Transparency Act

REPORTING FOR CONMODO AS
‍01.01.23-31.12.23

‍

The purpose of the Norwegian Transparency Act, which came into force on 1 July 2022, is for Norwegian companies to develop and achieve good working conditions and compliance with human rights in their supply chains. Conmodo AS publishes on this page its statement and updates it continuously in accordance with the law, otherwise no later than June 30 of each year.

‍

Introduction

Conmodo AS is the largest service company in Norway for mobile phones and small electronics. We cooperate with the largest players in telecom, retail, and insurance.

Conmodo focuses on stringent requirements for Health, Safety, and Environmental goals, and takes great care in our choice of environmentally friendly and sustainable practices.

Our values obligate us to conduct our business responsibly and perform to the highest ethical standards. These ideals are reflected in every part of our business routines. In this report, we describe the company's work in our due diligence assessments related to human rights, decent working conditions and ethical trading in line with the requirements of the Transparency Act.

‍

Entrenching accountability

It is rooted in the Board's 2023 Annual Report that we shall ensure basic human rights and decent working conditions. Conmodo's control system and internal procedures will ensure that our values and ethical guidelines are integrated into all processes we carry out in the day-to-day operations of our company. These expectations and standards are expected of our suppliers, their subcontractors, and all service partners of Conmodo AS.

‍

Due diligence assessments

As per the Transparency Act, due diligence assessments should be proportionate; that's why we prioritise those suppliers with whom we have the most trade and those industries where there is the greatest risk of human rights violations and exploitative working conditions.

Our cooperation with INANKO Procurement AS provides us with continuous risk assessment of our current and future suppliers. This cooperation contributes to our implementation of effective due diligence assessments.

INANKO notifies us of risks related to our supply chain, including legal and financial factors, credit risks, reputational risks, delinquencies and other relevant matters. We act accordingly to these alerts to identify and manage any risk factors in our supply chain.

These priority providers have been surveyed in regards to their compliance with OECD guidelines. Missing feedback is followed up about on an ongoing basis.

We have allocated resources to managing risk factors we have been alerted to, and treating existing concerns on a weekly basis.

As of 30.06.24, no risks or breaches have been uncovered with our suppliers.

Potential risk

Conmodo AS is aware of the inherent risks associated with our industry, especially concerning suppliers in raw materials and manufacturing. We aim to reduce harm as much as is possible through our choice in suppliers when achievable.

Measures to reduce risk

Digital case files are set up on all risk issues that are detected on an ongoing basis. Work on risk-mitigation measures and supplier priorities resides in this database. Before any action is taken against the supplier in question, the information obtained is to be thoroughly verified, normally conducted through dialogue with the supplier.

We carry out our analyses with a risk-based approach. In short, the scope of our efforts to map out and follow up on concerns is adjusted to the risk factor of the business relationship and the company’s potential for positive impact.

All high-risk case files will be followed up systematically and mitigative measures will be activated on an ongoing basis. All risk events on a provider are classified as either Red (High Risk), Yellow (Medium Risk) or Green (Low Risk). Previous events and actions taken by the vendor as recorded in our database will be reflected in their stance on this scale..

Suppliers are normally provided time to document and correct concerns. These concerns may be codified by contractual and legal measures to assure compliance.

In the event of gross violation of our standards and policies, we reserve the right to immediately terminate contractual relationships with the offending supplier.

Further analyses will be carried out starting from a risk-based approach. This means that the scope of mapping and follow-up is adjusted to the risk value of the relationship as well as the company's potential for positive impact.

Contact

Inquiries and questions relating to Conmodo's work on human rights and decent working conditions may be directed to quality@conmodo.com and will be answered no later than three weeks after the inquiry is received. All inquiries will be treated with utmost confidentiality.

‍