Statement of evaluation of due care

Onsagers AS has completed a superior evaluation of due care to identify possible negative consequences which Onsagers AS, companies in Onsagers’ supply chain, or other business associates may have caused or contributed to regarding human rights and decent working conditions.

The evaluation of due care within Onsagers AS was initiated by including accountability requirements into the company guidelines, and by having the board of executives make a formal decision on the matter. Subsequently, relevant process descriptions and corresponding action plans for the implementation of the work with the evaluation were prepared.

Policy for Responsible Business Conduct and Supplier Code of Conduct has been prepared to ensure that Onsagers AS has a policy for responsible business conduct, and to ensure that Onsagers’ suppliers correspondingly commit to responsible business conduct. Both codes of conduct are available on Onsagers’ official web sites.

In addition, a policy and routine for remediation and grievance mechanisms implemented to ensure that Onsagers AS has relevant processes to manage possible incidents of violation of basic human rights has been prepared.

Onsagers AS has adopted a Policy for Responsible Conduct and a corresponding Policy on Remediation and Grievance Mechanisms.

A superior risk assessment of the operation of Onsagers AS has been performed in cooperation with KPMG. Generally, the risk of violating human rights for service providers like Onsagers AS is low.

The core business of Onsagers AS is consultation services which are performed by highly skilled and educated academics with legal and scientific degrees, and by specialized administrators. The need for travelling to perform the core services is low, and the business operations are mainly based in Norway; however, Onsagers AS also has limited operations in Sweden, Germany, and Great Britain. The working conditions in Norway are highly regulated concerning basic human rights, such as workers rights, discrimination, and corruption; and, Onsagers’ business operations have small impact on the environment and climate.

Based on the character of Onsagers’ business operations, it is considered less likely that the company’s activities may cause or contribute to negative consequences regarding human rights and decent working conditions. Onsagers AS has carried out this work in cooperation with the sustainability department of KPMG.

Regarding the concrete evaluation of due care, the work on this issue with KPMG was concentrated on the supply chains regarding the risk of violating basic human rights.

In the supply chains, the international agent network has been prioritized for analysis. Onsagers AS cooperates with agents in more than 80 countries. These agent companies consist of counsellors with higher scientific or legal degrees, and specialized support staff.

In cooperation with KPMG, it was decided to focus the evaluation of due care for the agent network companies on employee rights, working and salary conditions, gender equality, discrimination, and corruption.

Concrete risk assessment has been performed on all the countries in which Onsagers AS work with agents regarding these risk factors.

Onsagers AS has submitted a Supplier Code of Conduct to all agents and suppliers to commit the agents and suppliers to behave in accordance with basic human rights. Moreover, Onsagers AS will on a regular basis continue to perform evaluations of due care on the companies in supplier chain.

Based on the superior evaluation of due care, risk assessments with a focus on human rights and working conditions shall always be considered when Onsagers AS works with new partners, agents, and suppliers; and, Onsagers AS will provide and submit a Supplier Code of Conduct to new suppliers to commit suppliers and agents to behave in accordance with basic human rights.

Should conditions which may lead to violation of basic human rights be revealed in Onsagers AS’ agent or supply chain, appropriate actions will be considered initiated regarding stopping, preventing or delimiting negative consequences based on which consequences that are revealed in the evaluation of due care.

Processes for the evaluation of due care has been implemented in the company, and Onsagers AS will continue contributing to respect for basic human rights and sustainable business activity in the future.