The Transparency Act – Account of Jensen’s due diligence assessments

The Transparency Act came into force on July 1st, 2022. The purpose of the Act is to promote companies' respect for fundamental human rights and decent working conditions among business partners and in supply chains. We are covered by the Act, and a significant part of it concerns the ensuring of public access to information about these conditions and how we handle them. The legal requirement, together with our and other companies' local measures, shall contribute to meeting and complying with UN Sustainable Development Goal 8 on decent work and economic growth and Goal 12 on decent work and production. 

The report shall be public and easily accessible on our website by June 30th each year and otherwise in the event of significant changes in the company's risk assessments. 

It shall be signed in accordance with the rules in section 3-5 of the Accounting Act. The core of the Act entails the obligation to perform due diligence, which consists of mapping possible negative consequences for fundamental human rights and decent labour conditions related to production and supply chains, implementing improvement measures, following up and reporting.

In our work with the Transparency Act and the due diligence process, we utilise Factlines' digital solution and services. Factlines is a Norwegian-owned, independent company that specialises in monitoring ethical, social and environmental requirements in supply chains. Factlines advises, develops and produces services with digital support to obtain efficient and verifiable information directly from suppliers and subcontractors.

We conduct an annual information collection from suppliers in the form of self-reporting for CSR (Corporate Social Responsibility). The questions in the self-reporting cover the requirements of the UN Global Compact, the suppliers' chain insight and follow-up practices, as well as their assessment of the risk associated with breaches of ethical guidelines in the relevant production countries. The data collection provides a basis for analysing whether good practices have been established to comply with the Transparency Act, Section 5 of the Public Procurement Act and the company's own contractual provisions. In 2024, we have sent out the survey to our most important transport companies, in addition to following up with suppliers considered high risk in the 2023 survey.

Read more about Factlines here.

In 2023, Hilding Anders International AB prepared a new version of the Code of Conduct. This is signed by our suppliers. In 2024 this has also been signed by the transport companies that we are using. They are thus required to act in accordance with these, including that they must secure their production, purchases and deliveries. The document can be found here. 

For potential new suppliers, we have established a pre-qualification routine. This involves the supplier signing and returning our Code of Conduct. We then send out the CSR questionnaire from Factlines’ digital platform, where we work in the same way as we do with the annual survey. If we consider the supplier's work on fundamental human rights and decent work to be satisfactory, a final financial assessment of the company is carried out before final approval.

The content of our Code of Conduct shows that we recognise our responsibility to ensure good ethical and environmental practices. We accomplish this within our organisation by ensuring that every employee receives a code of conduct upon being hired, extending to our direct operations, supply chain and the communities in which we operate. An important part of this work is to ensure that the products and services delivered by us do not violate our Code of Conduct. The document can be found here. 

Our suppliers must be able to account for where goods ordered from us are produced. In addition to this, we may require more information about how these suppliers work with human rights and decent labour conditions.

It is important to ensure that dishonesty, disloyalty, or corruption does not occur. This applies to all of the company's trade and transactions in all countries where the company or its subsidiaries and business partners operate. What is considered bribery is regulated by each country's legislation. Hilding Anders would particularly like to emphasise that we do not take any commission from suppliers. Should any of the company's employees, openly or implicitly, request a commission of any kind, we ask the supplier to immediately inform Hilding Anders. This can be done directly to Hilding Anders International (by reporting to any member of the Hilding Anders management team) or via the following notification page https://secure.ethicspoint.eu/domain/media/en/gui/106802/index.html or by e-mail: info.no@hildinganders.com

We believe that collaboration over time yields good results, and therefore want to work with suppliers and other business partners to achieve sustainable solutions, and to promote suppliers and other business partners that comply with the Transparency Act. Through this work, we contribute to meeting SDG 17: Collaborate to achieve the goals and target 17.17 on multi-stakeholder partnerships (Encourage and promote effective partnerships in the public, between the public and private, as well as in the civil society that build on partnerships' experiences and resource strategies). No organisation is too small to work consciously with sustainability, and we expect suppliers to be aware of their responsibilities, demonstrate a willingness to collaborate and take the necessary actions.

In 2024, our goals for the organisations we work with are:

• To have adopted ethical guidelines that comply with or exceed the requirements of the UN Global Compact and equivalent ILO core conventions, and that these are made known to all employees, their trading partners and suppliers. 

• Must have established a strategy for sustainability and social responsibility.

•  The suppliers must achieve a total score that shows a low or medium risk. If suppliers achieve a total score that shows high risk, we must immediately follow up and together with the supplier, assess measures to reduce risk.

We also continuously monitor the ITUC GRI - Home (globalrightsindex.org) which is an organisation that annually ranks all the world's countries in terms of which are the worst for working people, and which region of the world is the worst. We link this to the answers we receive from the survey.

