The Transparency Act

Transparency Act - Report on due diligence Brimer AS

Organization and areas of operating areas

Brimer AS is one of Europe's leading manufacturers of corrosion-free solutions in composite materials, GRP , a material that preserves – and lasts. Our employees are involved all the way from design and strength calculations through production, transport, assembly, to the completion of complete products at the customer's premises. We also deliver Contract Manufacturing to the municipal technical market both to water tanks , water treatment and wastewater treatment.

Brimer AS has a factory in Kvamsøy, and head office in Ulsteinvik. Together we have a strong and experienced professional environment, which takes on new challenges and creates solutions to protect, preserve and secure values for the customer – and for society.

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 aquaculture and fish processing/industry
• Process industry
• Turnkey contractor water and wastewater treatment
• Project management
• Service and maintenance
• Development of concept and products

The company is 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 heads in the value chain report to the CEO. The CEO reports to the Chairman of the Board. The Board consists of the Chairman of the Board and one board member.

Due Diligence

Conducting due diligence in Brimer AS is based on the OECD's model for due diligence assessments for responsible business:

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

Brimer AS's ethical guidelines apply to all employees, including subsidiaries, and shall form the basis for all professional practice regardless of where one practices their profession. Brimer AS's employees shall show respect for the interaction between technology/professional practice and human values, and contribute to openness 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 in Brimer AS shall strive for honesty, openness and correct and good conduct towards employees, customers, suppliers, competitors, business partners and authorities. The company and employees shall ensure that they do not contribute to violations of human rights 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 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 conducted in accordance with internationally recognized principles and relevant international conventions (including the UN Global Compact, ILO conventions, OECD Guidelines for Multinational Enterprises, UN Guiding Principles on Business and Human Rights, and UN Conventions on the Rights of the Child). Brimer AS expects all its suppliers to act in accordance with the Supplier Conduct Principles, and obtains written confirmation of this.

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

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

• Human rights
• Corruption

Brimer AS surveys its suppliers and business partners, and makes ongoing assessments related to risk.

Results from due diligence assessments

The due diligence assessment for 2024 was carried out on 24.02.2025.

Brimer has surveyed 110 suppliers in the Due Diligence Assessment, of which 108 are located in Europe. Of the 108 suppliers in Europe, 103 are located in the Nordic region. The remainder are in Africa and Asia. Of the suppliers, 12 suppliers have their production outside Norway, of which three have their production in countries with a higher risk of human rights violations according to the "Human Rights Index" in China, Egypt, India and Turkey, respectively, and of which 4 have their production in countries with a higher risk of corruption according to the "Corruption Perceptions Index", in China, Turkey, Egypt, Serbia and India, respectively. 98.2% of the suppliers Brimer AS trades with is located in Europe, of which 93.6% are in the Nordic region, and only 2.7% of the suppliers have production in high-risk countries. 52 out of 110 had signed documentation in accordance with Brimer AS's purchasing routines, which is a deviation from the company's goal of 100% documentation requirements. The deviations in documentation requirements were in most cases revealed in individual purchases related to projects, while regular suppliers meet the documentation requirements.

The assessment also reviewed critical suppliers, of which some new suppliers were defined as critical and some were removed in accordance with the current value chain. In total, Brimer AS identified 8 critical suppliers.

Brimer AS recognizes that the company has the greatest influence for any possible influence is with suppliers with whom it has the largest volume and turnover. The requirements in the purchasing process have been assessed to the extent that the threshold for the assessment of the effectiveness of NOK 150,000 in turnover, and therefore also for the issuance of Supplier Conduct Principles, is still appropriate as the company considers that we have the greatest opportunity for influence on suppliers in this category. In addition, tourism players, large retail chains, banks and insurance are exempt from the company's purchasing requirements, as Brimer AS considers that these are suppliers the company has little influence on due to the company's size, and which are protected by other strict regulations. Purchasing from countries with a higher risk of violations of basic human rights and decent working conditions according to the "Human Rights Index" and "Corruption Perceptions Index" in connection with the production of goods and the provision of services should nevertheless be considered exceptionally regardless of the industry, especially now that Brimer AS enters international markets.

Based on the company's due diligence assessment, it has been revealed that there is some risk of negative impacts on fundamental human rights and decent working conditions in the supply chain. It has been identified that the greatest risk of potential negative impact is associated with suppliers with production in countries with a higher risk of corruption and human rights violations according to the Human Rights Index, and the "Corruption Perceptions Index".

No objectionable conditions regarding basic human rights and decent working conditions have been identified in the supply chain used by the company so far. Brimer AS has considered.

‍

Measures taken to stop or limit risk

To minimize any negative impact, Brimer AS closely monitors partners, suppliers and customers during company visits and supplier audits, and requires documentation of a joint commitment to comply with fundamental human rights, corruption and other working conditions. Brimer AS plans external audits of suppliers based on criticality, turnover and geographical proximity to company location or production. An external audit plan for 2025 has been established and planned, based on the results of the due diligence assessment. Brimer AS is also a member of the Norwegian Circular Materials Technology (NCMT) industry cluster where work is being done on developing sustainable solutions within polymers and composites, including documentation and supply chain.

If documentation from suppliers does not satisfy the requirements for safeguarding basic human rights and decent working conditions, this could have consequences for the contractual relationship with Brimer AS. Brimer AS will strive to influence suppliers who do not provide satisfactory documentation, in order to minimize risk and repair any violations that have been committed to avoid further negative consequences. Measures have been taken directly against suppliers who have not provided sufficient documentation following the Due Diligence Assessment. In addition, the procedures for obtaining documentation from the project organization have been clarified and tightened, regardless of whether it is a one-time purchase. The result of this will be followed up more closely in 2025, where regular updates of the due diligence assessment will be established to ensure improvement of internal guidelines.

‍

‍