Prudential assessments

The Transparency Act requires that due diligence assessments be carried out and reported on. Due diligence is a process implemented to identify, prevent, mitigate and document how we manage any negative impacts on fundamental human rights and decent work.

All of OneCo's companies have carried out due diligence assessments based on the Responsibility Compass, which fulfils the OECD's guidelines for due diligence. This is to ensure that we have a consistent and holistic approach to the work across the companies in the Group.

The Responsibility Compass provides an introduction to the requirements of the guidelines and measures our performance in the areas of human rights, including labour rights, working conditions, environment and climate, consumer rights, anti-corruption, tax and competition regulations. The compass provides a status on how we carry out our work on responsible business conduct. When completed, it provides a picture of the extent to which we comply with the requirements of the OECD Guidelines.

The Group's supply chain and business partners

OneCo's operations are organised into six different business areas with independent profit responsibility. In addition, there is collaboration across the business areas for major deliveries and projects.

Overall, the hiring of staff, use of subcontractors and purchase of materials is consistent across the business areas. The various business areas have an independent responsibility to ensure transparency and compliance in their supply chains. The same applies to the conclusion of agreements and follow-up of business partners that are further defined in an overall authority matrix across the Group.

Prudential assessments for our business areas

tecknologies   Telecom
tecknologies Ocean
tecknologies Electrical
tecknologies Infra
digitalisering-hvit Technologies
Sweden

Telecom

The Telecom business area consists of three separate companies, one of which is covered by the Norwegian Transparency Act: OneCo Networks. OneCo Networks has approximately 1,100 employees who provide design, planning, engineering, construction, installation, maintenance, fault correction, optimisation and documentation of fixed, mobile and wireless networks. Our customers include leading telecoms operators, system suppliers, power companies, network owners, municipalities and businesses. We have mapped our risk related to direct negative impacts on people, society and the environment through our operations and through our business relationships, even where we have not caused or contributed to the impacts ourselves.

risk

We map risks and are constantly working on measures to prevent and reduce the likelihood of violations. We have identified these risks as the most serious in relation to violations of the provisions of the Transparency Act:

  • Use of subcontractors in our deliveries
  • Greenhouse gas emissions directly related to our production

Use of subcontractors in our deliveries

When selecting and working with subcontractors, we have a responsibility to ensure that rogue and criminal actors do not enter our production chain. Our goal is to ensure that we are not involved in any form of social dumping or labour market crime, and that our subcontractors comply as a minimum with statutory HSE requirements, requirements for proper accounting, and ensure a safe working environment for each employee.

When selecting and working with subcontractors, we have a responsibility to ensure that rogue and criminal actors do not enter our production chain. Our goal is to ensure that we are not involved in any form of social dumping or labour market crime, and that our subcontractors comply as a minimum with statutory HSE requirements, requirements for proper accounting, and ensure a safe working environment for each employee.

Greenhouse gas emissions directly related to our production

Climate considerations through sustainable production are becoming increasingly important in our deliveries. Both in the form of requirements from our customers and as part of the way we want to develop the company further.

Service vans
Internally, we have a large fleet of service vehicles and the emissions from these affect our climate footprint, including the way we maintain and use the vehicles.

Excavation
Excavation accounts for a large part of our deliveries. This affects the climate footprint in terms of emissions, but also in terms of impact on fauna in the areas where we dig.

Solid waste
Waste from our production is a burden on the environment, and a lack of awareness of and compliance with our procedures for good waste management poses a risk that the burden will be unnecessarily high.

Identified breaches

Use of subcontractors in our deliveries
We have surveyed our subcontractors through internal audits and dialogue meetings and have uncovered several violations. In brief, these have been breaches related to non-compliance with safety routines, deficiencies in employment contracts, lack of VAT registration and undesirable company structure to avoid legal requirements.

We have also had a very serious fall accident among our subcontractors. This incident has been investigated and several measures have been implemented as a result.

Greenhouse gas emissions directly related to our production
We have not identified any specific breaches related to greenhouse gas emissions, but we are working continuously to ensure that we have good control and an overview of our environmental impact as far as possible.

Measures that prevent and reduce breaches:

Use of subcontractors in our deliveries
We work continuously with our processes to map our subcontractors before entering into an agreement. Specific procedures have been drawn up to ensure good quality in this process.

