Transparency Act Report 2024

Transparency Act Report 2024

GENERAL INFORMATION

Purpose of the report

The Transparency Act shall promote businesses' respect for human rights and decent working conditions, as well as ensure the public's access to information. Among other things, the Act imposes a duty of information on the businesses and a duty to carry out due diligence assessments which must be explained in this report Report is published on www.soiltech.no

This report is to give the public insight into the business’ key findings in the due diligence assessments, and which measures have been implemented. This is the second report covering due-diligence for the Company and covers the period 14.06.2023-11.06.2024

Contact information

Inquiries about this report can be directed to:

Soiltech AS

Else-Karin Vådeland VP HSSEQ & Sustainability

Else.vaadeland@soiltech.no

ABOUT OUR BUISNESS

Organization and operating area

Established in 2011, Soiltech AS (Soiltech or the Company) is an innovative cleantech service provider specializing in the treatment, recycling and responsible handling of contaminated water and solid industrial waste streams at site

Soiltech’s technologies enable cost savings and lower CO2 emissions through waste reduction, waste recovery and reuse.

We design, build, own and operate our treatment technologies, providing services in close cooperation with the customer on their sites. The Company also offers biodegradable chemistry and solutions for treatment of contaminated water in the energy sector (produced water), aquaculture, municipal and other industries.

As a company, mainly in the energy sector, we recognize the role we play in promoting sustainable development and mitigating the impacts on human rights. Our operations are integral to the functioning of modern society, and we are committed to ensuring that our activities are conducted in a responsible and sustainable manner.

We base everything we do on the following core values:

Quality

Integrity

Responsibility

Soiltech Board of Directors

Gunnar Winther Eliassen, chairman

Eirik Flatebø, director

Olaf Skrivervik, director

Glenn Åsland, director

Carsten Brueckner, director

Dennis Alberding, deputy director

The board members Mr Eliassen, Mr Flatebø and Mr Skrivervik are compensated with an annual remuneration for their service. Mr Åsland, Mr Brueckner and Mr Alberding do not receive remuneration for their service. The Board members are elected for a service period of 2 years.

Soiltech Management Team

Jan Erik Tveteraas, CEO

Glenn Åsland, COO

Tove Vestlie, CFO

Bente Skogen, VP People & Organization

Else-Karin Vådeland, VP HSSEQ & Sustainability

Erik Røvde, VP Operations

Patrick Åsland, VP Technology & Newbuilds

The Soiltech group consists of parent company Soiltech AS and the subsidiaries Soiltech Offshore Services AS and Sorbwater Technology AS.

Soiltech operates world-wide and is headquartered in Sandnes, Norway. We are listed on Euronext NOTC in Norway under the ticker SOIL

Please see www.soiltech.no for further information about the Company.

Embedding Human Rights in our business

Soiltech complies with laws, rules, and regulations applicable to its business, including the Norwegian Transparency Act.

The Transparency Act includes requirements for reporting on basic human rights and decent working conditions for the company’s own business, the supply chain and the business partners. Soiltech’s Code of Conduct applies to all Soiltech critical and key suppliers, their subcontractors and third parties. It is the supplier’s responsibility to ensure that its representatives are familiar with this code and are committed to comply with it. Soiltech requires our suppliers to act in such a way that the impact on nature, people and society is both ecologically and ethically justifiable.

The Transparency Act aims to reduce the risk of human rights violations, avoid modern slavery and ensure decent working conditions. Soiltech’s obligations to respect basic human rights are laid down in our core values, Ethical guidelines and in our policy for Human rights.

Soiltech’s Anti-Bribery and corruption Policy applies to all employees, officers and directors of Soiltech and of all Soiltech’s affiliates world-wide, as well as any third party intermediaries/representatives such as resellers, contractors or agents.

Violations of the guidelines and policies can be subject to an investigation and may lead to termination of the supplier relationship.

Reporting of concerns

External parties can alert concerns using the contact information published on our website.

Internally, employees and consultants are encouraged to speak up about negative conditions in the workplace and seek advice if they are in doubt. They can report a concern to their line manager, a representative for the management team or safety delegates and AMU. If anyone see the need to report anonymously, we have established a whistleblowing channel where all reports are managed confidentially

Due Diligence Assessments

Our own Business

Soiltech has implemented a range of measures and systems to ensure that the company maintains high standards for human rights and decent working conditions. These include:

ISO 45001 Certification: Soiltech is certified by DNV according to ISO 45001, a leading international standard for occupational health and safety management systems. This demonstrates the Company's commitment to improving employee safety, reducing workplace risks, and creating better, safer working conditions.

Safety Representatives and Working Environment Committee (AMU): The Company has appointed safety representatives and established a working environment committee that actively addresses workplace health issues, ensures employee health and safety, and promotes collaboration between management and staff.

Occupational Health Services: Access to occupational health services ensures that all employees receive necessary health follow-up and preventive health care, which helps to maintain and improve health standards at the workplace.

Anonymous Reporting Channel: An anonymous reporting channel enables employees to report irregularities or concerns without fear of retaliation. This is an essential tool for maintaining an ethical workplace where the employees' rights are respected.

Incident Reporting System: The system for reporting observations, discrepancies, and improvements is central to continuously improving work processes and safety conditions. This system also helps identify and manage potential risks before becoming serious.

