The case for CSR/ Sustainability Reporting Done Responsibly


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Case study: How Avinor conducts its business responsibly

As a wholly state-owned limited liability company under the authority of the Norwegian Ministry of Transport and Communications, responsible for Norway’s 45 state-owned airports and for providing air navigation services for civilian and military aviation, Avinor makes every effort to operate in accordance with all external and internal regulations relating to corruption, misconduct, and ethics rules.  Tweet This!

This case study is based on the 2017 Annual and CSR report by Avinor published on the Global Reporting Initiative Sustainability Disclosure Database that can be found at this link. Through all case studies we aim to demonstrate what CSR/ ESG/ sustainability reporting done responsibly means. Essentially, it means: a) identifying a company’s most important impacts on the environment, economy and society, and b) measuring, managing and changing.

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Avinor’s mission is to develop and operate a safe, efficient, and sustainable aviation system throughout Norway. Operating ethically, openly, and transparently is, thus, a top priority. In order to conduct its business responsibly Avinor took action to:

  • establish ethics guidelines
  • implement an anti-corruption programme
  • promote impartiality
  • protect data privacy
  • comply with legislation and guidelines

What are the material issues the company has identified?

In its 2017 Annual and CSR report Avinor identified a range of material issues, such as ensuring good aviation services for the whole of Norway and performing its role in society in a safe, efficient and environmentally-friendly manner, being a good and professional employer, being a driving force in the work on climate and environmental challenges within aviation. Among these, conducting its business responsibly stands out as a key material issue for Avinor.

Stakeholder engagement in accordance with the GRI Standards              

The Global Reporting Initiative (GRI) defines the Principle of Stakeholder Inclusiveness when identifying material issues (or a company’s most important impacts) as follows:

“The reporting organization shall identify its stakeholders, and explain how it has responded to their reasonable expectations and interests.”

Stakeholders must be consulted in the process of identifying a company’s most important impacts and their reasonable expectations and interests must be taken into account. This is an important cornerstone for CSR / sustainability reporting done responsibly.

Key stakeholder groups Avinor engages with:  

Stakeholder Group
Customers (airlines and passengers)
Politicians
Airport partners
Local and central businesses
The Norwegian Armed Forces
Research environments
Special interest groups

How stakeholder engagement was made to identify material issues

To identify and prioritise material topics Avinor conducts regular stakeholder analyses and systematic dialogue with tis key stakeholders, gaining an insight into stakeholders’ opinions, expectations, and priorities.

What actions were taken by Avinor to conduct its business responsibly?

In its 2017 Annual and CSR report Avinor reports that it took the following actions for conducting its business responsibly:

  • Establishing ethics guidelines
  • Avinor’s Board has established ethics guidelines, which apply to the Board and all members of staff. Accordingly, over 90 percent of employees have completed Avinor’s ethics guidelines course, which covers the prohibition of corruption, bribery, and anti-competitive behaviour in violation of competition rules. Moreover, in 2017 Avinor developed additional ethical dilemmas and concluded an agreement with an external supplier to train all management groups and other personnel exposed to risk. A scaled-down version of the training is rolled out to other employees, and the course is mandatory, for all employees and hired personnel.
  • Implementing an anti-corruption programme
  • Avinor has a zero-tolerance policy towards corruption and has developed an anti-corruption programme, with a focus on prevention and control activities. Measures are established based on a risk assessment of relevant areas and governing documents have been developed, relating to these efforts, with a focus on the constant development of the anti-corruption programme. Avinor is also a member of Transparency International Norway and contributes to joint efforts regarding transparency, integrity, and responsibility in society to prevent corruption and fraud, both nationally and internationally.
  • Promoting impartiality
  • Avinor’s Board members and executive personnel submit an annual self-declaration of close associates with information about any transactions between the parties, and an external auditor carries out annual reviews of the formal relationships between the executive management, Board of Directors, and suppliers in the Avinor Group. Any relationships are documented and reviewed with the relevant parties, to confirm the information provided in the self-declarations. This annual review complements the assessments that must be made when issues arise regarding an employee’s impartiality in relation to various procurements, tenders, enquiries, participation in decision-making processes relating to commercial interests, etc. In addition, as regards anti-competitive behaviour and practices, Avinor is subject to public procurement regulations and group-wide guidelines supplement the regulations, ensuring competition in the conclusion of individual contracts.
  • Protecting data privacy
  • Avinor has appointed a data protection officer, responsible for helping people registered with the business (such as in customer databases) and employees in matters relating to Avinor’s processing of personal data. The data protection officer must notify the management of breaches of the Norwegian Personal Data Act and be the company’s contact for enquiries from the Norwegian Data Protection Authority. Additionally, Avinor has established a system for internal control pursuant to the regulations of the Norwegian Personal Data Act, and a privacy policy. Avinor has also drawn up a privacy declaration, to inform users about the use of information on its website, and concluded data processing agreements with subcontractors that process personal data on its behalf.
  • Complying with legislation and guidelines
  • Avinor’s compliance function monitors the Group’s compliance with external and internal regulations about corruption, misconduct, and ethics rules. The function defines the substance of Avinor’s responsibility to combat violations of labour market legislation, stipulates requirements, proposes relevant measures, monitors how Avinor follows up on its responsibilities, and establishes sanctions in cases of non-compliance. Avinor has also appointed a committee to handle notifications of reprehensible conditions in all parts of the organisation. Notifications can be submitted regarding inadequate safety procedures, bullying and harassment, careless administrative procedures, working conditions that violate the Working Environment Act, or corruption and other financial misconduct. The person submitting the notification can choose to remain anonymous, and the committee has established routines for the proper processing of notifications. The committee has, additionally, developed procedures and technical solutions that enable external actors to notify Avinor of reprehensible conditions. These notifications must be handled according to the same procedures as notifications from employees of the Group. In 2017, the committee received approximately 200 notifications, which it fully addressed.

