The audit was conducted from 5 to 8 March 2024.


In recent years, Havtil has found a number of breaches of the regulations concerning the working hours provisions. In order to plan and properly manage an individual’s working hours, a system for registering and following up working hours is a prerequisite. One of the purposes of Section 10-7 of the Working Environment Act and Section 7 of the Activities Regulations is that the company itself shall have the necessary overview of working hours and that the supervisory authorities are able to verify that the provisions are complied with.


The objective of the audit was to verify that Repsol has a system for registering and following up the working hours provisions. The audit did not investigate the company’s use of overtime and the management of risks associated therewith.


The audit identified three regulatory non-conformities. These applied to the following:

  • System for registration and follow-up of working hours
  • Competence in working hours
  • Involvement of employee representatives in the event of an extended offshore period

We also observed one factor that we have chosen to categorise as an improvement point. This concerned:

  • Routine for involvement of employee representatives in the event of extended overtime

What happens now?

We have asked Repsol to report by 6 May 2024 on how the non-conformities will be addressed and for their assessment of the improvement point observed.