Transparency Act Statement
Transparency Act statement for the period July 1, 2022 – June 30, 2023
Our mission at AaPW is simple: we work to protect. How? By developing a product portfolio ranging from high-visibility clothing for construction workers and life jackets that save lives, to waterproof leisure garments for an active urban and outdoor life.
Many of the products we supply, are used by people with risky work tasks – both on land and at sea. They need to feel safe at work and must be able to trust our garments to function as promised.
However, our customers should not only trust the final product. We also want them to have confidence in us as well as our actions – from how we act to the way we take care of our nature and our responsibility in the supply chain.
Quality at every level
One of our most important focus areas is to deliver high-quality products that last over time. This means that we have strict requirements for our manufacturers and their work. All AAPW’s employees work according to basic ethical principles, as expected by our business partners.
Our products consist of different elements like textiles, zippers, and reflective materials. Most of them are raw materials coming from outside Norway and the Nordic countries. AAPW's suppliers must comply with the same standards as the ones we require from ourselves, i.e., to run the business without compromising basic human rights and decent working conditions.
Ethical trade in Norway
Aalesund Protective Wear became a member of Etisk handel Norge (Ethical Trade Norway) in 2022, and we delivered our first report in February 2023. By being a member of Etisk handel, we achieve validity for our own ethical guidelines, as well as the guidelines we communicate to partners and manufacturers. In addition, we commit ourselves to perform a thorough review of how we promote and collaborate for a trade ensuring human rights, labour rights, development, and the environment.
Etisk handel is an excellent partner to support our work, and the membership provides us with expertise and challenges us on how to improve even more.
Would you like to know more? Download and read our policy for ethical trade.
The Transparency Act
The Transparency Act came into force on July 1st 2022, requiring both AAPW and other companies to be more open and transparent about how we affect the world around us.
The law will contribute to reducing the risk of businesses causing or contributing to violations of human rights. It also encourages us do our part to ensure decent working conditions, both from our suppliers and ourselves.
In addition, the Transparency Act requires us to carry out due diligence assessments to understand the risk of possible breaches, as well as to identify where measures must be taken. We are also obliged to inform about the basis for the due diligence assessments and their results.
Due diligence assessments
We carry out due diligence assessments of our own business as well as our suppliers, to ensure that our operations do not come at the expense of basic human rights and decent working conditions. The assessment is carried out by different parts of the organisation. The primary responsibility for the purchasing department, for example, are AAPW’s suppliers, while others carry out due diligence assessments regarding our selection of raw materials, manufacturers, and purchases.
The guidelines for due diligence assessments from the OECD also require us to carry out due diligence assessments in connection with various business decisions, and this is a legal requirement in line with other laws and regulations. We will for example implement this when establishing new business areas, launching new products, or acquiring other businesses. AAPW’s work is based on risk, and both risk assessments and analyses are part of our management system.
We are certified according to ISO 9001, and this is a part of our procedures/routines. Environmental issues and anti-corruption are also included in AAPW’s due diligence assessment.
Procedure and process
The process for due diligence assessments in AAPW is based on the «OECD's guide for due diligence assessments for responsible business», cf. the Transparency Act. We start by clarifying whether the due diligence assessment in question is already in process or has been previously carried out. Here, we can also make use of existing documentation and knowledge.
Our first step is to create an overview of all suppliers and manufacturers, and then carry out an overall risk assessment of home country, risk raw materials and country of origin for each of them. Based on this assessment, we are left with a list of suppliers where there may be risks related to human rights, decent working conditions, the environment and anti-corruption.
The next step is to carry out a detailed assessment of the risk list. We start with looking at the findings against the documentation and the knowledge AAPW has collected about the suppliers in question. Normally, the supplier's risk will be handled, and the supplier will receive a new low-risk status. For suppliers who have not handled the risk yet, we will obtain necessary information and documentation to further explore the risk. After making a new risk assessment, the supplier either receives the status "low risk" or "high risk". If the risk is high, the supplier will proceed the process by taking the next steps using a tool developed by Etisk handel. This is called the “salient risk tool” and consists of analysing and assessing the significant risk and where it is located.
In special cases, where the risk of breach is high or a breach is discovered, the case will be raised as a contingency issue and handled in accordance with AAPW's internal process. Measures will be drawn up and planned to reduce the uncovered risks. These may include local audits, changes to contracts and measures to stop or reduce the negative impact. Necessary internal and external resources will be involved, and an action plan for the responsible party(ies) will be set up.
