Inchcape Shipping Services approach to the Norwegian Transparency Act

The Norwegian Transparency Act, which came into force on July 1, 2022, aims to reduce the risk of human rights violations and ensure decent working conditions in the company’s own operations, in the value chain and with partners. The Norwegian law is intended to promote human rights and decent working conditions, while also ensuring access to information.

The law intends to:

a. Increase corporate responsibility and understanding of risk
b. Ensure human rights and decent working conditions for everyone in the value chain
c. Integrating social aspects into business strategy
d. Increase the victims access to compensation
e. Statutory requirements for processing and reporting:

Businesses must respect human rights and ensure decent working conditions. The basic human rights or decent working conditions include, among other things:

1. Slave labour / forced labour
2. Unionization and collective bargaining
3. Child labour
4. Discrimination
5. Brutal treatment
6. HMS
7. Wages and salaries
8. Working hours
9. Regular appointments
10. Living and sanitary conditions
11. The rights of indigenous peoples
12 Involvement of local communities

This applies to our own operations, business partners and supply chain. Businesses have a duty to conduct due diligence on human rights and decent working conditions. Measures must be implemented to rectify any negative consequences of the business. The law gives the right to insight and transparency in how the company works with the requirements of the Transparency Act. The supervisory authorities have the opportunity to impose sanctions for violations.

About Inchcape Shipping Services
Inchcape Shipping Services, portfolio company of private equity fund Epiris, is a leading Port Agency and Marine Services provider. Since 1847, Inchcape Shipping Services has provided the local knowledge and means to deliver port calls that enable businesses to ship smoothly and trade successfully.

Inchcape combines its worldwide infrastructure with local expertise through its global network of over 253 proprietary offices across 60 countries and a team of over 3,200 committed professionals. Our unique geographical footprint means we can offer customers a full range of marine services, delivered safely, transparently and with exceptional service wherever they are in the world.

Our diverse global customer base includes owners, charterers, and ship managers in the oil and gas, cruise, container, and bulk commodity sectors, as well as naval, government, and intergovernmental organisations.

Inchcape’s Norwegian operations consist of Port Agency Services and Terminal Operations.

Our approach to due diligence in relation to legislation

Inchcape Shipping Services is committed to respecting international human rights. The company has anchored its commitment in international human rights and labour standards, including those expressed in the International Bill of Human Rights and the Declaration on Fundamental Principles and Rights at Work. We are committed to the OECD Guidelines for Multinational Enterprises and the United Nations Guiding Principles on Business and Human Rights (UNGP).

Inchcape ensures the development of routines and guidelines, as well as the cooperation and internal learning among key employees. The company is responsible for conducting due diligence, risk assessments related to countries, input factors and suppliers, and developing appropriate measures to manage and limit risk, also in its supply chain.

Inchcape’s guidelines and due diligence assessment in connection with the Transparency Act are incorporated into Inchcape’s management system. This is the basis for the company’s certification in Quality (ISO 9001).

The management system covers the main process of the company, as well as support processes such as management and strategy, human resources/finance and accounting, HSE/quality/risk, business development and procurement. Inchcape works continuously to improve the management system, systems and routines.

As part of the implementation of the requirements under the Transparency Act, Inchcape has implemented the following:

a. Conduct internal audits to identify procedures and policies that need to be updated.
b. Introduced the Transparency Act in the Compliance Assessment Matrix for continuous monitoring and assessment.
c. Recertified ISO 9001 in 2024 with DNV.

Risk and measures

We have mapped Inchcape Norway’s greatest risk related to, directly or indirectly, contributing to violations of human rights and decent working conditions. The following risks areas and measures have been identified:

a. Industrial terminal operations: Crane operations and the handling of heavy machinery are demanding. Measures to ensure that these operations meet requirements for decent working conditions include strict routines for training, processes and HSE.
b. Procurement of services in the ship agency business: The ship agency business has a wide range of subcontractors and partners, and there is a risk that subcontractors do not act in accordance with the requirements. Measures to ensure that requirements are met include performing a due diligence of all subcontractors before they are used by Inchcape.

Inchcape will actively work to ensure that possible violations of human rights by subcontractors are detected. We will also encourage all our subcontractors to prepare/maintain a ‘supplier code of conduct’.

Our assessment

It is our assessment that Inchcape operates in industries and locations where there is a low risk of violations of key areas such as privacy, human rights conditions and business conduct. We consider our subcontractors used in customer assignments to represent low risk. Services and products are delivered by skilled companies with experience and trained personnel in an orderly and transparent labour market in Norway. We consider other subcontractors nationally and internationally to be low or medium risk and these are followed up regularly in accordance with other procedures.