The Difi High Risk List

The Norwegian Procurement Act requires Norwegian contracting authorities to implement appropriate measures to promote respect for human rights in public procurement where there is a risk of violation of such rights. Use the Difi High Risk List for assessment of the level of risks of human rights violations in global supply chain. The list includes all tiers of the production process - from raw material extraction to final assembly.

Publisert: 09. okt 2015, Sist endret: 03. jun 2019

Systematic high risk of human rights breaches linked to public procurement

Public entities daily  buy products with systematic high risk of human rights violations in the supply chain. Human rights violations are defined as abuses of the Universal Declaration of Human Rights and the ILO core conventions (prohibiting child labour, forced labour, discrimination and the right to organise).

The Agency for Public Management and eGovernment (Difi) provides information in accordance with the legal requirements through socially responsible public procurement (SRPP) tools, templates and step-by-step guidance.

The Difi High Risk List

The Difi High Risk List contains information on so called high risk products. Products are defined as «high risk procurement» when there are systematic documented high risk of human rights abuse occurring in the supply chain, meaning the value chain from raw material extraction to component production until finishing assembling. The documentation is based on reports and studies by ILO and other relevant sources (for example research reports and reports from acknowledged civil society- and union organisations). To make the list relevant in the daily practise of public procurers, specific product categories from each product group have been selected based on Norwegian public procurement activities.

How to use the Difi High Risk List

When planning the procucrement activity useful information about the risk within product group as well as specifically in the selected product categories will make the choice of SRPP instruments easier. Furthermore guidance on how to write SRPP tender documents and how to follow-up SRPP tender documents is found under each product group (see product groups in the left margin).

Disclaimer: The Difi High Risk List is a guidance tool, and not exhaustive. Products which are not currently on the list could therefore be high risk purchase. 

Information about High Risk list update

In 2017 Swedwatch has carried out risk-assessments on thirty-four products within five product categories on behalf of Direktoratet for forvaltning og IKT (DIFI), hereunder within the product categories furniture, medical consumables/supplies, office supplies, play and sports equipment and workwear, textiles and footwear.

 The risk-assessment reports aim to provide information on potential adverse impacts on labour rights and human rights in the supply chains of the selected products. The reports will guide contracting authorities on the importance of social considerations in their purchasing practices and when such criteria should be applied. The risk-assessments will also improve the readers’ understanding of what to look for when monitoring supplier compliance. Please notice that the risk assessment is based on suppy chains for high risk products imported to Norway and that the supply chain can look different for example for products imported to other countries/continents – such as North America.

It is important to note that the risk-assessments do not aim to scrutinise or describe the supply chain of any particular brand or supplier. The purpose is to give a general understanding of the potential risks linked to the product in general.

Each product is described based on components and materials used in the product. The general supply chain is presented in a table, along with a narrative explanatory paragraph. The supply chain table is divided into three sections; assembly, component and raw material, and provides an overview of most relevant countries. 

General risks are outlined and those which are categorised as most adverse risks for each step of the supply chain are summarised in an introductory table in order to provide an overview. The grading at the bottom of the risk-matrix indicates a combination of the severity and likelihood of the risk and aims to provide guidance on where main risks are located in the supply chain. For example, when a product is assembled in both a high-risk and a low-risk context to more or less the same extent, the risk will be graded lower than if the product had been predominantly assembled in a high-risk environment. This also means that even if a number of potential severe risks are listed in the column, the risk may still be considered low if it is likely that the production mostly takes place under safe and sound processes in a low-risk environment.

The grading includes the following steps: 

Very low riskLow riskMedium high riskHigh riskVery high risk

Method and data

The data used for the risk-assessments comes mainly from reports, articles, films and academic research. Suppliers, and to a some degree industry organisations/initiatives, have also been interviewed to provide input to the understanding of the supply chains. Trading data has been used for the mapping of the supply chains, as transparency and traceability is often limited. Therefore, the supply chain data, especially on a component and raw material level, partly presents the likelihood of a certain producing country being included in the supply chain. The supply chain data can therefore not be viewed as exact for every single product procured by Norwegian contracting authorities, but as a general estimate.  

The assessment was carried out between October to December 2017.


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