Introduction
The Transparency Act entered into force in Norway on July 1, 2022. The act was passed to strengthen corporate responsibility for human rights and decent working conditions – both within the company's own operations and in its supply chains. Under the Transparency Act (Act 2021-06-18-99, § 5), Sunday Power is required to publish an account of the due diligence assessments the company has conducted in accordance with § 4 of the Act. The Transparency Act requires companies to perform due diligence in line with the OECD Guidelines for Multinational Enterprises, while also setting requirements based on the size, nature, and context of the business.
Sunday Power is subject to the Transparency Act starting in 2025 and must report on its due diligence assessments at least annually, with publication no later than June 30 each year for the preceding year. This report is made available at www.sundaypower.no.
The Transparency Act is intended to help companies take responsibility – particularly in supply chains in countries with weaker legal protections and labor standards. The UN principles and the OECD model are key references for the Transparency Act.
Description of the business
Sunday Power is Norway's largest and leading player in Solar-as-a-Service, offering an end-to-end solution for solar and battery systems for commercial and industrial buildings. The solution focuses on efficiency in every part of the process, from consulting and engineering to installation and operation. Sunday Power is a privately owned company with 18 full-time and 2 part-time employees, with its head office in central Oslo. For the 2024 reporting year, the company had a turnover of just over 100 MNOK.
Work related to the Transparency Act began in 2025 and is part of the company's systematic approach to sustainability. The CEO has overall responsibility for sustainability in the business.
The company's organization consists of:
The company's board of directors
Chair of the Board
Einar Kristoffer Sunde
Board Member
Christian Rignes
Board Member
Kim Tornås Romero
Board Member
Karina Halstensen Birkelund
Board Member
Sheri Shamlou
Based on the UN Sustainable Development Goals, Sunday Power has identified the goals where we have the greatest impact. Based on our core business and value chain, we have chosen the following focus areas:
Through the development and operation of solar power systems and batteries for commercial buildings, we contribute to society's transition to renewable energy sources and reduced greenhouse gas emissions. Our contributions support Sustainable Development Goals 7, 11, and 13 – specifically affordable and clean energy, sustainable cities and communities, and climate action.
Completed due diligence
Due diligence is a systematic process we carry out to identify, prevent, mitigate, and account for the risk of negative impacts on people, society, and the environment – particularly regarding the UN Global Compact, human rights, and decent working conditions in our own operations and supply chain. In practice, the company conducts ongoing due diligence of suppliers, during major changes, with new suppliers or business areas, and at least annually.
Our due diligence work is anchored in recognized international standards, including the UN Guiding Principles on Business and Human Rights and the OECD Guidelines for Multinational Enterprises, which describe how companies should manage risk and perform due diligence in practice. We are committed to conducting regular and systematic due diligence in line with both legal requirements and these standards.
We purchase contractor services from our EPC (Engineering, Procurement and Construction) partners, all of which operate primarily in Norway.
Sunday Power involves relevant stakeholders in the due diligence process through surveys, dialogue, and follow-up.
List of our EPC partners and the date of their most recent due diligence:
- Solcellespesialisten AS
- Due diligence conducted 05.06.25
- Solenergi FUSen
- Due diligence conducted 11.06.25
- BlueTec AS
- Due diligence assessment conducted 16.06.25
- Sun Net AS
- Due diligence assessment conducted 10.06.25
- Differ Energy AS
- Due diligence assessment conducted 11.06.25
- Isola Solar AS
- Due diligence assessment conducted 11.06.25
How we have proceeded to identify risks
Through our due diligence assessments, we have mapped the risks in our own operations, at our suppliers, and at subcontractors. These can be grouped into three levels:
1. Direct suppliers, including EPCs in Norway
2. Service and material suppliers to our direct suppliers
3. Subcontractors of material suppliers, raw material processing, and raw material extraction
We have mapped overarching risks at all three levels and how our direct suppliers (level one) work with the risks identified at level two or three.
The mapping of risks has taken into account geographical and industry-specific risk elements. Our suppliers have conducted risk assessments both within their own operations and in the supply chain. The suppliers have mapped all internal business and activity areas to identify potential risk areas that can be linked to violations of human rights and decent working conditions.
