About us at Nordic Steel
Nordic Steel is Norway's leading competence center in steel. We work with engineering, advanced plate processing, certified welding and assembly. We deliver high-quality mechanical production and project management to customers in all industries. We produce everything our customers need in steel, for projects of all sizes. The main industries we serve are renewable energy, energy and offshore, aquaculture, transport and infrastructure, construction, HVAC, piping, aerospace and defense, and various other industries.
Nordic Steel and the Transparency Act
Nordic Steel is covered by the "Act on the Transparency of Enterprises and Work with Fundamental Human Rights and Decent Working Conditions (Transparency Act)".
The Transparency Act requires companies to identify and assess actual and potential negative consequences of violations of human rights and decent work within the company and in the supply chain. Those covered by the Act must report on the due diligence assessments and publish them on the website by June 30 each year, or in the event of significant changes in the company's risk assessments.
The due diligence is conducted in line with the OECD Guidelines for Multinational Enterprises in the area of human rights, which are consistent with the UN Guiding Principles on Business and Human Rights (UNGP).
The UN Universal Declaration of Human Rights is the basic document in the international work for human rights. It consists of 30 articles and applies to all UN member states. As an industrial company, it's important for us to lead the way, and we must have a profile that is sustainable and climate-friendly. We will do what we can to reduce climate emissions and promote human rights and the principles of democracy.
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Name: Nordic Steel AS
Organization number: 880 484 842
Head office address: Langmyra 6, 4344 Bryne
Products and services: Mechanical industry: Engineering, sheet metal working, welding and assembly
Description of the company's structure: The company is part of Nordic Steel Group
Turnover in 2023: 511 MNOK
Estimated number of employees: 145
We work systematically with basic human rights and decent working conditions. We do this by:
The work on the Transparency Act is led by the company's sustainability manager, in close collaboration with the operations manager, health and safety manager, and purchasing and logistics manager. The CEO is informed about the process along the way. Nordic Steel has anchored the work on the Transparency Act in the Board of Directors, to ensure that the requirements of the Act are safeguarded and followed up.
Organization and operations
Nordic Steel is located in Langmyra 5 and 6 at Bryne in Rogaland, where we have administration and production departments. We have regional offices in Ålesund and Oslo.
We have separate departments for project, technical, marketing and sales, accounting and payroll, administration and operations, purchasing and logistics, sheet metal work, assembly and welding. At the end of May 2024, we had 145 permanent employees in Nordic Steel. In addition, we always have some project employees in the production departments.
All production takes place at our premises in Bryne. The fact that the administration and production departments are co-located is a great advantage, partly for closer collaboration. It's also an advantage for our customers to have Norwegian production, as it makes it easier for them to follow up projects. Most of our customers are Norwegian companies, but in recent years we have gained more and more foreign customers. However, many of our deliveries go from us to Norwegian customers, and on to projects abroad. For example, offshore wind off the UK or subsea offshore in Brazil. We also have foreign customers who deliver to projects in Norway.
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Nordic Steel is a certified Eco-Lighthouse company and we are certified according to ISO 9001.
For many years, we have taken responsibility for the environment and sustainability. We want to help reduce our customers' carbon footprint, while ensuring social conditions and basic human rights throughout our value chain.
Working life and social responsibility are closely linked to environmental responsibility. We divide our sustainable choices into three core areas: People, working life and the environment. These areas are all linked to the UN Sustainable Development Goals. We have selected four SDGs that we work with in particular, because this is where we can make an extra difference. These are goals on good health and quality of life (no. 3), decent work and economic growth (no. 8), halting climate change (no. 13), and working together to achieve the goals (no. 17).
Collaboration is essential to achieve results in sustainability. In recent years, it has become particularly clear that governments and businesses must work together to find good solutions. Only then can we achieve sustainable development. Nordic Steel sees our sustainable choices and climate footprint as crucial to our future competitiveness.
Always responsible
Diversity, equality and human rights are about everyone having the same rights and being treated in the same way - regardless of who they are as a person and where they come from.
At Nordic Steel, we are fortunate to have many different people working for us. It gives us new perspectives, new learning and new insights. We also get to know other cultures and ideas - it's exciting.
Although people are different - and we celebrate that - everyone should have the same rights and obligations. We must have a safe and responsible working life and a culture where we treat each other with respect. We also recognize this in the UN's Sustainable Development Goals, which we work a lot with. The 17 Sustainable Development Goals (SDGs) are the world's joint work plan to eradicate poverty, combat inequality and stop climate change. As an industrial company, we take responsibility for the green shift, have low climate emissions and help our customers to make more environmentally friendly choices. We are also a workplace where we make responsible choices, from suppliers to the working environment.
We want to contribute to a more sustainable and responsible industry. We know that our employees, customers and suppliers appreciate this. The development towards a more sustainable future happens when we make responsible choices. Everyone can rest assured that we do this at Nordic Steel.
Nordic Steel has conducted due diligence on the UN Universal Declaration of Human Rights, and in line with the OECD Guidelines. We have mapped possible and actual negative impacts and significant risks regarding human rights, and have the following documents to ensure and demonstrate compliance:
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Effects and measures:
Nordic Steel operates in Norway where human rights are controlled by law and well implemented in society. All our employees are subject to the Working Environment Act and mandatory HSE requirements. We have systems, routines and procedures for training, development, follow-up and daily operations.
We have limited impact on society, other than on our own employees and our suppliers. Nordic Steel has no conflicts related to the UN Universal Declaration of Human Rights and shall respect the rights and local laws wherever we work. These are examples of the topics we have assessed for internal risks and opportunities:
We have identified the following risks through the due diligence performed:
1. There is a risk that personal injuries and strain injuries can occur, and we work continuously to ensure the safety and well-being of our employees (HR3*)
Initiated measures: Health, safety and environment is the most important thing we work with, every single day. All employees are trained before they start to ensure they have the best possible skills to do their job and understand the company's work processes. Important routines with us are about protective equipment, chemicals, machines, lifting, transportation and working environment. We have regular safety rounds, regular AMU meetings, a system that is risk-based, work according to Norwegian law and have working environment surveys.
