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SUSTAINABILITY LIBRARY 2023 People Occupational health and safety

Occupational health and safety

Lerøy Seafood Group (the Group) is committed to providing safe and healthy workplaces, by preventing work-related injuries and ill-health, as well as proactively improving its health and safety performance, fulfilling legal and other relevant requirements and working towards achieving defined health and safety objectives.
Positive and Negative Impacts of the Material Topic

Absence of harmful conditions that can cause injury and illness as well as health promoting measures are fundamental principles and rights at work. Promotion of safe and healthy working environment has significant positive impacts both on direct operations as well as operations of our supply chain. Respecting the right to safe and healthy working environment is an inherent part of good business practice. Lerøy expects and requires that the right to safe and healthy working environment is a core component within the operations of the company as well as in relation to employees and workers in our supply chains. Lerøy is working actively to ensure that the company prevents and mitigates the risk of contributing to adverse impacts on human rights.

To the best of our knowledge, the organization is not involved with negative impacts regarding promoting safe and healthy working environment.


Health and Safety Policy

The Group has developed Occupational Health and Safety policy which, on high level, outlines the long-term direction for the Group to support and continually improve its health and safety performance providing an overall sense of direction, as well as framework for setting health and safety objectives.

The policy sets out requirements for the Group’s own health and safety work as well as states that the same strict requirements apply to its business partners. The Group’s business partners must confirm that they acknowledge and will follow the principles stated in the Group’s Business Code of Conduct.

The Group aims to have zero injuries in the workplace and prevent all occupational illness. This is achieved through robust health and safety management which is crucial for succeeding with identifying, preventing and mitigating significant negative occupational health and safety impacts.

Health and Safety Culture

The Group is continuously working on developing a strong safety culture which further develops the defined health and safety direction of the Group. Safety culture in the Group is supported by the Group’s values, managerial practices, patterns of activities and competencies – core elements for ensuring and maintaining sustainable health and safety culture.

The top management in the Group has the ultimate responsibility for an adequate health and safety management in the Group. Each company within the Group has identified specific health and safety roles and responsibilities assigned to one or several individuals to ensure sound and consistent health and safety management locally.

Health and Safety Management

To protect the health and safety of its employees, manage the topic and related impacts, the Group is actively working with identifying and assessing risks, incident reporting and analysis as well as implementation of safety measures. Effectiveness of the implemented safety measures is constantly measured and monitored. The ultimate goal of health and safety management is to prevent workplace accidents and injuries, as well as to promote the overall well-being of employees. This includes providing training on safety practices and procedures, ensuring compliance with regulations and standards, and conducting regular safety audits. 

Lerøy has implemented a business system called Lerøy Way. The main principle of the system is aimed at maximizing performance efficiency and minimizing waste in the value chain. Lerøy Way concentrates on continuous improvement, problem solving, learning and development for all Lerøy employees. By streamlining operations, reducing inventory, and optimizing workflow, Lerøy Way also fosters a culture of innovation and ability to ensure competitiveness and flexibility towards the company's customers.

A team from Lerøy Way team performs audits of the companies in the Group in order to evaluate the degree of implementation of Lerøy Way business system in the companies in question. The audits cover such subjects as production management as well as health and safety management.

To track effectiveness of the actions taken each of the Group’s companies has defined occupational health and safety related KPIs which are monitored and reviewed as a minimum on monthly basis. The reported information and results provide an indication of progress toward the defined goals and targets. Successes as well as challenges and setbacks are identified and shared with relevant stakeholders. If necessary, based on lessons learned, changes are implemented. This may involve revising and updating policies and procedures and changing practices. Lessons learned are used to continuously improve the process to ensure that the actions meet the needs of stakeholders and deliver desired results. Relevant stakeholders receive information regarding implemented changes. 

The Group has implemented a Quality Management System which is available to all companies in the Group as well as employees (individuals who are in an employment relationship with the organization according to national law or practice regarding working time, GRI 2021) and workers (persons that perform work for the organization, GRI 2021) and the system contains general documentation regarding health and safety management. 

If relevant, the Group’s companies also have their own local health and safety management documentation libraries which include description of work processes, procedures and other company specific relevant documentation to ensure that all operations are carried out in a safe manner. All employees and workers are covered by relevant health and safety management system.

The scope and nature of the health and safety management work is defined by relevant own, client and legal requirements.

The legal requirements for health and safety management vary depending on the country of operation. However, some common legal requirements include that the employer is required to ensure health, safety and welfare of all its employees and workers. This includes providing safe equipment, appropriate personal protective equipment, training and information, hazard communication, ensuring that employees and workers are able to identify and manage risks as well as consulting with employees and workers on health and safety matters.

