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 Transparency Act and provides an overview of Cathwell’s work in 2024 to identify and manage risks of human rights violations and labour conditions in our supply chain.

Organisation

Cathwell was founded in Langesund, Norway, in the spring of 2003. We are a privately-owned company with a business address in Norway, and we have between 20-50 employees. We operate in the maritime sector, designing and producing solutions for cathodic protection and antifouling treatment for maritime, offshore and land-based industries. Our services include corrosion protection and antifouling solutions for ships, mobile offshore units, underwater structures and onshore installations in more than 50 countries. Over the past 20 years, Cathwell has continuously grown and established itself as the leading supplier in Scandinavia for cathodic protection and electrolytic antifouling treatment.

Internal whitsleblowing routines

In Cathwell, employees are encouraged to report critical issues. We value openness and constructive criticism, supported by our management. The whistleblowing routines are designed to ensure that employees feel safe and protected from retaliation when reporting such issues. “0194 Whistleblowing routine” describes how employees can report internally within Cathwell. A suggestion box has also been set up for employees, which can be used to provide feedback or complaints. These measures are intended to uncover negative conditions within the company.

Implementation of the Transparency Act

Cathwell started working on the Transparency Act early in 2024. The board decided to incorporate accountability for the act into the company’s guidelines. To ensure compliance, we developed procedures and guidelines to uphold fundamental human rights and decent working conditions. We updated our internal and supplier ethical guidelines, including them in our main agreements from 2024.

Mapping and Risk Assessment

Cathwell operates globally, and it is crucial for us that our business partners conduct their operations without violating fundamental human rights and decent working conditions. In 2024, we conducted a mapping of our largest suppliers to identify risk areas that may affect human rights and working conditions. The risk assessment is based on international indexes and reports, focusing on the following factors:

• Country risk: Assessment of the risk of human rights violations in the supplier’s home country.
• Industry risk: Risk related to specific industries and sectors.
• Product risk: Risk related to specific products and production processes.
• Known risk: Historical data and previously reported issues.

Negative consequences and significant risks

In our work with the Transparency Act, Cathwell has not yet identified any specific negative consequences for fundamental human rights and decent working conditions that require action during this reporting year. We continue to adhere to applicable international standards and are in ongoing dialogue with involved parties to uncover any needs for improvement.

On the other hand, based on our mapping and risk assessment, we have identified significant risks with certain suppliers outside of Europe. While we have not witnessed any specific violations of decent working conditions or human rights, obtaining information to confirm or deny these risks is challenging. This emphasizes the importance of strong partnerships and clear working agreements. Therefore, we are committed to pay extra attention to these areas in our ongoing due diligence efforts.

Measures and follow-up

Based on the risk assessment, we have developed a prioritised list of suppliers that require closer follow-up. We have implemented the following measures to ensure compliance with our standards for human rights and working conditions:

• Tailored questionnaires: These have been sent to all prioritised suppliers to collect detailed information about their practices.
• Cathwell’s code of conduct: All suppliers are required to sign and adhere to our ethical guidelines.
• HSEQ: Health, safety, environment, and quality are prioritized in meetings with suppliers.
• Factory visits and audits: Where information is lacking, we consider the possibility of conducting factory visits to uncover potential violations.

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

Expected results

We expect that our work with due diligence assessments and the improvement of routines and procedures will produce the following results:

• Confirmed compliance: Confirmation that the company follows human rights and decent working conditions.
• Increased transparency: Better access to information for the public and stakeholders about the company’s work with human rights and working conditions.
• Improved risk management: Robust systems for monitoring and handling risks.
• Engaged parties: Better collaboration with employees, trade unions and civil society organisations.
• Preventive measures: Implementation of measures to ensure ongoing compliance with legal requirements and international guidelines.
• Documented improvements: Concrete and measurable improvements in the company’s practices.

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 improve our processes and achieve better results going forward.

Future focus areas

In the future, we will particularly focus on:

• Follow-up of missing responses: We will prioritise following up with suppliers who have not responded, or have provided unsatisfactory responses, to our surveys.
• Improvement of routines: We will implement better routines for pre-assessment of new suppliers and business partners.
• Regular reviews: We will conduct regular audits to ensure that our suppliers and business partners continuously comply with our standards.

Conclusion

Our work under the Transparency Act is a central part of our commitment to conducting a responsible and ethical business. We will continue to work purposefully to identify and manage risks, ensure decent working conditions and protect human rights throughout our supply chain. Through these measures, we seek to achieve greater transparency and accountability in our operations.

For questions regarding the statement and our work with due diligence assessments, please send an email to contact@cathwell.com and mark it “Transparency Act”.

Revision 1, 18.06.2024