Further measures planned: HSE is a continuous effort, we work on improvements, have regular risk assessments and involve employees in safety rounds. In 2024, we will add an extra safety representative, so that we have a total of three. We will then cover all the buildings/areas with a safety representative at each location. An occupational health survey with the occupational health service is planned for the fall of 2024.
2. There is a risk that personnel do not receive equal pay for equal work (HR23)
Initiated measures: We follow the established salary matrix in the production departments. We report on the activity and reporting obligation in the annual report, where we, among other things, map salaries and gender equality.
Further measures planned: Extended mapping of gender equality and what is being done to fulfill the activity obligation (Activity and reporting obligation). Salary regulations are reviewed by the end of May each year.
3. There is a risk that personnel do not take part in the work environment (HR29)
Initiated measures: We have a strong focus on employee inclusion and a culture where we greet and talk to everyone. Social gatherings are organized both during and outside working hours, such as paddle training, bowling, barbecues, trips and a gathering after payday once a month. In June 2024, we launched our own app for internal communication, including contact information and photos of all employees, information about the company and about social activities.
Further measures planned: As we grow as a company, have more employees and are present in more locations, it is important that employees feel included in Nordic Steel. We also have several project employees who are part of us for shorter or longer periods of time. We are developing the app for internal communication and will use this as a communication channel for employees.
(*HR number = Human Rights Article Number)
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Nordic Steel buys goods from many different countries, but we strive to use local suppliers. Many local subcontractors are important contributors to Nordic Steel.
The most important commodity we buy is steel, and steel is produced all over the world. We buy steel in various material grades either from wholesalers or directly from individual steelworks with which we have agreements.
Nordic Steel is responsible for a sustainable value chain that does not negatively impact people or the environment. We conduct due diligence on the suppliers we have direct contact with in our value chain. Since steel is the most important commodity we buy, it is important for us to work closely with wholesalers to ensure that they have control over working conditions and human rights in the steel factories that supply them.
We are a growing company, and the number of employees at Nordic Steel is increasing. There is also a need for project employees during periods of high activity. We have therefore paid particular attention to the staffing companies with which we have agreements in our due diligence. At Nordic Steel, we work closely with our suppliers to create good, long-term relationships. Dialogue, openness and trust are important to us in our collaboration.
We have identified the following risks through the due diligence performed:
1. There is a risk that steel wholesalers and mills supply materials and components produced in countries that do not respect human rights (HR1, HR2, HR3)
Initiated measures: We have mapped our suppliers' potential risks. Our wholesalers are mainly located in Norway and subject to Norwegian law, but if we trade directly with the steel mills it is from abroad. Our supplier evaluation has been updated to include requirements for compliance with human rights and our suppliers must confirm this.
Further measures planned: We conduct annual audits of companies. In particular, we will ask about the wholesalers' follow-up and visits to the steel mills.
2. There is a risk that project employees through staffing agencies do not have contracts that comply with human rights (HR22)
Measures implemented: We only use staffing companies that are officially approved and thus subject to Norwegian laws and regulations.
Further measures planned: We conduct annual follow-up meetings (audits), and carry out seriousness checks and spot checks. We also check employees' employment contracts.
3. There is a risk that logistics companies do not comply with driving and rest time regulations and have an acceptable standard of living (HR24 and HR25)
Initiated measures: We have agreements with logistics companies confirming that they are compliant with the law and we verify this. Our supplier evaluation includes requirements for confirmation that they have no conflicts with the UN Universal Declaration of Human Rights.
Further measures planned: We conduct annual audits of companies and spot checks of drivers. We want to carry out more spot checks.
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Integrity
At Nordic Steel, we have a Code of Conduct that clearly emphasizes the values we stand for and what our rights and obligations are.
We shall avoid conflicts of interest, bribery or improper benefits, in order to obtain or retain improper benefits. This is very important to us, our customers and business partners. In all circumstances, we will promote honesty, integrity, loyalty and fairness.
Environment
Nordic Steel is a leader in sustainability in our industry, and sustainability is central to our organization. We have an environmental management system and strict routines for everything from HSE to waste recycling and transportation. In our own operations, we have low greenhouse gas emissions, with energy-efficient buildings and machines, and many electric trucks. We have no emissions to air or water.
An important task is to reduce our indirect emissions through the supply chain. We require suppliers with whom we have framework agreements to be environmentally certified. We challenge and encourage customers and partners to make more environmentally friendly choices, and we have good experience of helping customers to meet environmental requirements.
Responsible business conduct protects human rights.
Nordic Steel does that. And it's important to us that our partners do too.
No business partner risks related to human rights have been identified.
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At Nordic Steel, we work strategically with working conditions, the working environment and human rights. We've been doing this since before the Transparency Act came into force, but with the Act we've been able to raise the profile of these issues even further.
We have all our production in Norway and prioritize buying from local suppliers. However, issues such as the working environment and working conditions must always be high on the agenda, and we take responsibility both internally and externally. It should pay off to be a customer and supplier with us. But most importantly: It should be good to work at Nordic Steel.
In our work on the Transparency Act, we have uncovered risks internally and in our supply chain. We are pleased that we have systems and procedures in place to deal with this. By being open about risks and opportunities related to human rights and the working environment, we can contribute to better working conditions in the industry.
Our report on the Transparency Act (§5) is anchored in Nordic Steel's Board of Directors.
Bryne, 24 June 2024
