Cloudberry Annual report 2022 Sustainability report 74 be assessed and documented before FID. In tender processes Cloudberry pre-screens new suppliers and partners with a pre-qualification related to material ESG topics. This ensures awareness and commitment to sustainability in the value chain. In accordance with the Norwegian Transparency Act, Cloudberry has incorporated human rights due diligence in accordance with the OECD guidelines for Multinational Enterprises and the United Nations Guiding Principles for Business and Human Rights. Our activities The act relating to enterprises’ transparency and work on fundamental human rights and decent working conditions (the Norwegian Transparency Act) came into force in 2022. The main purpose of the Act is to promote companies’ respect for fundamental human rights and decent working conditions in connection with the production of goods and provision of services. As a company affected by the law, Cloudberry conducted a risk assessment in accordance with OECD guidelines based on ISO31000 for managing risks, to address the requirements for due diligence in accordance with the legal framework. The process was conducted through several interviews and workshops with key personnel with insight into relevant value chains, including the top management. Cloudberry’s suppliers are international, national, and local. In the due diligence assessment, we have primarily looked at the risk associated with players with direct supply to the entire business. In many contexts, Cloudberry uses large suppliers over which it has limited influence. The work around the due diligence assessment therefore focused on those suppliers and business associates where Cloudberry is a direct legal counterpart and has a real opportunity to influence. The due diligence assessment related to the Transparency Act is published on our website. A list of concrete initiatives and measures was developed to reduce the likelihood of the identified threats and to strengthen Cloudberry’s ability to deal with them if they do occur. The measures mainly focus on reinforcingCloudberry’s inquiries into the status of human rights and decent working conditions related to suppliers. This involves, among other things, increased supplier dialogue on these topics as well as clarifying internal routines and responsibilities to employees authorized to make procurements (project managers, business unit leaders etc). This increases their awareness of the content, and adherence to, the Transparency Act. Way forward In accordance with these findings and the identified improvement measures, Cloudberry currently develops the necessary guidelines, internal systems, and routines for conducting due diligence assessments and complying with other obligations of the Transparency Act. The company will publish a report on the due diligence assessment in accordance with the expectations of the Transparency Act by 30 June 2023. The report will be made publicly available on Cloudberry’s website. Cloudberry acknowledges that due diligence assessment is a dynamic and continuous process as circumstances in the organization’s operating environment are constantly changing. We will develop routines and systems to work preventively to mitigate potential negative impacts of our operations. Accordingly, the company will establish risk-based audits in the supply chain to secure the best risk management and practice on environmental, social and governance topics within the supply chain. We believe that securing responsible business conduct and good governance, internally and in our value chain, contribute to a long-term positive reputation making Cloudberry a desirable employer and business partner. Cloudberry adheres to good governance standards and always seeks to live up to the Norwegian Code of Practice for Corporate Governance (the “Corporate Governance Code”), last revised on 14 October 2021. The Code is available at the Norwegian Corporate Governance Board’s NUES website. Our adherence includes disclosure and transparency throughout our business to provide shareholders and stakeholders with accurate and up to date information about Cloudberry. For more detailed information on Corporate Governance Code please confer Cloudberry`s Corporate Governance Report 2022, also available in the Annual Report 2022. Contact person for this sustainability report: Suna F. Alkan, Chief Sustainability Officer sa@cloudberry.no
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