The Agreement on Responsible Contractor Behaviour (ABC Agreement) is a mandatory document that aims to establish a formal framework between OneCo and the subcontractor. Our subcontractors must also sign a self-declaration in which they confirm orderly working conditions in their own company. Among other things, we request staffing lists that include nationality, authorisations/certifications and the status of safety courses.

Key financial figures and other fact-based information are obtained from public sources. As far as possible, we want to use subcontractors who are registered in Startbank.

We seek to achieve a thorough onboarding where employees at our subcontractors complete electronic training in OneCo's HSE guidelines, our code of conduct and any professional courses.

Audit programmes are conducted for quality and HSE. In these, we check, among other things, that our subcontractors and our own organisation comply with applicable laws, regulations and guidelines, and that we have control over the working conditions of employees who perform work for or on behalf of OneCo.

We also conduct risk assessments in collaboration with our employee representatives.

Greenhouse gas emissions directly related to our production

For external parties who carry out work for us:
OneCo Networks is ISO 14001 certified, and subcontractors must apply the principles of ISO 14001 or another standard that is at least equivalent to the standard used by OneCo Networks. This means, among other things, that subcontractors must have thought through and described the environmental impacts that may arise in connection with the work for OneCo Networks.

Everyone who works for us is trained in our environmental goals, how we work to achieve them and what it means for their work situation. We seek to influence our business partners to improve their environmental performance.

A large part of our production includes excavation as part of the delivery. Subcontractors are almost exclusively used for this work. In collaboration with our customers and subcontractors, we want to use fossil-free excavators in this work. As of today, we have done this to a very modest extent.

To ensure OneCo Networks' environmental reporting, our subcontractors submit an annual report showing, among other things, dismantled EE waste from assignments for OneCo Networks, the number of batteries returned to an approved recycling company, fuel consumption on assignments for OneCo Networks and any environmental incidents such as acute pollution, damage to cultural heritage sites, damage to open land, etc.

Internal
We are working to phase in electric service vehicles on an ongoing basis. Good production planning can also lead to fewer kilometres driven. This reduces the environmental impact while making our production more efficient. We want to reduce the use of studded tyres where possible to reduce particulate matter - but without compromising safety.

In order to reduce emissions from motorised traffic in the countryside, we ensure good technical control of vehicles and familiarise ourselves with the rules that apply to the areas they will be travelling in.

Good waste management will also help to reduce our impact on the environment. Both in relation to actual production "on site" and internally in our administration where, among other things, reduced paper consumption is a desire.

Among other things, we have entered into agreements with several nationwide waste management contractors.

Electrical

OneCo Elektro has around 890 employees who deliver electrical engineering projects and assignments to customers in the public and private sectors. We deliver within the segments of construction and property, internal control, renewable energy and electrical power. We also deliver service assignments to our customers and partners in the same segments. A small part of our business is also traditional electrical work for private customers.

We have mapped our risk related to direct negative impacts on people, society and the environment through our operations and through our business relationships, even if we have not caused or contributed to the impacts ourselves.

risk

In relation to violations of the provisions of the Transparency Act, we have identified these risks as the most serious:

  • Use of hired personnel and subcontractors
  • Purchasing and control of products used in our production
  • Direct import of solar cells from China.
  • Training programmes
  • Imbalanced gender distribution internally
  • Greenhouse gas emissions directly related to our production
  • Focus on reporting deviations

Use of hired personnel and subcontractors

We have identified risks related to our use of hired labour and the use of staffing agencies.

OneCo Elektro uses hired labour to handle production peaks in our deliveries and in cases where we do not possess the right expertise ourselves. In most cases, we hire employees from competing organisations that are subject to the same collective bargaining conditions as ourselves. The risk of human rights violations is small for this part of our production.

In some cases, we also hire from staffing agencies that are not covered by collective agreements, and we have a major responsibility to ensure that employees in these agencies have satisfactory and legal working conditions, working environment and living conditions. We have had too little capacity to carry out a sufficient number of inspections, and this capacity in itself poses a risk that specific violations will not be uncovered.

In Oslo and Viken, the use of contractors will replace the use of hired labour. We have good routine descriptions related to duty of care and will intensify our internal control to ensure that our subcontractors comply with applicable laws and agreements, as well as our ethical guidelines.

Purchasing

We currently have around 5,000 suppliers in OneCo Elektro. These are suppliers where we make purchases ranging from a few hundred dollars to many millions annually. More than 60 per cent of our purchases are made through reputable wholesalers. The purchase of products represents a risk of human rights violations as a large proportion of these products are manufactured in other parts of the world where compliance with human rights is not as prominent as in Norway.

