NORWAY Law and Practice Contributed by: Elisabeth Roscher, Tine Vigmostad, Geir Sviggum and Kristin Nordland Brattli, Wikborg Rein Advokatfirma AS
• there is clear communications management throughout the crisis situation. 5.10 Mandatory Report Several sector-specific laws and regulations include mandatory reporting requirements related to incidents. One example is data secu- rity breaches, as outlined in 5.3 Co-Operating With Enforcement Authorities . Other examples include a duty to report serious workplace inci- dents to the Labour Inspection Authority under Section 5-2 of the Labour Act, and a duty to report environmental incidents under the Regu- lation on Notification of Acute Pollution or Risk of Acute Pollution. The way in which companies ensure timely and accurate reporting to regulatory bodies varies based on: • effective implementation of crisis manage- ment plans; • adequate training of employees; • following internal reporting procedures; 6. Communication 6.1 Co-Ordination of Communications Communication with stakeholders is definitely an important workstream, and is often handled in-house by the communications team or inves- tor relations team. There are also external com- munications advisers who assist in advising on communications workstreams in crisis situa- tions. Communication triggers may be legal obli- gations (see 5.3 Co-Operating With Enforce- ment Authorities ), and outside such obligations may be based on specific assessments of (inter alia) the role of the stakeholder and reputational • involving external legal counsel; or • a combination of such measures.
risks. Many companies have a communications director responsible for co-ordinating stake- holder interactions, but communication regard- ing larger crises also tends to be anchored in the crisis management task force, as further detailed
in 5.9 Reputation Management . 6.2 Internal Communication
It is very important to control access to com- munication during a crisis. This means that those who should be given all the details (normally the board of directors and senior management, as well as key functions) would be given access to such information, but that other details would be restricted from unnecessary access. If it is a public matter (for instance, due to a dawn raid by authorities), it is often advisable to send a brief holding statement to let the employees know that the company is aware of the situation. Which person(s) to contact and in which order would normally be included in a dawn raid man- ual or incident response plan. 6.3 External Communication Effective strategies for communicating with the • having statements anchored in the relevant members of the crisis management team and/or senior management; • identifying a single point of contact; and • media training. The content of the communication is also cru- cial for the public’s perception of the situation and the company, and providing an immediate, transparent and facts-based response is often beneficial in that regard. Collaborating with dif- ferent departments of the company (especially those with expertise within the field that the cri- public and media may include: • a clear communication plan;
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