VSME vs Regulation on Information Duty, Due Diligence, and Right of Access (Forskrift om informasjons- og påseplikt og innsynsrett)

The Regulation on Information Duty, Due Diligence, and Right of Access (Forskrift om informasjons- og påseplikt og innsynsrett) sets clear requirements for companies: contracting companies must inform suppliers about wage and working conditions, have routines to oversee compliance, detect and manage serious incidents, and ensure employees receive legal wages and working conditions.

Gathering and structuring all necessary information from suppliers can be challenging. This is where VSME becomes useful. While not a legal requirement, VSME is a structured reporting framework that provides consistent data on suppliers, their labor practices, and potential human rights or labor risks. This makes it easier for principals to meet the regulation’s obligations effectively.

In short:
VSME provides the structured data you need to support compliance with the regulation, even though it does not replace legal responsibilities.

Below is an overview of how VSME data can support the regulation’s requirements:

Requirement in the regulation	Relevant VSME point	What VSME provides	Why this can cover the requirement
Information duty: Principals must inform suppliers about wage and working conditions	B2 – Practices, policies and initiatives	Company policies and practices related to sustainability, including measures for working conditions and equal treatment	Documents that the company has guidelines and measures for working conditions internally and in the supply chain
Due diligence / Human rights: Control working conditions internally	C6 – Human rights policies and processes	Policies against child labor, forced labor, discrimination, and accidents	Documents system for responsible working conditions
Due diligence / Human rights: Detect and manage serious incidents internally and in the supply chain	C7 – Severe negative human rights incidents	Confirmed incidents such as discrimination, child labor, forced labor, etc.	Provides overview of serious violations
Working conditions: Employees must have legal wage and working conditions	B8 – Workforce characteristics	Number of employees by contract type, gender, and country	Provides overview of workforce structure and employment forms
Wages: Wages must comply with law or collective agreement	B10 – Workforce remuneration	Whether employees receive wages equal to or above minimum/collective agreement	Documents that the company follows minimum wage rules
Equal pay: Prevent discriminatory pay	B10 – Gender pay gap	Percentage pay gap between women and men	Indicates fair wage practices
Collective agreement coverage	B10 – Collective bargaining coverage	Percentage of employees covered by collective agreements	Provides indicator of organization and wage regulation
Health and safety (HSE): Safe working environment	B9 – Health and safety	Workplace accidents and safety systems	Shows control over the working environment
Training: Employee competence and training	B10 – Training hours	Average training hours per employee	Shows investment in the workforce
Whistleblowing mechanisms: Mechanisms to report critical issues	C6 – Human rights policies and processes	Whether the company has a grievance mechanism for employees	Can uncover violations of working conditions
Supplier structure: Principals must know who is involved in the value chain	C1 – Business model and value chain	Description of suppliers and business partners	Provides overview of suppliers
Right to information: Employee representatives can request documentation (Employment contracts, payslips, timesheets, etc)	–	–	–

Bottom line: by using VSME, companies can:

Structure and standardize supplier data relevant for wage, labor, and human rights compliance
Gain visibility into workforce conditions, policies, and potential risks across the supply chain
Spot potential issues early, such as missing policies or reported incidents
Support effective implementation of information, oversight, and documentation obligations