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The Transparency Act

The Transparency Act

Remøy Management is subject to the Act on Corporate Transparency and Work with Fundamental Human Rights and Decent Working Conditions (the Transparency Act).

The law came into effect in Norway on July 1, 2022, and aims to ensure transparency regarding companies' efforts to uphold human rights and decent working conditions. The law imposes obligations on companies, including Remøy Management, to assess the risk of human rights violations and decent working conditions within their own operations and throughout the supply chain, including business partners. This is done through due diligence assessments, and the work is based on a risk-based approach.

Based on a risk-based approach, the company must also implement measures to prevent, reduce, or eliminate identified risks.

The law also imposes an obligation to provide information, requiring the company to respond to written inquiries about how our business deals with and handles these risks.

The results of the due diligence assessments must be made available to the public through annual reports.

Foundation in the Remøy Management Board

It is established in the Remøy Management board that the company must comply with the obligations under the Transparency Act.

The company's CEO is responsible for the procedures under the Transparency Act, but the responsibility for conducting the due diligence assessments and other tasks is assigned to different areas of responsibility.

Risk evaluations within each area are reviewed twice a year by the company and the board, along with associated measures and time estimates.

The board is continuously informed about this work and as needed.

Organization and Operations of Remøy Management

The company operates fleets and offers ship management services, including planning and development, construction, commercialization, and mobilization. We also provide commercial, technical, and insurance administration services.

Remøy Management operates vessels for the aquaculture industry, including vessels approved for transporting fish from fish farms. We can provide services for offshore vessels, coast guard vessels, navy vessels, fishing vessels, and more. In addition, we develop new vessel solutions and handle project management related to conversion, purchase and sale, and relocation of vessels. We also provide services in business management, such as accounting, budgeting, and reporting.

Our fleet currently consists of 12 vessels, including four coast guard and navy vessels, one vessel operating in cable laying, and seven vessels in the aquaculture industry.

Remøy Management AS is the parent company of RM Drift AS, RM Drift II AS, and Remøy Management Crew AS.

Remøy Management AS has 14 employees. The subsidiaries Remøy Management Crew AS and RM Drift AS have 39 and 28 employees, respectively. There are no employees in RM Drift II AS.

Offshore personnel in the group are members of the Norwegian Maritime Officers' Association and the Norwegian Seafarers' Union. In addition, local agreements between the Norwegian Shipowners' Association and the Norwegian Maritime Officers' Association/Norwegian Seafarers' Union apply to offshore personnel.

Furthermore, the collective agreement for Polish seafarers between the Norwegian Shipowners' Association and the Polish Seafarers' Union, Maritime Section NSZZ Solidarnosc, Norwegian Maritime Officers' Association, Norwegian Association of Maritime Engineers, and the Norwegian Seafarers' Union (2021-2022) applies, as well as the collective agreement for Polish seafarers (wage levels) for the (hired) Polish crew operating within the group.

The group has a safety management system in accordance with the requirements of the "International Management Code for Safe Operation of Ships and for Pollution Prevention." The management system is extensive and includes guidelines and reporting obligations to ensure compliance with HSE requirements during fleet operations.

Methodology for our due diligence assessments

In our work to identify risks, we consider industry-specific factors and geographical conditions (countries).

When it comes to the industry, we conduct a general assessment of industry conditions, also based on the services and products of the supplier/business partner.

We seek to map and identify specific suppliers/business partners with an elevated risk. This is done, among other things, by investigating whether there is negative media coverage regarding working conditions and more. We also assess the extent to which the supplier publicly demonstrates an understanding that their business may have a negative impact on human rights and working conditions.

Regarding geographical risk, we base this assessment on information from the following sources:

(I) Human Rights Index (Scale from 1 to 10, where we consider the index score up to 50% of the scale as green (0.5 - 4.65), 50-75% as yellow, and 75% and higher as red).
(II) Corruption Index (Scale from 1 to 100, where we consider the index score 50-100 as green, 25-49 as yellow, and 1-24 as red).
(III) Global Rights Index (Scale from 1 to 5+, where we consider the index score 1-2 as green, 3-4 as yellow, and 5 as red).
(IV) Comments from what can be considered reliable sources, primarily the Norwegian embassy in various countries.

