Transparency act

The purpose of the Norwegian Transparency Act is to promote openness, transparency, and access to information in the public sector and entered into force on 1st of July 2022. It is designed to ensure that government agencies and entities are transparent in their operations and that the public has the right to access information held by these organizations.

The Transparency Act in Norway is part of the country's commitment to open government and is aimed at strengthening democracy and accountability by allowing citizens, the media, and other interested parties to access information related to government activities, decisions and documents. It specifies the rules and procedures for requesting and obtaining public information.

Key features for reporting related to the Transparency Act shall include:

  • Actual negative consequences and substantial risk for negative consequences which the enterprises have identified through their due diligence assessment and measures the enterprise has taken or is planning to implement to stop negative consequences or limit substantial risk. An account of due diligence shall be published.

And may include:

  1. The right to access public documents and information, subject to certain limitations for privacy, security, and other legally specified concerns.
  2. The obligation for government agencies and organizations to proactively publish certain types of information, such as annual reports, financial statements, and other documents of public interest.
  3. Procedures for making requests for public information, including timeframes for responses and potential appeals processes.
  4. Measures to ensure the protection of personal data and sensitive information.

Norwind policies relevant for the transparence act

  • Health and safety policy
  • Whistleblower policy
  • Non-smoking policy
  • Quality policy
  • Drug and alcohol policy
  • Anti corruption policy
  • Human rights policy
  • Harassment policy
  • GDPR policy

All our Policies are available on request.

Norwind Offshore code of conduct cover issues related to

Ethical Standards: The code defines the ethical principles and values that individuals or members of an organization are expected to uphold. This can include principles like honesty, respect, fairness, and integrity.

Behavioral Expectations: It outlines specific behaviors and actions that are considered appropriate or inappropriate. This may cover areas like honesty in reporting, respectful communication, non-discrimination, and conflict resolution.

Compliance with Laws and Regulations: Our code of conduct emphasizes the importance of adhering to relevant laws and regulations, both locally and internationally.

Freedom of Movement: Restrictions on the freedom of movement, such as being confined to company-provided accommodations, can raise human rights concerns.

Cultural Sensitivity: Being mindful of cultural differences and religious practices is important to ensure that foreign workers are not subjected to discrimination or harassment based on their cultural background.

Due Diligence Process

Norwind Offshore AS has established a due diligence process towards our supply chain and partners with focus on identifying and mitigate any unacceptable risk related to human resources involved in any activity related to the daily operation of our vessels. The process makes references to the principles outlined in OECD Due Diligence Guidance for Responsible Business Conduct.

We are committed, through our policies, to uphold and promote the highest standards of labor conditions and human rights throughout our operations and supply chains. We recognize that respecting the dignity and well-being of all individuals is not only a moral imperative but also essential for the success and sustainability of our business. Transparency builds trust and demonstrate our commitment to accountability. Thorough risk assessments are conducted to identify potential risk and negative consequences related to labor conditions and human rights in our operation. The risk assessments are based on analysis of geographical locations, industry specific risks and the involved work forces. We aim to engage the suppliers, sub-contractors, and other stakeholders to assess their commitment towards human rights and labor conditions. Our code of conduct including our customer and 3rd Party Policy clearly outlines our expectation and standards and it is anticipated that our personnel, customers, and 3rd party personnel adhere to the codes and policies.

We will, on a regular basis together with our stakeholders, conduct assessments and audits of exposed suppliers and subcontractors to ensure compliance with human rights and labor rights standards. This includes on-site visits, document reviews, and interviews with workers to verify decent working conditions. Necessary training will be provided to ensure that a trusted process is developed and sustained. The training will focus on ethical labor practices and compliance with international standards.  Norwind Offshore AS will support suppliers, subcontractors, and employees in the effort to increase awareness and understanding of human rights and fair labor conditions.

A whistleblower policy has been established and implemented to ensure that unacceptable working conditions and behaviors are reported and followed up. As human rights and fair labor conditions are dynamic issues, we continually seek ways to enhance our effort by monitoring and improving our process.

Risk & negative consequences

The following potential risks and negative consequences related to human rights and decent working conditions has been identified and included in our assessment related to our most critical suppliers and partners that have the highest assessment score:

  1. Discrimination: Treating foreign workers differently based on their nationality or ethnicity can lead to discrimination issues. All employees should be treated fairly and equally. Discrimination based on factors like gender, race, religion, or ethnicity within the supply chain can lead to unequal treatment and labor rights violations.
  2. Exploitation: Workers may be vulnerable to exploitation, such as low wages, long working hours, or poor working conditions. This can result in violations of their labor rights.
  3. Workplace Safety: Ensuring a safe working environment is a human rights obligation.  Suppliers may provide inadequate safety measures, leading to accidents, injuries, and even fatalities among workers. Suppliers may not comply with safety regulations, exposing workers to health risks and potentially hazardous conditions.
  4. Freedom of Association: Respect for the right of workers to join or form trade unions is a fundamental human right. Restrictions on workers' rights to form or join trade unions or engage in collective bargaining can be a risk.
  5. Migrant Workers' Rights: Migrant workers may face unique risks, such as passport retention by employers or contractual abuse. You should ensure they are aware of their rights and have access to legal protections. Migrant workers may face exploitation, abuse, and inhumane conditions within the supply chain.
  6. Privacy and Data Protection: Collecting and handling personal data from foreign workers may involve privacy concerns, especially if your data practices do not meet their home country's legal standards.
  7. Child Labor: Suppliers or subcontractors may employ child labor in violation of international labor rights standards, local laws, and company policies.
  8. Forced Labor and Modern Slavery: The use of forced labor or practices akin to modern slavery can be discovered within the supply chain, resulting in legal and reputational risks.
  9. Low Wages and Unfair Compensation: Suppliers may pay wages that do not meet minimum standards for a living wage, leading to labor rights violations.
  10. Excessive Working Hours: Workers in the supply chain may be subjected to excessively long working hours, which can lead to fatigue, stress, and health issues.
  11. Supply Chain Transparency: A lack of transparency in the supply chain makes it difficult to identify and address labor rights violations.
  12. Legal and Regulatory Risks: Non-compliance with international and local labor laws and regulations can lead to legal penalties and sanctions.
  13. Reputational Damage: Discovery of labor rights violations can damage a company's reputation, affecting brand image and customer trust.

No unacceptable risk or negative consequences have been identified through our latest assessment.

Upon written request, anyone is entitled to information from Norwind Offshore AS about how we handle actual and potential negative consequences pursuant to section 4 in the act. This includes both general information and information related to a particular good or service offered by Norwind Offshore AS. The information will be given, unless the claim does not provide sufficient grounds for identifying what the claim relates to, or the claim is manifestly unreasonable, or the requested information relates to information about someone's personal circumstances, and finally, the information requested relates to information about technical devices and procedures or other operational or business matters that would be of competitive importance to keep secret in view of the information concerned.

Norwind Offshore will provide information within three weeks after receipt of the request. If the amount of information requested makes it disproportionately burdensome to respond to the requirement, the information will be given within two months from reception of the request. A notification will be sent by Norwind Offshore within three weeks if such situation applies.

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