The Group has integrated risk management into its organizational activities, including health and safety management, and view it as an integral part of its governance, strategy and operational processes. 

If relevant, the Group’s companies also have their own local health and safety management documentation libraries which include description of work processes, procedures and other company specific relevant documentation to ensure that all operations are carried out in a safe manner. All employees and workers are covered by relevant health and safety management system.

Quality Management

The Group has a system (an integral part of Quality Management System) for reporting of safety observations, near-misses, injuries, non-conformances and proposals for improvement. This ensures that all types of safety observations, near-misses, incidents, non-conformances and proposals for improvement are registered in a single system helping the Group to gain an overview of the types of cases registered, trends and identify areas for improvement. In 2023 the Group commenced a project the aim of which is to make registration of safety observations, near-misses, injuries, non-conformances and proposals for improvement easier. It has also clarified definitions of registration categories and further developed possibilities for learning. HSE-case registration forms have been updated to make them more user-friendly as well as improve the registered data and analytics to provide an opportunity for knowledge-based decision making.

Incident Reporting and Risk Management

All work-related incidents, be they a near miss or an actual injury, shall be reported in the Group’s incident and improvement proposal reporting system where they are analyzed and handled by employees who have the competency to evaluate, and the authority make necessary changes to the existing practices to improve the overall health and safety performance of the organization. All companies have mapped out their work processes as well as identified process risks, hazards and their mitigating actions.

There shall be no reprisals against either employees or workers as a consequence of reporting of hazards and/or hazardous situations. On the contrary – Lerøy welcomes and encourages incident and hazard reporting as it is crucial for maintaining a safe and healthy work environment.

If relevant and necessary, for example in case of an extraordinary or new work activity to be carried out, a Safe Job Analysis (SJA) is performed prior to execution of the activity in question to ensure that potential risks are identified and there are barriers in place to address these risks. If the SJA concludes that there is a necessity to update or change the current processes or procedure, the change proposal gets submitted to the responsible process/procedure owner who evaluates the proposal and, if appropriate, makes the necessary changes. In 2023 a mobile SJA application was developed and implemented for a part of the Group's companies. The application will be developed further and implemented in the entire Group.

100% (6013 persons) of the Group’s management systems are internally and externally audited via various certifications schemes the Group is part of.

All employees and workers (6013 persons) have received necessary training on how to identify risks and carry out risk assessment as well as HSE related (relevant) internal and external training which is required by national legislation and internal Lerøy standards. Training such as hygiene and safe handling of chemicals training, gas hazard training, safety training, first aid training or training on (use of) particular equipment.

Training in the Farming companies is audited by ASC and Global G.A.P.  Norwegian Maritime Authority audits trawling companies on regular basis. The subject of training is part of the audits.

They also received both generic training regarding the organization, its processes and procedures as well as specific training depending on their position and the type of work they carry out. Review of specific, work-related hazards, hazardous activities and the appropriate procedures to address these is included in the training.

The Group launched a general HSE training. The online training is available for companies in the Farming segment on the Group’s digital training platform Motimate and covers such topics as:

Occupational Health and Safety Management in Lerøy:
  • Legal Requirements
  • Occupational Health and Safety Management system
  • Occupational Health and Safety Policy and Targets
  • Occupational Health and Safety related Roles in the Organization
Quality Management in Lerøy
  • Lerøy Quality Management System
  • Reporting of Non-conformances and Incidents – Definitions and Case handling
  • Reporting and Whistleblowing
Recordable work-related injuries
  • Trends and Statistics
  • Risk-reducing Measures
Emergency Preparedness and Risk Management
  • Emergency Preparedness
  • Risk Assessment, Action Plans and Safe Job Analysis
  • Training
Working environment and External Environment
  • Internal and External Environment
  • Working Environment and its key Features
Occupational Health and Safety Follow-up and Continuous Improvement
  • Occupational Health and Safety Follow-up
  • Continuous Improvement and Occupational Health and Safety Yearly Plan
Occupational Health and Safety related Compliance

All companies in the Group are compliant with the existing occupational health safety legislation in the countries they operate in as well as follow the principles laid out ISO 45001 standard Occupational Health and Safety, however none of the companies has a third-party certification an independent verification that the company meets the principles in the standard.

Occupational Health and Promotion of Employees' and Workers' Health

Most companies within the Group which have employees and workers have established cooperation with an occupational health and safety service provider. Occupational health service providers are involved in risk identification processes as well as serve as advisory bodies regarding various health and safety issues.

The Group uses only authorized occupational health and safety services as well as performs due diligence prior to contracting an occupational health and safety service provider.