Based on the analysis, the company will seek to further assess the actual conditions. Based on the results, the risks will be prioritized. The principle of the law implies that risks with a high level of severity and a high degree of potential impact should be prioritized first. Relevant measures (halt, prevent, or limit) are based on the analysis of the risk and the actual conditions.


Due diligence assessments - overall risk assessment of the business and supply chain

Own business
Norway has comprehensive and clearly defined laws and regulations that ensure basic human rights and decent working conditions for Norwegian employees. Remøy Management is subject to supervision by the Norwegian Maritime Authority. We have established organizational structures, guidelines, and procedures to ensure that we identify and manage actual and potential negative consequences related to human rights and working conditions. This includes employee training, ethical guidelines, supplier agreements, and control mechanisms to ensure that our standards are maintained.

In addition to ISO 9001 and ISO 14001 certifications, Remøy Management is MLC certified. MLC certification ensures compliance with the minimum requirements of the Maritime Labor Convention regarding working conditions, health, safety, and welfare for seafarers on board our vessels and provides seafarers with rights and protection according to the convention.

Based on the above, we consider the overall risk in our own business to be manageable.

Remøy Management procures spare parts, equipment, and services primarily in Norway, but some purchases are made in Sweden, the EU, and the UK. We are a member of Incentra, a purchasing organization owned by Norwegian shipowners. All our suppliers supplying the mentioned equipment are qualified suppliers and members of the organization.

Incentra manages long-term framework agreements with quality suppliers for spare parts, services, and consumables used for global vessel operations. The organization ensures framework agreements, HSE audits of suppliers, and provides a platform for networking and exchange of maritime expertise, quality, and efficiency. Before qualifying as an Incentra supplier, all suppliers must undergo extensive procedures. Incentra assesses suitability and requires, among other things, that suppliers meet high standards in health, safety, environment, and comply with Incentra's ethical guidelines. Incentra is selective in its choice of suppliers.

Remøy Management AS also has a crewing agreement with V. Group Global (Singapore) PTE. LTD.

V. Group is a major player that provides services in ship management, and the company hires crew members through this entity. The company has the impression that V.Group takes employee training and safety seriously. V.Group has its own global network of training centers where training for seafarers is conducted. The company regularly follows up with V.Group, requesting documentation such as pay slips for the crew members hired through this entity.

Based on the above, the company considers that the overall risk of human rights violations and decent working conditions is manageable both within its own operations and in the supply chain.

Specific risk assessment as of June 2023:

Based on a general assessment of the industry in which we operate, we have identified an elevated risk associated with shipyards (yellow). This is due to risky services (fall and crush accidents, emissions, pollution) and serious violations of working conditions in the industry recently uncovered. It has been revealed, among other things, that subcontractors to the shipbuilding industry have underpaid foreign workers and engaged in the abuse of overtime work. Remøy Management currently has one vessel under construction at a foreign shipyard, and there is close monitoring and extensive meetings with the shipyard to address this risk as well as the handling of risky tasks.

Measures taken to reduce the risk of human rights violations and decent working conditions:

In addition to the requirements set forth in the Labor Environment Act, the company has already implemented comprehensive supplier guidelines that include requirements for working conditions, wages, working hours, and health and safety standards. We conduct regular audits of our subcontractors to ensure compliance with these standards.

Our goal is to maintain a high standard of safeguarding human rights, ensuring safe working conditions, and considering environmental aspects throughout our operations. We will continue to develop our due diligence assessments, implement necessary measures, and report the results to ensure accountability and continuous improvement.

The law came into effect on July 1, 2022. Currently, it is challenging to predict the effects that the implemented measures have had or will have. However, the goal is for these measures to increase awareness and lead to more thorough assessments of existing and new suppliers.

This statement is signed by the board and the managing director of the companies.

The statement will be updated annually and in case of significant changes in the information provided in this report.

Revised and reviewed by the board and managing director, June 2023.

Even T. Remøy                            Helge T. Remøy
Managing Director/Chairman      Board Member