The Transparency Act
— Due Diligence Assessment SPERREFISH AS
Investigation of due diligence assessments regarding transparency and work on fundamental human rights and decent working conditions.
In the summer of 2022, the Transparency Act was adopted by the Norwegian Parliament. The purpose of the law is to promote companies’ respect for fundamental human rights and decent working conditions related to the production of goods and the provision of services, as well as to ensure the public’s access to information about how companies manage both potential and actual adverse impacts.
The Sperrefish Group regards the work related to the Transparency Act as a natural part of its sustainability efforts. We acknowledge that our operations may have negative impacts on fundamental human rights and decent working conditions. We aim to work purposefully to prevent, limit, or stop activities that contribute to negative consequences.
Duty of Due Diligence
The due diligence assessment under the Transparency Act shall be carried out in accordance with the OECD Guidelines for Responsible Business Conduct. The process is illustrated in Figure 1.
Sperrefish Group’s Due Diligence Assessment for 2022
General description of the company’s organization and operational area. The Sperrefish Group is organized as follows:
The activity mainly consists of purchasing, processing, packaging, and sale of fish, primarily carried out at factories in Fiskerstrand, Bud, and Ellingsøy.
The ultimate responsibility for compliance with the Transparency Act lies with the board and the management team. The CEO of Brødrene Sperre AS organizes the work related to the Act. Employees responsible for purchasing goods and services also play important roles.
Guidelines and routines for handling potential and actual adverse impacts on fundamental human rights and decent working conditions
Significant risk areas in own operations and measures to limit risk
It has been assessed that there is a low risk of negative impacts on fundamental human rights and decent working conditions in our own operations.
The Sperrefish Group’s overall approach to fulfilling the duty to respect fundamental human rights and decent working conditions is governed by compliance with Norwegian legislation. Sustainability work covers both own operations and the supply chain.
Sperrefish Group is a Norwegian company based in Norway and is therefore subject to strict regulations regarding governance and operations. In addition to the Transparency Act, the company complies with Norwegian health, environment, and safety legislation. Employees’ working conditions are secured through collective agreements. The company is affiliated with an occupational health service. There is a deviation system in place through which employees can report incidents or conditions and receive follow-up. Specific whistleblowing guidelines have been developed. The status of equality is monitored and reported in accordance with the Equality and Anti-Discrimination Act.
The Sperrefish Group is in the process of reviewing and possibly establishing new guidelines in line with the Transparency Act and OECD Guidelines. These guidelines will cover the entire company, the supply chain, and business partners, and will at minimum include how Sperrefish Group shall act responsibly, as well as expectations and requirements for suppliers and business partners, and how due diligence shall be conducted. New employees receive ethical guidelines which they must read before starting work.
Information on potential and actual adverse impacts identified through the due diligence process
Sperrefish Group respects fundamental human rights and, as part of ensuring decent working conditions both in its own operations and among suppliers and business partners, conducts risk-based due diligence assessments. It is important to emphasize that when Sperrefish Group deals with risks related to human rights, the risks do not apply to the company itself, but to the people concerned.
One must consider who may experience actual and potential impacts and thereby determine whether anyone’s rights are being harmed as a result of our actions.
Significant risk areas in the supply chain and among business partners, and measures to limit risk
Sperrefish Group is conducting a risk assessment of suppliers and business partners. Based on the materiality principle, it was initially decided to assess suppliers with an annual purchase volume exceeding the national threshold value of 1.4 million NOK per year.
Suppliers were categorized as low, medium, or high risk according to Table 1. The risk assessment was based on the industry to which the supplier belongs, the geographical area where the supplier is located or where goods are produced, the type of products purchased, and any risks associated with specific companies.
Risk | Suppliers | Planned measures |
|---|---|---|
Low | No action | |
Medium | Distribution of questionnaire | |
High | Distribution of questionnaire and further investigations (dialogue and documentation) |
Questionnaires will be designed and sent out after the summer. For suppliers with high risk, dialogue and documentation will be conducted based on the responses Sperrefish Group receives from the questionnaires.
If significant risks of violations of fundamental human rights and decent working conditions are discovered, Sperrefish Group will implement measures to prevent harm. If violations occur, the company will initiate measures to limit the extent of harm resulting from the violation, and in the most serious cases, cease activities contributing to negative consequences.
Duty to provide information
Sperrefish Group will respond to anyone who requests information in writing about how the company handles actual and potential adverse impacts. The information provided will be written, comprehensive, and understandable, and will be delivered no later than three weeks after the request is received.
For questions regarding this report and Sperrefish Group’s work related to fundamental human rights and decent working conditions, please send an email to inger@sperrefish.com.