1. The Norwegian Transparency Act
The Transparency Act is a shorter name for the “Act on business transparency and work with basic human rights and decent working conditions” which came into law on 1st of July 2022.
The purpose of the Act is to “promote businesses’ respect for basic human rights and decent working conditions in connection with the production of goods and the provision of services, and to ensure the public has access to information about how businesses deal with negative consequences for basic human rights and decent working conditions.”
The law is based on the OECD’s guidelines for multinational companies. The OECD’s guidelines for multinational companies are recommendations from the OECD countries to promote responsible business in all sectors. The guidelines set expectations for businesses in areas such as human rights, employee rights, the environment, tax, anti-corruption, competition law, consumer interests and transparency. The guidelines expect businesses to carry out due diligence assessments (risk assessments), and further that measures be taken to preserve the environment, respect human rights, safeguard employee rights and avoid corruption in any form.
In the Northcom group, we are concerned with being a responsible social actor and welcomes the Norwegian Transparency Act and takes the obligations posed by this legislation seriously.
2. About Northcom and the Transparency Act
2.1. Operations, products and services
The Northcom Group consists of eight legal entities and approximately 135 employees, represented on 11 different locations in Norway, Denmark, Sweden and Finland. We are a leading provider of critical communication solutions to industries such as police, defence, shipping, energy, offshore and emergency as well as to private companies.
Our respect for human rights and decent working conditions is expressed in our Code of Conduct, and followed up with frequent coworker surveys about e.g. working environment and wellbeing of our employees. If we suspect or uncover possible violations of human rights or decent working conditions, we will immediately implement the necessary measures.
The Norwegian Transparency Act motivates the group to work thoroughly and systematically with social responsibility Northcom AS (Norge) and thereby the parent company, Northcom Solutions AS, are among the approximately 9,000 Norwegian businesses covered by the Transparency Act (the combination of these two are hereafter called Northcom, unless other is specified). Potential negative impact on human rights and working conditions, and how we work to prevent such impact, is described below.
Equality, diversity and inclusion
Northcom Norge and Northcom Solutions combined have a staff of 35 employees, of which 20 % are women both in total and in the management group. The low percentage of women is in line with the recruitment pool and its gender-segmented education and work market in Norway. According to our frequent anonymous employee surveys, turnover, complaints or reported concerns, there are no indication of discrimination.
Northcom recognises however that there are discriminating structures in the society. We clearly express our non-tolerance towards discrimination in our Code of Conduct and will further work to ensure awareness regarding equal treatment, diversity and inclusion in our recruitment, management, promotion and renumeration processes.
Privacy
Northcoms products enable surveillance, which can be misused to invade privacy. This is outside Northcoms influence as Northcom does not control the customers’ use, nor decide on their permission to set up surveillance
Northcoms own processing of personal data is limited to employees and representatives from customers. To ensure privacy rights are respected, Northcom is in the process of improving the routines.
Health, Safety and Environment, including work hazard
Everyone has a right to a safe work environment. In Northcom, safety can be at risk for employees installing communication equipment at demanding locations. The risk is mitigated by HSE routines and training. Our track record indicate that these are effective, with few incidents and none characterized as serious the last year. The risk is therefore considered low.
Freedom to express opinions including reporting concerns and whistleblowing
Our frequent anonymous employee surveys, and communication with employees, provide employees with the opportunity to express their opinions and concerns. However, Northcom will assess the need to establish procedure for whistleblowing to further strengthen employees right to bring forward concerns which management must consider.
Supply chain and business partners
Northcom has worked with responsible procurement practices for over 40 years and has solid experience in selecting suppliers based on criteria such as quality, delivery security, sustainability, labour and human rights. We are aware that all trade in goods and services involves various types of risk and strive for a straightforward and transparent supply chain.
While our main and key suppliers reside in Europe, some have their production in regions where human rights and working conditions stand weaker. Northcom has therefore initiated assessment of a risk-based sample of suppliers, primarily within hardware. While some of the assessed suppliers publicly commit to human rights and decent working conditions and
explain their measures, others have less information available, which indicate higher risk. This will require more dialogue and possibly other measures such as audits or other control and reporting mechanisms.
Summary
Overall, our assessment is that the likelihood of Northcom to cause a negative impact on human rights and working conditions is limited, but not without potential for improvement. We have therefore identified measures to further improve and
- Guidelines for management of supplier risk, through dialogue, due diligence and follow up regarding social conditions
- Processes for reporting of concerns (whistleblowing) and for handling of such reports
- Initiatives to increase competence and awareness to ensure equality, diversity and inclusion