The Transparency Act
We Energy - explanation of the due diligence assessment in accordance with the Transparency Act.
Reporting period: 24.1 – 31.12.2023
We Energy is a supplier of products, services, and solutions within electrical engineering, automation, instrumentation, fiber optics, telecommunications, and fire and gas systems. The company was founded on January 24, 2023, and commenced operations in March of the same year. We have offices and a workshop at Forus in Stavanger and conduct our business in Norway.
Routines and internal guidelines that the company has for working with the Transparency Act
Due diligence assessments in relation to the Transparency Act are laid down in the company's management and quality system and are integrated into routines and processes according to which the business is run and managed. Respect for basic human rights and decent working conditions is anchored in the company's ethical guidelines and policy on respect for human rights. A procedure has been drawn up for the onboarding of new employees and hires to ensure that everyone is introduced to and receives training in the company's quality management system with associated guidelines and procedures.
We Energy wants to ensure a responsible supply chain where employee and human rights are safeguarded and respected. The company's procurement procedure stipulates that purchases can only be made from approved suppliers. HSE and human rights are one of the criteria in the evaluation where suppliers must confirm by signing a separate form that they have satisfactory routines.
We Energy has established its own whistle-blowing procedure, which gives employees and hired workers both the right and duty to report objectionable working conditions and in the event of suspicion of non- or insufficient compliance and respect for basic human rights.
Actually uncovered negative consequences in the period
The company has focused on developing procedures and routines for management and business management and is not covered by the rules in the Transparency Act in the first year of operation. They have nevertheless chosen to start work on the Transparency Act and to prepare a limited report. The company will be fully covered by the rules in the Transparency Act from and including the financial year 2024 (1.1.2024-31.12.2024) and is obliged to publish an account for this period by 30.06.2025.
In the current period, no negative consequences for human rights or decent working conditions have been uncovered within the company.
A preliminary risk assessment of suppliers has been carried out. The mapping has been based on size, industry and type of goods/services the supplier delivers. Based on this survey, 17 (10.4%) of a total of 163 suppliers come out with a high risk. For 35 (21.5%) of the suppliers, the risk is considered low, while for the remaining 111 (68.1%), the risk is assessed as medium.
Furthermore, a limited review has been carried out of two significant suppliers where the risk has been assessed as high. The review with the companies was carried out as a Team meeting and no negative consequences for human rights or decent working conditions were uncovered.
Risk of negative consequences
WE Energy complies with a number of requirements and regulations. The company is, among other things, bound by the collective agreement and applicable tariffs. This together with internal procedures and guidelines for health, environment and safety etc. means that the risk of negative consequences on basic human rights and decent working conditions for its own employees is considered low. Any negative consequences will be followed up through a procedure for handling deviations, corrective and preventive measures.
In the work to identify risks for possible negative consequences at suppliers, we have so far relied on secondary sources such as looking at selected suppliers' own accounts for due diligence assessments. This can provide a basis for further investigations and measures.
Guidelines and routines for fulfilling duties under the Transparency Act
The general manager has overall responsibility for the routine and must ensure that due diligence assessments are carried out in accordance with the law.
The company must carry out due diligence assessments in line with OECD guidelines. By due diligence assessments is meant to
1) Anchor accountability in the company's guidelines.
2) Map and assess actual and potential negative consequences for basic human rights and decent working conditions that the business has either caused or contributed to, or that are directly linked to the business, products or services through supply chains or business partners.
3) Implement suitable measures to stop, prevent or limit negative consequences based on the company's priorities and assessments.
4) Monitor the implementation and results of measures.
5) Communicate with affected stakeholders and rights holders about how negative consequences have been handled.
6) Ensure or collaborate on recovery and compensation where this is required.
Due diligence assessments must be carried out according to the following work methodology:
- Working meetings must be held to carry out due diligence assessments at least once a year.
- In the working meetings, risk mapping is carried out relating to our purchases of goods and services, based on information obtained from our suppliers
- We will seek available information on supply chains and mapping of risks from any industry associations and from other actors and other sources that are available.
- Based on risk mapping and prioritization/materiality assessment, areas for improvement and measures must be prioritized if deemed necessary
- The result of risk mapping is documented in a written report. The written report from our due diligence assessments is made readily available on our company's website in line with the Transparency Act.
- In line with the Transparency Act, we provide information in the annual report about where the report is available and update and publish the report by 30 June each year.
