Transparency Act

EN
NO

Transparency Act

The transparency Act

The Norwegian Transparency Act took effect on July 1, 2022. Smedvig AS and its subsidiaries, collectively referred to as “Smedvig,” recognize their duty to uphold fundamental human rights and ensure favorable working conditions. Smedvig is dedicated to conducting due diligence assessments in compliance with the Transparency Act.

This statement pertains to the period from January 1, 2023, to January 1, 2024, encompassing Smedvig AS and its subsidiaries. Through a materiality analysis, we have mainly prioritized examining Smedvig’s activities in real estate development, including Smedvig Eiendom AS and its subsidiaries, as well as Veni AS, where Smedvig holds the majority stake.

The objective of this statement is to present an overview of the due diligence assessments performed, any actual or potential negative consequences identified within our business partnerships and supply chains, and the corresponding corrective actions taken.

 

Organization

Smedvig consists of investment and development companies that invest capital and bring expertise to projects we believe in. Smedvig is an active developer and investor in various business areas, as well as holding a more liquid portfolio invested in international capital markets. Our primary business areas are real estate development, private equity, and other direct investments.

Smedvig Eiendom AS invests in and develops properties, primarily commercial real estate. Its core business includes acquisition, planning, leasing, and management of its own properties. Smedvig Eiendom AS mainly operates in the Stavanger region, but also owns properties in Hamar and Lillehammer, as well as development projects in Maidenhead near London.

Veni AS is a technology company that provides technical solutions in IT operations, infrastructure, proptech, sustainability, energy, and VDC. Its headquarters is in Stavanger, with an additional office in Oslo. Veni AS is eco-certified and is actively working to meet several standards, primarily ISO 9001 and ISO 27001.

 

Methodology

Smedvig has formulated group policies and guidelines, subject to continuous review and updates. These documents are endorsed by the management and boards of the relevant entities. Through ongoing communication with relevant suppliers, all have provided feedback regarding their adherence to fundamental human rights and acceptable working conditions. Where necessary, Smedvig has conducted additional inquiries to verify the information supplied by suppliers and business partners. Furthermore, pertinent suppliers and business partners have been briefed on Smedvig’s expectations regarding compliance with the Transparency Act, ensuring its observance across the entire supply chain. In order to reinforce compliance with the Transparency Act, Smedvig has emphasized to suppliers and business partners the significance of reporting any infringements or suspected infringements within their own operations or those of their subcontractors.

  1. Mapping of Suppliers and Business Partners
  • Based on a materiality analysis, we have identified relevant actors in our supply chains and among our business partners.
  • Collecting information on their practices related to human rights and working conditions using questionnaires and follow-up questions when deemed necessary.
  1. Risk Assessment
  • Evaluating the risks associated with different types of suppliers and Smedvigs’s influence on them.
  • Evaluating the risk of negative impacts on human rights and working conditions related to our suppliers and business partners.
  1. Measures and Follow-up
  • Implementation of measures to prevent and reduce identified risks.
  • Establishment of policies, guidelines, and updating tools for monitoring and following up on implemented measures.

 

Mapping and Risk Identification                                                                                                       

Most of our suppliers and business partners are based in Norway, which lowers the risk associated with high-risk countries. We haven’t identified any actual negative impacts on human rights or working conditions in our supply chains or among our business partners. However, this doesn’t mean such issues don’t exist. We recognize that there is still a potential risk due to the industries we operate in.

Through our mapping, we have identified the following areas with potential negative consequences for human rights and working conditions:

  1. Real Estate Development

As a real estate developer and manager, the business uses suppliers in various industries, including those considered at risk, such as construction, cleaning, and catering. The risk of breaches of fundamental human rights and decent working conditions cannot be ruled out.

  • Risks include violations of workers’ rights among suppliers and subcontractors, such as unfair and illegal contracts, breaches of working time regulations, and inadequate compensation.
  • There is a risk of labour crimes, including the creation of fake companies and evasion of taxes and fees.
  • There is also a risk of violations of health and safety regulations. Large construction or renovation projects can increase the risk of injuries to employees, workers, or other visitors.
  1. Technology and Innovation

Unlike the previously mentioned business, Veni AS uses suppliers with an international presence, which can increase risks if they are located in high-risk countries. Potential risks for the technology and innovation sector include:

  • Poor working conditions in the production chains for electronic components, such as unfair and illegal contracts, violations of working time regulations, and inadequate compensation.
  • Negative environmental impacts, especially from international companies producing or reselling electronic components.
  • Privacy breaches when handling user data.

 

Measures to Manage Risk

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

  1. Implementation of a Transparency Act Policy
  • Implementation of a Transparency Act policy at Smedvig level that, among other things, commits to an “onboarding” process, ongoing follow-up of new and existing suppliers, reporting, and documentation requirements for the relevant companies in Smedvig.
  1. Contractual Obligations and Reporting
  • Include requirements for complying with the Transparency Act, ensuring the protection of human rights and working conditions in contracts and ordering procedures when onboarding new suppliers and business partners.
  • Set up a reporting system for employees to report violations of human rights or working conditions.
  • Assess different digital platforms to streamline and improve the analysis and monitoring of suppliers and business partners and make it easier for suppliers to report to Smedvig.
  1. Training and Support
  • Ensuring increased awareness and training of relevant employees regarding Smedvig’s obligations under the Transparency Act.
  • Support for relevant suppliers and business partners upon request, to improve their practices and compliance with the Transparency Act.
  1. Specific Measures within Industry Categories

Prior to the enactment of the Transparency Act, Smedvig established a practice of primarily using known suppliers with whom we have long-term collaborations. This approach has provided us with a good understanding of these suppliers and is considered a risk-reducing practise for preventing negative consequences.

Specific Measures for Real Estate Development:

  • Prioritizing the prevention of injuries to employees, workers, and visitors during large construction or renovation projects through effective project management and strong collaboration with contractors and other stakeholders.
  • Enhancing the systematization and frequency of contract follow-ups.
  • Conducting on-site inspections.
  • Focusing on and monitoring suppliers that use hired labour.

Specific Measures for Technology and Innovation:

  • Presenting Veni’s “Code of Conduct” to suppliers and business partners.
  • Assessing new customers’ published statements regarding the Transparency Act.
  • Providing additional training for employees on privacy regulations.

 

Results and Further Measures

In our evaluation, there is room for improvement in obtaining reliable and consistent information from our suppliers and business partners, which is crucial for accurately assessing the effectiveness of our measures. We are monitoring advancements in data quality and consistently evaluating different digital platforms to better organize collected information, enhance analysis, and streamline ongoing monitoring. We anticipate enhancements in this area moving forward.

During the reporting period, we believe our initiatives have resulted in positive outcomes:

  • Increased awareness and attention to the Transparency Act and relevant regulations internally and among our suppliers and business partners. We anticipate that this, coupled with ongoing monitoring, will help mitigate risks associated with suppliers, business partners, and subcontractors.
  • Heightened awareness of existing agreements and regulations concerning privacy internally and among our customers, suppliers, and business partners.
  • Strengthened vigilance concerning the risks associated with suppliers in high-risk countries, potentially leading to improved risk management and, over time, a decrease in suppliers from such regions.

Smedvig will persist in monitoring, evaluating, and adjusting our due diligence procedures and initiatives to ensure compliance with the Transparency Act. We are committed to continuously improving our practices while upholding regulatory obligations.

 

Signed by the Board of Directors of Smedvig AS

Stavanger, June 20, 2024.

 

Inquiries regarding the Transparency Act can be directed to post@smedvig.no.