Transparency Act
Transparency Act – Due Diligence Statement
Introduction and Scope
This statement has been prepared in accordance with the Norwegian Transparency Act of June 18, 2021, No. 99, relating to enterprises’ transparency and work on fundamental human rights and decent working conditions.
The statement applies to the Smedvig Group and covers the parent company Smedvig AS and its subsidiaries (collectively “Smedvig”). Based on a materiality assessment, particular focus has been placed on Smedvig Eiendom AS and Veni AS. The statement covers the Group’s due diligence efforts for the financial year 2025.
Smedvig has chosen to prepare a consolidated group statement, as the companies are closely integrated through ownership, governance, shared suppliers, and system support. Company-specific matters are described where relevant.
Operations and Anchoring of the Work
2.1 Group Structure and Operations
Smedvig AS is the parent company of the Group and has no operational activities. The company is responsible for ownership governance, group functions, and overarching support functions.
Smedvig Eiendom AS invests in, develops, and manages commercial real estate. Its operations are primarily located in the Stavanger region, with certain properties and projects elsewhere in Norway and in the UK.
Veni AS is a technology and competence company providing IT operations services and advisory services within technology, sustainability, and energy, primarily to clients in Norway.
2.2 Anchoring in Governance and Organization
Work related to the Transparency Act is anchored in the Group’s board and management. Responsibility and follow-up are integrated into the Group’s governance systems, including through ethical guidelines (code of conduct), procurement processes, supplier monitoring, and whistleblowing channels.
All employees in the Group are subject to Norwegian labour legislation, with written employment contracts, the right to organize, and established whistleblowing channels for both employees and external parties.
3. Due Diligence Assessments, Methodology, and Implementation
The due diligence assessments have been conducted in accordance with the Transparency Act and the OECD Guidelines for Responsible Business Conduct, as reflected in applicable guidance. The work has included:
- mapping of own operations and supply chains
- risk assessments based on the nature, scope, and supplier structure of the business
- prioritization of suppliers and risk areas
- collection of information through questionnaires and dialogue
- documented assessments and follow-up
The prioritization of suppliers and risk areas is based on an overall assessment including, among other factors, type of delivery, industry affiliation, geographical exposure, the scope and duration of deliveries, and the Group’s actual ability to influence.
As part of the follow-up of measures described in last year’s statement, the Group implemented Protencon in 2025 as a common digital solution for monitoring compliance with the Transparency Act and the supply chain. The solution enables more structured and consistent collection, analysis, and documentation of supplier information across Group companies.
The use of digital tools does not replace independent professional assessments but serves as a support tool for structured follow-up, risk assessment, and documentation over time.
The due diligence assessments are based on available information and dialogue with suppliers. The Group is nevertheless aware that insight into certain parts of indirect value chains may be limited and therefore continuously works to improve its data basis and follow-up procedures.
4. Actual Adverse Impacts and Significant Risk
4.1 Actual Adverse Impacts
Based on the due diligence assessments carried out in 2025, no actual adverse impacts on fundamental human rights or decent working conditions have been identified in the Group’s own operations or supply chains.
This applies to Smedvig AS’ limited supplier base, suppliers related to real estate development, operation and management in Smedvig Eiendom AS, as well as suppliers and subcontractors within IT services and technical equipment in Veni AS.
4.2 Significant Risk – Group Assessment
The Group’s overall risk profile is assessed as low to moderate, based on the nature, scope, and geographical footprint of its operations.
Although no actual adverse impacts have been identified during the reporting year, the Group recognizes that certain parts of its operations and value chain are associated with inherent risk. The due diligence assessments are therefore focused on identifying and mitigating risks before they materialize.
The following risk areas have been identified as most relevant to the Group:
- risk of violations of workers’ rights among suppliers and subcontractors in real estate, construction, and operational services, including non-compliance with requirements for wages, working conditions, working hours, and contractual arrangements
- risks related to the use of subcontractors and complex supply chains, where the Group’s direct influence may be limited
- risk of breaches of health, safety, and environment (HSE) regulations in construction and refurbishment projects, particularly where multiple parties are involved
- risks related to global supply chains for technical equipment and IT components, including working conditions among manufacturers and subcontractors outside the Nordic region
- risks related to information security and data protection in the use of IT suppliers and subcontractors, which may affect individuals’ rights if not adequately managed
The risk assessments are based on the Group’s operations, supplier structure, and experience from previous due diligence assessments, and are prioritized based on materiality and the Group’s ability to influence.
Despite the identified risk areas, the due diligence assessments and supplier follow-up conducted in 2025 indicate that no significant risks have materialized into actual adverse impacts in the Group’s operations or supply chain.
5. Measures, Follow-up, and Results
5.1 Measures Related to Actual Conditions
As no actual adverse impacts have been identified, no measures have been implemented to stop or mitigate such impacts during the reporting year.
5.2 Follow-up of Measures Described in Previous Statements
Previous statements identified a need to strengthen the data basis and system support for work related to the Transparency Act. This has been followed up in 2025 through:
- implementation of Protencon as a common digital platform for supplier follow-up
- more structured and documented collection of supplier information
- ongoing assessment of risk alerts based on external data sources within compliance, media, credit, and reputation
Alerts identified through the solution have been assessed and have not revealed any actual adverse impacts in the Group’s value chain in 2025.
The work on further developing the Group’s governance, risk, and compliance (GRC) systems has continued, with the aim of further integrating risk management, compliance, and internal control over time.
6. Duty to Provide Information and Contact Point
In accordance with the Transparency Act, the Group responds to requests regarding how actual and potential adverse impacts are handled. Inquiries may be directed to: mail@smedvig.no.
Concluding Assessment
This statement provides a comprehensive, balanced, and verifiable account of the Smedvig Group’s work related to the Transparency Act for the financial year 2025 and builds on the efforts and assessments presented in previous statements.
Smedvig will continue to monitor and update its due diligence assessments and implemented measures to ensure compliance with the Transparency Act. The Group is committed to continuous improvement and works systematically to strengthen its practices, enhance follow-up processes, and reduce the risk of breaches of fundamental human rights and decent working conditions in its supply chain.
Signed by the Board of Smedvig AS
Oslo, 16 June 2026
*For inquiries regarding the Transparency Act, contact: post@smedvig.no