The Transparency Act
Applicable to: AVA of Norway AS, Nøstetorget 5, 5011 Bergen, Norway
Reporting Period: 01.01.2023 – 31.12.2023
Statement on Due Diligence Assessments 2023 (Published 2024)
The Transparency Act § 5a:
General description of the organization of the business, operational area, policies, and routines for handling actual and potential negative consequences for fundamental human rights and decent working conditions.
Organization
Our business is organized as a limited company, with a business address in Norway. Our company is part of the organized labor market and is affiliated with Virke.
Operational Area
AVA of Norway AS works with the development and sale of cleaning products. The company has activities in 26 countries and has established subsidiaries in Germany and England. AVA of Norway does not sell goods to Russia or Belarus.
Policies/Routines
AVA's focus is to deliver a new washing experience, designed to last. With this focus, we believe that we can actually influence and counter the trend we have seen over a long time, where products become cheaper and their lifespan decreases.
The work with the Transparency Act is not coordinated with other actors in the industry, and thus has been based on an interpretation of the legislation and advisory support has been utilized. The work largely aligns with the routines and policies already established in the company and is thus in its third year of routine and systematic work.
Our routines and policies regarding durability/sustainability, including routines under the Transparency Act, are anchored in the business system and in the board's work. A separate group (Risk Management Group) has been established for sustainability and due diligence assessments, sustainability analysis, and sustainability audits of AVA's suppliers and partners. The routines include the distribution of responsibilities and tasks within our business, mapping and assessing negative impacts/harm based on our operations, supply chains, and business relationships, collaborating on remediation and compensation where required, stopping/preventing negative impacts/harm, monitoring implementation and results, as well as communicating how the impact has been managed and handling information requests.
AVA has been working, and continues to work, with the UN Sustainable Development Goals, with a particular focus on Goal 8 and 12, where Target 12.5 is a significant part of the foundation for the company's existence: To significantly reduce waste by 2030 through prevention, reduction, material recycling, and reuse.
Key Suppliers
When updating or entering into new agreements, requirements of the Transparency Act are imposed by incorporating them into, or having suppliers declare that they comply with the act. Assessments are carried out four times a year and reported to the management team and board once a year. If changes/extended clarifications are needed, this is reported continuously. Throughout 2023, work and meetings have been conducted according to plan.
Minor/Occasional Suppliers
Here, size, risk, and utility of an assessment are considered, and in countries with greater risk, this is monitored more closely with higher requirements. Focus remains on larger suppliers and suppliers in risk areas.
The Transparency Act § 5b:
Information about actual negative consequences and significant risks for negative consequences that the business has uncovered through its due diligence assessments.
The procedure is revised annually. Last revision date: May 9, 2023.
In the fall of 2023, we updated our risk assessment where the following stakeholder groups were identified: Our own employees, local communities of our own businesses, employees in our supply chain and suppliers' local communities, customers, end-users, and business partners. This remains unchanged from 2022. Various sources of information have been used and are used continuously to map possible and actual negative impacts on people in our value chain. Among other things, we conduct dialogue meetings with some of the stakeholder groups, industry networks, etc. We also use internal and external surveys, reports, research, media, online searches, and internationally recognized indices and assessments carried out by recognized organizations. The Risk Assessment Group has worked specifically on issues at least every other month throughout 2023. A significant change in 2023 is that inventory operations are now only carried out by external parties.
We have mapped various risks and made prioritizations based on the following factors: Risk of high severity (i.e., a high risk of serious violations of human rights and labor rights), risk of many people being affected, degree of irreparability if the damage occurs, and the likelihood that the negative impact will actually occur. Additionally, in assessing suppliers, we have also allowed the scope of the supplier agreement and how significant a customer we are for the supplier to partially factor in.
Based on this, we have the following prioritized areas we are working on:
- Safe workplace for employees.
- Decent work in the supply chain among goods and service providers,
- Safe conditions in our own work environments.
We have worked on several of these areas for a long time and do not necessarily assess the risk of negative
impact as equally significant for all areas, precisely because risk-reducing measures have been implemented over a long time. Nevertheless, this work must continue with high priority so that we avoid accidents in the future.
Here are our ongoing and prioritized measures:
- Risk-reducing measures related to health, safety, and environment (HSE) for employees in our own production (such as training, routines, procurement of equipment, etc.).
- Further mapping of working conditions through direct dialogue with selected suppliers as a basis for developing an action plan as well as the implementation of already defined risk-reducing measures.
- Inspections and visits to selected suppliers to map further and potentially develop and implement measures.
- Dialogue with local stakeholders (such as neighbors, municipalities, etc.) to map risks and possible measures and to continue existing measures.
The effectiveness of all measures will be assessed continuously within the Risk Management Group.
The Transparency Act § 5c:
Information about any measures the business has implemented or plans to implement to stop actual negative consequences or limit significant risks for negative consequences, and the outcome or expected results of these measures.
Description
We use a dedicated working group to systematically work to stop actual negative consequences and limit significant risks for negative consequences. The measures are evaluated and corrected continuously throughout the year. The group reports to the management team and annually to the board. The group has the mandate to stop the use of suppliers that may appear risky, or suspend use until further clarification is made.
The procedure is revised annually. Last revision date: May 9, 2023.
In the fall of 2023, we updated our risk assessment where the following stakeholder groups were identified: Our own employees, local communities of our businesses, employees in our supply chain and suppliers' local communities, customers, end-users, and business partners.
Various sources of information have been used and are continuously used to map possible and actual negative impacts on people in our value chain. The Risk Management Group works systematically throughout the year and is developing good and established routines to ensure quality. The group also utilizes internal and external surveys, reports, research, media, online searches, and internationally recognized indices and assessments carried out by recognized organizations.
When prioritizing the various risks that were mapped, several factors were weighted: Risk of high severity (i.e., a high risk of serious violations of human rights and labor rights), risk of many people being affected, degree of irreparability if the damage occurs, and the likelihood that the negative impact will actually occur. Additionally, in evaluating suppliers, we have also considered the scope of the supplier agreement and how significant a customer we are for the supplier.
Based on this, we have the following prioritized areas we are working on:
- Safe workplace for employees in our own production
- Decent work in the supply chain among goods and service providers
- Safe conditions in our own neighborhoods
We have worked on several of these areas for a long time and do not necessarily assess the risk of negative impact as equally significant for all areas, precisely because risk-reducing measures have been implemented over a long time. Nonetheless, this work must continue with high priority to prevent accidents in the future.
Here are our ongoing and prioritized measures:
- Risk-reducing measures related to health, safety, and environment (HSE) for employees in our own production (such as training, routines, procurement of equipment, etc.)
- Further mapping of working conditions through direct dialogue with selected suppliers as a basis for developing an action plan as well as the implementation of already defined risk-reducing measures.
- Inspections and visits to selected suppliers for further mapping and potential development and implementation of measures.
- Dialogue with local stakeholders (such as neighbors, municipalities, etc.) to map risks and possible measures as well as to continue existing measures.
The effectiveness of all measures will be evaluated in the spring of 2024.
Contact Information
For questions or requests for more information, you can email Eirik@avaofnorway.com with a copy to post@avaofnorway.com.
For signed PDF: 19912779996050 (avaofnorway.com)