Due diligence assessments

The Transparency Act entered into force on 1 July 2022 and requires “larger enterprises” to ensure fundamental human rights and decent working conditions within their own operations, while at the same time imposing corresponding requirements on the enterprise’s suppliers and business partners.

Through the Transparency Act, Kvarv AS is obliged to carry out due diligence assessments in accordance with the legislation, and to publish the statement once a year, by 30 June of the relevant year.

Kvarv AS is a family-owned company, or a holding company as it is also called. No typical business activities such as trade, aquaculture or industry take place in Kvarv AS. The Kvarv Group is instead the sum of all the businesses operated under the parent company Kvarv AS. Through the investment companies Kverva AS and Forward Project AS, Kvarv AS holds ownership interests in a number of companies, most of which are located along Nordic coastlines.

Kvarv AS has reviewed the parent company’s and the Group’s suppliers and business partners in order to identify companies that represent a high risk of violations of human rights, corruption and indecent working conditions.

Kvarv AS is a family-owned company and its suppliers and business partners include financial institutions, insurance companies, real estate companies, consultants, auditors, lawyers, cleaning and canteen service providers, and IT suppliers. It is assessed that the parent company has no suppliers or business partners that represent a high risk of human rights violations. Nevertheless, there are some inherent risks, such as the potential risk of human rights violations in the supply chain of IT companies (on the component side). Companies that supply IT products (PCs, laptops, projectors, etc.) are generally large, global groups, and Kvarv AS assumes that these address the risk of human rights violations in an adequate manner with their subcontractors.

Kvarv AS has requested its key suppliers to submit their due diligence assessments; this applies in particular to the main suppliers within IT, banking, legal and consulting services. Based on a risk-based approach and the statements received from suppliers, no further measures are considered necessary. To the extent that Kvarv AS identifies a risk of human rights violations among its suppliers, the matter will be raised with the relevant supplier.

The risk of human rights violations and indecent working conditions may be greater in the supply chains of the various portfolio companies in the Kvarv Group. Kvarv AS follows up the work of its portfolio companies under the Transparency Act by ensuring that appropriate annual due diligence assessments are carried out and that other obligations under the Transparency Act are complied with. Based on a risk-based approach and the statements received from suppliers, no further measures are considered necessary. To the extent that Kvarv AS identifies a risk of human rights violations in its portfolio companies, the matter will be raised with the relevant portfolio company.

The work related to the Transparency Act is anchored in the Board of Kvarv AS, with a focus on business ethics and human rights. Social sustainability and fundamental human rights are to be embedded in guidelines for responsible business conduct.

In the event of any structural changes in the Kvarv Group, we will also emphasise that any new group companies comply with the Transparency Act and operate sustainable businesses.

Statements for the most important portfolio companies are available on the respective companies’ websites.

Kvarv AS is committed to responding and will respond to enquiries about how the company manages the risk of adverse impact on fundamental human rights and decent working conditions.

Enquiries can be directed to apenhetsloven@kvarv.no

Trondheim, 25 March 2026

Bjørn M. Wiggen
(Chair of the Board)

Harald Ellefsen
(board member)

Oddny Witzøe
(board member)

Gustav Magnar Witzøe
(managing director)