T O SLETTEBØE AS
OUR HUMAN RIGHTS POLICY
Quality in all aspects of our business model is a trademark for T O Slettebøe AS. Our core values – reliability, quality, availability, and reputation – are also closely linked to our goal of being a responsible and sustainable business. Our product range includes almost everything that is used in an industrial context. We represent the world's leading manufacturers in our local market and import many products that are sold nationally. Apart from sales and engineering, we also have a service department that covers most needs within assembly, service, and repair.
An extensive supply chain with many branches also entails risks for people and the environment, both at manufacturing level and in connection with the extraction of raw materials. At T O Slettebøe, we are aware of our environmental and social footprint, and are committed to ensuring that the products we sell are as sustainable as possible. This includes a focus on basic human rights and decent working conditions, which is a central part of a sustainable and responsible supply chain.
Our policy for basic human rights and decent working conditions explains our commitment, significant areas of risk and how we work to implement this in our business conduct. The policy further clarifies what we expect from suppliers (see also our ethical guidelines for suppliers).
This human rights policy explains our commitment and how we seek to put it into practice. The policy clarifies further what we expect from suppliers (see code of conduct for suppliers).
We comply with relevant national and international laws, rules, regulations, and norms in our daily business. As part of this commitment, we strive to implement our corporate responsibility to respect human rights in line with the United Nations Guiding Principles (UNGP) on Business and Human Rights and the OECD Guidelines for Multinational Enterprises throughout our operations.
We support the 2030 Sustainable Development Goals and respect all internationally recognized human rights, including the International Bill of Human Rights and the principles concerning fundamental labour rights set out in the International Labour Organization’s (ILO) Declaration on Fundamental Principles and Rights at Work.
As set out in the UNGP, all companies have a responsibility to respect human rights, which means preventing and addressing negative impacts on people resulting from their business operations.
We undertake human rights due diligence to identify, prevent, mitigate, and account for how we address risks to people’s human rights in our operations and our supply chain.
As required by the Norwegian Act relating to enterprises’ transparency and work on fundamental human rights and decent working conditions (the Transparency Act), we will publish an account on our human rights due diligence. Also, as required by the Transparency Act, we provide information about our human rights due diligence if requested by external parties.
Key human rights issues for our company
Our own activities
We are committed to respecting the basic human and labour rights of our employees. We follow all relevant Norwegian legislation on the working environment, health, safety, and environment (HSE), diversity and anti-discrimination, employees' freedom of association and privacy. Our daily work in these areas is governed by our personnel handbook.
All employees must have a working environment that provides the basis for a health-promoting and meaningful working situation, which provides complete security against physical and psychological harm. We ensure HSE in the workplace through our quality policy, health and safety policy, environmental policy, and associated procedures. These are reviewed at regular intervals.
At T O Slettebøe, we have an ambition of zero injuries to personnel and material. We have not had any serious accidents, and the risk of negative consequences for people in our own workplace is low. Employees must be treated with respect and dignity. Unwanted strain, bullying and harassment are not accepted in our company.
We are committed to strengthening diversity across the company, which includes strengthening the gender balance at management level and recruiting employees from different nationalities. We do not accept any form of harassment or discrimination against employees or others with whom we deal through our business. The company works actively to ensure equal opportunities and rights and prevent discrimination, and we follow the Equality and Discrimination Act. We respect the privacy of our employees, customers, and suppliers. Employees of T O Slettebøe have an obligation to process information with care. This includes both personal information and confidential information.
Employees are encouraged to report concerns that may arise in the workplace. HSE incidents are reported via our internal HSE procedure. Our procedure for dealing with bullying and harassment or other inappropriate behaviour and ethical concerns is readily available to all employees.
Supply chain
To meet our customers' needs, T O Slettebøe has a broad product range that includes almost everything that is used in an industrial context. We are proud of this, but we are also aware that a supply chain that includes many links, countries and industries also entails risks for people and the environment, both at manufacturing level and in connection with the extraction of raw materials.
