The Norwegian Transparency Act

Report on the Norwegian Transparency Act

Business ethics is a core value for Circio, and we are committed to conducting business responsibly. Circio recognizes that an important part of ethical business conduct is being alert to and preventing the risks of cruel practices taking part in our business, including our supply chain. Circio is working to ensure that effective systems and control mechanisms are in place to prevent unethical business conduct. The Employee Handbook and Board Handbook explain how accountability is rooted in Circio’s guidelines.

Circio supports and respects the protection of internationally proclaimed human rights and requires that the company and our employees do not abuse, or are complicit in the abuse of, human rights. Circio strives to ensure good working conditions, with strict requirements with regard to health, safety, and environment. We also promote respect for labour rights in our relations with business partners.

All employees will be given regular training in the content of the company’s Code of Conduct to secure their knowledge of Circio’s ethical framework. All new employees need to read the Code of Conduct as part of their onboarding process. The Code of Conduct has been developed and adopted to secure that Circio’s mission, values and high ethical standards are complied by everyone associated with the company. It is the employee’s own responsibility to respect and act in compliance with the Code of Conduct. Employees should report any violation or suspicion of violation of the Code of Conduct to their Manager and/or HR in Circio.

Risks of negative consequences internally will be identified through a risk assessment process. Circio will perform risk assessment to identify, measure and understand the most important risks in our supply chain. We are committed to cooperating in the remediation of negative impacts that Circio identifies as being responsible or associated with. Circio expects all business partners to comply with our Code of Conduct.

When it comes to communicating with affected stakeholders regarding the handling of negative impacts, we prioritize maintaining an ongoing and open dialogue with our business partners and suppliers. In the unlikely event of an incident or suspicion thereof, we will actively engage with the relevant stakeholders to swiftly address and mitigate any adverse consequences. Moreover, we will ensure that relevant stakeholders are informed about how we have managed negative impacts through our established communication channels and regular interactions. By fostering transparency and regular communication, we strive to uphold accountability and transparency in our approach to handling negative issues. Additionally, in cases where recovery and replacement are necessary, we will actively collaborate with relevant parties to provide or facilitate the required support.

The Code of Conduct is available on our website and was adopted and approved by the Board of Directors on 20 December 2022.

Any concerns about the business conduct, or advice regarding the policies or practices for responsible business conduct, shall be sent to the CFO Lubor Gaal at