Transparency Act
Transparency Act July 2022
As a means to promote enterprises’ respect for fundamental human rights and decent working conditions in connection with production of goods and provision of services, the Act of Transparency came into effect in July 2022. The Act applies to larger enterprises that are resident in Norway and that offer goods and services in or outside Norway. The Act also applies to larger foreign enterprises that offer goods and services in Norway, and that are liable to tax to Norway pursuant to internal Norwegian legislation. Saren Energy and their subsidiaries are serious about this act, and will through this document shed light on how we adhere to its content.
SAREN Energy AS Compliance with
the Transparency Act
Below follows a compliance account with § 5 of the Transparency Act for SAREN Energy AS (SAREN) including subsidiaries (SAREN group) for the year 2022.
GENERAL DESCRIPTION OF THE ENTERPRISE (Transparency Act § 5, letter a)
Our operation is organized as follows: SAREN owns the three Waste Incineration and Energy companies Kvitebjørn Varme AS, Kvitebjørn Bio-El AS and Sarpsborg Avfallsenergi AS. SAREN is owned by SAREN Midco AS (100%), which in turn is owned by Sarpsborg Infrastructure AS (92.5%) and Snowflake Capital AS (7.5%). SAREN entities are located in Sarpsborg, Fredrikstad and Tromsø. The core business is to supply reliable and sustainable district heating, industrial steam, and electricity from surplus heat from waste incineration are delivered to industry, public and private customers.
We have established the following guidelines and routines to handle actual and potential negative consequences for basic human rights and decent working conditions: The group has already established guidelines and routines for this through supplier evaluation and HSE programs. In the process of ensuring compliance with the Transparency Act, these are gathered across the group into a common system and quality assured. The OECD guidelines for due diligence assessments for multinational companies in accordance with Section 4 of the Transparency Act have been implemented. The level of the due diligence assessment is adapted to SAREN, the nature of the business, the context of operations, and the severity of and the likelihood of negative consequences of violating basic human rights and not providing decent working conditions.
Compliance with the Transparency Act, accountability and the process described below, has been adopted by the board of SAREN and is anchored with the management groups across SAREN. Supplier audits are carried out as part of the HSE program, and requirements from the Transparency Act are included. Internal routines have been established to respond to and access requests. When evaluating and approving new suppliers, our Ethical Guidelines for Suppliers must be signed, and our supplier sustainability evaluation must be completed. Established suppliers are subject to sustainability evaluation in accordance with a 5-year plan. For 2023 the target is to exceed an 80% response rate from the sustainability evaluation and zero deviations from the due diligence assessment. By 2030 the target is a 100% mapping of suppliers and zero deviations from the due diligence assessment. Findings from the due diligence assessments are compiled and reviewed to set measures. The report is updated, signed, and published in accordance with § 5 third and fourth paragraphs of the Transparency Act. SAREN’s compliance assurance related to the Transparency Act is described in our Sustainability Framework.
ADVERSE IMPACTS AND SIGNIFICANT RISKS (Transparency Act § 5, letter b)
The due diligence assessments have uncovered the following actual negative consequences and significant risk of negative consequences: No negative incidents or significant risk of negative incidents regarding basic human rights and decent working conditions have been identified through our due diligence assessments.
MEASURES (Transparency Act § 5, letter c)
To stop actual negative consequences and limit the significant risk of negative consequences, we have implemented the following measures: No negative incidents or significant risk of negative incidents regarding basic human rights and decent working conditions have been identified through our due diligence assessments.
Implemented measures have produced the following result or expected result: No negative incidents or significant risk of negative incidents regarding basic human rights and decent working conditions have been identified through our due diligence assessments.
Questions about the Transparency Act can be sent to: sustainability@sarenenergy.com
The document can be downloaded in its entirety via the link below: