Purpose
The procedure aims to ensure that our business, Kraft Finans, and our collaboration within the supply chain promote the objectives of the Freedom of Information Act. This includes respect for fundamental human rights and decent working conditions in the production of goods and delivery of services, ensuring public access to information on how businesses handle adverse impacts on fundamental human rights and decent working conditions.
The procedure aims to ensure that Kraft Finans fulfills requirements to conduct and account for due diligence assessments while meeting transparency obligations under the Freedom of Information Act.
Scope
The procedure covers due diligence assessments related to direct and indirect purchases within our business. Due diligence assessments are conducted using a risk-based approach through our risk system, Ignite.
Responsibility
The management and the board hold overarching responsibility for the procedure and, in collaboration with responsible professionals, ensure due diligence assessments are carried out in various parts of our business areas.
Description
The implementation of due diligence assessments should be based on the OECD’s model for due diligence assessments in responsible business conduct.
Conducting Due Diligence Assessments
Due diligence shall be conducted as follows:
Due diligence assessments are to be conducted at least once a year.
Risk profiling related to our purchases of goods and services.
We shall seek available information about supply chains and risk profiling from industry associations we are affiliated with and other relevant entities.
Based on risk profiling, priority is given to areas where improvements and measures should be prioritized.
The results of risk profiling are documented in a written report. This report, as per the Freedom of Information Act, is made easily accessible on our business’s website.
In accordance with the Freedom of Information Act, we disclose in the annual report where the report is accessible and update and publish the report by June 30 each year.
Measures
Based on risk profiling, specific measures are assessed and decided upon by responsible parties.
Measures can be implemented directly with the supply chain or in collaboration with partners in the same industry as Kraft Finans.
Changes
If our business within a procurement area becomes aware of significant changes in supply chains, responsible parties shall follow up and, if necessary, revise due diligence assessments, documenting this in a written report.
Follow-up
During the execution of due diligence assessments, the responsible compliance officer shall ensure follow-up and evaluation of measures.
Deviation
Upon suspicion of breaches of contractual obligations related to the Freedom of Information Act, deviations shall be reported to management. We will then follow up with the respective suppliers to our business. Deviation handling is documented in a written report.
Handling
As per the Freedom of Information Act, anyone has the right to request information in writing about how our business manages actual and potential adverse impacts related to human rights and decent working conditions within our supply chains. This includes both general information and information related to a specific product or service the business offers. If we receive information requests, Compliance (adv@kraftfinans.no) should be contacted for response and management of the information request.
References
Freedom of Information Act on Business Transparency and Work on Fundamental Human Rights and Decent Working Conditions (Freedom of Information Act, LOV-2021-06-18-99).
