Transparency on Responsible Supplier Conduct
The Freedom of Information Act (FOIA) applies from July 1st, 2022, and aims to promote businesses' respect for human rights and decent working conditions in the production of goods and delivery of services. The law also ensures public access to information within these areas.
At Sørby Utleie AS, we uphold human rights throughout our business.
We establish and maintain frameworks, including governance documents, risk assessments, systems for identifying and classifying risks, and due diligence assessments.
We implement due diligence assessments based on five priority United Nations Sustainable Development Goals (SDGs) that we believe we can influence the most. We conduct risk assessments and due diligence assessments of suppliers and internal conditions.
Assessment of Material Risks When assessing material risks, we consider parameters such as the size of annual deliveries, geography, industry, and negative incidents.
Our due diligence assessments are conducted based on risk-based prioritization. This means that the scope of investigation and follow-up is tailored to the supplier's assessed risk. We also conduct a similar analysis of internal conditions, where work on activity and reporting obligations is also central. In case of any breaches, measures to eliminate or reduce risk will be implemented. Improvement areas where we have influence will also be followed up, and we will report on the status and developments in relevant areas.
Reporting on Due Diligence Assessments Information about our work with the Freedom of Information Act will be updated here, on our website. We will prepare an annual report that will be available to the public.
Supplier Code of Conduct
A reputation for high business ethics standards is essential to our commercial success. At Sørby utleie AS, our business practice is as important as the results we achieve, and we expect our suppliers to share the attitude of relationships characterized by openness and trust. Our ethical guidelines set our standards and commitments of ethical nature that we believe will contribute to the company's success through:
To help us manage risks To protect our reputation and maintain long-term interests To develop a coherent practice in this area To meet the expectations of our owners In order to fulfill our ethical guidelines, we also expect you as a supplier to Sørby utleie AS to support our continuous efforts to conduct our business in a responsible manner, based on the duty to respect human rights, workers' rights, protect health, safety and the environment, prevent corruption, and generally apply sound business practices.
In this endeavor, we expect all of our suppliers to follow these ethical guidelines (hereinafter referred to as the "CoC"). This CoC is based on the Universal Declaration of Human Rights, ILO conventions, the Public Access to Information Act, and the UN Global Compact's 10 principles for sustainable development.
In addition to other quality elements and commercial aspects, Sørby utleie will consider compliance with this CoC when selecting suppliers. The CoC outlines a minimum standard of behavior. We expect our suppliers always to exercise good judgment, caution, and care by following both the requirements and intentions of the CoC. Furthermore, we expect our suppliers to be transparent and have an open dialogue about the challenges they face as part of their business.
When this CoC is communicated to a specific supplier, it shall be deemed a contractual document and an integrated part of any contract entered into between Sørby utleie and the relevant supplier.
In addition to compliance with this CoC, Sørby utleie expects all suppliers to comply with applicable national and international laws and regulations.
1. Public Access to Information Act
The Public Access to Information Act promotes companies' respect for fundamental human rights and decent working conditions in connection with the production of goods and the delivery of goods and services, as well as ensuring the public access to information about how businesses handle negative consequences for fundamental human rights and decent working conditions.
Suppliers are expected to follow the OECD Guidelines for Multinational Enterprises and to carry out due diligence in accordance with the OECD Due Diligence Guidance for Responsible Business Conduct, ensuring compliance with the Public Access to Information Act. Where necessary, due diligence reports shall be submitted.
Furthermore, all suppliers have a duty to provide information, where requested by Sørby utleie, about risks and how any negative impacts are handled.
2. Supplier Relations
Sørby utleie expects its suppliers to extend a principle of fair and honest trade to all with whom they do business, including employees, subcontractors, and other parties. The supplier shall comply with applicable laws regarding bribery, corruption, fraud, and other prohibited business practices. The supplier shall not offer, promise, or give inappropriate benefits or incentives to customers, suppliers, or government officials.
The supplier shall not, directly or indirectly, use forced or child labor, nor shall they discriminate against employees or use physical punishment or other forms of mental or physical coercion. The supplier shall promote safe and healthy working conditions and shall respect the right of employees to freedom of association and collective bargaining.
We expect our suppliers to ensure that their subcontractors and suppliers comply with the same ethical guidelines as those
3. Legal Compliance
Suppliers must comply with their respective national laws and regulations and international conventions on social and labor conditions, child labor, and environmental protection. When a relevant national law and one of the standards defined in these ethical guidelines address the same issue, the stricter of the two should be applied.
If any conflict is found between a relevant national law and one of the standards defined in these ethical guidelines, the supplier must inform Sørby utleie AS and provide relevant details about the deviation.
4. Child Labor
Sørby utleie AS deeply respects children's right to development and education. Suppliers shall take all necessary measures to ensure that there is no child labor at their own production or operating sites or at their subcontractors' production or operating sites. Child labor is defined as work performed by children under the age of 15 or younger than the age to complete compulsory education in the local area. However, the legally mandated minimum age for employment must never be violated. Young workers (15-18 years old) shall not be employed in work that endangers their health or safety, including night shifts.
The supplier shall have a confirmed copy of an official document showing the worker's date of birth. In countries where this is not possible, the factory shall implement an appropriate method to assess the age of its workers.