We are working on conducting due diligence assessments of our entire supply chain and have started with suppliers where we make purchases worth more than NOK 5 million annually.

We are actively working to reduce the total number of product suppliers throughout our value chain. This will, among other things, give us better control over our suppliers' compliance with the requirements of the Transparency Act.

Through our analysis using the "Responsibility Compass", we have discovered that we do not pass on our internal requirements for the working environment and climate measures to our subcontractors to a sufficient extent. This applies, among other things, to climate measures to reduce CO2 emissions, where OneCo Elektro itself has obligations in relation to SBTi and Eco-Lighthouse.

Direct import of solar cells from China

Direct import of solar cells from China is addressed as the largest single risk. OneCo Elektro has entered into an agreement with a specific company that produces solar cells used in our assignments in Norway. In order to ensure that we comply with the requirements of the Norwegian Transparency Act, we use an external company to carry out controls at this factory and in its production chain in general.

Read more about how we work with due diligence on solar panels here.

Training programmes

Through our analysis, we have discovered that we do not adequately train our own employees in relation to our work with our environmental goals.

 

Gender distribution internally

The gender distribution internally in OneCo Elektro is highly skewed. This in itself constitutes a risk of discrimination, among other things. Risks and measures related to this are described in the Group's gender equality report.

Greenhouse gas emissions directly related to our production

We largely use fossil-fuelled service vehicles in our assignments. This also applies in cases where the assignments take place in "barn-like" areas of the country and where the daily mileage to/from the assignment is short.
We use very few chemicals in our production.

Focus on reporting deviations

We work continuously to ensure that we have good control over our operations, including HSE and quality requirements. We motivate employees to report non-conformities and to speak up when there are issues that can be improved, changed or corrected. A culture of openness where speaking up is valued is therefore something we work on at all levels of the company. Good follow-up of non-conformities is a prerequisite for this work, and we use non-conformities for continuous improvement - e.g. by turning non-conformities into "learning sheets" that can be used to ensure competence building and learning internally.

Identified breaches

We have mapped breaches of our ethical guidelines among our own employees, as well as breaches of internal procedures and guidelines related to purchasing. These have been dealt with internally.

We have had cases where our employees have had unpleasant experiences based on gender and ethnicity on assignments for us. This has been dealt with internally and in co-operation with the customer.

In addition, we have uncovered breaches of the provisions of the Working Environment Act at two of our subcontractors of staffing services. Through dialogue, requirements and guidance, we have sought to correct the violations that have been uncovered. As a result of this process, we have decided to end our co-operation with one of these companies. The improvement process is ongoing in the other case.

Measures

  • We are strengthening our purchasing organisation both internally in OneCo Elektro and at Group level, partly to ensure that we can carry out better follow-up and control of our suppliers.
  • In the time ahead, we will reduce the number of suppliers
  • We will increase the number of internal controls and audits of staffing agencies and subcontractors
  • All new agreements and renegotiations will require a completed self-declaration that fulfils our duty of care regarding finance, employee rights, HSE, etc.
  • Requirement for Startbank registration for all major suppliers. This will give us good insight into the seriousness of the contractors and will facilitate the work of obtaining the necessary documentation.
  • We will carry out better training of our employees in relation to our environmental work. This will take the form of information, microlearning programmes and concrete measures locally.
  • Seek to improve the gender balance internally (see the Group's gender equality report)
  • Phasing in of electric cars, and redistribution of cars so that those who have the opportunity can drive fossil-free. Inform and involve employees in the preparation of climate measures. Raise employee awareness of defensive driving and reduce unwanted driving through better production planning. Reduce travelling where possible through the use of Teams meetings where appropriate.
  • Conduct campaigns to increase the number of reported HSE and quality deviations, aiming for a minimum of one deviation per employee annually. Reduce the processing time per deviation.

Technologies

OneCo Technologies is the Group's technology company and system integrator, focusing on core activities in critical infrastructure, industry, renewable energy and construction. Our strengths lie in delivering electronic and physical security, IT and health technology, system-integrated solutions and automation systems within water and wastewater, industry, food, construction, energy, transport and offshore operations. We currently have 140 employees, who help to combine products and services into a complete delivery for us as a total supplier.

risk

We have mapped these risks as the most serious and which we will therefore focus on in further work:

  • Purchasing and control of products used in our production
  • Greenhouse gas emissions directly related to our production
  • Imbalanced gender distribution internally

Purchasing

OneCo Technologies currently uses around 900 suppliers. The majority of our purchases are made through recognised wholesalers in Norway. In addition, we make some direct purchases of materials, mainly from the UK, Germany and the USA.

