Transparency Act Statement

The Transparency Act came into force on 1 July 2022. The main purpose of the Act is to promote respect for fundamental human rights and decent working conditions. The Act also ensures that the public has access to information about how companies handle their human rights risks.

Introduction and Background

The Transparency Act requires Norfra AS and its subsidiaries to:

• carry out due diligence assessments in accordance with the OECD Guidelines for Multinational Enterprises;

• report on our work with due diligence related to human rights and decent working conditions;

• respond to information requests from the public.

Norfra AS has since the Act came into force worked systematically to establish a comprehensive system to address human rights and labour condition risks in our operations, supply chain, and with our business partners. We are committed to building long-term, trust-based relationships based on professional expertise and integrity, and we aim to provide transparency about our work with human rights and decent working conditions in our annual report.

Our Business and Area of Operation

Norfra AS is a Norwegian-owned seafood group specialised in purchasing, producing, selling, and exporting high-quality Norwegian white fish products to the global market. Norfra AS was founded in 1994 and today offers a range of high-quality seafood to customers in many countries. Norfra exports products annually. We only supply seafood of the highest quality, caught by the coastal fleet and handled carefully to ensure freshness upon delivery. The Norfra Group has its headquarters and export company in Tromsø and production facilities in several locations in Norway.

Commitment and Policy

This statement describes our policies and routines for handling risks related to human rights and decent working conditions. Norfra Group is committed to acting responsibly and ensuring respect for fundamental human rights and labour rights. Our human rights policy and ethical requirements for suppliers guide this work. These policies require compliance with internationally recognised human rights principles, including the UN Guiding Principles on Business and Human Rights and relevant parts of the OECD Guidelines.

Risk Assessment

The Norfra Group has carried out a risk assessment to identify actual and potential negative impacts or human rights violations at both corporate and supply chain levels. We use frameworks based on international human rights and due diligence guidelines to prioritise risks and potential impacts.

The risk assessment did not identify any actual negative impacts or human rights violations caused by Norfra or its affiliates during the reporting period. For more detailed information about the risk assessment results, inquiries can be directed to the Transparency Act contact address.

Preventive Measures and Actions

To address the identified risks, we have implemented a plan that includes general risk-reducing measures and targeted actions for priority risk areas. These measures include developing governing documents for our human rights and decent working condition efforts, collecting documentation from suppliers, and gathering statistical information about working conditions in our subsidiaries.

Ongoing Work and Future Plans

In the coming year, we will continue to improve our due diligence processes and build competence related to human rights and decent working conditions. Due diligence assessments will be carried out annually and when there are material changes in risk profiles. Norfra will publish reports and respond to information requests as required by the Transparency Act.