Which GRI Standards and corresponding Sustainable Development Goals (SDGs) have been addressed?

The GRI Standards addressed in this case are:

1) Disclosure 205-2 Communication and training about anti-corruption policies and procedures

2) Disclosure 205-3 Confirmed incidents of corruption and actions taken

3) Disclosure 206-1 Legal actions for anti-competitive behavior, anti-trust, and monopoly practices

4) Disclosure 419-1 Non-compliance with laws and regulations in the social and economic area

 

Disclosure 205-2 Communication and training about anti-corruption policies and procedures corresponds to:

  • Sustainable Development Goal (SDG) 16: Promote peaceful and inclusive societies for sustainable development, provide access to justice for all and build effective, accountable and inclusive institutions at all levels
  • Business theme: Anti-corruption

Disclosure 205-3 Confirmed incidents of corruption and actions taken corresponds to:

  • Sustainable Development Goal (SDG) 16: Promote peaceful and inclusive societies for sustainable development, provide access to justice for all and build effective, accountable and inclusive institutions at all levels
  • Business theme: Anti-corruption

Disclosure 206-1 Legal actions for anti-competitive behavior, anti-trust, and monopoly practices corresponds to:

  • Sustainable Development Goal (SDG) 16: Promote peaceful and inclusive societies for sustainable development, provide access to justice for all and build effective, accountable and inclusive institutions at all levels
  • Business theme: Compliance with laws and regulations

Disclosure 419-1 Non-compliance with laws and regulations in the social and economic area corresponds to:

  • Sustainable Development Goal (SDG) 16: Promote peaceful and inclusive societies for sustainable development, provide access to justice for all and build effective, accountable and inclusive institutions at all levels
  • Business theme: Compliance with laws and regulations

 

80% of the world’s 250 largest companies report in accordance with the GRI Standards

SustainCase was primarily created to demonstrate, through case studies, the importance of dealing with a company’s most important impacts in a structured way, with use of the GRI Standards. To show how today’s best-run companies are achieving economic, social and environmental success – and how you can too.

Research by well-recognised institutions is clearly proving that responsible companies can look to the future with optimism.



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References:

1) This case study is based on published information by Avinor, located at the link below. For the sake of readability, we did not use brackets or ellipses. However, we made sure that the extra or missing words did not change the report’s meaning. If you would like to quote these written sources from the original, please revert to the original on the Global Reporting Initiative’s Sustainability Disclosure Database at the link:

http://database.globalreporting.org/

2) https://www.globalreporting.org/standards/gri-standards-download-center/

Note to Avinor: With each case study we send out an email requesting a comment on this case study. If you have not received such an email please contact us.

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