Introduction

JWS is a Norwegian-owned international provider of services within high-pressure cleaning, cuttings and swarf handling. The head office is in Norway, and the number of employees in 2022 was 38, who are organized in a flat organizational structure. The turnover in 2022 was approximately NOK 140 million. Since its inception in 1997, the company has provided services in most areas of the North Sea. JWS delivers tailor-made solutions to customers and has a staff of highly qualified employees, who enable the delivery of services from idea to design and execution with equipment and personnel.

Human rights and working conditions

JWS maintains a high focus on human rights and decent working conditions related to the company's operations. A separate policy has been established for this: “JWS shall respect internationally recognized human and labor rights both in its own operations and in our value chain. Applicable laws and regulations, including internationally recognized conventions on human rights and decent working conditions, must always be complied with. We respect and promote the UN's basic human rights and the International Labor Organization's (ILO) core conventions. JWS strives to follow the UN's guiding principles for business and human rights and the OECD's guidelines for multinational companies. We shall contribute positively and constructively by influencing the work for human rights, the prevention of child labor and safeguarding labor rights, both internally and towards our suppliers, subcontractors, and trading partners. Safeguarding human rights and decent working conditions is a central part of our ethical guidelines, which apply to all employees, board members, managers, hired personnel, consultants, company representatives and everyone who performs work on behalf of or otherwise represents JWS. Everyone is responsible for familiarizing themselves with and complying with the standards and principles described in the ethical guidelines. We expect suppliers, subcontractors, and trading partners to act in line with the purpose of the policy and follow all internationally recognized human rights principles and fundamental employee rights as described above as well as local legislation within their geographical areas, throughout the value chain. In this connection, a separate policy for sustainable procurement has been drawn up. In contracts with suppliers, subcontractors, and other trading partners, it is required that the content of this policy, our ethical guidelines and Policy for sustainable procurement shall be followed. As part of the improvement work for a responsible supply chain, JWS has established a system to ensure systematic auditing and follow-up of suppliers, including checking that human rights and decent working conditions are safeguarded as described above.”

Compliance with the Norwegian Transparency Act (Transparency Act)

Act on business transparency and work with basic human rights and decent working conditions (the "Transparency Act") was implemented on 1 July 2022. JWS is covered by the scope of the Act, ref. Transparency Act §§ 2 and 3. Transparency Act § 4 requires JWS to carry out due diligence assessments on identifying actual and possible negative consequences for basic human rights and decent working conditions (ref. § 4 a-f). According to § 5 of the Act, the results of the due diligence assessments must be made public through an annual report. This document contains an account of the work with the Transparency Act that JWS has carried out in the period from July 2022 to June 2023. The purpose of the account is to provide information about the findings from the due diligence assessments, and which measures JWS has implemented.

Anchoring responsibility and compliance with requirements

The board of the company decided on responsible operation in accordance with the requirements of the Transparency Act on 19 August 2022. In this decision, the company's administration was made responsible for implementing these requirements in operations and towards all employees.

Establishment and introduction of policies

To ensure the necessary anchoring within the company and with relevant stakeholders, the following policies have been implemented:

• Policy for human rights and decent working conditions
• Policy for sustainable procurement
• Ethical guidelines

All employees are required to be familiar with the content of these policies. Furthermore, these policies have also been communicated to the company's most important suppliers.

Due diligence assessments

The procurement process and risk assessments of suppliers are important in the work to promote respect for basic human rights and decent working conditions. JWS has therefore carried out a survey of the most important suppliers/business connections related to the following theme:

• Implemented management systems
• Guidelines for respecting human rights
• Human rights assessments
• Guidelines relating to abuse, threats and mistreatment
• Procedures for minimum age for employment
• Freedom of organization and the right to a collective agreement
• Guidelines for discrimination based on race, gender, age, skin color, religion, disability, sexual orientation and ethnicity
• Guidelines that ensure reasonable working hours and fair remuneration
• Guidelines that ensure holidays and leaves of absence
• Guidelines that promote respect for social, ethical, and environmental standards in the supply chain in their companies and in their respective supply chains
• Process for obtaining information and transparency about the supplier's efforts related to ESG issues
• Guidelines or an action plan relating to remediation in the event of discovery of negative effects on ESG issues in the supply chain
• Responsibility for complying with local laws on health and safety regulations
• System for assessing health and safety risks
• Regular communication of guidelines, practices and expectations for health and safety to employees and suppliers

Results from the surveys have been subject to risk assessments based on

• geographic risk
• industry risk
• management system
• obligation in relation to JWS policies

JWS has also carried out a self-assessment relating to the same topics as for suppliers/business relations.

Results and measures

Based on completed risk assessments, we assess the following:

• Internal conditions: Low risk
  • Implemented measures:
    • Well established and communicated management system
    • Clearly communicated policies
    • Established notification routines
    • Good reporting culture and focus on improvement work
• Supply chain: Low/medium risk
  • JWS has some Norwegian suppliers with increased industry risk (Oil and gas)
  • Implemented measures:
    • Relevant requirements and policies covering suppliers have been communicated
    • Received acceptance from the suppliers of obligations to comply with requirements and policies
  • Planned future measures:
    • Auditing of the suppliers with the highest risk score according to their own plan
    • Close follow-up and cooperation with suppliers in case of any need for measures in the supply chain

Further follow-up and communication

JWS will report annually per 30 June on the company's further work and follow-up of the Transparency Act. Any measures in connection with further follow-up will be mentioned in the report. Information requirements in accordance with the Transparency Act are, as mentioned, handled according to a separate procedure. If information is needed, written inquiries to transparency@jws.no will be answered in accordance with the requirements of the law.