The transparency act

The Transparency Act came into effect on July 1, 2022, and aims to promote businesses’ respect for fundamental human rights and decent working conditions.

Introduction

This statement has been prepared in accordance with the Norwegian Transparency Act and provides an overview of Cathwell’s efforts to identify and manage risks of human rights violations and unacceptable working conditions in our supply chain.

Organisation

Cathwell AS was established in Langesund, Norway, in the spring of 2003. We are a privately owned limited company headquartered in Norway, with between 20 and 50 employees. The company develops, designs, and produces solutions for cathodic protection and marine fouling prevention in maritime, offshore, and land-based sectors.

We serve customers in over 50 countries, and our systems are used globally in demanding environments. Over more than 20 years of steady growth, Cathwell has established itself as a leading company in its field in Scandinavia.

Internal whistleblowing routines

At Cathwell, employees are encouraged to report concerns about critical or questionable conditions. We value openness and constructive criticism, supported by management. The whistleblowing routines are designed to ensure that employees feel safe and protected from retaliation when reporting such issues. Document “0194 Whistleblowing Routine” outlines how employees can report internally within Cathwell. A suggestion box has also been set up, which can be used to submit feedback or complaints anonymously. These measures are intended to help uncover and address negative conditions within the company.

We have implemented routines and systems that ensure due diligence assessments are conducted thoroughly and systematically within our operations. Our focus on continuous improvement helps us maintain high standards and swiftly identify and address future challenges. This approach, combined with robust routines, gives us confidence that we are meeting national and international requirements. We are committed to maintaining and improving these standards in the future.

Implementation of the transparency act

Cathwell began its work with the Transparency Act early in 2024. The board decided to embed accountability for the Act within the company’s internal guidelines. To ensure compliance, we developed and improved procedures and policies that safeguard fundamental human rights and decent working conditions. Our internal guidelines and supplier ethical codes were updated and included in our supplier agreements starting in 2024, establishing obligations throughout the supply chain.

Mapping and risk assessment

Cathwell operates globally, and it is essential for us that our business partners conduct their operations without violating fundamental human rights or decent working conditions. In 2025, we continued the process of mapping our largest suppliers to identify risk areas that may impact human rights and working conditions. The risk assessment is based on international indices and reports and focuses on the following factors:

• Country risk: Evaluation of the likelihood of human rights violations in the supplier’s country.
• Industry risk: Risks related to specific industries and sectors.
• Product risk: Risks associated with specific products or manufacturing processes.
• Known risk: Historical data and previously reported issues.

Negative consequences and significant risks

So far, in our work with the Transparency Act, Cathwell has not identified any concrete negative consequences related to fundamental human rights or decent working conditions that required corrective action during this reporting year. We continue to follow applicable international standards and remain in ongoing dialogue with stakeholders to uncover any potential areas for improvement.

However, based on our mapping and risk assessments, we have identified elevated risk levels related to some of our suppliers outside of Europe. Although no specific violations have been observed, we face challenges in obtaining reliable information to confirm or deny potential risks. In 2025, we continued our efforts to collect data on actual and potential risks related to human rights and decent working conditions in our supply chain.

Measures and follow-up

Based on the risk assessment, we have prepared a prioritized list of suppliers requiring closer monitoring. We have implemented the following measures to ensure compliance with our standards for human rights and working conditions:

• Questionnaires: Questionnaires have been distributed to prioritized suppliers to collect detailed information about their practices.
• Cathwell’s Code of Conduct: All suppliers are required to sign and comply with our ethical guidelines.
• HSEQ focus: Health, safety, environment, and quality are emphasized in meetings with suppliers.
• Dialogue: When risks are identified, we will, where needed, enter into dialogue with the relevant suppliers or partners to gather more information and assess possible improvement measures.

If violations are not addressed within a reasonable timeframe, the contract may be suspended or terminated.

Expected results

We expect our work on due diligence assessments and the improvement of routines and procedures to lead to the following outcomes:

• Confirmed compliance: Confirmation that the company complies with human rights and decent working conditions.
• Increased transparency: Better public and stakeholder access to information about the company’s work on human rights and labour conditions.
• Improved risk management: A robust system for identifying, monitoring, and handling risks.
• Engaged stakeholders: Strengthened collaboration with employees, trade unions, and civil society organizations.
• Preventive measures: Implementation of proactive actions that ensure continued compliance with laws and international guidelines.
• Documented improvements: Concrete and measurable improvements in practice, visible procedures for HSE and quality assurance, and alignment with applicable international legislation.

Continuous improvement

Due diligence assessments are an ongoing process. We regularly monitor and evaluate our suppliers and business partners. Experiences and feedback from these assessments are used to enhance our processes and achieve improved results going forward.

Future focus areas

In the time ahead, we will particularly focus on the following:

• Follow-up of high overall risk: When total risk is assessed as high, we will intensify follow-up efforts through closer dialogue and collaboration with the relevant suppliers or business partners.
• Follow-up of missing responses: We will follow up closely with suppliers who have not responded or whose responses are unsatisfactory..
• Improvement of routines: We aim to implement stronger routines for the pre-assessment of new suppliers and business partners.
• Regular reviews: We will conduct audits on a regular basis to ensure our suppliers and business partners continuously meet our standards.

Conclusion

Cathwell’s work with the Transparency Act is a vital part of our commitment to operating a responsible, sustainable, and ethical business. We work systematically to identify and manage risks in our supply chain, ensure decent working conditions, and protect fundamental human rights.

Through continuous improvement, transparent processes, and responsible supplier engagement, we strive to enhance openness and trust—both internally and among our partners, customers, and the wider society.

Our ambition is to further develop this work in line with growing expectations from authorities, the market, and society at large, and to be a driving force for responsible business practices in our industry.

For questions about this statement or our work on due diligence assessments, please contact us at contact@cathwell.com and mark the email with “Transparency Act.”

Revision 2, 23.06.2025