Transparency Act

The Transparency Act came into force on July 1st, 2022. This will ensure decent working conditions throughout the value chain and promote transparency around how we as an organization respect human rights and decent working conditions. The Transparency Act shall, together with other measures, contribute to Norway's efforts to meet the UN's sustainability goal no. 8 on decent work and economic growth, and goal no. 12 on responsible consumption and production.

We at PatoGen are positive towards legislation that contributes to increased focus and respect for basic human rights and decent working conditions.

Our business practices

PatoGen provides services based on biotechnological analyses to detect disease agents and genetic markers in fish. This information is used by fish breeders in their preventive fish health work.

The company's head office is in Ålesund. The group delivers services through the use of laboratories in Ålesund, Bodø and Oban (Scotland), as well as through agreements with subcontractors and consulting services from a subsidiary in Kinvarra (Ireland). PatoGen is 100% owned by Dr. Fürst Medisinsk Laboratorium AS.

PatoGen's objective is to contribute to predictability in the aquaculture industry by preventing infection and disease, which will further improve profitability for customers. At the same time, preventive and systematic work with fish health will help take care of the industry's increasing demands for a gentle and sustainable production of fish. In the company's vision "We inspire actions for healthier fish", PatoGen states to be at the forefront of fish health challenges and that a lot of resources are used for research and development to take care of customers' needs.

PatoGen also works with measures to minimize waste and a more optimal use of resources, which includes recycling materials and reducing unnecessary consumption, including plastic. PatoGen participates in research projects and collaborates with academic institutions and authorities to develop and implement sustainable solutions for fish health and farming.

Due diligence assessment

Our due diligence assessment processes consist of;

• mapping and identification of risks for violations of human rights and decent working conditions

• implementation of measures to reduce negative risk

• implementation of measures and monitoring of results

All workers, both our own employees and employees in our supply chain, must have decent working conditions in line with the UN Convention and national labor legislation at the production site. Goods and services delivered to PatoGen must be produced under conditions that are compatible with requirements in the Transparency Act. Our routines and processes to ensure basic human rights and decent working are included in our management system and are based on OECD guidelines.

PatoGen expects the same from our suppliers as we demand from ourselves. Human rights and working conditions are included in our ethical guidelines. Routines have been designed for reporting objectionable conditions, and employees are followed up through, among other things, employee interviews and employee surveys.

We have a good overview of our suppliers, systemized in our agreement archive. In order to produce an analysis result, we depend on subcontractors for the delivery of equipment, instruments and reagents that have been manufactured and approved for laboratory purposes.

We see that the main weight of risk associated with suppliers of products is found in the underlying supply chains. Therefore, in a separate supplier declaration, we have demanded that our suppliers identify subcontractors where there is an underlying risk of violations of human rights and decent working conditions, and thus demand that suitable preventive measures are implemented in relation to them.

Our prioritization of suppliers for due diligence assessment is initially based on;

• criticality for operations/size of purchase

• whether they deliver products or services within one of the categories on the Directorate for Administration and Financial Management (Direktoratet for Forvaltning og Økonomistyring: DFØ) high-risk list

• if they operate within an industry where the risk of negative consequences is higher

PatoGen's suppliers are risk assessed and evaluated annually, within different quality parameters. Our ethical requirements for suppliers are now included in this evaluation. Suppliers are closely monitored regarding the risk of negative conditions, through internal routines and procedures. Where there is an increased risk of breach of ethical requirements, we will monitor and possibly initiate measures. An example of an early measure could be to request access to the supplier’s own work with due diligence assessment or other documentation of compliance with the Transparency Act.

If, after various measures, one still finds the possibility of a risk of breach of ethical requirements, this will be a basis for considering whether the contract with the supplier should be terminated. We value good cooperation with our suppliers and preferably implement measures after dialogue with the supplier in question. The type of measure will be assessed in relation to identified risk.

So far, through our work with due diligence assessments, no actual negative consequences have been uncovered, either internally or in our supply chain. Should negative consequences be discovered in the future, this will be registered and processed in our document management system. An expected result of having initiated work with due diligence assessments is to be able to contribute to increasing awareness of social, economic and climate conditions both among our employees and in the supply chain.

Information about our work with due diligence assessment is published in our annual report, which is approved by the board.

Questions regarding PatoGen's compliance with the Transparency Act can be addressed to: post@patogen.no

Ålesund, 25.06.2024