Aker Solutions shall respect human and labor rights. We support and respect internationally proclaimed human and labor rights, as defined by the International Bill of Rights and the International Labor Organization (ILO) Fundamental Conventions.
We oppose modern slavery in all its forms. Read our full statement in accordance with the UK Modern Slavery Act.
Aker Solutions often engages in work under challenging conditions, requiring the highest level of diligence in order to maintain the human and labor rights and the safety of employees and customers, subcontractors, consultants and other parties. Moreover, we have own operations as well as supply chain in countries associated with high political, corruption and human rights risks. Because of the nature of our work and the locations where we operate, human and labor rights are material topics for Aker Solutions.
Our Approach
Human rights concerns are by their very nature multi-faceted and linked to multiple business processes. We strive to integrate human rights considerations into core business processes in our own operations as well as in cooperation with our suppliers and business partners and in interactions with communities where we operate. We think that such a holistic approach contributes to building a company culture where managing human rights risk and minimizing harm to people is considered as part of our core business.
To meet our commitments as to respect and support of human rights, Aker Solutions shall maintain a human rights program which is embedded in our global compliance program managed by the Business Integrity & Compliance (BIC) team and led by the Chief Compliance Officer (CCO). The CCO has a direct and independent reporting line to the Audit Committee.
Our global compliance program is risk-based and designed to prevent, detect and respond to compliance and integrity risks, including human rights risks arising from the company’s own activities and business relationships with suppliers and other partners, and learn from incidents of human rights violations.
The program consists of three key elements:
I. Commitment and Governance
The company’s commitment to human and labor rights is covered by the Global Framework Agreement between Aker ASA and the Norwegian and international trade unions Fellesforbundet, IndustriALL Global Union, NITO and Tekna and our own Human Rights Policy.
The multifaceted nature of human rights requires cross-functional coordination. We have therefore established a Human Rights Committee with participation from the following functions/ representatives: HSSE, BIC, People and Organization (P&O), Data Protection, Sustainability, Supply Chain and Communications, as well as representatives from the Unions. The Human Rights Committee’s mandate is to ensure that the company has a sound human rights system and to continuously improve this system. The committee’s mandate is authorized by the CEO. The committee reports to the CEO and the Audit Committee on a quarterly basis.
Aker Solutions has a Code of Conduct which is endorsed by the Board of Directors, and it constitutes a framework for managing compliance and integrity risks. It describes our commitments and requirements regarding business practice, personal conduct and expectations towards business partners. The Code of Conduct outlines clear principles and rules in key compliance and integrity areas, including Caring for People which comprises human rights and labor rights, health, safety and security, anti-harassment and diversity topics. Our Code of Conduct was revised in 2021 and is available 7 languages.
In 2021, we launched a stand-alone Human Rights Policy anchored in our existing firm commitment to respecting human rights expressed in the Code of Conduct. The Policy is aligned with the requirements of the International Bill of Rights and the ILO Fundamental Conventions. It constitutes a building block in our framework for managing human rights risks. Our Human Rights Policy is approved by the executive management team, is available in 7 languages and can be found in our management system as well as on our website.
Principles and requirements as to business integrity and compliance including human rights are cascaded down the organization through numerous policies and procedures, including:
- Business Integrity Policy and Procedure
- Country Risk Procedure
- Business Partner Qualifications and Integrity Due Diligence Procedure
- Supplier Approval Procedure
- Supply Chain Risk and Compliance Procedure
- Supplier Declaration Form
- Terms and Conditions for Suppliers
- Global HR procedures
- HSSE procedures
Business integrity and compliance matters including human rights are regularly discussed with management and formally reported on to the Audit Committee by Chief Compliance Officer on a quarterly basis.
II. Due diligence - Activities to Identify, Prevent and Mitigate Human Rights Violations
Risk assessment
Assessment of business integrity risks including human rights is an integrated part of our Enterprise Risk Management (ERM) process which is subject to a quarterly review. We have an established process for conducting country risk assessments, including human rights, for new country entries or for projects in new countries. We use Maplecroft’s 11 indices on human and labor rights to risk-assess countries where we currently operate.
Aker Solutions has identified that potential significant risk exposure to human rights violations may be detected in the global supply chain. The most important prescriptions in the International Bill of Human Rights related to supply chain management are:
- Right not to be subjected to slavery, servitude, forced labor, or child labor
- Right to enjoy just and favorable conditions of work, and
- Right to health
We strive to ensure that our suppliers, vendors and subcontractors share our commitment to safety, business integrity, respect for human rights and compliance. We also expect that they in turn also apply the same principles towards their own employees, suppliers, subcontractors and agents with whom they work in the delivery of goods and services to Aker Solutions. We therefore cascade our expectations and requirements for human rights protections to our suppliers and subcontractors. These requirements are included in our Supplier Declaration. The Supplier Declaration is used in our supplier pre-qualification process and commitment to the Supplier Declaration is a prerequisite for becoming qualified as a supplier, vendor or subcontractor to Aker Solutions.
Contractual clauses
Contractual clauses are a tool to signal expectations of respect for internationally recognized human rights to our business associates. Contractual clauses can allow us to demand a contractual party address and eventually rectify human rights violations or terminate a contract if deemed necessary. We endeavor to include human rights clauses in all contracts with our business associates.
