As of July 1, 2022, the Norwegian Transparency Act came into force. The purpose of the act is to ensure that businesses respect for fundamental human rights and decent working conditions among business relationships and in supply chains.

An important part of the Act is to ensure the general public access to information regarding these matters and how businesses handle them. In combination with other measures, the legislation is meant to contribute to the Norwegian efforts to meet and comply with United Nations Sustainable Development Goal no. 8 on “Decent work and economic growth” as well as Goal no. 12 on “Responsible consumption and production”.

The core of the Act involves the duty to conduct and account for due diligence assessments. Due diligence assessments implies that businesses must identify any possible negative consequences for fundamental human rights and decent working conditions related to production and supply chains, implement improvement measures, follow up and report.

Due Diligence – What does Pongo AS do?

Pongo AS is a medium-sized Norwegian car imports company with a long history dating back to 1940. The company is currently owned by Gill Gruppen AS (51%) and Sojitz Corporation (Japan) (49%). Pongo has a total of 10 subsidiaries and 55 employees. The Group had a turnover of 1.8 MMNOK in 2022.

The subsidiaries Norwegian Mobility Group AS and Subaru Norge AS are obliged to conduct due diligence assessments in accordance with the size criteria specified in the Transparency Act. The remaining companies that make up Pongo AS are covered by the Group’s fundamental principles of business ethics. These principles provide guidance for human and labour rights that cover our work in our own organization and at our suppliers.

The guidelines are based on the UN guiding principles on Business and Human Rights and describe the main principles for how we address the human and labour rights that are most relevant to our day-to-day operations.

How we comply with due diligence assessments

The document “Compliance og samfunnsansvar” (Compliance and Corporate Social Responsibility) describes how the Groups companies shall conduct its work. This document describes how we shall abide by due diligence criteria and work on improvements and measures in our own organisation as well as in the supply chain. Furthermore, the document describes how we expect the companies to act in order to implement the policy to a high standard. The company shall analyse the risk of divergence from the policy on an annual basis. In addition, the work to safeguard human rights shall be assured.

• Norwegian Mobility Group AS has 25 direct suppliers and multiple subcontractors.
• Subaru Norge AS has 18 direct suppliers and multiple subcontractors.

We are requesting all direct suppliers approve the section of the Code of Conduct that describes our supplier requirements related to human rights and other sustainability topics. This means that the suppliers undertake to carry out its obligations in accordance with internationally recognised standards related to human rights, working conditions, the environment and anti-corruption. We will monitor our suppliers through supplier audits and, where appropriate, third-party audits.

Ten requirements for supply chain conditions:

Human Rights

Principle 1: The company shall support and respect the protection of internationally recognised human rights, and

Principle 2: ensure that the company is not complicit in human rights violations.

Work

Principle 3: The company shall uphold freedom of association and ensure that the rights of employees to engage in collective bargaining is recognized in practice, and

Principle 4: Abolish all forms of forced labour,

Principle 5: Ensure elimination of child labour, and

Principle 6: Ensure that discrimination in employment is abolished.

Environment

Principle 7: The company shall support a precautionary approach to environmental challenges, and

Principle 8: Take initiatives to promote increased environmental responsibility, and

Principle 9: Encourage the development and use of recognized environmental technologies.

Anti corruption

Principle 10: The company shall prevent any form of corruption, including extortion and bribery.

Further information on our work can be found in the following documents:

• Etiske retningsliner (Ethical guidelines)
• Code of Conduct

Questions on how we work with the Transparency Act can be sent to aapenhetsloven@gillgruppen.no