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Transparency Act Report

About the Transparency Act

The Transparency Act is a law enacted by the Norwegian Parliament, which came into force on July 1, 2022. The law aims to promote companies’ respect for fundamental human rights and decent working conditions, and to ensure public access to information.

Introduction

This statement describes how Frontkom works to identify and assess negative consequences that may arise from violations of, or the risk of violations of, fundamental human rights and decent working conditions. Furthermore, it explains the measures and routines Frontkom has implemented to prevent and mitigate such consequences. The purpose of this statement is to provide the public with insight into the key findings from our due diligence assessments, as well as any measures that have been implemented. Our approach to due diligence assessments is in line with international standards, including the UN Guiding Principles on Business and Human Rights (UNGP), and the OECD Guidelines for Multinational Enterprises. This statement is updated annually by June 30, and in the event of significant changes in the company’s risk assessments.

About Frontkom

Frontkom was founded in Fredrikstad (Norway) as “Front Kommunikasjon” in February 2000. In 2008, the company was reorganized into a digital consultancy house and has since grown to nearly 80 team members. We have our own offices and access to shared offices in the following locations in Europe: Trondheim, Fredrikstad, Oslo, Funchal, and Warsaw. Additionally, we have employees working remotely from Sweden and other locations in Portugal, Poland and Ukraine. After the merger with NyMedia late in 2023, Frontkom is now subject to the Transparency Act from 2024.

Frontkom has established a “Code of Conduct” to ensure responsible supply chains and partnerships, outlining the group’s expectations and requirements in various areas related to corporate social responsibility and the environment, including fundamental human rights and decent working conditions.

Annual Report in Accordance with the Transparency Act

We have established the following guidelines and routines to manage actual and potential negative consequences for fundamental human rights and decent working conditions:

Frontkom began the due diligence assessments with a general analysis of its own operations, suppliers, and business partners. Our own operations include activities in Norway, Poland, and Portugal. We purchase other services for our operations, such as office rental, server services, software licenses, and other digital platform services.

To ensure fair employment conditions, all employees in Frontkom have a written employment contract in a language they understand, in accordance with national laws and regulations. We operate in three different countries with a dedicated country manager to ensure compliance with national rules and regulations where the employee is employed, including labor law, equality, non-discrimination, etc.

We actively work with equality by collaborating with national authorities in Norway and educational institutions in Portugal to attract and recruit people from diverse backgrounds through, for example, work placements, language practice, internships, etc. In 2022, 33% of all new hires were women, and we are continuously working to achieve a healthy gender balance.

Human Rights in Supplier and Stakeholder Organizations

In addition to ensuring fair employment conditions, we also evaluate each potential purchase, collaboration partner, supplier, etc., to ensure we use trusted parties concerning labor rights, sustainability, human rights, etc.

Frontkom acknowledges and operates under the human rights, UN conventions, and ILO conventions enforced by the national authorities in the countries where we operate.

We have a sustainability group that leads Frontkom’s efforts to help achieve the UN Sustainable Development Goals.

To ensure that the companies in the Frontkom Group comply with the OECD Transfer Pricing Guidelines for Multinational Enterprises, an agreement has been established with the companies in the group.

Whistleblowing Routine

At Frontkom, we have an organizational structure with clear reporting lines. We encourage employees to first raise issues with their direct line manager. If it is necessary to escalate further, the organizational structure should be used as an escalation path.

Anchoring Accountability

In the board meeting on June 21, 2024, a separate case on the group’s work with the Transparency Act was discussed.

Supplier Mapping

We have obtained a complete overview of the suppliers and business partners we have had during the period. After the initial mapping, where we sorted suppliers and other partners by size and risk profile, we selected a representative sample we reasonably could influence to participate in our survey. This survey is expected to be conducted in the summer of 2024 to give us increased insight into potential negative consequences.

Contractual Requirements

In all new supplier contracts, requirements related to the Transparency Act will be incorporated. This will give Frontkom the ability to closely monitor these requirements and obligate suppliers to actively work with transparency in their operations.

Results from Due Diligence Assessments

Through our due diligence assessments, we have uncovered the following actual negative consequences: As the supplier survey is ongoing, we must await its results before drawing any conclusions.

In addition, we have identified the following significant risks of negative consequences: Same as the above point.

To halt uncovered negative consequences, we have implemented the following measures: Same as the above point.

To mitigate significant risks of negative consequences, we have implemented the following measures: Same as the above point.

Implemented measures have yielded the following results or expected results: Same as the above point.

Contact with Frontkom

Frontkom receives inquiries related to the Transparency Act via a dedicated email address: [email protected].¬†