Transparency Act

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NO

Transparency Act

Transparency Act – Due Diligence Statement

Introduction

The Act on Enterprises’ Transparency and Work on Fundamental Human Rights and Decent Working Conditions, L18.06.2021 nr. 99, hereinafter called “The Transparency Act” came into force on July 1, 2022. Smedvig AS and its subsidiaries (“Smedvig”) acknowledge their responsibility to respect fundamental human rights and ensure decent working conditions. Smedvig is committed to conducting due diligence assessments in accordance with the Transparency Act.

This statement covers the period from January 1, 2024, to December 31, 2024, and includes Smedvig AS and its subsidiaries. Based on a materiality analysis, particular attention has been given to Smedvig’s operations in property development, including Smedvig Eiendom AS and its subsidiaries, as well as Veni AS, where Smedvig is the majority shareholder.

The purpose of this statement is to provide a clear overview of the due diligence assessments carried out, the actual and potential adverse impacts identified among our business partners and in the supply chain, and the measures implemented to prevent or mitigate these risks.

Organization

The Smedvig Group consists of investment and development companies that invest capital and contribute expertise to projects we believe in. Smedvig is an active property developer and investor across various business areas, in addition to holding a more liquid portfolio invested in international capital markets. Our primary business areas are property development, private equity, and other direct investments.

Smedvig Eiendom AS invests in and develops real estate, primarily commercial properties. Its core activities include acquisition, planning, leasing, and management of its own properties. The company mainly operates in the Stavanger region, with additional properties in Hamar and Lillehammer, and development projects in Maidenhead, near London.

Veni AS is a technology and consulting company offering services in IT and sustainability, having previously also included construction and design consulting. Veni focuses on clients in construction, infrastructure, and real estate, with its main operations and customer base in the Stavanger region. The company was re-certified as an Eco-Lighthouse in 2024 and aims to achieve ISO 27001 and ISO 9001 certifications in 2025 and 2026, respectively.

Methodology

The methodology remains unchanged from the previous period. Policies and guidelines related to the Transparency Act are anchored in the management and boards of the relevant companies and communicated to employees. Based on a materiality analysis, relevant suppliers were contacted and asked to respond to questions regarding compliance with fundamental human rights and decent working conditions. Where necessary, Smedvig conducted further investigations to verify the information. Suppliers and business partners were also informed of Smedvig’s expectations for compliance throughout the supply chain. Smedvig has emphasized the importance of whistleblowing in cases of violations or suspected violations by the company or its subcontractors.

1. Mapping Suppliers and Business Partners

  • Identification of relevant actors in our supply chains and among business partners based on a materiality analysis.
  • Collection of information on their practices related to human rights and working conditions through questionnaires and follow-up questions where needed.

2. Risk Assessment

  • Assessment of supplier types and Smedvig’s ability to influence them.
  • Evaluation of risks for adverse impacts on human rights and working conditions related to our suppliers and business partners.

3. Measures and Follow-Up

  • Implementation of measures to prevent and reduce identified risks.
  • Monitoring and compliance with policies and guidelines using tools for tracking and follow-up.

Risk Identification

Most suppliers and business partners are based and operate in Norway, which reduces geographic risk associated with high-risk countries.

Based on responses and follow-up questions, no actual adverse impacts on fundamental human rights or decent working conditions were uncovered. However, Smedvig acknowledges that this does not guarantee the absence of such impacts. The company remains exposed to potential risks due to the nature of the industries in which it operates.

Identified areas of potential risk:

  1. Property Development

As a property developer and manager, the company engages suppliers across several industries, including sectors considered high-risk, such as construction, cleaning, and catering services. Consequently, the risk of violations of fundamental human rights and decent working conditions cannot be ruled out.

  • Risk of labor rights violations, such as illegal contracts, excessive working hours, or insufficient compensation.
  • Risk of labor crime, including fake companies or tax evasion.
  • Risk of health and safety violations during major construction or renovation projects.
  1. Technology and Competence

Unlike the previous period, Veni now primarily works with suppliers and business partners that are registered and operate in Norway. A limited number of suppliers are headquartered outside of Norway, and these are mainly used for specific software solutions. Potential risks associated with operations in the technology and innovation sector are considered to include the following:

  • Privacy risks related to user data handling.
  • Cybersecurity threats and potential data breaches.
  • Labor conditions in electronics production chains, especially abroad.
  • Environmental risks from international production and transport of IT equipment.

Risk Mitigation Measures

To address the identified risks, Smedvig has implemented the following measures:

1. Training and Support

  • Follow-up on group policy for compliance on The Transparency Act, including onboarding, ongoing evaluation of suppliers, and documentation requirements.
  • Training for employees on obligations under the Transparency Act.
  • Support for suppliers and partners to improve their practices upon request.
  • Cybersecurity awareness training to help employees recognize and respond to threats.

2. Contractual Obligations and Reporting

  • Integration of human rights and labor standards into contracts and procurement routines.
  • Establishment of whistleblowing systems and employee training to report concerns.

3. Sector-Specific Measures

As previously noted, Smedvig had already established a practice prior to the Transparency Act coming into force, of primarily working with well-known suppliers, with whom the company has had long-standing relationships and therefore possesses solid familiarity. This is considered a risk-reducing practice regarding potential adverse impacts in general.

Property Development:

  • Focus on preventing injuries during construction through strong project management and collaboration.
  • Improved contract follow-up
  • Site inspections.
  • Special attention to the use of temporary labor.

Technology and Innovation:

  • Collaboration with Norwegian-registered suppliers.
  • Use of certified distributors and preference for eco-certified products.
  • Through partnerships with Norwegian IT companies representing major international technology providers (such as Microsoft, Google, and others), Veni works to ensure that requirements related to human rights, data security, and ethical guidelines are upheld throughout the entire value chain.

Results and Future Actions

Previous measures have improved project oversight, awareness of temporary labor use, and contract management. External expertise has been engaged to ensure compliance with regulations, strengthening roles under the Construction Client Regulations and the Working Environment Act.

In technology, Veni’s Code of Conduct has been shared, new client disclosures reviewed, and staff informed about privacy regulations.

There is still room for improvement in obtaining reliable and consistent data from suppliers. Various solutions have been considered, and the company is exploring digital platforms to improve data collection and analysis. A GRC system is being implemented to enhance oversight.

During the reporting period, we believe that our measures have had a positive impact:

  • Increased awareness and follow-up on the Transparency Act.
  • Improved compliance with privacy and cybersecurity standards.
  • Greater vigilance when working with suppliers in high-risk countries.

Smedvig will continue to monitor and update its due diligence assessments and measures to ensure compliance with the Transparency Act. The company is committed to continuous improvement and systematic efforts to reduce risks of human rights violations and poor working conditions in the supply chain.

Signed by the Board of Smedvig AS

Stavanger, June 16, 2025

*For inquiries regarding the Transparency Act, contact: post@smedvig.no