Synergies or silos? Exploring human rights considerations in sustainability reporting practices in the Nordics

2.1. Norway

Norway's first VNR was submitted in 2016, ⁵ followed by a second reporting cycle in 2021. ⁶ It is possible to observe an evolution in the reports, the first one being a brief evaluation of the country's initial steps, whereas the second is an extensive report, consequently going much more in-depth into the country's actions implementing the 2030 Agenda.

The first report builds strongly on the discourse of human rights and draws a clear connection between human rights and the 2030 Agenda, perceived as a ‘unique opportunity and platform for boosting human rights implementation at the country level.’ ⁷ This framing of the 2030 Agenda within a human rights discourse is further emphasised by Norway's acknowledgement of its obligations under international human rights law and how the efforts to meet the SDGs must be in line with existing norms and standards. ⁸

The implementation of the 2030 Agenda is further connected to Norway's support of the United Nations (UN) High Commissioner for Human Rights and the integration of human rights into the overall work of the UN. ⁹ The report further denotes an understanding of the existing interconnection between human rights and the 2030 Agenda by reflecting on the potential synergies within human rights mechanisms such as the Universal Periodic Review and those follow-up procedures established under the 2030 Agenda. ¹⁰

This approach to a 2030 Agenda anchored in human rights disappears to a great extent in the country's second VNR. Whereas the 2016 report had a section dedicated to explaining the country's human rights-based approach, ¹¹ no such section is found in the second report. Furthermore, no significant reference to human rights is made until the discussion of Norway's foreign and development policy and more importantly, in reference to the LNOB principle. ¹² It is in this context that Norway discusses the consistency of its policies with ‘the principles and obligations set out in human rights conventions’ ratified by the country. ¹³ Further discussion of rights happens almost exclusively within the framework of the LNOB principle and in the context of foreign and development policies. No further human rights mechanisms or instruments are considered.

It is possible to observe a significant change in the level of involvement and participation of stakeholders in the elaboration of the VNRs. The lack of stakeholder involvement in Norway's first VNR was identified as a key challenge from the beginning in 2021's VNR. ¹⁴ Norway tried to address this issue by entrusting three umbrella organisations, namely the Norwegian Forum for Development and Environment, the UN Global Compact (UNGC) Norway and SDG Norway, to coordinate civil society, the private sector and academia respectively. ¹⁵ The Sami Parliament (Sámediggi) was involved in both reviews, highlighting the importance of ‘standards and ethical guidelines’ for achieving the SDGs that ensure the protection of Indigenous people's rights. ¹⁶ Remarkably, whereas the UNGC Norway had a leading role as an umbrella organisation representing the business sector, only the Sami Parliament alluded to the fact that ‘human rights are the first 10 principles of the UNGC’ in relation to corporate responsibility towards the 2030 Agenda. ¹⁷

One of the most noteworthy aspects from one report to the other is the absence of the Norwegian National Human Rights Institution (NHRI) in 2021's VNR. Whereas the NHRI was consulted in preparation for the 2016 report, there is no mention of it in 2021. ¹⁸ Norway's latest report only considers NHRIs once, specifically in the section about the promotion of the LNOB principle in their foreign and development policy. Norway remarks how ‘vital’ it is to support NHRIs as part of these external policies to ensure ‘that the rights of minorities and vulnerable groups are not left behind’. ¹⁹ No similar reference can be found for the national context.

2.2. Sweden

Sweden's first VNR, completed in 2017, is characterised by a strong commitment to gender equality and ‘the full enjoyment of human rights by all women and girls’ as a pre-requisite for implementing the 2030 Agenda. ²⁰ Overall, the 2030 Agenda is perceived as a means to ‘realise, achieve gender equality and empower women and girls.’ ²¹ Human rights considerations beyond the rights of women and girls in the VNR are limited to listing ‘human rights’ as part of a long inventory of issues that will be realised through the 2030 Agenda alongside ‘the long-term protection of the planet’ or ‘fighting poverty and hunger.’ ²²

There are no references to a human rights-based approach in the implementation or reporting beyond the use of a ‘rights perspective and the perspective of poor people’ in relation to Sweden's Policy for Global Development (PGU). ²³ There are no other groups of rightsholders highlighted and no mention of the country's pre-existing obligations under international human rights law. Instead, the VNR seems to be anchored on Sweden's contribution to, and obligations under, international environmental frameworks such as the Paris Agreement or the Addis Ababa Action Agenda on Financing for Development. ²⁴