We include ‘audit rights’ clauses in our contracts with suppliers to have the possibility to verify their compliance with the Supplier Declaration commitments on a risk basis.
Training, communication and awareness building
Business ethics training is one of Aker Solutions’ key initiatives in building awareness about business integrity and preventing unethical behavior or breaches of the Code of Conduct, including human rights infringements.
We provide various types of ethics and compliance training to our employees:
- We provide a Code of Conduct refresher e-learning training to all employees on an annual basis. In 2021, approximately 71 percent of employees defined as the target group completed the training
- Business ethics training is offered to all new employees and in 2021, approximately 1,200 new employees completed this type of training online
- There are numerous trainings on other compliance topics provided to defined target groups of employees throughout the year, via internal online platforms
- During 2021, we conducted business integrity awareness training including human rights topics to some selected key suppliers in Malaysia and Angola. These training were conducted by BIC Compliance Officers responsible for these geographical regions
- We conduct regular communication campaigns to build awareness in the organization around the Code of Conduct, whistleblowing, and other relevant business integrity topics, including human rights
Due diligence
Aker Solutions performs integrity due diligence (IDD) on our customers, suppliers and other business partners such as JV partners, third-party representatives, and alliance partners. Projects and new country entries are subject to integrity and country risk assessments.
The purpose of the IDD process is to ensure that adequate level of risk assessment and risk mitigation is performed on the background and profile of potential new or existing business partners or other stakeholders when evaluating whether they meet Aker Solutions’ compliance and integrity standards. In our IDD review, a business partner or a stakeholder is analyzed to identify potential integrity and compliance concerns with the purpose to mitigate compliance and reputational risks for Aker Solutions. Potential integrity and compliance concerns and risks may relate to:
- Corruption or bribery
- Human rights violations
- Violations of international sanctions
- Other economic crimes (e.g., money laundering, terror financing)
- Environmental breaches
- Or other material risks
Key procedures governing this process are:
- Business Integrity Policy and Procedure
- Country Risk Procedure
- Business Partner Qualifications and Integrity Due Diligence Procedure
- Supplier Approval Procedure.
III. Monitoring and Reporting
Inspections, Reviews and Audits
We perform regular inspections for our own locations, projects and business partners. Controls of human rights guidelines and directives are regularly carried out, sometimes also in conjunction with a broader review of health and safety, procurement procedures and / or quality. A key risk exposure to human rights violations can potentially be found in the supply chain. Supply Chain teams conduct ISO-based supplier audits, where human rights and anti-corruption is part of the audit program. A risk-based audit selection methodology has been developed to ensure that high risk suppliers are subject to audits. During 2021, we conducted risk-based human rights supplier audits in Angola.
During 2022, we plan to engage external specialized human rights inspection service providers to support our auditing efforts in the supply chain and expand our on-site and worker-centric audit capacity and capabilities.
Reporting of Concerns, Whistleblowing and Grievance Mechanisms
We are committed to building a culture of trust where employees are comfortable to ask questions, seek guidance, raise concerns and report suspected violations. Aker Solutions’ whistleblowing channel allows anyone (including externals) to report concerns, incidents, breaches or suspected breaches of the Code of Conduct, other internal policies, or laws and regulations.
We all have a responsibility and must have the courage to speak up promptly about ethical questions or issues, and anything we believe, in good faith, to be a suspected violation. Notifications can be sent anonymously through Aker Solutions whistleblowing channel or by email to whistleblowing@akersolutions.com.
We do not tolerate retaliation against anyone who speaks up in good faith to ask questions, raise a concern, report a suspected violation or participate in an internal company investigation.
Investigations
All notifications to the whistleblowing channel are received and managed by our BIC department and are treated with strict confidentiality. BIC has a mandate from Aker Solutions’ Board of Directors to investigate alleged compliance violations. Investigations are carried out in accordance with the rules set out in the Whistleblowing Procedure and the Investigation Procedure.
Incidents and investigations that uncover malpractices or breaches of causing, contributing to or being complicit in human rights violations shall result in recommended remediation and improvement actions. In such cases, remediation and improvement actions will be directed at the negatively impacted people and will prevent and mitigate the adverse effects now and reduce the risk of causing adverse effects in the future.
Internal and External Reporting
Aker Solutions is a listed company on the Oslo Stock Exchange and follows the Norwegian Accounting Act for annual reporting. In addition, Aker Solutions follows the Euronext guidance on ESG reporting of January 2020. Pursuant to the UK Modern Slavery Act 2015, the company reports annually on steps that have been taken to ensure that there is no slavery or human trafficking in the supply chain. Internally, the Human Rights Committee reports on a quarterly basis to the Audit Committee through the Chief Compliance Officer.
The Transparency Act
Aker Solutions welcomes the Norwegian Transparency Act (“Åpenhetsloven”) that represents a considerable step ahead in the industry’s joint effort to conduct its operations in the most sustainable way, and in the full respect of fundamental human rights and decent working conditions.
The Transparency Act is a new Norwegian law which shall promote:
- Respect for fundamental human rights and decent working conditions in connection with the production of goods and the provision of services and
- Ensure the general public’s access to information regarding how companies address adverse impacts on fundamental human rights and decent working conditions.
Requests related to Aker Solution’s management of human rights risks and compliance with the Transparency Act can be sent to transparency@akersolutions.com