The Transparency Act
We commit to respecting all internationally recognized human rights in accordance with the UN's Guiding Principles on Business and Human Rights. We emphasize sustainable practices that consider people, the environment, and society. The Norwegian Transparency Act, effective from July 1, 2022, aims to prevent human rights violations and poor working conditions. We have conducted due diligence assessments based on OECD guidelines, and our practices for evaluating current and new suppliers are well established and in ongoing use. Solwr, comprising three entities (Solwr Group AS, Solwr Software AS, and Solwr Robotics AS), adheres to sustainable and ethical business practices across all units. Our goal is to deliver scalable, sustainable, and integrable logistics technology solutions while balancing people, the planet, and profit.
This statement covers the reporting period from January 1, 2025 to April 1, 2026. We extend the period beyond 12 months to make sure all suppliers with annual payments is included in our investigation. The reporting period denotes the period the statement applies to and was prepared in; supplier relationships predating this period are regarded as concluded, and the April 1 cut-off gives us the time needed to finalize the statement before publication. For this period, we have assessed 206 suppliers and subcontractors across Solwr, and identified no actual adverse impacts in our investigation. This figure covers both newly evaluated suppliers and updated assessments of suppliers previously reviewed. The assessments are documented in two separate statements - one for Solwr Robotics AS and one for Solwr Group AS and Solwr Software AS - reflecting the different boards of the entities. Both statements are available in PDFs at the bottom of this page. The number of suppliers has been deliberately reduced compared to the previous period, as part of a strategy to consolidate purchasing with fewer, more reliable partners and thereby strengthen control and traceability.
Transparency in the supply chain remains a priority. Our assessments cover geographic risk, industry-specific risk, and risk related to human rights, corruption, and working conditions, as well as the collection and verification of suppliers' own policies. We continue to prioritize suppliers with controlled production chains, long-term partnerships, and transparent reporting. We note with concern that the global outlook is moving in a negative direction, with increased pressure on human rights in many parts of the world. Our internal risk index, which draws on several reputable international reports - among others the Universal Human Rights Index (UHRI), the ITUC Global Rights Index, the Corruption Perceptions Index, the Good Country Index, the WJP Rule of Law Index, and Freedom in the World - indicates a rising risk of human rights violations across several regions. While this index forms an important foundation, our risk assessments go beyond it, helping us identify where enhanced scrutiny is required.
For our robotics operations, we purchase components, industrial electronics, and precision mechanics largely through Norwegian and European intermediaries. Our mapping shows, however, that the underlying manufacturing of these components is to a large extent located in regions of increased risk, particularly in Asia. Several of our key brand suppliers have documented production in such regions, even though the purchase itself takes place through European or Norwegian entities, and traceability further down the chain can be limited. We recognize that our due diligence today primarily covers the first and second tiers of the supply chain, and that full traceability down to the individual component manufacturer has not been achieved. We regard this limited visibility as the most significant identified risk for our hardware operations, and we are working to obtain more documentation from brand owners about their own supply chains.
For our software and group operations, a substantial share of our software and cloud services is provided by companies of U.S. origin. For these suppliers, there is a risk related to limited visibility and control further down the chain, both regarding working conditions at subcontractors and matters of jurisdiction over data and operations. We have also noted that certain suppliers have development or operational functions in areas of elevated risk. Such cases are followed up closely and assessed on an ongoing basis. The specific geographies and suppliers concerned are described in the two statements available on this page.
At the same time, we see positive developments. Access to public reporting from suppliers has improved, and it is increasingly common to find published statements on sustainability and human rights. However, there is still considerable room for improvement when it comes to full transparency and documented compliance throughout global supply chains.
Solwr expects suppliers to adhere to our Supplier Code of Conduct and to respect international human rights principles. We maintain procedures for identifying, managing, and responding to potential violations. The framework for managing ethical breaches consists of notification and internal registration, dialogue with the supplier, a requirement for corrective measures, and - if necessary - termination of collaboration. All suppliers are obliged to make documentation available on request, and Solwr reserves the right to conduct audits and verify conditions at subcontractors.
Solwr values lawful, ethical, and transparent operations, guided by a range of internal policies including anti-corruption and conflict of interest, information security and privacy, ethical conduct and competition law, professional management and contract handling, social responsibility and sustainability, and zero tolerance for human trafficking and exploitation. Ethical training is included in onboarding for all new employees, and we have established clear procedures and channels for whistleblowing. Our ESG (Environmental, Social, and Governance) strategy remains central to how we operate. It focuses on environmental sustainability, social responsibility, and ethical business conduct. We aim to be an attractive workplace that promotes diversity, openness, responsibility, and integrity, and our leaders are expected to lead by example and foster a culture where concerns can be raised and addressed.
Although no actual violations have been identified so far, we remain vigilant and proactive in monitoring suppliers, especially those operating in or sourcing from high-risk regions. Going forward, we will work to improve visibility further down the component and subcontractor chains, continue to reduce the number of suppliers for better control, prioritize partners with a high degree of traceability, hold regular internal status reviews, and publish our measures and responses to any deviations on our website. Our goal is to contribute to a fairer and more sustainable future in our own operations, in our value chains, and for society as a whole.
Read the official statement for the companies here: (Norwegian)
Redegjørelse åpenhetslov Solwr Software + Solwr Group 2026 (PDF)Redegjørelse åpenhetslov Solwr Robotics 2026 (PDF)For any questions or inquiries about The Transparency Act in Solwr, contact:
compliance@solwr.com