The report references several key human rights issues but does not explicitly use human rights language to refer to them. For example, under the government's work to implement the 2030 Agenda, there is no consideration of rights and obligations under some key categories such as ‘integration’ or ‘food security’. ²⁵ In other cases, rights are equated with goals, such as the case of ‘health and well-being.’ ²⁶ The report nonetheless references key business and human rights regulatory frameworks such as the UN Guiding Principles on Business and Human Rights (UNGPs), the OECD Guidelines on Multinational Enterprises or the ILO Core Conventions and Tripartite Declarations. ²⁷ These are discussed as part of the country's ‘increased ambition for sustainable business’, used interchangeably with ‘CSR’. Whereas the adequacy of including these human rights regulatory frameworks under these notions might be debatable, ²⁸ it is nonetheless relevant that Sweden reflects on companies’ responsibility ‘to comply with internationally recognised human rights in their operations in Sweden and abroad.’ ²⁹

In stark contrast with the overall approach from its initial VNR, Sweden's second report submitted in 2021, anchors the implementation of the 2030 Agenda explicitly on ‘human rights and gender equality’ and expands the rightsholders considered beyond women and girls to also explicitly encompass ‘the rights of the child, including the perspectives of children and young people and their right to meaningful participation.’ ³⁰ Sweden's global development policy continues to be based on ‘the rights perspective and the perspectives of poor people.’ ³¹ The group of topics discussed using a rights-based approach is expanded, and a particular emphasis is placed on sexual, reproductive and health rights (SRHR). There is also an increased focus on business and human rights with clearer expectations for companies. ³²

The report evaluates its work to implement the 2030 Agenda under different international platforms, including the European Union, the UN, and the OECD. ³³ The recommendations by ‘international review bodies’ in relation to human rights, as well as Sweden's performance in the latest Universal Periodic Review, are evaluated in the context of the LNOB principle. Other national human rights-related concerns, such as the situation of Indigenous peoples, national minorities and general non-discrimination regulations, are also reviewed as part of the LNOB principle, but not in reference to the country's obligations under international human rights law. ³⁴

Stakeholder engagement is also a key difference between both reports. The 2017 VNR only indicates that a ‘large number of stakeholders’ contributed to its production but does not specify the type of engagement or the nature of these stakeholders. ³⁵ In contrast, Sweden's second VNR goes into a great deal of detail to include the contributions of key stakeholders from civil society, the business sector, and the research community. ³⁶ It is important to highlight that Sweden's NHRI only became operational in January 2022, and it will be relevant to follow-up its involvement in the third VNR reporting cycle. ³⁷

One key example of consequential stakeholder participation in the second VNR is found in the critiques to the Government's work on sustainable business. Swedish Civil Society Organisations (CSO) comments included in the VNR point towards a lack of compliance among many companies with regards to human rights policies in their operations. ³⁸ They point towards a wider problem of policy coherence in areas such as business and human rights, were ‘certain policies counteract policy goals in other areas’ and ‘ambitions have been lowered, in order to favour other, short-term interests.’ ³⁹

2.3. Denmark

Denmark's understandings of the 2030 Agenda are strongly anchored in human rights in its 2017 VNR, in particular the rights of women and girls, with a specific focus on SRHR. ⁴⁰ Throughout the report, it is highlighted the Government's view that ‘the SDGs and human rights are interrelated in a mutually supportive way, in which human rights can guide the follow-up on the SDGs just as the SDGs can contribute to the realisation of human rights.’ ⁴¹ As with human rights, there is an understanding that the 2030 Agenda and the SDGs ‘are universal and applicable to all countries, including Denmark.’ ⁴² However, a human rights- based approach is only explicitly mentioned in its international development and cooperation policies. ⁴³ International human rights mechanisms are only mentioned in reference to the Danish candidacy for the Human Rights Council in 2019–2021. ⁴⁴

Thematically, there seems to be a strong focus on business and human rights frameworks such as the UNGPs and the OECD Guidelines in both VNRs. Businesses also reference the implementation of the UNGPs as a tool to integrate the SDGs into their business practices. ⁴⁵ Nevertheless, the discussion of business responsibility to respect human rights is anchored exclusively on CSR practices, and most companies consulted by the UNGC Denmark use the SDGs as ‘a tool to brand and communicate about initiatives.’ ⁴⁶ This can challenge human rights understandings of corporate responsibility if the SDGs are used by companies as a mere marketing tool instead of guiding their business practices to meet their responsibility to respect human rights.

