Transparancy Act

The Transparency Act is legislation aimed at enhancing transparency and accountability in
businesses, ensuring that both public and private organizations practice openness and take
responsibility for their actions and consequences.
This statement has been prepared in accordance with Section 5 of the Transparency Act and aims to
provide the public with insight into Fosstech AS (Fosstech)'s key findings from due diligence
assessments and the measures taken to address risks and negative impacts associated with our
operations.
Fosstech, as a responsible company, upholds internationally recognized human rights throughout our
operations and supply chain. We conduct our business in a manner consistent with the UN Guiding
Principles on Business and Human Rights and the ten principles of the UN Global Compact.
Fosstech AS
Fosstech is part of the Bertel O. Steen Industri (BOSI) group, which consists of 17 companies across
the Nordic region. BOSI has prepared a group-level Transparency Act report that provides an overall
description of the group’s efforts related to human rights and decent working conditions. This report
is available on the group’s website: www.bosindustri.no/transparencyact.​

Fosstech is organized at the following overarching levels:

1. Board: Responsible for the company's strategic governance and operations.
2. CEO: Accountable for day-to-day operations and implementation of company policies.
3. Departments: Organized by functions and responsibilities to ensure efficient operations and compliance with policies.

Fosstech is engaged in the development, production, and sale of cables, connectors, and
electromechanical equipment for use underwater and in other demanding environments. We serve
customers and partners both domestically and internationally, and we are committed to complying
with applicable laws, regulations, and industry standards in the countries where we operate.

Human Rights and Decent Working Conditions
Fosstech is strongly committed to respecting human rights and ensuring decent working conditions.
We continuously conduct assessments and reviews of our supply chain. We have adopted a riskbased
approach, considering both the size and the country of origin of our suppliers as key criteria.
Additionally, we have established effective whistleblowing channels and grievance mechanisms to
identify and address negative consequences.
Our internal policies and procedures, which underpin our work on human rights and labour
conditions, provide guidance to all employees in the company. We emphasize principles such as
equality, diversity, fair working conditions, and health and safety.

This includes:

• Ethical guidelines: Clear guidelines promoting human rights and decent working conditions.
• Training and awareness: Employee training on their responsibilities and the importance of human rights and decent working conditions.
• Supplier management: Requirements for our suppliers to adhere to human rights and decent working conditions.

Supplier chain management:

1. The Supplier Conduct Principles are available on our website.
2. We are working to ensure that all regular suppliers receive Fosstech’s Supplier Conduct Principles, which they must confirm compliance with by signing. In addition, they are required to conduct a self-assessment in relation to these principles.
3. When entering into contracts with new suppliers, we aim to familiarize ourselves with the supplier and understand their quality system requirements.
4. For suppliers deemed significant to Fosstech, we conduct physical internal audits at their premises. These audits involve visits and conversations, focusing on areas such as health and safety, workplace conditions, worker participation, training, and working hours.

• We conduct audits of selected suppliers annually, using a risk-based approach that considers factors such as:

                i. the supplier's size relative to Fosstech,
                ii. the country where the subcontractor is based and
                iii. the supplier's reputation in the market.

Actual Negative Impacts and Risk Assessments
Through our due diligence assessments, Fosstech has not identified any actual negative impacts or
significant risks associated with our operations. Fosstech works with several subcontractors in
various countries, including China. Trade with China may involve an elevated risk of links to forced
labour or other human rights violations. However, to date, our assessments have not uncovered any
breaches of human rights or violations of decent working conditions within our supply chain.

Measures and Results
We acknowledge that the work on human rights and decent working conditions is an ongoing
process, and all employees at Fosstech are committed to improving measures and practices based on
experiences and changes in the environment. We have a particular responsibility to monitor and
follow up with suppliers located in higher-risk countries. If we identify actual negative consequences,
we will take action to stop such impacts and mitigate significant risks. Furthermore, we will regularly
evaluate the effectiveness of these measures to ensure continuous improvement and the
achievement of desired outcomes.
We continuously monitor our supply chain and conduct detailed assessments for all new suppliers.

Conclusion
At Fosstech, we are committed to conducting our business in a responsible and transparent manner.
Through this disclosure, we have provided initial insights into our organization and our efforts
regarding due diligence. We remain dedicated to managing and enhancing our practices to achieve
sustainable results and make a positive contribution to society.

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