The suppliers have conducted thorough due diligence and risk assessments in line with the Transparency Act and OECD guidelines.
Our suppliers have used source-based documentation and the use of external researchers and third-party verification of supply chains. Some have also conducted supplier visits in China and Europe for physical inspection and dialogue. When ordering solar panels from Southern China, we have the option to halt delivery if risks are uncovered.
Which risks have been identified
The risk can be separated into operations in Norway, service providers in Norway and abroad, and goods suppliers in Norway and abroad. See the following risk matrix for the various areas and their risk profiles.
Risk matrix:
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Risk areas and potential negative consequences
In general, the most high-risk area is the procurement of materials. This applies particularly to products manufactured in Asia due to an increased likelihood of labor rights violations and a lower degree of transparency. This is based on risk assessments conducted with regard to geography, industry, and the supplier's ability to document good working conditions. China is an especially vulnerable region, as most solar modules and inverters are produced there, and several of the supply chains remain closed and difficult to trace.
Solar modules have been identified as the product category with the highest risk. This is because the modules or their supply chains are almost exclusively located in China, where risks related to forced labor, poor working conditions, ecological degradation, and social risks have been identified. Risks related to forced labor and human rights violations have been identified during the processing and extraction of polysilicon in the Xinjiang region of China.
For inverters, a medium risk of human rights violations has been identified in connection with their production and supply chain. The risk is considered medium—despite no identified cases involving us or our suppliers—due to opaque supply chains and production facilities that have not been audited.
For our direct service providers, or service providers to our direct suppliers, social dumping is the identified risk considered likely. This applies particularly to the hiring of labor for construction sites or services provided to construction sites, such as scaffolding.
We have also assessed the risks of negative environmental impact, both as a direct or indirect cause of negative impacts on human rights and worker welfare, and to identify ecological risk in itself. Risks of negative environmental impact have been identified in connection with the production and transport of materials for solar power plants, as well as negative impacts from low recycling rates in parts of the industry. Specifically, a medium risk of ecological degradation has been identified in connection with the extraction of metals such as aluminum, copper, and silver, which are used in solar modules, inverters, and mounting hardware.
To identify specific risks among the various subcontractors, we have created an overview of the different manufacturers used in our installations. Based on this, we can subsequently identify risks at the individual level and implement targeted measures beyond those already in effect (see the next chapter).
Overview of module manufacturers in our portfolio
Supplier
Country of origin
Phono Solar
China
LONGi Solar
China
JA Solar
China
DMEGC
China
Trina Solar
China
HuaSun
China
Tongwei
China
Overview of inverter manufacturers in our portfolio
Supplier
Country of origin
Growatt
China
Solis
China
Sungrow
China
INVT
China
Kaco
Germany
Overview of mounting hardware manufacturers in our portfolio
Supplier
Country of production
PanelClaw
Netherlands (primarily)
Van der Valk
Netherlands
IBC Solar
Germany
What we do to prevent and mitigate
Our strategy for preventing and mitigating risk is based on the selection of Tier 1 and Tier 2 suppliers. Furthermore, we utilize an informal exclusion list to disqualify suppliers, regardless of tier, if there is documented unacceptable risk or actual negative impacts in their operations or value chain. We use our purchasing power to steer toward the selection of the right panel manufacturers. We are engaged in the Expert Group for Responsible Supply Chains, organized by Fornybar Norge (formerly the Solar Energy Cluster), and we require our suppliers to meet the requirements of, among others, the UN Global Compact, the Solar Industry Forced Labour Prevention Pledge, and the Solar Power Europe Supply Chain Transparency Working Group.
Solar modules and implemented measures
We have excluded solar module manufacturers that may have ties to regions suspected of involvement in forced labor. We work actively to document the modules' value chains and reduce risk. This is also achieved by requiring our EPC partners to undergo qualification and continuous follow-up to ensure they adequately monitor their own suppliers and their respective value chains.
We only select BloombergNEF Tier 1 panels. We have excluded the panel supplier Jinko Solar due to identified risks of ties to forced labor in the Chinese region of Xinjiang, according to the report "In Broad Daylight." Furthermore, we discovered that an EPC had supplied us with the wrong panels on an installation where they provided Tier 2 panels for the roof. Tier 2 panels typically do not have specific or high sustainability requirements, or well-documented conditions or value chains, compared to Tier 1. There is greater risk associated with the production and value chains of these panels. The EPC was required to replace the panels with an approved Tier 1 supplier. Due to the supplier's breach of contract and the associated risk, we have terminated the partnership.