Denmark's second VNR in 2021 seems to miss this interconnection between human rights and the 2030 Agenda. There is no significant use of rights language or considerations outside the scope of LNOB and international policy. The same statement found in the first VNR where the Government finds the SDGs and human rights to be ‘interrelated and mutually supported’ is now exclusively confined to the international policy section. ⁴⁷ Furthermore, in this version, the Government adds a few nuanced words to the sentence changing the meaning of the original meaning to ‘the SDGs can contribute to the realisation of human rights and shape the Government's global engagement’ further pointing to a trend where human rights considerations within the Sustainability Agenda are limited to international development and foreign policies. ⁴⁸

The stakeholder engagement in both VNRs is considerable, with active contributions from the private sector, academia, and CSO, especially in the second VNR. The Danish NHRI is listed as a contributor to the 2017 report but there is no mention of the extent of its contribution. ⁴⁹ There is no mention of the Danish NHRI in the second VNR. In both reports, the CSOs seem to favour the use of human rights language and lead the inclusion of human rights considerations when referring to the governments’ measures and their own contributions to the implementation of the SDGs.

For example, the work by the Danish organisation International Work Group for Indigenous Affairs in the development of ‘The Indigenous Navigator’, a tool that collects disaggregated data and monitors the implementation of Indigenous Peoples’ rights in relation to the SDGs. ⁵⁰ The work of Women and Development's (KULU) work is conducted through a women's rights lens, but the report highlights its connection to SDG 4 (Quality education), SDG 5 (Gender equality) and SDG target 16.9 (Legal identity). ⁵¹

The CSOs however highlight the existence of a ‘silo mentality’ in the implementation of the 2030 Agenda in the country, ‘especially in the separation between the national implementation of the SDGs (through the national action plan) on the one hand, and Denmark's international contribution to the SDGs (through the strategy for development cooperation and humanitarian actions) on the other.’ ⁵² Furthermore, they describe a ‘monographic approach’ where the SDGs are regarded as ‘something external’ and not an agenda for practical change. ⁵³ This has led to ‘missed opportunities for creating synergies or identifying potential areas of conflict and contradiction between the national and international levels.’ ⁵⁴

2.4. Finland

Finland actively advocated for a 2030 Agenda founded on ‘broad-based participation and human rights.’ ⁵⁵ Nonetheless, human rights considerations in Finland's VNR from 2016 are mostly limited to the country's development policy. ⁵⁶ Finland refers to the promotion of human rights in development cooperation as a ‘key objective, alongside enabling people and authorities to promote human rights.’ ⁵⁷ This is defined as the basis of their human rights-based approach, which ensures that development policy covers ‘the rights of women, girls and children, and those of people in the weakest position, in particular those with disabilities.’ ⁵⁸ However, this is perceived as an ‘external dimension.’ ⁵⁹

This trend continues in Finland's second review in 2020, where there was a strong usage of human rights language both in the development and foreign policy and in the LNOB section. ⁶⁰ One key difference is that the LNOB section also acknowledges the national context and the need to complement the country's LNOB approach in development policies with considerations of human rights also at home. ⁶¹ Nonetheless, we still find most human rights considerations in the country's external policies.

This includes references to the work of the UN in the implementation of the Sustainability Agenda and Finland's efforts to ensure that this work takes into consideration ‘international law, democracy and human rights.’ ⁶² Supporting the work of the United Nations Office of the High Commissioner for Human Rights, as well as the existing human rights monitoring mechanisms are central elements to ensuring the rights of ‘women and girls, indigenous peoples and persons with disabilities’ which are among the key priorities in Finland's foreign policy. ⁶³ Other groups of rightsholders prioritised by Finland's international work include human rights defenders, Indigenous people and women and girls. ⁶⁴

Following the same tendency identified in the majority of VNRs studied, Finland's considerations of human rights are limited to LNOB or foreign policy sections in the report. For example, the VNR preparatory seminar on basic and fundamental rights mentioned above was framed within the discussion of ‘critical issues regarding LNOB in Finland.’ ⁶⁵ Equally, most references to human rights are found exclusively in the development and ‘external policy’ sections of both reports. ⁶⁶

