Transparancy Act
 Statement on due diligence assessment in Fosstech AS

In July 2022, the Norwegian Parliament enacted the Transparency Act to promote respect for fundamental human rights and labour conditions. 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 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 are currently implementing new requirements that establish a more holistic approach to human rights. The process of reviewing our entire supply chain began in 2023 and has continued through 2024. We have adopted a risk-based approach, considering both the size and the country of origin of our suppliers as key criteria. Additionally, we have established effective whisleblowing 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. All suppliers receive our Supply Code of Conduct, which they must confirm compliance with through signature.
2. Significant suppliers are required to provide self-assessments related to their evaluation of relevant quality standards and the Supply Code of Conduct.
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.
   1. 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.
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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. Our preliminary work has not revealed any violations of human rights or decent working conditions.

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. If we identify actual negative consequences, we will work to halt such consequences and mitigate significant risks. Furthermore, we will regularly evaluate the effectiveness of these measures to ensure continuous improvement and achieve desired outcomes.

We continuously monitor our supply chain and conduct detailed assessments for all new suppliers. 
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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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For questions regarding the Transparency Act, please contact our CFO or Quality Manager.

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