RSA AND THE TRANSPARENCY ACT

POLICIES / PROCEDURES

RSA shall comply with its obligations under the Transparency Act and operate responsibly with regard to human rights and decent working conditions, in accordance with an internal procedure for compliance with obligations under the Transparency Act. The internal procedure is anchored in the management and made known to everyone in the company, and thus functions both as an information letter to the company and as a procedure for compliance with the obligations under the Transparency Act.

The procedure provides general information about the Transparency Act and its scope, the company's work with the Transparency Act and whistleblowing channels. The procedure includes allocation of responsibilities and tasks, mapping and assessment of negative impact/damage based on own operations, supply chains and business relationships, cooperation on
and compensation where required, stopping/preventing negative impact/damage, monitoring of implementation and results, as well as communication of how the impact has been handled and processing of information requirements.

Furthermore, the procedure provides information about the notification channel that will help to identify any negative consequences and significant risks, and that information requests should be directed to aapenhetsloven@rsa.no

For suppliers, RSA has developed guidelines and contractual requirements to clarify expectations and hold them accountable. The provisions are intended to help ensure that the goods and services delivered under the contract are produced under conditions that comply with basic human rights and decent working conditions.

The provisions ensure access to suppliers' due diligence assessments where they are covered by the Transparency Act, and information about suppliers' purchases of goods and supply chains where they are not covered by the Act. The contractual requirements to be used must be assessed specifically from supplier to supplier based on a risk assessment.

RSA shall request how suppliers work with the topic in relation to their subcontractors where it is considered appropriate and feasible, and preferably in detail if necessary. Where it is considered necessary, appropriate and feasible based on the risk assessments, self-reporting shall be used.

Relevant questions may be related to the ten principles of the UN Global Compact1, the supplier's code of conduct, mapping of suppliers and production countries, self-assessment of risk in countries from which they purchase, management systems and certifications, workers' rights, etc.

NEGATIVE CONSEQUENCES AND RISKS

Work has been initiated to map and risk assess suppliers and
business partners, in accordance with the requirements of the Transparency Act. Due to the fact that we are in the early mapping phase, we do not currently have structured information about the supply chains.

RSA's supply chain often consists of several links with subcontractors. This requires prioritization in the due diligence assessments. Mapping is prioritized based on where there is considered to be the highest risk of negative impacts on human rights and decent working conditions based on geography and product, as well as criteria such as which suppliers are interacted with the most, the size of purchases and where RSA considers that they will have the greatest influence. Deliveries within the risk groups will be subject to a stricter regime for documentation and control. 

Our purpose is that through due diligence we will seek to identify, mitigate and avoid potential and actual negative impacts with business partners and in our supply chain. The work of mapping, identifying and managing impacts on fundamental human rights and decent working conditions is a continuous process.

ACTION

RSA has anchored accountability with regard to compliance with obligations under the Transparency Act in the company through a board resolution and internal guidelines/procedures. The internal policy/procedure has been made known to everyone in the company. Furthermore, the procedure provides information about the whistleblowing channel that will help to uncover any negative consequences. For suppliers where appropriate, RSA implements contractual requirements related to the Transparency Act, such as contractual requirements that ensure access to suppliers' due diligence assessments where they are covered by the Transparency Act, and information about suppliers' purchases of goods and supply chains where they are not covered by the Act.

RSA shall request how suppliers work with the topic in relation to their subcontractors where it is considered appropriate and feasible, and preferably in detail if necessary. Where it is considered necessary, appropriate and feasible based on the risk assessments, self-reporting shall be used. RSA follows up nonconformities by creating an improvement proposal/action plan for the supplier, or requires the supplier to submit this themselves, and follows these up afterwards. The main goal of the measures is to create lasting change that benefits workers and the environment.

Questions and inquiries can be directed to aapenhetsloven@rsa.no

The report in its entirety can be read here

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