Transparency Act

Background
The Transparency Act came into force on 1 July 2022. The purpose of the Act is to ensure fundamental human rights and decent working conditions by requiring larger companies to conduct necessary due diligence assessments and publicly disclose their efforts and implemented measures.

Organization
The parent company, Haug & Buer Holding AS, is located in Halden. The group is organized as follows:

  • Parent company: Haug & Buer Holding AS

  • Wholly owned subsidiaries: Norcar AS, Norcar Logistics AS, Gamle Svinesundveien 140 AS, Norwagen AB (located in Sweden)

  • Partially owned companies: Sjø Eiendom AS, Norcar Denmark ApS (located in Denmark), Norcar Belgium BV (located in Belgium), Norcar Deutschland GmbH (located in Germany)

The business is hereinafter referred to as Norcar.

Operational Area
Norcar is a B2B dealer of cars and motorized vehicles, including logistics services related to vehicle supply chains. Within the group, there is also a property company with no external tenants.

Policies and Procedures
Norcar shall comply with the obligations of the Transparency Act and operate responsibly with regard to human rights and decent working conditions, in accordance with internal procedures. Norcar is a small organization with few employees, and its routines are anchored in management and well known to all staff. We strive to be a workplace characterized by equality and generosity.

Norcar will inquire how suppliers address these issues with their own subcontractors where it is considered appropriate and feasible, and in detail if necessary. Where deemed necessary, appropriate and feasible based on risk assessments, self-reporting will be used. We have zero tolerance for any illegal or unethical business conduct internally and among business partners.

Negative Impacts and Risk of Negative Impacts

Internal Conditions:
In a small organization with high activity levels, there is a risk that workloads can occasionally be high. This has not been identified as an actual consequence so far, but Norcar maintains a strong focus on the issue and keeps close dialogue with employees.

External Conditions:
The automotive industry has a complex and challenging supply chain with numerous factories and component suppliers worldwide. In addition, today’s battery technology contains raw materials often sourced from conflict areas or regions with weak human rights protections. This makes the due diligence process both important and demanding. A complete mapping of potential and actual negative impacts as a result of working with external suppliers is very difficult, if not impossible.

To reduce risk in the dealership chain, our suppliers and partners are primarily authorized brand dealers, importers, or large brokers with direct factory contact. In performing our logistics services, we use subcontractors from various parts of the world. The transport sector is also an industry that can be vulnerable to poor working conditions.

Measures
All employees at Norcar are required to familiarize themselves with the company's procedures related to the Transparency Act. Through our due diligence processes, we aim to identify, reduce, and avoid potential and actual negative impacts among business partners and throughout our supply chain. Mapping, identifying, and managing the impact on fundamental human rights and decent working conditions is an ongoing process.

To reduce the risk of negative consequences, our business is based on cooperation with large and reputable suppliers. Norcar will inquire how suppliers and subcontractors work with these issues where it is deemed appropriate and feasible, and in detail if necessary.