Annual HSEQ KPIs: Soiltech uses key performance indicators (KPIs) to measure and analyse important areas such as sick-leave (short and long-term), injuries, oil-in-water ratios for sea discharges, and customer satisfaction. These indicators are crucial for evaluating the Company's performance and effectivity in addressing human rights and working conditions.

Overall, these measures demonstrate Soiltech’s commitment to fulfilling requirements concerning human rights and decent working conditions. The Company actively takes steps to ensure that all employees work under fair and safe conditions, in line with international standards and best practices.

Suppliers

Soiltech's approach to assessing and approving suppliers involves a structured and detailed process, ensuring suppliers meet stringent criteria in various areas such as quality, health and safety, and environmental impact, along with adherence to human rights standards. Here's a summary of how Soiltech performs this assessment:

Registration and Categorization: Suppliers are initially registered in the Customer Relationship Management (CRM) system and categorized based on potential impact and risk level into Critical (A), Key (B), or Other suppliers (C). This categorization helps in determining the extent and frequency of evaluations and audits required.

Risk Assessment: Soiltech conducts an initial risk assessment focusing on geographical risks (based on labor conditions and other country specific risks), industry risks (linked to standardized NACE codes), and social risks (a composite measure of geographical and industry risks). This assessment helps in identifying areas with potential human rights violations and poor working conditions.

Supplier Approval: Before being fully approved, A & B suppliers must fill out a detailed Supplier Questionnaire covering various aspects of their operations, from technical capabilities to adherence to Soiltech’s code of conduct which includes criteria like human rights, health and safety, and environmental practices. Suppliers are evaluated and need to be approved in all three areas (Quality, Health & Safety, and Environment) and must accept Soiltech’s code of conduct.

Evaluation and Auditing: Depending on their categorization, suppliers undergo periodic evaluations and audits. Critical and key suppliers face more frequent and detailed assessments. The evaluation process includes various performance metrics such as delivery reliability, product quality, financial stability, compliance with health and safety standards, and environmental impact.

Ranking: Based on the evaluation, suppliers are ranked and may be approved, conditionally approved (requiring follow-up reviews or specific improvements) or rejected. High-level oversight, such as from the VP Operations, is required for suppliers who do not meet the minimum standards initially. This process not only ensures that Soiltech's suppliers comply with current standards but also supports the Company's commitment to sustainable and ethical operations.

Documentation and Continuous Monitoring: All evaluations, approvals, and relevant supplier documentation are recorded in the CRM. Any changes to their status or performance could cause reevaluation or additional audits.

Identified risks and prioritization

When considering potential breaches of the Transparency Act, it is observed that the risk of noncompliance is higher among suppliers operating internationally in regions where the transparency legislation does not apply. Consequently, our strategic focus is to continue to work closely with our suppliers abroad to mitigate these risks. This proactive approach involves enhancing compliance and oversight measures to ensure that our suppliers adhere to the ethical and legal standards expected by Soiltech. This alignment is crucial in maintaining our commitment to transparency and ethical business practices across our supply chain.

Implemented Measures

Description of measures implemented

Below is a list of all implemented measures

2022 Measures

1 Developed our supplier Questionnaire and incorporated Supplier’s Code of conduct. This includes, for example, acting on equal terms in competitive markets, security regarding the products and services provided by the supplier, compliance with labour market rules, human rights, anti-child labour, discrimination, conflict of interest, bribes and gifts, and international standards.

2023 Measures

2 Continuous monitoring of actual and potential risks of negative impact on human rights and decent working condition in our supply chain.

3 Working pro-actively on identifying meaningful KPIs related to supplier human rights risk identification

4 Providing training and awareness to the organisation on human rights topics. Awareness has been communicated via HSE monthly topic and the yearly professional exchange days held in Q1 2024.

5 Collaborate and work together with other small and medium businesses within our industry on the Transparency Act, to be able share and learn from each other.

6 Collaborate with software developers on tools to perform due diligence. Collaboration started with www.compera.no, for the development of a software tool to report sustainability through our value chain (Scope 3).

2024 Measures

7 Added social risk as a method to better evaluate the suppliers’ risk related to human right violations. To establish a baseline, we use risk factors related to geography and industry, using a combination of these factors to assess social risk.

Results and Future Plans

Results of implemented measures

Based on our risk analysis and due diligence, we have not identified any actual adverse impact on fundamental human rights and decent working conditions linked to our operations.

Plan for Continuous Improvement

We will continue to focus on the following key areas:

• Policy development

• Due diligence processes

• Supplier management

• Employee training and engagement

• Monitoring and reporting

• Community and stakeholder engagement

• Grievance mechanisms

By focus on these areas, Soiltech will continue our commitment to promote and safeguard human rights and decent work conditions throughout our operations and supply chain.

THE BOARD OF DIRECTORS

Sandnes, 11. June 2024

GUNNAR WINTER ELIASSEN EIRIK FLATEBØ DR. CARSTEN BRUECKNER

Chairman Director Director

Electronically signed

Electronically signed Electronically signed

OLAF SKRIVERVIK

GLENN ÅSLAND

JAN ERIK TVETERASS

Director Director CEO Soiltech AS

Electronically signed

Electronically signed Electronically signed

TOVE VESTLIE

CEO Sorbwater Technology AS & Soiltech Offshore services AS Electronically signed