We have long-term, well-established relationships with many stable suppliers that ensure a large degree of continuity in our supply chain. Most of our suppliers are either Norwegian suppliers, or European suppliers who are themselves subject to laws and regulations related to decent working conditions and increased requirements to carry out due diligence related to the risk of breaches of international standards in supply chains.
A challenge related to carrying out due diligence is that the large segment of goods for industrial use – from machines, tools, equipment to fasteners and hardware – has not been subject to investigations and research in the same way as goods sold in the consumer market. Generally, the supply chain is complex and often lacks transparency beyond the first tier.
Global challenges in production and at raw material level
We know that many products are made in Asia, where the risks to workers and other stakeholders in industrial manufacturing in several countries can be high, including:
- Risk of forced labour
- Discrimination in the workplace, both with regard to gender and discrimination against minorities
- Lack of freedom of association
- Health and safety in the workplace
- Working conditions, both with regards to working hours and decent wages
Even when finished goods are produced in Norway or the EU, this is no guarantee that the supply chain is risk-free, as challenges may exist elsewhere at other tiers. One of the most significant risks in the industry is a lack of transparency down the supply chain, and that production and raw material extraction can take place in regions where historically associated with considerable human rights related challenges. There are major challenges in several of the countries that supply the raw materials (minerals and metals) for the products in our value chain. Amongst others, Brazil, China, and India are major suppliers of iron, which is one of the main input factors for what eventually ends up as finished products. Human rights violations in connection with extraction have been documented in a number of cases in these and other producer countries. Documented violations include the forced relocation of local populations and major environmental problems with negative consequences for people. However, traceability and information about the origin of these minerals and metals are a major challenge – for the entire industry and a number of other sectors. This is a challenge that no company can solve on its own and is a task that will take a long time to solve.
We take our share of the responsibility by setting clear expectations for suppliers.
T O Slettebøe expects the same from our suppliers as we do from ourselves. This means that all employees and others affected by the business are treated with dignity and respect. We expect suppliers and other business partners to adhere to our Supplier Code of Conduct, which includes an expectation to adhere to global minimum standards, namely respect for international human rights and decent working standards, including the prevention and management of forced and child labour. We examine our suppliers on their commitment to human and labour rights and their own supply chain due diligence.
We also ask our suppliers to document their due diligence. If we identify direct links to serious human rights violations in any component of our products, we will enter into dialogue with the supplier to address the issue. If identified abuses are not addressed and remediated after a reasonable period of time, contracts may be suspended or terminated.
Together with other companies in the industry, as well as suppliers, authorities and other stakeholders, we want to contribute to a sustainable supply chain where the social pillar is safeguarded.
Link: Code of conduct for suppliers.
Our approach
Our commitment to respect human rights and decent working standards is implemented in line with the UNGP and OECD Due Diligence Guidance for Responsible Business Conduct (figure 1). This approach includes:
- Top-level commitment and oversight;
- Embedding the responsibility to respect human rights in relevant policies and procedures;
- Awareness-raising among employees;
- Processes to identify potential and actual human rights risks in our own activities and in our value chain;
- Requiring human rights due diligence from our suppliers and business partners;
- Procedures to follow up on identified risks and impacts;
- Tracking the effectiveness of measures to address identified risks and impacts, with a view to ensuring continuous improvement;
- Reporting on our human rights due diligence, in line with the Norwegian Transparency Act;
- Contributing to remediation of harms if caused or contributed to by our activities;
- Periodically reviewing and improving our policy and its implementation.
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Figure 1.
The six steps of the OECD due diligence process
Source: OECD
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Responsibility
The policy is approved by the board. The CEO is responsible for its implementation.
Transparency about our commitment to human rights
In accordance with the Transparency Act, we publish our due diligence account on our webpage. We update and publish the account yearly.
We respond to requests for information about our human rights policy and due diligence, in line with the information duty of the Transparency Act.
Contact: post@sletteboe.no
References
UN Guiding Principles on Business and Human Rights (UNGP)
OECD Guidelines on Responsible Business Conduct
OECD Due Diligence Guidance for Responsible Business Conduct
Norwegian Transparency Act
Approved by the board: 21.03.2023