reporting: Economic dimension, External Social Responsibility, Codes of Conduct and Supply Chain Management