We are actively working to reduce the number of suppliers and primarily want to be left with larger companies that comply with guidelines and requirements under the Transparency Act, through ISO certifications, Eco-Lighthouse and other systems such as SBTi.

Greenhouse gas emissions directly related to our production

We aim to carry out our production in a sustainable way and we share this goal with our customers. Our goal is to be environmentally certified under ISO 14001, a process that has already begun.

Service vans
We currently use both fossil-fuelled and electric service vehicles in our assignments. Fossil-fuelled vehicles have the greatest impact on our climate footprint. We are therefore working purposefully to phase in more electric cars in our business.

Business travel
OneCo Technologies will work actively to reduce our travelling activity to an appropriate minimum and use Team Meetings where applicable. Assessments must be made before a physical journey is decided to be carried out.

Solid waste
Good routines and the correct handling of waste will minimise the risk of environmental impact. This is emphasised in our projects and deliveries. All employees are responsible for limiting the risk of environmental damage and utilising opportunities for improvement. The company must comply with relevant environmental regulations.

Identified breaches
Throughout the year, several internal and external audits are carried out to uncover any breaches and deviations. We have not uncovered any breaches in connection with this mapping in the past year.

We work actively to map our entire supply chain. In particular, this applies in cases where we directly import goods and materials.

Measures

  • Adopt the Agreement on Responsible Supplier Behaviour (ABC) as part of our contracts.
  • Conduct a more thorough mapping of new partners, prepare an internal checklist of points to be reviewed with new suppliers and new customers.
  • Seek to improve the gender balance internally by raising awareness in recruitment processes, in accordance with the Group's Gender Equality Report.
  • Phasing in electric cars and driving fossil-free in deliveries where possible. Reduce business travel where possible and appropriate.

Ocean

OneCo Ocean has around 110 employees who look after OneCo's investments in offshore and marine markets.

Today, OneCo Ocean delivers services to, among others, the Norwegian Defence, offshore installations and shipping companies in Norway.
We identify whether we can be directly linked to negative impacts on people, society and the environment through our business relationships, even if we have not caused or contributed to them ourselves.

risk

  • Hiring of labour

FO Ocean's main risk lies in our use of agency workers who contribute to production peaks in our projects. To some extent, we hire labour from staffing agencies that are not covered by collective bargaining agreements, and we have a responsibility to ensure that the hired workers have satisfactory and legal working conditions.

Internal control
We want to expand - and develop - our internal control. Both in terms of increased capacity in the number of audits.

Solid waste
Waste from our production can have an environmental impact. We currently use an external supplier for waste management, and we do not have adequate follow-up procedures to ensure that we reduce our impact on the environment.

Reported deviations
We focus on increasing the number of non-conformities to ensure good control of our deliveries. We are working to increase the number of reported deviations and learn from the deviations that are reported. It should be safe to report non-conformities and we encourage all employees and contractors to speak up if they see non-conformities, make observations or have suggestions for improvements.

Identified breaches

OneCo Ocean has no directly identified breaches other than improvement points in ISO certification audits and orders for improvement from the State Administrator, who has had several inspections at the facility in Kristiansand. There are registered deviations in the discharge of oil in the dry dock, parts of which passed the barriers and entered the sea outside. This was collected with the help of oil-sucking booms that were passed in the sea in the vicinity of the dock (communication with public authorities was carried out).

Measures:

  • Close improvement proposals and deviations from audits.
  • Increased focus on safe job analysis and "Toolbox talks" with improvement as the theme
  • Increased number of safety representatives and safety rounds.
  • We will increase the number of internal controls and audits of the staffing agencies and suppliers we use.
  • Conduct campaigns to increase the number of reported HSE and quality deviations. We aim to report at least one deviation per employee per month.

Infra

Oneco Infra has around 95 employees working with the design, construction, operation and maintenance of road and rail infrastructure. We have mapped our risk related to direct negative consequences for people, society and the environment through our operations and through our business relationships, even if we have not caused the consequences ourselves or contributed to them.

risk

In relation to the Transparency Act, we have mapped these risks as the most serious and which we must focus on further:

  •   Procurement and control of products used in the projects
  •   Control of subcontractors' subcontractors
  •   Greenhouse gas emissions directly related to our production

Purchasing

Oneco Infra uses around 500 suppliers today. These are suppliers where we make purchases from a few hundred dollars to many millions. The vast majority of purchases are made through recognised wholesalers.

