Transparency act
1. Introduction
Norwind Offshore AS is committed to conducting business in accordance with fundamental human rights, decent working conditions, and responsible business practices. Through our operations, supply chain, and business relationships, we seek to identify, prevent, mitigate, and account for actual and potential adverse impacts on people and society.
This statement has been prepared in accordance with the Norwegian Transparency Act (Åpenhetsloven) and is based on the due diligence principles described in the OECD Due Diligence Guidance for Responsible Business Conduct.
The report describes Norwind Offshore AS' policies, governance structure, due diligence process, identified risks, and measures implemented to prevent and mitigate adverse impacts on human rights and decent working conditions.
2. Governance, Policies and Guidelines
Norwind Offshore AS has established policies and management systems designed to promote ethical business conduct, responsible employment practices, and compliance throughout our operations and supply chain.
The following governing documents support our work under the Transparency Act:
- Health and Safety Policy
- Human Rights Policy
- Anti-Corruption Policy
- Whistleblower Policy
- GDPR Policy
- Harassment Policy
- Drug and Alcohol Policy
- Quality Policy
- Non-Smoking Policy
These policies are available upon request.
Norwind Offshore's Code of Conduct establishes expectations for employees, suppliers, subcontractors, customers, and other business partners. The Code addresses:
- Respect for human rights
- Compliance with applicable laws and regulations
- Anti-corruption and ethical business conduct
- Equal treatment and non-discrimination
- Workplace health and safety
- Freedom of association
- Respectful and professional behaviour
- Protection of personal data and privacy
3. Due Diligence Process
Norwind Offshore AS has implemented a due diligence process covering suppliers, subcontractors, and business partners whose activities may be linked to our operations.
The process follows the OECD framework and includes:
Risk Identification
Potential risks are identified through assessments of:
- Geographic location
- Industry-specific risks
- Workforce composition
- Nature of services provided
- Previous performance and compliance history
Supplier Evaluation
Suppliers and business partners are evaluated based on their commitment to human rights, labour standards, ethical business conduct, and compliance with applicable legislation.
Monitoring and Follow-Up
Where relevant, Norwind Offshore conducts reviews and assessments of suppliers and subcontractors. Follow-up activities may include:
- Documentation reviews
- Supplier questionnaires
- Audits and site visits
- Dialogue with suppliers and workers
- Corrective action plans
Awareness and Reporting
Employees and stakeholders are encouraged to report concerns through established reporting channels. A whistleblowing process has been implemented to ensure concerns related to human rights, labour conditions, or unethical conduct are investigated and addressed.
4. Risk Assessment
As part of the due diligence process, Norwind Offshore has assessed potential risks relating to human rights and decent working conditions within its operations and supply chain.
The following risk areas have been identified:
Labour Rights
Potential risks include:
- Excessive working hours
- Inadequate wages or compensation
- Restrictions on freedom of association
- Unfair treatment of migrant workers
Human Rights
Potential risks include:
- Discrimination and unequal treatment
- Harassment and inappropriate workplace behaviour
- Child labour
- Forced labour and modern slavery
Health and Safety
Potential risks include:
- Unsafe working environments
- Inadequate safety management systems
- Occupational injuries and illnesses
Business Conduct
Potential risks include:
- Corruption and unethical business practices
- Lack of transparency in supply chains
- Non-compliance with legal and regulatory requirements
5. Findings and Measures
During the reporting period, Norwind Offshore conducted due diligence assessments of suppliers and business partners considered most relevant to our operations.
No actual adverse impacts or unacceptable risks relating to human rights or decent working conditions were identified through the assessments performed.
Norwind Offshore continues to strengthen its due diligence process through:
- Ongoing supplier evaluations
- Regular review of governing policies
- Training and awareness initiatives
- Monitoring suppliers and activities
- Continuous improvement of reporting and follow-up processes
Should unacceptable risks or adverse impacts be identified, Norwind Offshore will implement appropriate corrective actions, including engagement with suppliers, improvement plans, enhanced monitoring, or termination of business relationships where necessary.
6. Future Work
Norwind Offshore AS recognises that risks relating to human rights and decent working conditions may evolve over time due to changes in our operations, business relationships, and external conditions.
We will therefore continue to maintain and further develop our due diligence processes in accordance with the requirements of the Norwegian Transparency Act and the OECD Due Diligence Guidance for Responsible Business Conduct.
Future efforts may include ongoing review of risk assessments, supplier and business partner evaluations, internal policies, and relevant governance processes where considered appropriate based on identified risks and business needs.
Norwind Offshore AS will continue to assess the effectiveness of its measures and make adjustments where necessary to support responsible business conduct and compliance with applicable legal requirements.
7. Requests for Information
Pursuant to the Norwegian Transparency Act, any person has the right to request information regarding how Norwind Offshore AS addresses actual and potential adverse impacts on fundamental human rights and decent working conditions.
Requests may relate to general information regarding our due diligence process or to specific products and services provided by Norwind Offshore AS.
Information will normally be provided within three weeks of receiving a request. Where the volume or complexity of the request makes this disproportionately burdensome, a response will be provided within two months, and the requester will be informed accordingly.