The Transparency Act

Our due diligence assessments are intended to enable us to identify, prioritise and address adverse impacts on people in our value chains, whether they arise directly in our own operations or indirectly through our suppliers or business partners.

The due diligence assessment is built around the UN Guiding Principles on Business and Human Rights and the OECD model for due diligence for responsible business conduct.

Being good at due diligence does not mean that a business has no adverse impact on people, society and the environment, but rather that the business is open and honest about its challenges and handles them in the best possible way in consultation with its stakeholders.

Anchoring responsibility and principles in guidelines and management systems

We have updated our code of conduct to comply with customer requirements and the requirements set out in the Transparency Act. The code of conduct applies to Leiv Sand Transport AS and wholly/partly owned companies, and has been approved by the board. Requirements have been included for how we are to relate to our supply chain and business partners.

We have developed new procedures for hiring and for following up third parties. We work continuously to ensure a responsible supply chain at every level. We will work to ensure that our suppliers and sub-suppliers have principles and procedures in place to actively prevent and address breaches of fundamental human rights and decent working conditions.

We will review the general contract terms with our suppliers when agreements are to be updated/renewed/entered into.

How we are organised

The board of Leiv Sand Transport AS consists of owners, an employee and external expertise, and is responsible for strategy, for setting direction for all work and for evaluating results from measures linked to the chosen strategy. The board assesses and approves reports relating to the Transparency Act — including carrying out mapping and analysis (due diligence) to uncover how our business may have an impact in relation to the requirements and purpose of the Transparency Act.

The implementation of decisions, analyses, necessary tasks and work is allocated to managers who have a function and responsibility for the relevant business area.

Which markets we operate in

The transport and logistics market in Europe.

Mapping and assessment of adverse consequences and risk

Leiv Sand Transport AS uses internal tools to keep track of our suppliers. This means that all our suppliers and business partners are mapped and information is entered into a database for further processing, and thus a due diligence assessment is carried out.

• We use information about our suppliers and business partners, their industry, country of production, and the products and services to be delivered, and assess these factors against established indices for country and product risk as described below.
• In cases where there is a higher inherent risk of breaches of human and labour rights, we will obtain further information about the supplier's work, procedures and requirements relating to human rights and decent working conditions.
• Leiv Sand Transport AS has established and will carry out risk assessments with respect to the inherent risk of breaches of fundamental human rights and decent working conditions.
• We use objective and internationally recognised indices for country and product risk.
• Where it concerns suppliers, the due diligence assessment shall aim to establish long-term contract-based relationships, be carried out ahead of contract signing and form an important element in supplier selection.
• The due diligence assessment is carried out based on information obtained from the supplier through tailored questionnaires, on further dialogue with the supplier in case of uncertainty, by gathering available information via open searches and publicly available databases, and where deemed necessary through checks performed by suitable third parties.
• Leiv Sand Transport AS categorises its suppliers as green, yellow or red based on information gathering and the subsequent due diligence assessment.
• It is an overall objective that the entire supplier base is green, but in some cases this will require changes over time.

For suppliers at green level, the due diligence assessment indicates that there is minimal risk of adverse consequences in the supplier relationship and that no measures are taken. For suppliers at yellow level, we consider there to be a moderate risk of adverse consequences in the supplier relationship, and that through further dialogue with the supplier we seek to minimise the risk of adverse consequences. For suppliers at red level, we consider there to be a clear risk of adverse consequences, and our objective is to reduce our connection with the supplier and/or influence the supplier in a positive direction.

Preventing, reducing or stopping adverse impact / harm

• Leiv Sand Transport AS shall actively prevent, reduce or stop breaches of human and labour rights.
• Any non-conformities in our own operations we will correct ourselves.
• If non-conformities occur at a supplier or business partner, the appropriate measures will be assessed more closely based on the type of breach and depending on Leiv Sand Transport AS' influence in the individual case.
• We shall follow up that improvement measures are implemented and maintained.

We shall cooperate with other organisations and companies in the transport/logistics industry to integrate the preventive work into the internal controls of our shared suppliers.

Measures

As described above, we will implement measures if a customer initially comes out with yellow or red risk. The measures that can be implemented are:

• Follow-up questionnaire to the customer.
• Follow-up meeting with the customer.
• Code of conduct / ethical guidelines where the customer signs that there are no adverse consequences relating to their deliveries to Leiv Sand Transport AS.
• Termination of the supplier if necessary.
• Reduction of deliveries from the supplier as far as possible.
• In extreme cases where it is not possible to procure goods or services without adverse consequences, this may have consequences for what we can offer onward to our customers.

As described above, in the event of suspicion of possible adverse consequences, Leiv Sand Transport AS will enter into dialogue with our suppliers to clarify the facts. Should actual adverse consequences be uncovered in the supply chain, Leiv Sand Transport AS will, in dialogue with affected and/or particularly vulnerable groups, seek to remedy these in a reasonable manner.

Leiv Sand Transport AS has prepared and updated policy and a code of conduct for employees and suppliers. Changes have been made to the management system, and other necessary routines have been prepared to meet the requirements of the Transparency Act. Leiv Sand Transport AS is very positive about this legislation and has high expectations that it will serve its purpose.