The Transparency Act

The Transparency Act - Report on due diligence Entec Brimer AS

Organization and areas of operating areas

Entec Brimer AS is a subsidiary of Entec Group AS, and is located in Kvamsøy and Ulsteinvik.

The company is a technology and manufacturing company with expertise and activity within:

• Production of complete tanks and pools built in composite and other materials, and parts related thereto.
• Equipment for land-based aquaculture
• Fish processing/Industry
• Process industry
• Turnkey contractor water and wastewater treatment
• Project management
• Service and maintenance
• Development of concept and products

Companies divided into the following organizational areas: Product Development, Sales and Marketing, Project, Engineering, Production and Assembly, in addition to Finance, HR and HSEQ.
The department managers in the value chain report to the CEO. The CEO reports to the Chair of the Board of Entec Brimer AS. The board consists of the Chair of the board and one board member.

Due Diligence

The due dilgence assesment in Entec Brimer AS is based on the OECD's model for due diligence for responsible business conduct:

The model has six steps that describe how the company works for more responsible and sustainable business practices and provides a holistic approach to due diligence as a method.

Guidelines and routines

Entec Group AS's ethical guidelines apply to all employees in the group, including the subsidiaries, and must form the basis of all professional practice, regardless of where one practices one's profession in the group. Entec Brimer AS's employees must show respect for the interaction between technology/professional practice and human values, and contribute to transparency about the consequences of technological/professional solutions for society, the environment and the individual. A precautionary approach is sought to be used in all work.

Employees of Entec Brimer AS shall strive for honesty, openness and a correct and good conduct towards employees, customers, suppliers, competitors, business associates and authorities. The company and employees must ensure that they do not contribute to human rights violations and are aware of their social responsibility.

The Company recognizes its responsibility to promote and comply with fundamental human rights and decent working conditions in connection with the production of goods and the provision of services.

Supplier Conduct Principles have been established to ensure safe working conditions throughout Entec Brimer AS's supply chain, and ensure that workers are treated with respect and dignity, impartially and fairly, that business operations are environmentally sound, and that the business is run in accordance with internationally recognized principles and relevant international conventions (including the UN Global Compact, ILO conventions, OECD guidelines for multinational enterprises, the UN's guiding principles for business and human rights, and UN conventions on children's rights). Entec Brimer AS expects all its suppliers to act in accordance with the Supplier Conduct Principles, and obtains written confirmation of this.

Entec Brimer AS conducts an annual due diligence assessment of its value chain to map, prevent, mitigate, and account for actual and potential negative consequences of its own operations, supply chain and the activities of its business associates.

In the due diligence assessment, the following topics are assessed:

• Human rights
• Employment and industrial relations
• Environmental protection
• Anti-bribery, bribery offers and extortion
• Consumer interests
• Disclosure of information

Entec Brimer AS maps its suppliers and business associates, and conducts ongoing assessments related to risk, which apply to fundamental human rights, decent working conditions, sustainability and the environment to ensure good working conditions and environmental focus in the value chain.

Results from due diligence assessments

Entec Brimer AS acknowledges that the greatest influence the company has for influence is with suppliers with which it has the largest volume and turnover. In 2024, the company has therefore tightened its criteria in relation to the assessment of suppliers to where there is the greatest need and potential for influence when it comes to implementing any measures. Purchases from countries with a higher risk of violations of fundamental human rights and decent working conditions in connection with the production of goods and the provision of services must nevertheless be considered extraordinarily, especially now that Entec Brimer AS is becoming more international.  

Based on the company's due diligence assessment, it has been revealed that there is risk of negative consequences for fundamental human rights and decent working conditions in the supply chain. It has been identified that the greatest risk of potential adverse impacts relates to suppliers with production in countries with a higher risk of human rights violations, such as India, Turkey and China.

Measures taken to stop or limit risk

To minimize any negative impact, Entec Brimer AS is close to partners, suppliers and customers during company visits and supplier audits, and requires documentation of a joint commitment to comply with basic environmental requirements, human rights and other working conditions. External audit plan for 2024 has been established and planned, based on the results of the due diligence assessment.

Entec Brimer AS is also a member of the Norwegian Circular Materials Technology (NCMT) business cluster, where work is being done on the development of sustainable solutions in polymers and composites.

If documentation from the suppliers does not satisfy the safeguarding of fundamental human rights and decent working conditions, it will have consequences for the contractual relationship with Entec Brimer AS.

Entec Brimer AS will strive for and influence suppliers who do not provide satisfactory documentation, to minimize risk and repair any violations that have been committed to avoid further negative consequences.

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