It is relevant to highlight that in the 2020 report, the evaluation of Finland's measures to implement the 2030 Agenda through their international policies includes a section connecting measures with the relevant SDGs and rights supported. One example includes Finland's work to ‘enable developing economies to offer more jobs, livelihoods and well-being’ which connects with SDGs 1,8,9 and 12, and was implemented by supporting the labour rights of 560.000 workers and small farmers and mobilising resources during their presidency of the Council of the European Union to promote EU's action ‘on the role of the private sector in advancing human rights.’ ⁶⁷ From all the studied VNRs, only Finland's latest report includes such a clear practical illustration of the connection between policies and the interrelated human rights and SDGs impacted by them.

Finland's stakeholder engagement in the elaboration of both VNRs is remarkable, including the participation of a wide range of actors such as youth groups, the Expert Panel on Sustainable Development, and even ‘Santa Claus himself’. ⁶⁸ In fact, Finland's second VNR is said to have a ‘specific flavour’ given by ‘the broad engagement of key stakeholders.’ ⁶⁹ Fifty-seven CSOs participated in the process of evaluating the country's performance and a specific seminar on basic and fundamental rights was hosted in preparation for the VNR. ⁷⁰ However, it is also remarkable that none of the reports mentions the involvement of the NHRI.

3.1. The silos

Some SDGs remain clearly siloed from human rights. This affects particularly SDG 7 (Affordable and clean energy), SDG 9 (Industry, innovation, and infrastructure), SDG 11 (Sustainable cities and communities), SDG 13 (Climate action) and SDG 15 (Life on land). None of the VNRs studied consider the human rights underpinnings of these SDGs, nor any connection whatsoever with human rights.

According to the Danish Institute of Human Rights (DIHR) Guide to the Sustainable Development Goals, each of these SDGs is strongly interlinked with articles from the Universal Declaration of Human Rights (UDHR) and the eight core international human rights treaties. ⁷² SDG 13 has the most interconnections, correlating with seven core international human rights treaties. ⁷³ Whereas the connections between each SDG and the international conventions vary, it is possible to find synergies between the five of these SDGs and The International Covenant on Economic, Social and Cultural Rights (ICESCR). ⁷⁴

A clear missed reporting opportunity for each of these SDGs is their strong connection with Indigenous rights. Sami people in Norway, Sweden and Finland, and Kalaallit Nunaat (Indigenous Peoples of Greenland) continue facing challenges to have their rights over the land and resources fulfilled. ⁷⁵ According to the DIHR Guide, SDGs 7, 9, 11 and 15 and multiple of their targets relate to several articles from the UN Declaration on the Rights of Indigenous Peoples (UNDRIP). This is a cause of concern as Sami representatives consulted for the VNR process highlighted a lack of sufficient promotion and protection of Indigenous people's rights, in particularly in Finland and Sweden. ⁷⁶ One potential reason for the lack of human rights considerations in these SDGs is the absence of human rights organisations involved in the individual SDG evaluations. ⁷⁷

Another example of missed synergies in the individual reporting of these four SDGs is their strong connection with business and human rights. The private sector, along with international business and human rights regulatory frameworks, have consolidated their presence in the VNRs either as contributors to the report, or stakeholders with a key role in the implementation of the 2030 Agenda. Perhaps one of the most obvious SDGs related to the private sector is Goal 9 (Industry, innovation, and infrastructure), and yet, no mention of how instruments such as the UNGPs or the Global Compact Principles are related to the private sectors actions in the implementation of this particular Goal. This is also the case with the creation of sustainable cities and communities and climate action. The space dedicated to report on the implementation of Goal 15 creates the perfect intersection between Indigenous rights and the responsibility of the private sector to respect human rights in relation to the use of land and resources of Indigenous communities. However, none of the studied reports includes these human rights considerations.

