high-risk list

The High-Risk List is a guidance tool published by Norway's DFØ that identifies product categories with systematically documented high risk of human rights violations in global supply chains. It serves as a practical resource for contracting authorities conducting socially responsible procurement.

How does the high-risk list work?

The list covers the entire value chain — from raw material extraction to final assembly — and includes ten product categories: workwear and textiles, vehicles, construction materials, ICT products, chemicals, conflict minerals, office supplies, toys and sports equipment, food and beverages, and medical equipment. Risk assessments draw on evidence from the ILO and UN regarding violations of ILO core conventions, the UN Convention on the Rights of the Child, and national labour legislation in producing countries.

In Norway, the Public Procurement Act § 5 requires contracting authorities to have suitable routines to promote respect for fundamental human rights where there is a risk of violations. The High-Risk List is DFØ's recommended starting point for this assessment. When a product falls within a listed category, DFØ recommends including ethical contract clauses that require suppliers and subcontractors to conduct due diligence assessments in line with the UN Guiding Principles (UNGP) and OECD Guidelines.

Key elements for suppliers

• Ethical contract clauses: DFØ and Ethical Trade Norway have developed standardised terms for high-risk procurements
• Certification: Suppliers can demonstrate compliance through schemes such as Fairtrade, FSC, GOTS, or TCO Certified
• Contract monitoring: Authorities follow up through self-assessments, document inspections, and where necessary, factory audits
• Advisory, not exhaustive: The list is a starting point — organisations must also conduct independent assessments

At the EU level, the Corporate Sustainability Due Diligence Directive (CSDDD) similarly targets high-impact sectors including agriculture, apparel, and ICT manufacturing. Tools like Cobrief can help suppliers identify tenders with social responsibility requirements.

The High-Risk List gives public buyers a concrete framework for addressing human rights risks, helping ensure that public funds do not finance production marked by forced labour, child labour, or other serious abuses.