Norwegian Transparency Act

2024 STATEMENT ON DUE DILIGENCE ASSESSMENTS PURSUANT TO THE NORWEGIAN TRANSPARENCY ACT

FOR EKER GROUP AS

Introduction

The purpose of this document is to describe how Eker Group AS (hereinafter “Eker Group” or the “Company”) complies with its obligations under the Norwegian Act relating to enterprises’ transparency and work on fundamental human rights and decent working conditions (the “Transparency Act”). Should any material changes occur in Eker Group’s risk assessments during the year, updated information will be published on the Company’s website.

The main objective of the Transparency Act is to promote enterprises’ respect for fundamental human rights and decent working conditions in connection with the production of goods and the provision of services. In addition, the Act aims to ensure public access to information regarding how enterprises address negative impacts on fundamental human rights and decent working conditions.

This report covers the reporting period from January 1, 2024 to December 31, 2024. It also includes information on the Company’s due diligence activities during 2024, as well as an overview of planned initiatives for 2025.

The following sections describe the Company’s structure, organization, business activities, policies, and procedures.

Overview of the Company’s Structure, Organization, Business Activities, Policies, and Procedures

Structure, Organization, and Business Activities

Eker Group is the parent company of a corporate group whose purpose is to provide services within administration and IT; leasing; purchase and sale of shares of all kinds; development of concepts, products, and companies; purchase and sale of real estate; as well as participation in other related business activities.

The Eker Group is a Norwegian limited liability company and a leading player within industrial design, healthcare, technology, and real estate.

The business is built on a solid foundation of experience and expertise, with approximately 50 dedicated employees across the Group working daily to ensure that customer needs are met with the highest levels of efficiency and security.

Only Eker Group AS is subject to the Transparency Act. Other group companies are therefore not described in further detail in this statement.

Policies and Procedures

Introduction

To ensure compliance with the Transparency Act, the Board of Directors has adopted policies governing responsible business conduct and compliance with the Act.

The Chief Executive Officer has overall responsibility for ensuring that the Company’s plan for conducting due diligence assessments, as well as the establishment of procedures for handling information requests, is implemented and carried out in accordance with the Transparency Act.

In addition, a working group has been appointed with responsibility for conducting risk assessments. The working group holds meetings at least once a year to carry out due diligence assessments.

Own Business Operations

The Company aims to conduct its business in an ethical and sustainable manner, with a strong focus on its own employees. Continuous efforts are made to ensure compliance with the UN Guiding Principles on Business and Human Rights, with particular emphasis on Sustainable Development Goal No. 8 concerning decent work and economic growth.

Employees are considered the Company’s most important resource, and competitive terms and conditions are offered across all positions. All employees are provided with decent wages and working conditions. The Company is recognized for having a positive working environment and a healthy, sustainable work-life balance.

The Company has established health, safety, and environment (HSE) routines, including regular safety training and risk assessments, to ensure a safe working environment.
Security procedures and HSE efforts are updated regularly in accordance with applicable legislation and industry best practices.

Supply Chain and Business Partners

The Company actively works to promote respect for fundamental human rights and decent working conditions in line with the Transparency Act. Eker Group does not tolerate violations of human rights or decent working conditions in its supply chain or among its business partners.

All suppliers and business partners are expected to comply with applicable laws, rules, and regulations relevant to their operations, including—but not limited to—requirements relating to ethical business practices, human rights, employment and labor conditions, working environment, health, and safety.

Results of Due Diligence Assessments

Methodology: Due Diligence Assessments

Eker Group conducts risk assessments based on the Norwegian Agency for Public and Financial Management’s (DFØ) high-risk list, which provides information on products associated with elevated risk. In addition, information from industry associations and other relevant sources is used to identify and prioritize areas for improvement.

Based on identified risks and priorities, concrete measures are implemented to address, prevent, or mitigate negative impacts or harm. These measures may be directed at individual suppliers or carried out in cooperation with the industry more broadly. The effectiveness of these measures is reviewed in annual working group meetings to ensure continuous improvement and compliance with Eker Group’s obligations.

Any suspected deviations related to the Transparency Act are reported to the responsible subject-matter expert, who will initiate the necessary follow-up actions.

This approach ensures that the Company operates to high ethical standards, in compliance with applicable legislation, and underscores its commitment to transparency at all levels.

Key Findings: Own Operations

The Eker Group employs approximately 50 people. It is confirmed that relevant legislation relating to working environment, working hours, employment protection (the Working Environment Act), applicable regulations on health, safety, and environment (HSE), equality and non-discrimination (the Equality and Anti-Discrimination Act), as well as other relevant regulations, are complied with.

The risk associated with Eker Group’s own operations is considered low, as the Company primarily operates in Norway—a country generally regarded as low risk. In addition, the Company has internal policies and procedures for responsible business conduct and complies with Norwegian legislation.

In 2024, no negative impacts or significant risks of negative impacts on fundamental human rights or decent working conditions were identified in Eker Group’s own operations.

Key Findings: Suppliers and Business Partners

Through the due diligence assessments, it has been identified that there may, in principle, be a risk of negative impacts on fundamental human rights and decent working conditions within the supply chain.

This typically relates to higher risk at the raw material production level, including the production of tires, components, and batteries. Risk factors may include poor working conditions, low wages, and lack of trade union rights. However, Eker Group is assumed to have limited leverage over these suppliers.

Based on the risk assessments, the Company’s largest suppliers have been contacted for further mapping of their work related to fundamental human rights and decent working conditions.

To date, no negative impacts or significant risks of negative impacts on fundamental human rights or decent working conditions have been identified among business partners.
Eker Group will continue its efforts to influence business partners in their work related to the Transparency Act.

Measures and Results

In 2024, and continuing into 2025, Eker Group has focused on preventing negative impacts on fundamental human rights and decent working conditions.

If Eker Group has suppliers operating in areas classified by DFØ as high risk, and there is uncertainty regarding the supplier’s impact, the Company will request explanations and documentation. If a supplier cannot document satisfactory compliance with fundamental human rights and decent working conditions, Eker Group will assess whether this should have consequences for the contractual relationship.

It is noted that some suppliers may be difficult to replace. In such cases, Eker Group will work closely with the supplier to improve working conditions and ensure compliance with the Company’s ethical guidelines.

No additional specific measures were implemented during the reporting period, as no actual negative impacts or significant risks of negative impacts on fundamental human rights or decent working conditions were identified.

Remediation and Compensation

No matters requiring remediation or compensation were identified during the reporting year.

Eker Group AS
Bård Eker
Chair of the Board

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