Many of the products we buy are manufactured in other parts of the world, and this therefore represents a risk of human rights violations, especially with regard to production in countries with less focus on the issue than Norway.

We are actively working to reduce the number of suppliers and primarily want to be left with larger organisations that have ISO certifications, Eco-Lighthouse or other systems such as SBTi. We also primarily want to use suppliers that are registered in Startbank to ensure seriousness. This, together with audits, will make Oneco Infra better able to verify that the product chain complies with the requirements and guidelines of the Transparency Act.

Subcontractor's subcontractor

We have many years of experience in document control of subcontractors and their follow-up. In our industry, the spotlight on social dumping has been prominent for several years and the document regime of public agencies and counties (our clients) has been strict.

One risk is still the subcontractor's use of subcontractors. Subcontractors who are not experienced in our industry pose a risk in that they do not know the requirements and can therefore enter into agreements with other subcontractors who do not have satisfactory and legal working conditions, working environment and living conditions.

We are actively working to improve our systems for identifying subcontractors' contractors so that we can quality-assure them correctly in relation to applicable laws and agreements, contracts with clients and our ethical guidelines.

Greenhouse gas emissions directly related to our production

Oneco Infra makes extensive use of fossil-fuelled vehicles in the implementation of our tunnel rehabilitation projects. Many of our projects are located on European and county roads in sparsely developed areas. This means there are few charging options. However, we have purchased some electric vehicles that are used in projects in areas with good charging facilities. We will replace fossil-fuelled vehicles in line with the development of range and charging options.

Sweden

Sweden is not subject to the Swedish Transparency Act, but has mapped its own risks related to human rights and a safe working environment. OneCo Sweden has close to 400 employees across large parts of Sweden and works with integrated service deliveries in telecommunications, energy and IT.

risk

We carry out risk mapping on an ongoing basis and work continuously on measures to prevent and reduce the likelihood of accidents.
Our biggest risks related to the Transparency Act are:

  • Greenhouse gas emissions from service vehicles and business travel
  • Use of subcontractors
  • Waste management

Greenhouse gas emissions from service vehicles and business travel

We are working purposefully to reduce greenhouse gas emissions, for example by phasing in electric cars. By the end of 2023, more than 25 per cent of our vehicle fleet will be electric cars. We are also working on route optimisation and adapting vehicle types to reduce our environmental impact.

We recommend digital meetings and the use of trains as a mode of travel, where appropriate. For example, we encourage everyone to use public transport to our head office in Stockholm where we no longer have parking facilities.

Use of subcontractors

All our contractors and suppliers must go through a qualification process before a contract is signed. This means, among other things, that they undertake to follow our ethical guidelines and our environmental requirements. They also undertake to comply with applicable laws and regulations, as well as having the correct insurance schemes and using trained/certified personnel.

Waste management

Good waste management in all parts of our operations is important to reduce our climate footprint. This applies both to waste from our own production and the waste we handle on behalf of our customers. In order to minimise our environmental impact, our employees must have good knowledge and follow applicable procedures for waste management and use approved waste management companies.

Risk across the business areas

Wages and working conditions for hired workers and subcontractors constitute a risk across OneCo's business areas. Annually, we hire labour from external companies for NOK 440 million. This mainly concerns labour that contributes to production peaks in projects.

We also use subcontractors to fulfil parts of our contract deliveries. These can be excavation contractors, assembly, transport or logistics services. These are areas of expertise where we do not have our own employees who can carry out this part of the production.

We have uncovered several cases of non-compliance with the provisions of collective bargaining agreements and other legislation related to the labour market at some suppliers. The number of suppliers of goods and services used in our production is currently very high. This increases complexity and makes it more difficult to maintain full control of our supply chain.

Internal

Internally, highly skewed gender distribution (only 12 % women in total and only 4 % women in operational positions) can increase the likelihood of gender discrimination and harassment based on gender. We have discussed this in our equality and discrimination report. Here we discuss risks related to, among other things:

  • Recruitment and selection
  • Expertise and development
  • Rewards and bonuses
  • Turnover

In addition, which risk-reducing measures have been implemented - and will be implemented in the future. Another risk element is related to purchasing and our purchasing processes. This is discussed specifically as a separate item.