Other Goals that remain siloed for the most part are SDG 6 (Clean water and sanitation) and SDG 14 (life below water). Unlike SDGs 7, 9, 13 and 15 above, three of the eight evaluated VNRs make some reference to human rights in relation to Goals 6 and 14. However, the referred connections are superficial. In the case of Goal 6, Finnish CSO's have contributed to its progress report during the country's second VNR. It is these organisations that bring up the ‘evident’ interrelation between water, sanitation and women's and girls’ rights and how positively the country's development policy priorities have taken this into consideration ⁷⁸ — remarkably, the Government's evaluation of SDG 6 does not consider this connection between water and sanitation and human rights. ⁷⁹ On the other hand, the Swedish government acknowledges how the country ‘should pursue a rights-based approach to water management and access in line with LNOB’ as a future measure. ⁸⁰

In the case of SDG 14, only Norway's first report connects its activities falling under the ‘life under water’ Goal with its obligations under international law. It does not conduct an in-depth evaluation, but merely mentions that the existing rules regulating fisheries are ‘in accordance with international law regarding the rights of minorities and Indigenous peoples.’ ⁸¹ This reference is omitted from the latest report from Norway, where it is relevant to highlight that no Indigenous’ peoples or minority representatives were consulted for the individual evaluation of SDG 14. ⁸²

3.2. The synergies

In stark contrast with the SDGs analysed above, other Goals were clearly connected with human rights in a consistent manner throughout the studied VNRs. This is the case of SDG 3 (Good health and well-being), SDG 5 (Gender equality), SDG 10 (Reduced inequalities) and SDG 16 (Peace, justice, and strong institutions). The individual SDG reporting for each of these SDGs reflects on the synergies existing between them and human rights and analyses the implementation challenges and next steps through a human rights lens in most of them.

Reporting on the implementation of the ‘Good health and wellbeing’ goal and its targets, Norway highlights how ‘health and access to basic health services are fundamental human rights and a prerequisite for economic growth and social inclusion.’ ⁸³ Sweden also reflects on how ‘care shall be delivered with respect to the equal value of all humans and the dignity of every individual’, ⁸⁴ echoing the language of the UDHR.

Where the State does not reflect on these synergies, the civil society stakeholders involved in the SDG implementation evaluation bring a human rights lens into their analysis. For example, Norwegian and Danish CSOs refer to their countries lack of equal health rights for undocumented migrants, Sami population and other disadvantaged groups. ⁸⁵ In the same way, Finnish CSOs commend their country's positive role defending health and ‘associated rights’ at the European Union level and their efforts leading the rights of people with disabilities in this area. ⁸⁶

SDG 5 (Gender equality) is also analysed through a human rights’ lens in all the VNRs. The four Nordic countries indicate their commitment, or ‘global responsibility’, to promote, empower and/or support women's and girls’ rights. ⁸⁷ Sweden's engagement with SDG 5 is particularly emphasised throughout the entire report and overlaps with the analysis of other SDGs due to the country's dedicated feminist foreign policy, which has as an objective to ensure the ‘full enjoyment’ of women's and girls’ human rights. ⁸⁸ Finland's VNR highlights how its foreign and security policy is based on human rights and their ‘key objective is to systematically promote gender equality and full realisation of the human rights of girls and women.’ ⁸⁹ Denmark also emphasises its leading role ‘in the fight for equality between the genders and equal rights for women and girls both at the state level and in international negotiations’ under SDG 5. ⁹⁰

A shared reporting trend for SDG 3 and SDG 5 in the Nordics is an emphasis on SRHR. All the VNRs studied include references either by the State or the CSOs to advancements or implementation challenges in this area. ⁹¹ Promoting SRHR is a ‘main priority’ for Norway and Norwegian CSOs emphasise how the country is a ‘strong international advocate for gender equality and SRHR.’ ⁹² Finland and Sweden share this emphasis on SRHR and each country's role defending them internationally. ⁹³ In addition, most references to SRHR have a particular focus on the rights of women and girls. ⁹⁴

SDG 10 (Reduced inequalities) is also connected to human rights throughout the studied VNRs, although in a much more superficial manner. In the evaluation of its progress implementing this Goal, Norway states that it ‘supports the human rights-based approaches of the UN’ ⁹⁵ and that the country works to promote gender equality and respect for workers’ rights in the private and public sectors. ⁹⁶ Both Sweden and Finland point to the realisation of equal rights through the national legislation and the welfare state. ⁹⁷ Many of the VNRs put special emphasis on the rights of vulnerable groups such as people with disabilities, children, LGBTQ persons, Roma populations, and other minority groups. ⁹⁸

