Transparency Act

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AZIWELL GROUP – TRANSPARENCY ACT

1. Introduction AZIWELL GROUP ("AZIWELL") is committed to ethical business practices and compliance with the Norwegian Transparency Act ("Åpenhetsloven"). This document outlines our approach to due diligence, our policies, and actions to ensure respect for human rights and decent working conditions throughout our operations and supply chains.

2. Company Information: AZIWELL has it’s headquarter in Norway, and delivers services and has local establishments mainly in North America, South America and Europe. For information on business model and products, please see the website (www.aziwell.com) or the Annual Report.

3. Commitment to Human Rights and Decent Working Conditions AZIWELL is dedicated to conducting business responsibly. We adhere to international standards, including the UN Guiding Principles on Business and Human Rights and the OECD Guidelines for Multinational Enterprises. We ensure our operations do not infringe upon human rights and that our partners follow fair labor practices.

4. Due Diligence Process AZIWELL's due diligence process follows a structured approach to identify, assess, and address risks related to human rights and decent working conditions. This includes:

4.1. Risk Assessment: Regularly identifying and assessing risks within our own operations and our supply chains. This assessment considers factors such as geographical location, industry sector, and nature of the business relationship.

4.2. Preventive Actions: Implementing measures to prevent and mitigate potential risks. This includes contractual clauses, audits, and collaborations with partners to improve working conditions.

4.3. Monitoring and Evaluation: Continuously monitoring and evaluating the effectiveness of our actions. This involves conducting regular supplier audits and engaging with stakeholders to address concerns.

4.4. Reporting and Transparency: Publishing an annual report detailing our efforts, findings, and actions taken to improve human rights and working conditions.

5. Policies and Governance
• Code of Conduct: AZIWELL has established a Code of Conduct that sets out the expectations for our employees and business partners. It emphasizes the importance of compliance with labor laws, respect for human rights, and environmental responsibility.
• Supplier Code of Conduct: We require all suppliers and partners to adhere to our Supplier Code of Conduct, which aligns with our commitment to ethical business practices. This includes requirements related to working hours, wages, health and safety, child labor, forced labor, and environmental sustainability.
• Whistleblower Policy: AZIWELL encourages transparency and accountability by providing a safe and confidential platform for employees, suppliers, and partners to report any concerns related to unethical behavior or breaches of human rights. A whistleblowing policy and a channel for employees to voice concerns have been implemented.  

6. Risk Identification and Management AZIWELL’s risk identification involves a systematic review of our supply chain. We categorize risks into high, medium, and low based on the following factors:
• Country of Operation: Higher risks associated with suppliers operating in regions with known labor rights issues.• Industry-Specific Risks: Risks unique to the drilling and engineering sectors, such as hazardous working conditions.
• Supplier Practices: The history and reputation of suppliers regarding ethical labor practices.

7. Actions to Address Risks
• Supplier Audits: AZIWELL plans to conduct regular audits of its main suppliers, focusing on compliance with labor laws, health and safety standards, and environmental regulations.• Capacity Building: We work collaboratively with suppliers to improve working conditions, provide training, and promote best practices in the industry.
• Engagement with Local Communities: By engaging with local communities where we operate, we ensure that our projects benefit local stakeholders and do not negatively impact human rights.

8. Reporting and Communication AZIWELL is committed to transparent communication regarding our due diligence efforts. We will publish an annual Transparency Act Report, which should include:
• Results of risk assessments
• Actions taken to address identified risks
• Progress and areas for improvement
• Future plans for strengthening our due diligence process

9. Use of independent contractors abroad As part of our business model, Aziwell buys services from independent contractors based in other countries. During 2024, Aziwell reviewed the contractor group and found it to be a low-risk group.If anything changes to the group, we are committed to auditing independent contractor salaries and working conditions, including a salary benchmark. All independent contractors have flexible agreements when performing services for Aziwell. However, Aziwell, are considering, as part of the ongoing process for improving working conditions for our external contractors, to hire these as Aziwell employees, to ensure that all aspects of their work environment is within the Aziwell standard. This will be an ongoing consideration and will be part of the yearly reporting.

10. Contact Information For further information on AZIWELL's due diligence process and Transparency Act compliance, please contact the Group CFO.

11. Annual Update AZIWELL will follow-up on the status of all the actions in every annual reporting period, to include items as:

• Further embed human rights and decent working conditions considerations in our assessment, decision-making processes, and policies.
• Continue focusing on partnerships and content which drives awareness of human rights and decent working conditions.
• Continued focus across the group on human rights and decent working conditions related to procuring, e.g., hardware, electronics, etc.
• Continue to educate employees in our Code of Conduct and encourage employees to promote our company values in every aspect of their function

12. Revision and Updates This documentation is reviewed and updated annually to reflect changes in legislation, company policies, and global best practices.