Transparency Act

Statement: Transparency Act
Company name: Nordic Health Partner AS
Address: Vassbotnen 15, 4313 Sandnes
Date: 24.05.2025

GENERAL INFORMATION

Nordic Health Partner AS is a Nordic company based in Norway and Denmark, and is part-owned by the global company International SOS.

The company provides complementary health services within occupational health services and offshore health services to the energy and maritime sectors in the Nordic region. With more than 40 years of experience, the company offers specialized and quality-assured services to players operating in demanding working environments.

We have approximately 110 employees in Norway and Denmark, with offices in Bergen, Haugesund, Stavanger and Esbjerg.

At Nordic Health Partner, we work continuously with risk assessments, and we work preventively and executively to safeguard the health of both our own employees and our customers’ employees. We have a strong focus on sustainability and ethics, and our policies have been developed over a long period of time. Our work to ensure fundamental human rights and decent working conditions in our own operations and in the supply chain is part of our overall strategy and is integrated into our business.

In accordance with our guidelines, Nordic Health Partner carries out risk assessments concerning human rights and decent working conditions. In undertaking these assessments, we follow a prepared guide that is based on the UN Guiding Principles on Business and Human Rights (UNGP, 2011) and the OECD’s Due Diligence Guidance for Responsible Business (2018). The guide describes a risk-based method that starts with anchoring, mapping and risk assessment, and ends with measures, reporting and monitoring. This is a continuous process to identify areas in your own or suppliers’ operations that carry particularly high risk.

THE DUE DILIGENCE ASSESSMENT MODEL

The due diligence assessment model has been introduced in our operations in the following way:

Step 1: Anchoring sustainability in the business

Anchoring sustainability in the business is about having relevant policies and guidelines in place, as well as effective management systems for implementing these. For us, this means that we have a sustainability strategy with relevant goals, and that we are clear externally about our responsibility to work with due diligence assessments and responsible purchasing practices. We also have a “Supplier Code of Conduct” that must be signed by all relevant suppliers. We also have routines for selecting, approving, collaborating with and following up on suppliers.

Step 2: Mapping Nordic Health Partner’s impact on people, society and the environment

Mapping is about identifying the risk of negative impact both in the company’s own business and in the supply chain. This is done by establishing an overall risk picture in order to prioritize significant risk areas for more thorough mapping. We must have an overview of our suppliers’ handling of working conditions, as well as other requirements in the Transparency Act, and we conduct risk assessments of prioritized suppliers

Step 3: Stop, prevent or reduce negative impact

Based on the risk assessment and prioritization of risk in step two, plans are prepared with measures that are implemented to stop, prevent and reduce the risk of negative impact. When a prioritized risk has been established, measures are implemented, and we prepare plans that describe what we do to stop, reduce or prevent negative impacts of the prioritized risk. This may include following up with a supplier through audits, requirements for the agreements and possibly assessing the contractual relationship.

Step 4: Monitoring the implementation and effect of measures

Monitoring the implementation and effect of measures concerns whether Nordic Health Partner is making sound due diligence assessments, and whether we are implementing effective measures to prevent recurring deviations. We must therefore regularly review our measures and plans to ensure that these have the desired effect.

Step 5: Communicating how negative impacts/damage have been handled

Nordic Health Partner shall, in dialogue with our customers and employees, be open about the assessments made in our value chains. We shall also report openly and honestly about measures and challenges. This will be described in the company’s annual reports.

Step 6: Remediation where required

Should a deviation occur, we shall take measures to ensure that those responsible for the deviation rectify this. If we are not internally responsible for the deviation, we shall hold the responsible part accountable. In connection with the Transparency Act, the number of actual or reported cases of human rights violations shall be logged and reported in accordance with our own routine for this. In this context, it is worth mentioning that the OECD clearly states: ‘Companies are expected to act in accordance with local laws and standards, and to assess, prevent and address violations of human and labour rights, environmental damage and bribery resulting from their own activities, suppliers and other business relationships.’

The due diligence model shall enable us to identify, prioritise and address negative impacts on people, society and the environment in our value chains, whether they arise directly in our own activities or indirectly through our suppliers. We conduct due diligence assessments of our own operations, our subcontractors and other partners, and expect our subcontractors and partners to do the same. Selected suppliers must report regularly to us on how they work with labor and human rights in their own operations, and we also ask suppliers to publicly report this work. The Transparency Act requires that we conduct due diligence assessments of the services we provide, and that we provide insight into this work to anyone who may request it.

NEGATIVE CONSEQUENCES, RISKS AND MEASURES

Nordic Health Partner actively uses the due diligence assessment model in our efforts to strive for sustainable operations that are in line with conditions for decent working conditions.

In our work with suppliers and risk assessments, we regularly send out surveys to suppliers we consider a potential risk factor. These surveys deal with sustainability and decent working conditions, and are one of several tools we use to risk assess our suppliers. There is a varying degree of response to these surveys. On the other hand, our suppliers are well established in Norway, and have therefore published declarations (the Transparency Act) on their websites. By reading these declarations, looking at response data from the survey, and through continuous dialogue with subcontractors, we have a good starting point for identifying any risks. Our due diligence methodology also enables us to continuously implement and evaluate measures.

In the past year, we have not identified any risks that have led to the implementation of measures. We have developed our own guidelines and routines for due diligence assessments.

Lars Olav Matre
Managing Director

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