5. Forced labor
Forced labor or involuntary labor is not tolerated by Sørby utleie AS. This includes labor under duress or other forms of work performed against one's will or choice. There shall be no deduction of wages as a result of fines or penalties imposed during the implementation of disciplinary action, unless it is with reference to a collective agreement or allowed by law.
Workers shall not be required to submit a deposit, original identity papers, or work permits to the employer or any other body on behalf of the employer.
6. Working hours and wages
Sørby utleie AS acknowledges the need for a healthy balance between work and leisure time for all employees. Unless national law provides otherwise, working hours and wages should be in accordance with ILO Conventions Nos. 1, 14, 26, and 131.
7. Health, safety, and working conditions
Suppliers must ensure that they or their producers or subcontractors comply with all local laws, directives, and regulations relating to health and safety in the workplace or in any other location where production or work is carried out, and that they implement any changes to these laws, directives, or regulations.
Sørby utleie AS expects suppliers to provide safe and adequate work facilities for all of their employees. Specifically, and as a minimum:
- Access to clean sanitary facilities, drinking water, and fire escape routes
- Provision of meal breaks
- Adequate ventilation and temperature control
Workers shall receive regular and documented health and safety training, and such training shall be repeated for new employees.
8. Disciplinary Practice
Sørby utleie AS expects its suppliers to treat each of their workers with respect and dignity. No employee shall be subjected to physical, sexual, psychological or verbal harassment or abuse.
9. Prohibition of Discrimination
Sørby utleie AS expects its suppliers to treat everyone fairly when selecting and treating their employees and shall not treat any person less favourably on the grounds of their race, colour, religion, sexual orientation, age, gender, nationality, disability, marital or health status, trade union membership, political affiliation, or ethnic origin.
10. Freedom of Association and the Right to Collective Bargaining
Sørby utleie AS respects the employees' right to organize and bargain collectively. This means that suppliers must also recognize their employees' freedom to choose whether to join or establish an organization, including labor organizations.
Employee representatives shall not be discriminated against and shall have access to perform their representative functions in the workplace.
If the right to join or form trade unions is restricted by law, the employer shall facilitate and under no circumstances hinder parallel means for independent and free association and negotiations.
11. Recognized Employment Conditions and Employment Contracts
All employees shall have the right to an employment contract. As far as possible, work performed shall be based on a recognized employment relationship that protects the employee's rights and social security as established through national law and practice.
Obligations towards employees shall not be avoided by the use of employment contracts, subcontractors, or other labor arrangements.
All employees shall be provided with written and understandable information about their employment relationship with regard to pay before they enter employment, and about the information on their pay for the relevant pay period each time they are paid.
12. Protection of the environment
All suppliers of Sørby utleie AS shall strive to operate their businesses in a way that minimizes the negative impact on the environment as much as possible. This applies to the entire value chain from raw material production to sale to the consumer.
Suppliers must comply with the obligations and guidelines set by local and national law. In addition, suppliers must work to reduce waste and emissions to air, soil, and water, handle chemicals in an environmentally safe manner, handle, store, and dispose of hazardous waste in an environmentally safe manner, and contribute to the recycling and reuse of materials and products.
13. Consideration for marginalized populations
The production and extraction of raw materials for production shall not contribute to the destruction of resources and livelihoods for marginalized populations, for example, by claiming large tracts of land or other natural resources on which these populations depend.
The supplier shall take positive measures to meet the requirements of this CoC and incorporate the principles of the CoC into their business. The supplier must also take measures to ensure that these requirements are met by their subcontractors.
The supplier shall periodically and systematically review how their own business complies with the requirements of this CoC.
The supplier shall have in place complaint systems that enable anonymous reporting of unfair treatment and/or other complaints.
The supplier shall obtain Sørby utleie AS's consent before production or parts of production are outsourced to a subcontractor.
When the supplier uses subcontractors in connection with a delivery to Sørby Utleie AS, all links shall be traceable regarding the production site. The supplier shall, upon request, provide information about all subcontractors and their production sites.
Sørby utleie AS expects suppliers to actively conduct self-evaluations and monitor their management processes to ensure compliance with these ethical guidelines. In addition, Sørby utleie AS reserves the right to carry out audits to verify compliance with these ethical guidelines.
Sørby utleie AS reserves the right for us, or representatives appointed by Sørby utleie AS, to have free access to the production facility, with or without prior notice. Such representatives must document a signed approval from Sørby utleie AS.
16. Breach of Guidelines
In cases where Sørby utleie AS finds that the supplier is breaching these ethical guidelines, we will strive to find a solution where the supplier will operate in compliance with the guidelines within an agreed-upon time period. If the supplier does not improve on the current issue and show willingness to respect ethical guidelines after this agreed-upon period, we will terminate the partnership with the supplier.
17. Development of Ethical Guidelines
Sørby utleie AS expects improvement measures to be implemented by the suppliers when necessary. We will review these ethical guidelines regularly and introduce revisions where necessary. This includes continuous evaluation and, if applicable, improvement of our own policy and procurement practices to make it easier for suppliers and subcontractors to comply with these ethical guidelines.
Suppliers who fill out our supplier approval form declare that as a supplier, they have read and understood these ethical guidelines and that they will fulfill the requirements specified. In case of non-compliance with these ethical guidelines, we will inform company about it and submit a plan on how we can achieve compliance.
They further agree to inform their subcontractors about these ethical guidelines and do everything they can to ensure that they also comply with the specified requirements.