The Group is working on promoting employees’ and workers’ health by offering voluntary health promotion services, such as in-house training and voluntary training groups which the employees and workers can join. Some of the companies offer a yearly physician check-up to evaluate the health condition of the person in question and suggest further check-ups/treatment if necessary/appropriate. Information regarding employee and worker health promotion is published on and communicated via the company’s intranet which is available to all employees and workers.

Sick pay practicies

The companies in the Group follow the respective sick pay practicies in various contries in accordance with local legislations and company policies. All employees are entitled to sick pay regardless of employee category/ seniority level or contract type. The companies ensure that the requirements for living/ minimum wage standards are met, based on collective agreements and/or in compliance with national legal standards.

All Norwegian companies cover the difference from the state's maximum limit for sick pay to the current salary for their employees, with the exception of sailing employees in our trawler company who follow the respective industrial collective agreement. Companies in Norway, Italy and Spain advance wages in the event of sick leave.

Employee and Worker Participation

The Group has four core values – Honest, Open, Responsible and Creative. These are incorporated in all our activities and shall define our behavior at work. All employees and workers are encouraged to provide feedback thus influencing and developing transparent two-way communication, consultation and participation practice.

Employees and workers are enabled to contribute and comment on health and safety practices, and it is ensured that all employees and workers have an opportunity to reporter hazardous situations, so that preventative measures can be put into place and necessary corrective action taken. The Group views consultation and participation of employees and workers as a detrimental success factor for the organization and its development.

83% of all companies in the group have a formal joint management-worker health and safety committee/ safety representative.  NB! In smaller size companies, where it is not required to have a safety committee, safety representative represents the employees and workers in matters concerning health, safety and working environment.

The aim of the committee is to enable a two-way communication and exchange of information as well as give informed feedback to be considered by the organization before implementing a change or deciding.

Employee representatives, which represent both employees and workers, are a central part of the joint management-worker health and safety committee. The committees meet at least four times a year, extra meetings can be held if necessary.

The committees are handling issues such as occupational health and safety services, reports from safety representatives, training, organizational changes, corrective and preventative measures, risk evaluation as well as other working environment related issues. The Group aims to be a learning organization and is inviting feedback regarding improving its safe work practices.

Employees' and Workers' Right to Remove Themselves from Hazardous Work Situations

The Group’s Code of Conduct, which all employees of the group must acknowledge and follow, states that health and safety is the number one priority of the Group and that no compromises shall be made when it comes to the employee’s and worker’s safety. All employees and workers have the right to remove themselves from work situations that they believe could cause an injury or ill health.

Occupational Health and Safety Performance Indicators 2023

The Group is monitoring and measuring the following health and safety performance indicators. These indicators are used to track the effectiveness of actions taken as well as evaluate progress of actions taken. The indicators are reviewed monthly both locally by the companies as well as the Group’s Management Team. If a performance in an indicator is not satisfactory measures are put in place to improve the performance on the indicator in question. If necessary and appropriate relevant updates are incorporated into the organization’s operational policies and procedures.

Performance indicator

Result  (2023)


Lost time injury frequency rate (LTI- H Value)


((Number of injuries resulting in absence form work) x 1 000 000/ total number of working hours in the respective period)


Total lost time injury frequency rate (TLTIFR)


((Number of injuries resulting in absence form work) + (Number of injuries without absence from work)) x 1 000 000/ total number of working hours in the respective period


Leave of absence due to illness (total)

6,04 %


Leave of absence due to illness = ((Number of  total sick leave days) x 100/ Number of possible working days)

Leave of absence due to illness (short-term)

2,35 %


Leave of absence due to illness = ((Number of short-term sick leave days) x 100/ Number of possible working days)

Leave of absence due to illness (long-term)

3,69 %

Leave of absence due to illness = ((Number of long-term sick leave days) x 100/ Number of possible working days)

Work-related injuries with absence


Number of work-related personal injuries that have resulted in absence from work

Number of work-related injuries without absence


Number of work-related personal injuries that have not resulted in absence from work

Number of near-misses


Work-related incidents/situations that cause physical injury but do not result in treatment by medical personnel

Number of safety observations


Fault or defect, for example, equipment, technical objects or breach of routines and procedures that may cause physical damage/ harm

Number of fatalities related to work


An occupational fatality is a death that occurs while a person is at work or performing work-related tasks

% of companies having working environment committee (or safety representative, if/ when relevant) which includes an employee representative


Companies having a working environment committee which includes an employee representative

  • H1 value/ Lost Time Injury (LTI) frequency = 0
  • Total number of near-misses and safety observations 2023: 3 per person-years