1          Purpose

he 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) work to ensure compliance with the requirements of The Transparency Act.

2          Integrity Due Diligence Assessment

Due diligence assessments are done to uncover conditions that potentially and actually can negatively affect social sustainability. Assessments are carried out based on the OECD’s guidelines for due diligence assessments. The assessment is done for CSS’ 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
• Check of company Code of Conduct/Ethics Code
• 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 Rating)
• Company evaluation based on company information
• Assessment of risk of negative influence on social sustainability
• Integrity Due Diligence check (questionnaire) on high-risk suppliers

The risk level of each supplier and client is assessed based on these investigations, i.e., the risk of negative impact on social sustainability. Furthermore, an integrity due diligence assessment is performed on the suppliers that are considered to have high potential risk.

Based on feedback, the risk is reviewed.

Results from the assessments can be found in our quality management system. It can be made available on request.

3          Continuous preventive actions

CSS works preventively to minimize and remedy the problems through active work and follow-up of clients and suppliers.

We have a risk-based follow up approach to the follow-up of clients and suppliers. We 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 risk is reduced
• Requiring compliance with and contracting our Code of Conduct from existing and new suppliers
• Risk assessments of new suppliers and clients

Document version: 4
Last updated: 28/06/2023