Transparency act

Updated: 25.06.2026
Reporting period: January 1st – December 31st 2025

This statement has been prepared in accordance with Section 5 of the Norwegian Transparency Act and provides an overview of how Kvenna AS works to ensure respect for fundamental human rights and decent working conditions within its own operations and throughout its supply chain. The statement is based on the OECD Due Diligence Guidance for Responsible Business Conduct.

About Kvenna AS

Organisation number: 933 704 262
Owner: Novela Teknologi AS
Managing Director: Stein-Ove Riksheim ( / +47 934 04 453)
Chair of the Board: Frank Ove Reite
Number of employees: Approximately 45

Core business:

The company provides CNC machining of metal components, engineering services, service and related deliveries to the marine, subsea and offshore industries.

Policies and procedures

Kvenna AS has established and implemented the following overarching policies:

• Zero tolerance for child labour, forced labour and discrimination
• Common ethical guidelines applicable to all employees
• Requirements to safeguard human rights and decent working conditions, both internally and among suppliers
• Board-level anchoring, with compliance ensured through supplier requirements and internal training
• Collective bargaining agreements that help ensure good and predictable working conditions for employees

Due diligence assessments

Kvenna AS uses the OECD due diligence model as the basis for identifying, assessing and managing risks.

The work initially includes a systematic mapping of the supply chain, with particular focus on suppliers assessed as presenting an elevated risk. Risk assessments are then carried out based on factors including geographical location, industry affiliation and product category.

Based on these analyses, deliveries to the marine and subsea segments have been prioritised, as these areas are characterised by high complexity and stringent requirements for documentation and compliance.

The document has been signed using Orgbrain eSign – a standard electronic signature in accordance with EU Regulation 910/2014 (eIDAS).

Mapping and prioritisation

The company has carried out a mapping of its supply chain, with particular focus on suppliers representing a high procurement value.

Risk criteria

The risk assessments are based on:

• Geographical location
• Industry/product category

One identified risk area relates to deliveries of raw materials where traceability may be challenging. Efforts are underway to ensure traceability within these deliveries.

Measures implemented

To address identified risk factors, Kvenna AS has implemented several targeted measures:

• Collection of self-declarations and relevant documentation from suppliers in prioritised risk categories
• Classification of critical suppliers based on risk and significance to the business
• Documentation requirements relating to quality, environmental management and working environment

As an integrated part of its due diligence efforts, the company conducts annual, systematic supplier evaluations. These evaluations cover both matters relating to human rights and working conditions, as well as operational and commercial aspects.

As of the reporting date, no actual adverse impacts or significant risk deviations relating to human rights and working conditions have been identified within the company’s own operations or supply chain.

At the same time, the assessments indicate a need for continued improvement in the following areas:

• Clarification of supplier obligations
• Level of documentation among certain suppliers
• Transparency within sub-supplier tiers

Future measures

Going forward, Kvenna AS will prioritise the following areas of development:

• Improved clarification of supplier obligations
• Further development and strengthening of supplier evaluations and follow-up processes
• Increased focus on internal training in responsible business conduct

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