Finally, it is in the reporting of SDG 16 where we find the strongest ties to human rights. All the countries studied identify human rights as the foundational basis for peace, justice, and strong institutions. Norway highlights how ‘democracy, human rights and the rule of law protect the rights and privileges of individual citizens’ and are ‘thoroughly addressed in the 2030 Agenda, and particularly SDG 16.’ ⁹⁹ The four countries point out how human rights are enshrined in their Constitutions, and they are taking steps to codify the rights of vulnerable groups. ¹⁰⁰ Each country report focusses on different measures articulating these synergies, for example national plans or strategies on human rights, ¹⁰¹ or contributions to international human rights bodies such as the UN Human Rights Council or the UN OHCHR. ¹⁰²

Another element all these countries have in common in their progress assessment for SDG 16 is the emphasis on their global contributions to building inclusive societies based on human rights and the rule of law. ¹⁰³ These activities are framed within the countries’ foreign and development policies, which is a trend observed in the assessment of the overall 2030 Agenda implementation as well as in the progress reports for individual SDGs. Due to its relevance, this trend will be further explored in the section below.

3.3. Human rights as an ‘External’ dimension

A clear emerging trend in the Nordics based on the studied VNRs is the inclusion of human rights considerations mostly within the country's foreign and development policies, but surprisingly not with their implementation efforts at national level. This trend was also highlighted in the study of the overall human rights-based approach of the Nordic reports.

One example can be found in the assessments of SDG 2 (Zero hunger). Norway refers to its efforts towards food security as ‘rights-based’, but only in relation to their international support. ¹⁰⁴ Swedish development policy has women's rights at its core due to the central role women have in relation to food security, and it promotes a ‘rights-based approach to food security’ in their development practices. ¹⁰⁵ It could be argued that both countries are far ahead in the local implementation of SDG 3. However, both Sweden and Norway have received recommendations through different UN human rights Treaty Bodies to fulfil the right to access food resources of Indigenous Sami population. ¹⁰⁶ In addition, some of these Treaty bodies have expressed concerns over access to food and nutrition of elderly population, children, migrants, asylum seekers and other minority groups in Norway. ¹⁰⁷

Another relevant example is SDG 17 (Partnerships for the Goals). Only three VNRs mention human rights in under the individual assessments of this Goal. Finland's 2020 review highlights the country's commitment to a human rights-based development policy and the need for the country to demand a ‘human rights-based approach as a prerequisite for all projects and funding’ related to sustainable development. ¹⁰⁸ Sweden's second review refers to its efforts at EU level to create binding rules on business and human rights and Denmark highlights its work supporting human rights and sustainability schemes between countries in Africa, the Caribbean, and the Pacific. ¹⁰⁹

On the one hand, this trend points to a possible collaboration gap between the Nordic governments, local human rights organisations and NHRIs in the implementation of the 2030 Agenda. Silo mentality seems to be prevalent and preventing potentially beneficial synergies in the implementation of both human rights and sustainability agendas. Many VNRs identify this lack of policy coherence, with Sweden identifying it as one of its biggest challenges, particularly ‘in terms of analytical tools and clear methods for identifying and managing synergies and incoherence between different policy areas.’ ¹¹⁰

‘Externalising’ human rights considerations and placing them almost exclusively under international policies gives a ‘blurred’ notion of the States obligations to respect, protect and fulfil human rights in their own countries. In a communication to the Norwegian Parliament in relation to the country's action plan to implement the SGDs, Norway's NHRI pinpoints that the Parliament mixes in several cases ‘obligations under international law and long-term political goals,’ something they warn against. ¹¹¹

It is possible to affirm that the studied VNRs point to a nearly consistent absence of human rights considerations in the national contexts, the only area where States not only have clear jurisdiction, but human rights obligations under international human rights law. It is much more difficult to argue that these States have any human rights obligations beyond their own borders. In other words, States can pay lip service to human rights and set ambitious goals in this ambit beyond their borders without any real consequences if they do not meet said goals. The absence of a human rights lens over the local implementation of SDGs that tightly overlap with human rights obligations is a concerning trend that should be explored in further research.

3.4. CSOs and business as human rights actors

The absence of human rights considerations in the local context is most often remedied by the feedback of CSOs. It is possible to observe a higher use of human rights language and references in those VNRs where the comments of CSOs have been actively included though dedicated sections. CSOs not only include human rights considerations but explore their implications and synergies with the implementation of the SDG in question to a further extent.

