1          Purpose

The Transparency Act shall promote companies’ respect for fundamental human rights and decent working conditions in the production of goods and the provision of services by ensuring the public access to information on how the company works to prevent negative consequences within social sustainability. This document describes how Connector Subsea Solutions AS and subsidiaries (CSS AS) work to ensure compliance with the requirements of The Transparency Act.

2          Integrity Assessment

Integrity assessments are carried out to uncover circumstances that can potentially or actually negatively affect social sustainability. These assessments are conducted in line with the OECD guidelines for due diligence. The assessments apply both to CSS AS’ suppliers and clients:

For clients:

• Identification of clients
• Mapping of geographical location
• Check as an initial reference against Transparency International Corruption Perception Index (TICPI) based on geographical location
• Review of the company’s ethical guidelines/Code of Conduct
• Assessment of potential and actual risk of negative influence on social sustainability

For suppliers:

• Mapping of geographical location
• Check list (including Transparency International Corruption Perception Index (TICPI) and human rights assessment)
• Company assessment based on available information
• Assessment of risk of negative influence on social sustainability
• Integrity assessment (questionnaire) for suppliers considered high risk

The risk level of each supplier and client is assessed based on these investigations, i.e., the risk of negative impact on social sustainability. In addition, an integrity assessment is carried out for suppliers considered to have a high potential risk.

CSS AS currently has no suppliers or customers assessed as representing high risk of violating fundamental human rights and decent working conditions.

3          Continuous preventive actions

CSS AS works proactively to minimize and remedy challenges through active engagement and follow-up with clients and suppliers.

We take a risk-based approach to monitoring clients and suppliers and work continuously with requirements and follow-up through:

• Review and follow-up of risk according to the following routine:
  • Low risk: no follow-up regarded necessary
  • Medium risk: annual review of risk to detect changes in risk levels
  • High risk: quarterly monitoring until the risk is reduced
• Requirement for compliance with and contractual inclusion of our Code of Conduct for existing and new suppliers, or alternatively approval of the supplier’s own ethical guidelines
• Risk assessments of new suppliers and clients

Document version: 2
Last updated: 27/06/2025
Link to download PDF (Norwegian): Transparency Act