Transparency Act
Explanation of due diligence assessments Trafsys AS and Norphonic AS (herafter referred to as the Company)
The purpose of the Transparency Act is to promote businesses’ respect for fundamental human rights and decent working conditions in connection with the production of goods and the provision of services, as well as to ensure that the general public has access to information about how individual businesses handle negative consequences for such human rights and working conditions.
The Transparency Act underpins the Company’s strategic direction on sustainable development, which includes both climate, working environment and people. This strategic direction, expanded to include people and their fundamental rights as well as decent working conditions, is enshrined as a core commitment in the Company’s strategic foundation.
Organization, operational area, guidelines and routines
The Company has a quality system that has been established, documented, implemented and maintained in accordance with the requirements of NS-EN ISO 9001, ISO 14001 and ISO 45001. The quality and environmental management system is built up with procedures, manuals and routines. Process descriptions, work instructions, document templates and quality plans are covered in the document structure of the quality system. To ensure compliance with the Transparency Act, relevant documentation and processes for implementation in the quality system have been drawn up.
Several new documents have been created, as well as changes made to existing documents, to strengthen the Company’s work with the Transparency Act. The most central documents include:
- Due diligence and risk assessment form
- Privacy policy
- Code of Business Conduct
- Action plan related to the Transparency Act
Information on actual negative consequences and significant risk
According to the Transparency Act, the Company must conduct due diligence assessments. This involves:
Establish accountability in the Company’s policies
Mapping actual and potential negative consequences for fundamental human rights and decent working conditions
Implementation of measures to stop, prevent or limit negative consequences
Follow-up on the implementation and results of such measures
Communication with affected stakeholders and licensees
Cooperation on restoration and compensation where required
The work on due diligence assessments has started. A checklist has been prepared, but no concrete assessment has yet been carried out. There have been no incidents or situations related to collaboration partners and suppliers that indicate the need for an immediate due diligence assessment. The first assessment of suppliers will be based on geographical location as a risk factor.
Measures to limit risk and results of measures
Several of the Company’s major suppliers are foreign and have published reports on their work with corporate social responsibility (CSR) and compliance with OECD guidelines. The Company has a responsibility to help protect basic human rights and decent working conditions.
To date, no negative impacts or risks of such impacts have been identified, nor have specific measures been taken. This is ongoing work that will continue in accordance with the Company’s action plan. Based on risk assessments, requests for information will be sent out to suppliers who are considered to need a more thorough assessment.
This statement describes the Company’s organization, scope of operations, policies and procedures for managing actual and potential negative impacts on fundamental human rights and decent working conditions in line with the Transparency Act. It also provides information on any identified impacts and measures that have been or are planned to be implemented.
Assessments and measures carried out in the past year show that the Company conducts its business in accordance with its policy on sustainable development and in line with the intention and purpose of the Transparency Act.