The Transparency Act and Reporting
Ålesund, 18.10.24
HAF POWER SOLUTIONS AS's work with human rights and ethical trade
1. Introduction
The ACEL Group is committed to conducting its business with integrity, in line with human rights and with the aim of contributing to sustainable development. This report has been prepared on the basis of the Transparency Act, which came into force on July 1, 2022 and to which the ACEL Group is subject. In line with section 5 of the Transparency Act, the ACEL group's policies and findings are thus published to fulfill the due diligence assessment.
The ACEL Group is a total electrical contractor headquartered in Ålesund. The group consists of the companies ACEL Invest AS, ACEL AS, HAF Power Solutions AS, ACEL Baltic UAB, and currently has a total of approx. 170 man-years. The company has departments within engineering, switchboard production, marine installation, maritime/offshore service worldwide, electrical installation and service for housing, commercial buildings and aquaculture. The products we supply typically consist of switchboards, sub-distribution boards, starters, propulsion systems, energy storage systems, energy control systems and bridge and engine room consoles.
The ACEL Group is committed to being a responsible corporate citizen and is aware that trading in goods and services involves various types of risk. The company works actively to ensure fundamental human rights and decent working conditions both in its own organization and in the supply chain. The company has drawn up a Code of Conduct in accordance with the OECD guidelines. This has been implemented in the contractual basis with the company's suppliers where ACEL has deemed it necessary based on a proportionate risk analysis.
In the following, ACEL will describe the internal guidelines, the findings that the company has registered and the measures that have been implemented.
2. Description of HPS's follow-up of the Transparency Act
2.1 Anchoring accountability
HAF POWER SOLUTIONS AS has anchored accountability for the Transparency Act in the company's senior management and implemented procedures for conducting the due diligence assessment in the company's QA system (PL-01.04 Transparency Act due diligence assessments and information requirements). Furthermore, the organization shall perform a review of all relevant internal and external documents to ensure that the Act is complied with at all times.
2.2 Vulnerability assessments/risk assessments and practical implementation
HAF POWER SOLUTIONS AS has mapped its subcontractors. Based on the overall review, an initial selection has been carried out based on the principle of proportionality and the principle of risk, where it is crucial that HAF POWER SOLUTIONS AS has the opportunity to influence its suppliers and contribute to the promotion of fundamental human rights and decent working conditions. The selection is a risk-based approach based on the following criteria:
Turnover/Size
Industry/product
Geography
Are the companies themselves covered by the Transparency Act/monitoring reports (1*)
(*1) For more details about the selection, please refer to our "Step 2: Map and assess negative impact/damage" section in our QA document (PL-01.04 Transparency Act due diligence and information requirements)
3. Conducting the due diligence assessment
After this initial selection, a broader due diligence assessment is carried out to clarify that the supplier meets the requirements for fundamental human rights and decent working conditions. An assessment is then made of the general and specific risks faced by the individual supplier. Based on this assessment, a prioritized list for further measures and monitoring is prepared in line with the Transparency Act.
This process is carried out annually for existing suppliers. This is also done continuously when creating new suppliers if they are covered by the criteria mentioned above.
If HAF POWER SOLUTIONS AS should uncover negative conditions, this will be reported in accordance with the Transparency Act.
HAF POWER SOLUTIONS AS has identified that the greatest potential risk is associated with the supply chain for electronics and ICT, building and construction materials (metal), workwear and footwear and products containing conflict materials. HAF POWER SOLUTIONS AS has a particular focus on suppliers with a registered business address abroad. Based on this selection, there are some suppliers for which measures and routines for monitoring will be implemented.
4. Implementation and planned measures for follow-up of the due diligence assessment.
4.1 Follow-up of our subcontractors and measures to reduce risk
When purchasing/hiring, all suppliers who are covered by the criteria mentioned above must sign the Code of Conduct. This is to ensure compliance with basic requirements for environmental, ethical and social guidelines, and we shall have standard contracts with appropriate contract clauses.
If we uncover or see that there is a high probability of degrading working conditions and human rights violations at potential or existing suppliers, we will assess our further cooperation.
HAF POWER SOLUTIONS AS reserves the right to conduct audits if necessary and request additional information where there is a high risk of violation of fundamental human rights and decent working conditions
If a subcontractor has received negative focus/reputation in the industry/media or similar, we may request more information from the subcontractor. If we do not feel this is sufficient, this may lead to further inspection/attendance at their premises.
For existing suppliers where risks have been identified, checks have been carried out using a Code of Conduct questionnaire. As a follow-up to this, a separate report is published on the website.
4.2 Funn/undersøkelser i inneværende år
Vi har gjennom året kontrollert og fulgt opp eksisterende og nyeleverandører og kunder.
Det har vært et tilfelle der vi har gjennomført utvidedeundersøkelser, uten å kunne konkludere eller påvise brudd.
4.3 Rapportering og offentliggjøring av informasjon
HAF POWER SOLUTIONS AS oppdaterer redegjørelsen og offentliggjøres innen 30. junihvert år og ellers ved vesentlige endringer i virksomhetens risikovurderinger.
It will be published on the HAF POWER SOLUTIONS AS website: https://www.hpsolutions.no/transparency-act
https://www.hpsolutions.no/ has its own notification channel through the email address: varsel@acel.no
Enhver henvendelse om innsyn til https://www.hpsolutions.no/ og hvordan selskapet håndtererfaktiske og mulige negative konsekvenser for grunnleggende menneskerettigheterog anstendige arbeidsforhold i henhold til åpenhetslovens § 6, skal rettes til kamy@acel.no, Karin Aas Myhren senior innkjøper.
Vi vil svare innen 3 uker, om informasjonskravet ikke er særligomfattende. Om henvendelsen åpenbart er urimelig eller forespørselen gjelderforretningshemmelig informasjon, vil vi avvise henvendelse med begrunnelse.
