Bovet’s approach to the Transparency Act

The Norwegian Transparency Act, which came into force on 1 July 2022, aims to reduce the risk of human rights breaches and ensure decent working conditions in a company’s own activities, its value chain and at its partners. In addition to promoting human rights and decent working conditions, the Act will secure access to information.

Transparency Act Report 2022

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Bouvet’s business

As a consultancy, Bouvet is oriented towards the Norwegian and Swedish markets and operates in both public and private sectors.

The business comprises six regions and has 12 offices in Norway and three in Sweden. Its regional model ensures little bureaucracy and short decision paths, and gives scope for regional adaptation of the organisation and services in the six regions. That includes the operation of their own offices.

Bouvet has more than 1 870 employees and the business offers a broad range of services in information technology, design, communication and enterprise management. The ambition and values of the business support the autonomy of the individual region while providing the basis for sharing and for fellowship-based development. For more information about our employees, read the employee annual report.

Partners are used in circumstances where clients need expertise and solutions which Bouvet does not possess, and the business makes use of hired subcontractors where it lacks the capacity to meet demand.

Bouvet’s approach to due diligence pursuant to the legislation

Bouvet’s approach will comply with the principles in the OECD’s guidelines on responsible business conduct. Conducting due diligence will be integrated in Bouvet’s existing management system in accordance with the process outlined below.

Figure: OECD process for due diligence and support measures 1. Integrate responsible business operation in guidelines and management system 2. Identify and assess negative impacts in operations, supply chains and business relationships 3. Halt, prevent or reduce negative impacts 4. Monitor implementation and results 5. Communicate how the impacts are handled 6. Offer or collaborate on restitution where appropriate

The management system is owned by the CEO, with operational responsibility assigned to the group quality manager. Operational administration and training are organised through Bouvet’s regional quality and environmental managers. The COO, IT manager, chief information security officer (CISO), office managers and persons responsible for HR are closely involved in implementation, and are responsible for measures related to their functions.

An annual briefing is given to the board on the work and possible changes.

Overall results and Bouvet’s work on due diligence

An overall due diligence process has been conducted. Bouvet takes the view that it operates in a sector and at locations where the risk of breaches is low.

Reviews of suppliers and partners have revealed a high risk of breaches at international cloud and platform providers and at manufacturers of components and hardware. Bouvet takes the view that it unfortunately has very little opportunity to exert direct influence on these, but is in a dialogue with local representatives for the companies.

In order to work actively to halt and prevent negative effects, clear guidelines and obligations between Bouvet and its suppliers and partners when entering into agreements represent important preventive measures. Dialogue and collaboration are viewed as important measures in reducing negative impacts.

As part of the work of monitoring implementation and results, clear responsibilities and structures have been established as a further development of the existing management system.

Further work on preparing a statement

Bouvet will work on further integration of the Act’s requirements in its existing management system in order to incorporate due diligence as part of its continuous improvement process. The company will continue working on in-depth assessments, adopting the necessary measures and contacting priority suppliers. Initial work will be carried out in the autumn of 2022, and will thereafter be revised regularly and particularly in the event of changes to the risk picture. A statement pursuant to the legal requirements will be publicly available on Bouvet’s website no later than 30 June 2023.

More details

For more details, see the attached information on Bouvet’s approach and on the status of the work.

If you have direct questions about the way Bouvet handles actual and negative consequences for human rights and decent working conditions, use the following e-mail address to get in touch: [email protected]

Bouvet will respond to all enquiries within 21 days.