It has also been discovered that the panel supplier Eurener has been unwilling to provide requested documentation and shows little willingness to cooperate. This is being followed up specifically by one of our EPC partners, but we will not approve this manufacturer, as a lack of cooperation and documentation can indicate that they do not have control over their value chain, posing a risk that operations may not be in line with OECD guidelines or the principles of the UN Global Compact.
Inverter manufacturers – risk and measures
We conduct ongoing due diligence of our suppliers, including inverter manufacturers. As of today, we have not identified specific human rights violations linked to our current active suppliers. Nevertheless, we have previously decided to terminate partnerships with certain inverter manufacturers based on the risk of indirect involvement in human rights violations.
One of these is the Israeli inverter manufacturer SolarEdge Technologies Inc. The company is established and still managed from Israel, with its headquarters in Herzliya. Although there is no documentation that SolarEdge is directly involved in military activity or supplies to the Israeli military, we have chosen to exclude the company from our supplier base. The decision is based on ethical considerations regarding the state's role in violations of international law in Gaza and the West Bank.
The background for this is that SolarEdge contributes to the Israeli tax system, which in turn funds a state policy documented to lead to serious human rights violations. The UN, Amnesty International, and Human Rights Watch have described Israel's warfare in Gaza as potential genocide and a violation of international humanitarian law. We therefore believe it is incompatible with our values and the requirements of the Transparency Act to continue a commercial partnership that could indirectly contribute to this situation.
We are monitoring the situation closely and will continue to make specific assessments if new information emerges or circumstances change.
Systematic follow-up
The operational responsibility for following up and further developing our work on human rights and working conditions is assigned to the company's Deployment & Operations department. This function is responsible for implementing due diligence, conducting risk assessments, documentation, audits, and continuous improvement of relevant processes. They also handle non-conformities.
Internally, we focus on guidelines for ethical trade and human rights, employee training, and established whistleblowing procedures. All employees and associated parties are obligated to report potential violations of ethical guidelines, laws, and regulations. Reporting can be done via an immediate supervisor, the CEO (Jonas Ibsen Brynildsrud), or the Chairman of the Board (Einar Sunde). Reports are handled confidentially and in accordance with data protection legislation.
Externally, we focus on systematic supplier evaluations, risk assessments, and close cooperation with suppliers to achieve improvements. This includes third-party verification of value chains, including full traceability of solar panels from raw material to finished modules. We also have EPC partners who conduct supplier visits and inspections in China and Europe.
Our policies and guidelines are available to all employees. Our goal is to achieve Miljøfyrtårn (Eco-Lighthouse) certification by the end of 2025.
Report on our efforts
This statement describes Sunday Power’s efforts to comply with the requirements of the Transparency Act for the 2024 calendar year. It covers the company’s due diligence assessments, including risk evaluations of both our own operations and our supply chains. Furthermore, it outlines the measures implemented to address identified risk areas related to fundamental human rights and decent working conditions. Our work with the Transparency Act is an ongoing process, and we are committed to further developing and strengthening these efforts moving forward.
The 2024 assessment has not uncovered actual negative impacts related to human rights or working conditions within our operations or among our suppliers. Nevertheless, we have identified supplies originating from China as a specific risk area. This assessment is based on recognized international risk reports, which highlight challenges such as forced labor in certain sectors and regions, as well as the complex and often opaque structure of global value chains.
Based on this, this area is and will remain a high priority in our continued due diligence work. Our overarching goal is to ensure that our entire supply chain complies with the requirements for ethical trade, international labor standards, and human rights, and that our procurement of contractor services contributes to a more responsible and sustainable value chain.
We will ensure that requested and relevant information is made available in accordance with the Transparency Act’s duty to provide information (§ 6), and that procedures are in place to respond to inquiries from the public.
Please contact Kjetil Laupsa Steine (COO) or Jonas Ibsen Brynildsrud (CEO) with any questions.
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