Time has then come to go through with the chosen measures, which will be continuously documented to reveal if they are actually having the desired effect. The next phases involve evaluation and learning. We confirm that the measures taken have solved the previously identified risk and reduced the negative impact. Furthermore, we conduct evaluation meetings and propose improvements to avoid similar situations in the future.
Among other things, AAPW's suppliers are selected based on their product and raw material, operating country, and the size (volume) of our purchase from them. The qualifying tool and the criteria used as a basis for selecting suppliers will be constantly assessed and updated. Our aim is that the tool will consider any new issues that may arise, for example relating to human rights and working conditions.
Based on specific criteria, our risk tool has automatically identified that 100 of our 398 suppliers are subject to a more detailed risk assessment. A closer manual evaluation reduced the number of suppliers significantly, down to 48 in total. These remaining suppliers were then tested against our due diligence assessment process.
Due diligence assessments of AAPW's supplier database will normally be repeated annually or in the event of significant changes. New suppliers will be carefully assessed in connection to a pre-qualification. This routine has been incorporated as part of ISO 9001.
The tool developed by Etisk handel uses solid and recognized sources to assess risk. The sources quantify the degree of risk, an important element when it comes to carrying out risk assessment in an objective way. All sources update their assessments and data annually, which coincides with our annual due diligence assessment policy. These are the sources we have used as a basis for due diligence assessments of suppliers:
|Land risk||ITUC-rapport 2022 (countries with tough conditions for workers/employees)||International Trade Union Confederation - Building Workers’ Power|
|Child labour||UNICEF, Percentage of children in employment | Human Development Index||UNICEF's Child Labor Statistics|
|Wages, wage level, living wage||Wage indicator||WageIndicator.org|
|Environment||Environment Performance Index||Yale Center for Environmental Law & Policy|
|Corruption||Corruption Perception Index||Transparency International|
|Human Rights/Labour Standard||DFØ Product Risk||Høyrisikolisten | Anskaffelser.no|
|Multiple Risk Categories||MVO Risk Checker||MVO Risk Checker / MVO Nederland|
An important part of the risk assessment work is that the tool provides limit values, calculated by the tool based on the sources we use (see table above). Suppliers in countries with points below the limit values, who use raw materials or carry out their operations/activities in countries below the limit values, are automatically given a high risk in the tool. These will further be passed on to detailed analysis and identification of significant risks in the next step of the tool.
This is shown in the following model:
If we uncover risk or see that there is a danger of risk – i.e., we see a significant risk of infringement of rights – this manufacturer will be asked to explain the situation.
During this first inquiry, the request will ask for an explanation. If the report does not show satisfactory conditions, the manufacturer will be given a deadline to document that an improvement of the conditions has been made or reported satisfactorily. If the conditions are not rectified, the producer will ultimately be taken out of business.
Having said that ‒ we are aware of our responsibility. We know that the survey does not absolve us of conditions that may already have arisen while they were producing for us. In such cases, we must try to restore the conditions the best possible way. Where possible, we will do this in collaboration with local trade unions or similar.
Our measures to reduce risk
After having completed the risk map, we did not uncover any actual negative conditions. Neither did we find any significant specific potential risks. Going forward, we will focus on carrying out measures where we prevent them from occurring, especially deeper down in the supply chains. These will be the following measures for the future:
- Strengthen the cooperation within the supply chain: Set common goals and invest in the supply chain through dialogue and the development of skills.
- Support a free trade union organization and collective negotiations.
- Explore deeper into the supply chain: We need to find out more when it comes to the supply chain for cotton. We must look at the conditions under which our raw materials are produced, conditions in the transport system, and the like.
- Reduce the environmental and climate footprint in the supply chain: We must set up a climate account for 2023, hence Scope 3 according to the GHG (Green House Gas protocol). Dialogue and eventually requirements for suppliers to deliver quarterly data on emissions.
Our suppliers and producers must sign and accept our Code of Conduct.
Statement submitted to Ethical trade Norway
Our Transparency Act statement is signed by the board and has been submitted to Ethical trade Norway. You can see AAPWs signed statement here (in Norwegian only).
Do you have any questions?
If you have questions related to how we handle the Transparency Act, please feel free to send an e-mail to Bodil Molvik, our Sustainability and Compliance Specialist.