Human Rights Due Diligence

Summa supports and respects the protection of internationally proclaimed human rights. Decent working conditions for everyone involved in our operations and value chains are taken seriously, and Summa works systematically to ensure that we are not complicit in human rights abuses such as modern slavery, forced labor, child labor, and denial of the right to freedom of association.

Human Rights related risks are incorporated in Summa’s work streams and in the dialogue with the Board. Further, Summa is committed to promoting responsible business practices in our value chains and we carry out due diligence assessments on human and worker rights and the environment in accordance with the UN's guiding principles for business and human rights (UNGP, 2011) and the OECD's model for due diligence assessments for responsible business (2018).

Summa performs human rights due diligence on potential investments as part of our mandatory ESG due diligence in the pre-investment phase. As part of the investment cycle, Summa’s evaluation approach requires investments to be screened for both general- and sector-specific ESG issues and opportunities prior to acquisition. ESG risks are initially assessed alongside other types of risks as part of a rigorous process of due diligence. Environmental, social, and governance issues are prioritized in the due diligence depending on materiality to the business, materiality to the broader set of stakeholders and the level of impact. Similar to concerns about the level of financial returns, a determination that there are material adverse impacts or other sustainability risks that cannot be solved or mitigated, will result in a decision not to invest.

Further risk assessment of acquired companies are performed throughout the ownership period. The detection of risks to human-, and labor rights should be closely monitored, with the portfolio company in question needing to develop mitigation measures and targets to reduce the risk and prevent potential damage.

The Norwegian Transparency Act

The Norwegian Transparency Act entered into force on July 1st, 2022 and requires businesses to provide information on their efforts to respect fundamental human rights. The Act applies to larger enterprises that are resident in Norway as well as larger foreign enterprises that offer goods and services in Norway, and that are liable to tax to Norway pursuant to internal Norwegian legislation.

Enterprises that are covered by the law are required to carry out due diligence in accordance with the OECD Guidelines for Multinational Enterprises. This includes actions to:

a) Embed responsible business conduct into the enterprise's policies,

b) Identify and assess actual and potential adverse impacts on fundamental human rights and decent working conditions that the enterprise has either caused or contributed toward, or that are directly linked with the enterprise's operations, products or services via the supply chain or business partners,

c) Implement suitable measures to cease, prevent or mitigate adverse impacts based on the enterprise's prioritizations and assessments pursuant to (b),

d) Track the implementation and results of measures pursuant to (c),

e) Communicate with affected stakeholders and rights-holders regarding how adverse impacts are addressed pursuant to (c) and (d), and

f) Provide for or co-operate in remediation and compensation where this is required.

Illustration: OECD Due Diligence Guidance for Responsible Business Conduct.

Due diligence shall be carried out regularly and in proportion to the size and nature of the enterprise, the context of its operations, and the severity and probability of adverse impacts on fundamental human rights and decent working conditions.

Enterprises shall publish an account of their continuous due diligence process annually, either on the company website or in sustainability and annual reports.

Norwegian portfolio companies

Summa requires all Norwegian portfolio companies covered by the Transparency Act to comply with the requirements and report on their risk assessment and mitigation measures by June 30th. The statement of each company will be made available on their individual websites and/or in their annual report.

Going forward the companies will report annually on their continuous due diligence work, including risk assessment and tracking of implemented mitigation measures.

Summa Equity Advisory AS

Summa Equity Advisory AS is covered by the Transparency Act and has assessed and updated internal routines for procurement to comply with the requirements.

Summa Equity Advisory AS has few suppliers, whereas no suppliers are associated to our services or operations. Most suppliers are related to the day-to-day operation of the Oslo office. A risk assessment of the various procurement categories has been completed and additional information is currently requested from our suppliers in the categories of office supplies and consumables, food and drinks, flowers, furniture and interiors, cleaning and renovation, electronics, and electricity.

Based on the information received from each supplier, the supplier’s maturity in handling the inherent risk of human-, and labor rights in their operations and/or supply chain will be assessed. Those who show little or no intention of implementing mitigation measures to reduce risks will be registered on our exclusion list and we will not proceed to purchase their products/services, but instead find more responsible alternatives.

For hotels, restaurants, catering, and similar suppliers, a process description for screening for an internal whitelist is currently under development. All potential whitelisted entities will be assessed based on the implementation of a human rights policy, supplier code of conduct, process for due diligence for their own procurements, and whether an environmental policy and sustainability strategy/targets have been established.

If you have any further questions regarding our work to comply with the Transparency Act please contact:

Whistleblowing channel

Summa has implemented a publicly available whistleblowing channel to ensure that infringement of human rights or damage to people, environment and/or society in our operations or supply chain are reported. This mechanism supports our remediation process and can be used by individuals, workers, communities and/or civil society organizations.

Summa has set up a whistleblower channel through WhistleB for internal and external stakeholder to report objectionable conditions in our organization or among our portfolio companies. Incidents that should be reported include breach of our Code of Conduct , corruption, environmental destruction, and infringement of human and/or labor rights. We encourage all who are aware of possible objectionable conditions to notify through our channel in good faith, so that Summa can deal with the situation or event in a proper manner.

Anonymous complaints are welcome. However, as anonymous complaints are difficult to investigate without compromising the confidentiality of the complaint, we do not encourage anonymous complaints.

Summa has policies and processes in place to make sure the whistleblower is protected against reprisals. By submitting a complaint, you accept that Summa handles the complaint in accordance with the current procedures for handling complaints. Deliberately presented false accusations are considered a breach of the Code of Conduct and will be subject to disciplinary action.

Access the whistleblower channel here.