One very relevant example can be found in Norway's second VNR, where the human rights synergies of each SDG, in both national and international contexts, are mostly identified by the participating CSOs. ¹¹² For instance, in the evaluation of SDG 8, the government's assessment superficially refers to the Norwegian labour model as a safeguard for workers’ rights nationally and the efforts to adopt a mandatory human rights due diligence law. ¹¹³ The CSO's assessment on the other hand describes these issues in depth by exploring the repercussions of said due diligence law, as well as the limitations of the labour laws in the country where vulnerable

groups such as immigrant workers are still at risk of exploitation. ¹¹⁴ Furthermore, the CSOs analysis also points out to a ‘lack of coherence between different policies related to SDG 8’, meaning that ‘human rights, workers’ rights and environmental rights repeatedly lose out to trade interests where Norway negotiates trade agreements with countries where these rights are at serious risk.’ ¹¹⁵

Just like in the example above, CSO contributions are also fundamental to paint a more comprehensive picture of the country's human rights situation through the lenses of the SDGs. In Finland's second review, the government's assessment of SDG 16 reflects on the country's global responsibility to ‘develop effective societies based on a brad democracy concept, where promoting human rights, rule of law […] and empowering citizen's participation are considered key to reinforce democracy.’ ¹¹⁶ Finnish CSOs on the other hand express concern over the weapons exports to countries which ‘violate human rights according to international reports.’ ¹¹⁷ These organisations also highlight positive advancements by the country, such as the role of Finnish actors supporting the rights of women, children, young people and people with disabilities in fragile States. ¹¹⁸

CSOs tend to also represent the interests of specific social groups, such as the elderly, young people, or Indigenous populations, among others. For this reason, their contributions tend to provide more data for the implementation assessment of both the sustainability and the human rights agendas. Additionally, they bring into the picture a more intersectional perspective, which - although limited by the format - allows for better reflection of different rightsholders experiences. Nonetheless, some rightsholders’ views remain underrepresented, for example those of LGBTQ + individuals which, except for Sweden's 2021 report, have not been included. ¹¹⁹

It is relevant to mention that although the participation of the private sector in the VNRs is limited, and in most cases through the representation of umbrella organisations such as the Global Compact, their role is directly connected with human rights in multiple occasions. It is possible to observe a consolidation of business and human frameworks such as the UNGPs or the OECD Guidelines for Multinational Enterprises from the first to the second cycle of VNRs in the Nordics, where corporate responsibility to respect human rights not only seems to be widely accepted but also expected. ¹²⁰ Each country assesses the advancements in the implementation of these frameworks through diverse lenses, but always under a version of ‘CSR’ or ‘Sustainable business’. ¹²¹ This points to a possible conceptual gap in the States’ understandings of these regulatory frameworks as associated to the sustainability agenda but not necessarily to human rights.

It is clear, however, that there are stronger expectations for business to play a key role in the implementation of the 2030 Agenda, and to do so while respecting human rights. This is also reflected in the more ambitious measures put forward by some States such as Norway, that has introduced a mandatory human rights due diligence law (Transparency Act). ¹²² In its VNR, Norway directly links this law to the fulfilment of SDG 8 (Decent work and economic growth) both at home and abroad by ensuring that Norwegian companies report of human rights in their value chains. ¹²³ CSOs from Denmark also highlight the significant contribution of responsible business conduct to the SDGs, but calls for a ‘smart mix’ of measures that combines voluntary initiatives as well as mandatory ‘human rights and environmental due diligence in accordance with the UNGPs and the OECD Guidelines.’ ¹²⁴ This ‘smart mix’ —although not explicitly acknowledge as such in the VNR— is strongly anchored in human rights as developed by former Special Representative for Business and Human Rights John Ruggie in relation to the UNGPs. ¹²⁵

The private sector is expected to play a key role in the realisation of the 2030 Agenda. ¹²⁶ Deva has argued that ‘the UNGPs and the SDGs appear to be two siblings born four years apart with little connection’ as the UNGPs do not make an explicit connection between human rights and the sustainable development agenda. ¹²⁷ Notwithstanding this gap in the theory, it is clear in the practice as reflected in the VNRs, that Nordic States perceive a clear interconnection between the UNGPs and other business and human rights frameworks and the SDGs.