ESG due diligence has become continuous, not one-off

^{Notes from the CEO | Henrik Halvorsen | August 2025}

August is the time for Arendalsuka (always in week 33) and while in past years Factlines’ team members had travelled there both to interact directly with customers and to expand our network, this year the tone one encountered on the dock and on the piers was different. The face of ESG has been changing and evolving with every new political and economic turn, and that has made companies and financial actors reflect on the actual meaning of sustainability initiatives, beyond pure reporting for compliance’s sake.

In other words, while at first sight it would appear that only the E in ESG would have survived such a strong legal overturn, companies are finding that Environmental topics cannot be so easily decoupled from Social and Governance ones. Gathering emissions data is but the first step in a long and continuous process of constant improvement, which also includes having full visibility over one’s supply chain and the inherent risks posed by it.

The tentative conclusion by players such as DNB and Storebrand, as was voiced throughout the week, is that in practical terms, due diligence is neither a one-off exercise, nor something which can safely be ignored without further exposing organisations to different categories of risk, including specific threats newly posed by AI adoption.

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With the initial entry into force of the EU AI Act on August 2nd, companies and their value chain will need to contend with yet one more risk area to assess and evaluate.

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If you have a challenge or want to discuss certain supply chain-oriented risks and how to address them efficiently, please contact us. We are here to help!

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Henrik Halvorsen, CEO in Factlines