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Statement of due diligence assessments Trafsys AS and Norphonic AS (hereinafter referred to as the Company)

The Transparency Act came into force on 1 July 2022. The purpose of the act is to promote companies’ respect for basic human rights and decent working conditions in connection with the production of goods and the delivery of services, as well as to ensure that the public has access to information about how the individual business handles negative consequences for such human rights and working conditions.

The Transparency Act emphasizes that the company’s strategic direction on sustainable development, which includes both climates, working environment and people. This strategic direction of sustainable development, extended to include people and their basic human rights and decent working conditions, is enshrined as a core investment in the company’s strategic foundations.


A general description of the company’s organization, operating area, guidelines, and routines for dealing with actual and possible negative consequences for basic human rights and decent working conditions.

The company has a quality system that has been established, documented, and maintains a system for quality and environmental management and continuously improves its effectiveness in accordance with the requirements of NS-EN ISO 9001, ISO 14001 and ISO 45001. The system for quality and environmental management is built up with procedures, manuals, and routines. Process descriptions, work instructions, document templates and quality plans are covered in the Quality Systems’ Level 4. From July 2022, the Transparency Act has been drawn up regarding creating good documentation for implementation in the Quality System. This is to be as well-equipped as possible regarding the requirements of the law.

In the quality system, we have created several new documents, as well as making changes to other documents. The new and most central documents are:

  • Due diligence assessment/risk assessment form
  • Privacy statement
  • Declaration on business ethics and social responsibility/Code of Business Conduct
  • Action plan – The Transparency Act

Information about actual negative consequences and significant risk of negative consequences that the Company has uncovered through due diligence assessments.

According to Section 4 of The Transparency Act, the company has an obligation to carry out soundness assessments. This means that the company must anchor responsibility in the company’s guidelines, map actual and potential negative consequences for basic human rights and decent working conditions, implement suitable measures to stop, prevent of limit negative consequences, monitor the implementation and results of such measures, communicate with affected parties, stakeholders and rights holders about how negative consequences have been handled, as well as ensuring of collaborating on recovery and compensation where this is required.

The work on due diligence assessments has started. A checklist has been drawn up, but there has not been time to make a specific assessment yet. No incidents/situations have arisen in relation to our collaboration partners and suppliers that would indicate that there was reason to carry out a due diligence assessment. The starting point of the first due diligence assessment of the supplier to be carried out will be due to the supplier’s geographical location.


Information about measures that the business has implemented or plans to implement to stop actual negative consequences or limit significant risk of negative consequences, and the result or expected results of these measures.

Some of the company’s larger suppliers are foreign and have different explanations on their websites about relation with CSR (Corporate Social Responsibility) and OECD guidelines. By virtue of its position and size, the company has a particular for, and the opportunity to influence in a positive sense, compliance with and protection of basic human rights and decent working conditions.

In the work so far, no negative consequences or risk of negative consequences have been uncovered, nor have any measures been taken to date. It is important to note hat this is ongoing work that will continue in accordance with the Action Plan and the report to meet the requirements of the Transparency Act. Based on a risk assessment, we will send out requests for information to suppliers that we believe must be assessed concretely and more thoroughly that a category assessment of suppliers.

This is a statement from the company about our organization, scope, guidelines, and routines for dealing with actual and possible negative consequences for basic human rights and decent working conditions in line with the Public Disclosure Act. It also provides information on any negative consequences or risk of such consequences through due diligence assessments as well as measures that have been implemented to stop actual negative consequences or limited risk of negative consequences.

Assessments and measures carried out in 2023 show that we conduct business in accordance with our policy for sustainable development and that our operations are in accordance with the intention and purpose of the Transparency Act.

Updated April 5th 2024