Transparency act

Scana ASA – our actions with regards to the transparency act

In Scana ASA and in our portfolio companies we work actively to ensure that we comply with basic human rights, as well as to ensure decent working conditions in our own operations and in the supply chain.

Figure 1. Due diligence process & supporting measures[1]
[1] OECD (2018), OECD Due Diligence Guidance for Responsible Business Conduct

1. Integrate responsible business practices into management systems and guidelines.
Responsible business conduct is embedded in our processes and documents for business management, including our Code of Conduct. The Code of Conduct describe the general ethical principles for governance of Scana including supplier interactions, and the conduct expected of employees, partners (including agents and contracted personnel) and supplier.

The Code of Conduct shall support and guide the companies in which Scana ASA has a considerable share, and employees, partners and suppliers in carrying out their tasks and responsibilities and decision making to ensure these activities are carried out in an ethically responsible manner and in line with the standards set by Scana. You may find our Code of Conduct here. Our Sustainability Manager, in cooperation with Scana ASA management are responsible for the content of governing documents, coordination, internal advice and reporting, while other group staff and the subsidiaries are responsible for compliance and follow-up.

2.Mapping and assessment of risks for negative impacts in the business and supply chain
Risks for violations of human rights and decent working conditions have been assessed for internal processes, as well as with regards to our critical suppliers. In general, the main adverse impacts may be found in the procurement process, as well as in the interface with our suppliers and their
subcontractors. These are therefore prioritized in terms of measures and follow-up. Going forward, the risk mapping will be updated, and several measures will be assessed within several procurement categories.

3.Cease, prevent or mitigate adverse impacts
We work in a structured way to ensure a responsible and sustainable supply chain. We want to ensure that the suppliers’ employees have proper employment agreements, documented wages, freedom of association, that working time regulations are observed and that the employees’ health and safety are taken care of.

To achieve these goals, we are implementing the following measures:

a) We will develop ethical guidelines for suppliers, that all new suppliers must accept and sign. The standard includes requirements for working conditions, human rights, wages, forced labor, freedom of association etc.

b) We evaluate our suppliers through background checks, self-evaluations, and system audits.

c) If we uncover violations of applicable laws, regulations, or our ethical standards, we require corrective actions to be taken within a set timeframe. We work closely with the supplier during the remediation process to ensure genuine improvement.

d) In some cases, we might see that our own procurement practices may contribute to increasing the risk of indecent working conditions. In these cases, we review our own practice and improve it.

4.Track implementation and results
Improvement measures are followed up so that we ensure that conditions. We log deviations and results and report on this in the Annual report which includes the Sustainability report.

5.Communicate how impacts are addressed
We report our efforts on the work with human rights and decent working conditions in our annual report. We prepare information that should be easily accessible by the public, such as information on our website. In case of cause of- or contribute to human rights impacts, we are committed to communicate the relevant information to impacted or potentially impacted rightsholders in a timely, culturally sensitive, and accessible manner. Where there are potential risks to stakeholders or staff (including arising from the disclosure of personal information) full disclosure may not be an option.

6.Provide for or cooperate in remediation when appropriate
The appropriate process to enable remediation will be dependent upon several factors including legal obligations, stakeholder preferences, availability of mechanisms, the nature of the adverse impact and where the adverse impact occurs (i.e. within our own operations or supply chain). We follow up cases that require compensation or recovery of damage. We have early warning systems and grievance mechanisms in place e.g. whistle blowing policy. As of today, we have not had any such cases.

7.More information
You can read more about the work with supplier management and ethics in the supply chain in our annual and sustainability report. Our ethical guidelines are published on www.scana.no

In case you would require more information on how Scana ASA works to ensure basic human rights and decent working conditions, send an e-mail to post@scana.no Inquiries by post can be sent to:

Scana ASA | Wernersholmvegen 49 | 5232 Paradis | Norway

We provide Account of Human Rights Due Diligence pursuant to Section 4 of the Norwegian Transparency Act: