Modern Slavery Statement

EcoOnline and its subsidiaries (the “Group”) is committed to preventing acts of modern slavery and human trafficking from occurring within its business and supply chain and imposes the same high standards on its suppliers. In this context, we believe that the Modern Slavery Act 2015 is a significant step in encouraging companies to identify and tackle the risks of modern slavery, human trafficking across business operations and in supply chain.

EcoOnline is a software-as-a-service (SaaS) provider developing innovative solutions to help ensure workplace safety in a sustainable and efficient way. Product coverage includes areas such as chemical safety, health & safety (EHS), learning management, lone worker safety, whistleblowing, compliance management, and environmental, social and governance (ESG).

EcoOnline has a global presence, serving more than 10,000 customers in multiple countries, and maintains a diverse workforce of 900+ employees.

The Group is headquartered in Oslo, Norway, and operates business units in Norway, Sweden, Denmark, Finland, the United Kingdom, Ireland, Germany, Canada, the United States, and New Zealand.

To find out more about the nature of our business, please click here.

In order to deliver SaaS solutions and become the preferred provider of EHSQ tools and services, we work with a range of suppliers. At the Group, we put our suppliers into four different categories: Infrastructure critical; strategic business services; other technology providers; and other business services. Infrastructure critical suppliers include service hosting providers and providers of security monitoring services. Strategic business service providers include financial services institutions, insurance providers, consultants, and law firms. Other technology and other business services providers include those who provide tools and services supporting our day-to-day activities, but our critical for delivering the services to our customers.

Considering the global nature of our business, and the need to engage a wide range of suppliers, we understand that there may be human rights deviations within the value chains. However, we will not tolerate a culture that does not seek to remediate any such deviations. We are working toward the eradication of all forms of forced labour and Modern Slavery, and we fully understand the duty to respect human rights.

As a part of our commitment to combating modern slavery and human trafficking, we have implemented the following policies: Code of Conduct; Supplier Code of Conduct; Anti-Bribery and Corruption Policy; Anti-Money Laundering and Counter Terrorist Financing Policy; Recruitment Policy; Equal Opportunity Policy; Grievance Policy; Gifts and Entertainment Declaration Procedure; Business Partner Due Diligence Procedure; and Whistleblowing Policy.

All employees are required to familiarize themselves and comply with the policies. All policies are made available in the common repository and are communicated regularly.

As part of our efforts to monitor and reduce the risk of slavery and human trafficking occurring within our supply chains, we have adopted the following due diligence procedure that must be completed before we sign new agreements contractors, consultants, collaborators, outsourced service providers and others who perform services for or on behalf of the EcoOnline Group (henceforth called “Business Partners”):

1. The Business Partner must respond to self-assessment questionnaires covering human rights, decent working conditions, environmental responsibility, information security, and data protection.
2. The Business Partner must demonstrate that they have a policy prohibiting bribery and corruption or sign ours.
3. We undertake an independent assessment to identify and assess actual and potential adverse impacts on fundamental human rights and decent working conditions, by considering geographic risk, sector & product risk, enterprise level risk, and relationship risk.
4. Lastly, we also screen all entities using third party software against an international database covering sanctions, adverse media, and state ownership.

Our procedure is designed to:

• Establish and assess areas of potential risk in our business and supply chain
• Monitor potential risk areas in our business and supply chain
• Reduce the risk of slavery, human trafficking, sanctions program violations, bribery and corruption, money laundering, terrorist financing, and breaching of data protection regulations occurring within our business and supply chain

The Group regularly evaluates the nature and extent of its exposure to the risk of modern slavery occurring in its business and supply chain by having adopted the OECD due Diligence Guidance for Responsible Conduct of 2018. This guidance represents a common understanding among government and stakeholders on due diligence for Responsible Business Conduct (“RBC”).

Our strategy therefore consists of six components:

1. Embed responsible business conduct into policies and management systems.
2. Identify and assess actual potential adverse impacts associated with the enterprise’s operations, products, or services.
3. Cease, prevent, and mitigate adverse impacts.
4. Track implementation and results.
5. Communicate how impacts are addressed.
6. Provide for or cooperate in remediation when appropriate.

Considering that the Group’s core business is to provide SaaS solutions to make workplaces safe, sustainable, and efficient, and our core markets are in Western Europe, North America, and New Zealand, we do not consider that we operate in high-risk sectors or locations.

Given that all Business Partners that the Group engages which involve some level of human interactions and cooperation over time are in scope of the full Due Diligence process, potential risks will be identified, investigated, and mitigated in collaboration with the relevant Business Partner and internal stakeholders.

We enforce a strict code of compliance and do not tolerate slavery and human trafficking within our supply chain. For example, we always seek to insert contractual clauses binding each party to comply with all applicable state, national, and international laws, rules, and regulations relating to ethical and responsible standards of behaviour, including, without limitation, those dealing human rights. If we find evidence of failure to comply with the rules, we will seek to terminate our relationship with the relevant supplier.

Based on an assessment of the Group's activities, and the Group's 50 most critical Business Partners, we consider the Group's overall exposure to risk of modern slavery occurring in our business and supply chain to be low.

The Group uses KPIs to measure how successful we have been in mitigating the risk of slavery and human trafficking taking place in any part of our business or supply chains. These are as follows:

We invest in educating our staff to recognize the risks of modern slavery and human trafficking in our business and supply chains. Through our training programs, employees are encouraged to identify and report any potential breaches of our anti-slavery and human trafficking policy. Employees are taught the benefits of stringent measures to tackle slavery and human trafficking, as well as the consequences of failing to eradicate slavery and human trafficking from our business and supply chains. Examples of training courses we have administered over the past year include an eLearning module named Conduct and Ethics which covers how to detect and report suspicious behaviour. For reporting suspicious behaviour, the Group has implemented whistleblowing solutions which permit reports to be submitted completely confidential and anonymous as described in the Whistleblowing Policy.

The Group’s commitment to combating slavery is anchored in the Board of Directors, and the Group Management Team. The Group has also appointed the Head of Risk and Compliance to assess, monitor and report on the status of the Group’s compliance maturity.

Following our review of our actions this financial year to prevent slavery or human trafficking from occurring in our business or supply chain, we intend to take the following further steps to tackle slavery and human trafficking:

1. Ensure Business Partners of the last year’s acquired entities are vetted in accordance with the Business Partner Due Diligence procedure.
2. Amend supplier contract wording where applicable to ensure the Group has contractual recourse if modern slavery issues are identified at contract renewal.
3. Follow up on staff who have not completed the mandatory training.
4. Implement policies and procedures related to responsible business conduct in the acquired entities.

This statement was approved by the Board of EcoOnline Group June 30, 2023, and signed by Board’s Chair, Markus Nagel.

Markus Nagel

Chair of the Board
EcoOnline AS