Norwegian Transparency Act Report 2023
The Norwegian Transparency Act, also known as the Åpenhetsloven, is a law enacted in Norway to enhance corporate transparency and promote human rights and decent working conditions within supply chains.

Statement of Due Diligence Assessments

According to the Transparency Act.

This statement covers the period from January 1, 2023, to December 31, 2023.

Norwegian report can be downloaded from here

 

Firenor AS was subject to the Transparency Act for the first time in 2023. We focus particularly on sustainability, which we believe is a natural part of due diligence assessments. Furthermore, we consider it extremely important to deliver high-quality equipment as our products are intended to save lives, without significantly compromising the environment. Firenor AS is a member of Klimapartnere Agder and is certified according to ISO 9001 and 14001.

 

Due diligence assessments are conducted continuously to varying degrees across different departments within the company. The board and management have overall responsibility for ensuring that the company always complies with laws and regulations. The managing director monitors both daily operations and the maintenance and improvement of guidelines and routines through close presence and regular meetings, and reports this to the board. The board has reviewed and signed this statement.

 

The Company

Firenor AS has its office and workshop in Kristiansand. We have a total of 33 employees as of the end of 2023.

 

We are a total supplier of equipment and systems for fire protection primarily to oil, gas, and offshore wind platforms. In other words, we have sales, project, engineering, assembly, and service departments. We assemble components in-house, while subcontractors handle welding, painting, and similar tasks. The service department travels to perform installation, maintenance, and repairs at customer sites.

 

We are 100% owned by Firenor International AS, which is in turn owned by a publicly listed company in Sweden, Concejo AB. Firenor AS has transactions with several group companies, including the supply and purchase of engineering and sales work, as well as components for fire protection systems. 

 

We have both customers and suppliers from around the world. Measured in NOK, the majority of our suppliers are Norwegian. It is important for us to use local and national suppliers where possible. Over three-quarters of our purchases are from European suppliers, including Norwegian ones. We also purchase engineering hours from our group companies in Asia.

Supply Chain

Most of what we purchase are metals and technical components. Our deliveries are to markets with strict quality requirements for materials, components, and execution. This means that we must purchase our goods and services solely from reputable actors. In Norway, we have laws and guidelines regulating working conditions and prohibiting human rights violations. However, our suppliers may have subcontractors from other countries that do not have equally favorable conditions and are at greater risk for human rights violations and poor working conditions.

Internal Guidelines

We are committed to adhering to our ethical values, both within the company and in dealings with suppliers and customers. We have zero tolerance for corruption, bribery, and discrimination, and we require compliance with human rights at all levels. Integrity is a keyword in our company, and we expect everyone representing Firenor AS to always act with integrity and transparency.

 

Several procedures have been developed to support our guidelines, which are always available to all employees. The procedures cover, among other things, ethical values, HSE, sustainability, and supplier evaluation.

Significant Risks

Significant risk is defined based on an overall assessment of severity and likelihood. Risks considered low in both factors are not deemed significant. Severity is assessed based on possible consequences for life, health, and society. Likelihood is assessed based on both our own evaluations from experience and knowledge within the company, and reports from independent organizations and public entities in Norway.

Purchase of metals and technical components

Risk: In some parts of the supply chain for various metals and technical components, there may be human rights violations and poor working conditions.

 

Findings: No actual deviations have been detected among suppliers during our due diligence assessments.

 

Actions: Even though we have not detected any deviations, this does not necessarily mean they do not occur. In 2024, additional resources will be allocated to supplier development. We continuously work on improving our routines to better detect any potential deviations. We will review our supplier contracts to ensure the terms are sufficient to prevent human rights violations, including those of subcontractors.

 

Furthermore, we will send a questionnaire concerning sustainability and human rights to our largest suppliers and all suppliers from high-risk countries. What is considered high-risk countries is determined in connection with the assessments related to the likelihood.

 

We have already established routines for our own supplier audits, including physical visits and evaluation forms. We will further review these routines to ensure the inspections are adequate to uncover actual deviations.

 

In addition, we want to explore better systems related to procurement, making it even easier for us to identify where further investigations are needed.

 

We aim for the mentioned actions to ensure that our suppliers impose strict requirements on their subcontractors and make it easier for us to select suppliers. The actions will also help embed the importance of considering criteria related to sustainability, working conditions, and human rights in supplier selection across the entire company.

Purchase of workwear and protective equipment

Risk: Suppliers and subcontractors may violate human rights and have employees working under poor conditions, and there is a risk of poor quality.

 

Findings: No actual deviations have been detected among suppliers during our due diligence assessments.

 

Actions: Embed guidelines with criteria related to sustainability, human rights, and working conditions in supplier selection through updated procedures. Besides the importance of preventing human rights violations, it is also crucial for the safety of our employees to ensure that clothing and equipment are of high quality.

Employee work at the workshop and customer sites

Risk: Work at height, work with gas and chemicals, work with heavy machinery and large components.

 

Findings: No actual deviations have been detected during our due diligence assessments.

 

Actions: We already have strict safety routines and equipment. However, there is always a risk that cannot be eliminated due to the possibility of either human error or equipment failure. We will review safety routines and update procedures as necessary. We will also ensure that employees have the required safety competencies by updating and improving the overview of courses and competencies for each employee.

 

We already have routines for reporting and notifications related to HSE and have informed all employees about the complaint channels available. We have our own improvement system, employees can report to the immediate manager, and we also have an independent whistleblower contact.

 

In 2024, we have also established a Working Environment Committee that regularly reviews possible risks and works to maintain good working conditions. We expect this to provide further insights into potential risks and areas for improvement related to working conditions.

Summary

Through our due diligence assessments in 2023, we have not uncovered any actual negative impacts on people. However, we will systematically work to improve our guidelines and routines to further reduce risks. In addition to the above-mentioned actions, we also plan to formalize this process further through procedures and regular meetings and are exploring possibilities for having a dedicated public channel for receiving any notifications from external parties. Through our operations, we will contribute to ensuring that people work under good conditions with respect for human rights and the achievement of sustainability goals.