4.1 Corporate social responsibility, strategy and guidelines

We have followed up the 2 companies that had not adopted a strategy for social responsibility last year. One expresses that they want to take active social responsibility and work to establish documentation that will help to gain control in their own value chain, and where measures must be taken to reduce risk. They now have an agreement with consultants who will help them in this work. The other shows little or no will to this. The consequence of this is raised to the management. We have not uncovered any actual negative consequences, but the answers they give us contribute to an increased risk of negative consequences. In this year's survey, we have found a transport company that has not adopted a strategy for its social responsibility. We have followed this up, and we have now received good fact-based information which shows that this will be in place during the autumn.

Everyone in this year's survey responds positively that they have adopted ethical guidelines that at least comply with the requirements of the UN Global Compact and corresponding ILO core conventions, and 3 out of 4 respond positively that these have been made known to all employees, their trading partners and suppliers. We will follow up on the respondent that answered negatively to this.

Last year's results showed that 37 have adopted internal ethical guidelines that are at least as comprehensive as the requirements of the UN's Global Compact and the equivalent of the ILO's core conventions. 34 have ethical guidelines that are distributed and/or communicated to subcontractors. We were not satisfied with this and followed up the individual companies. We no longer trade with 2 of these suppliers, We have a close dialogue with the others and see little risk with them, apart from one textile supplier. We will consider following this up with a physical audit in the autumn. We also have 2 other textile suppliers in the same district that we will also assess for a physical audit at the same time.

Last year's survey showed that 2 out of 44 suppliers scored with a total that indicates a high risk profile, and as described, this has been followed up closely, and this year's survey shows that everyone who answered has a low risk.

4.2 Suppliers' insight and follow-up of their own supply chain
35 of the 44 suppliers have routines/systems for monitoring the supply chain. 21 of our suppliers have carried out self-reporting from their suppliers in the past year and 32 have carried out on-site inspections at production sites. 4 responded that they have discovered breaches of their ethical guidelines in the past year. We will continue to follow up on these, with the aim that they constantly show improvement. The transport companies in this year's survey all respond positively that they have good insight into their own supply chain where relevant.

4.3 Risk
From last year's survey, the suppliers stated that they do business in 34 different countries. Among these are countries with a high risk of violations of labor and human rights. Turkey is ranked as the 10th worst country in the world for working people. The survey shows that 6 suppliers either produce in Turkey or buy raw materials from producers in Turkey. As we did last year, we have maintained our focus on how these suppliers assess the risk situation in Turkey, and all of them assess the risk as low. The textile manufacturers who either produce in or buy raw materials from Turkey have only stated that they buy from 2 countries. They have the option of specifying 5 countries. From experience, it is common for textile manufacturers to buy yarn from the East. We followed this up with a visit to one of our textile suppliers in autumn 2023 where production takes place in Romania. This supplier showed us documentation that indicates good control of its value chain. In the autumn of 2024, we will consider visiting and conducting an audit in accordance with the requirements of the Transparency Act at the textile suppliers that have production in Turkey.

4.4 Labour conditions and rights
All suppliers respond that they comply with necessary laws or regulations covering employee social rights.

4.5 Environment
All suppliers respond that they ensure compliance with all necessary local laws and regulations related to environmental protection, with the exception of one. It is the same one that is repeated on all points. 35 out of 44 suppliers from last year and 3 out of 4 carriers this year responded that they have an environmental plan with defined goals and action plans to improve their environmental impact. 34 have procedures to reduce CO2 emissions.

4.6 Conflict minerals
21 of the suppliers answered yes to including a ban on the use of conflict minerals in contracts with their suppliers. For some of the suppliers, conflict minerals are not relevant.

4.7 Anti-corruption
36 of the suppliers have policies against bribery and corruption.

Through the Factlines system, a number of follow-up measures are automatically sent out that deal with further specialisation, possible documentation of our own ethical guidelines, routines for supplier follow-up, etc. These are tasks that we continuously follow up with suppliers through dialogue. Any findings may also lead to a physical audit. Primarily, we want to notify the supplier of such an audit, but in accordance with our Code of Conduct, we can also visit unannounced.

Based on our findings, we will implement the following: 

• Immerse ourselves in suppliers who, for one reason or another, have not adopted a sustainability strategy, and put together a deadline to get this in place.

• Follow up on the suppliers who have not yet adopted ethical guidelines and/or have not distributed these to their subcontractors about implementing this work.

• We will follow up suppliers who have not established routines or a system for following up their suppliers and ask them to implement this.

• We will follow up every supplier who lacks an overview of their value chain and the raw materials / components, especially within the textile suppliers.

• We will follow up suppliers who do not comply with local laws and regulations relating to environmental protection.

• We will demand that the 8 suppliers who have not established guidelines against bribery and corruption get this in place.

• We have a supplier who is overall ranked as high risk and who shows no desire to improve. Over the past year, we have followed up, and will now put forward a proposal that we end trading with this company and find another supplier.

The Transparency Act §6 – right to information: 

• E-mail adress –  info.no@hildinganders.com.
• All enquiries are registered and logged. We will respond as quickly as possible and within 3 weeks.