The Norwegian Transparency Act

Introduction

This is a statement on Tromsø Vind AS and Raudfjell Vind AS’ assessments pursuant to section 4 of the Transparency Act, cf. section 5 of the Act. The statement has been updated as of 19 June 2023.

The companies’ business is the production of wind power through ownership and operation of the Kvitfjell and Raudfjell wind power plants in Tromsø municipality. The wind turbines have a total installed capacity of 288.1 MW, with 67 turbines.

Management of the companies and the wind power plants is largely handled by Prime Capital AG. Operation of the plants is overseen by Zephyr AS.

The companies are owned by Nordlicht Holding GmbH & Co. KG.

Working environment

As the operator of the wind farm, ensuring fair labor conditions and prioritizing safety in our operations is a top priority. We recognize that the employees are essential to the success of the business, and their safety and well-being must be our greatest concern.

Business operations in Norway are subject to strict requirements for the working environment and employees’ rights, which both we and our subcontractors are obliged to comply with.

To guarantee fair working conditions, we ensure that our contractual partners comply with all applicable laws and regulations, including those related to minimum wage, working hours and workplace safety. This is done by seeking to include explicit requirements for compliance with relevant laws and regulations, including those related to the working environment, in the contracts our companies enter into with subcontractors and service providers.

Safety in the workplace is one of the highest priorities for us. To ensure a safe working environment and minimize potential dangers and risks, a proactive approach is taken by our contract partners.

All employees working within the wind farms are provided with comprehensive training and support to perform their duties safely and effectively. Potential risks are identified through regular safety inspections to ensure that the equipment and facilities meet the highest standards.

Equality and Diversity

Our companies are committed to sustainability and recognize that promoting equality and diversity is essential to creating a more sustainable and just society. We are committed to promoting equality and diversity in all areas of our business, including our business partnerships and supply chain. We expect our suppliers and partners to comply with all applicable laws and regulations relating to equality and diversity.

Local Impact on Communities

As part of our social responsibility, our company recognizes the responsibility towards communities impacted by the wind farms. Therefore, we have ensured that the wind farms do not have a harmful impact on the local communities. Any unavoidable impact on the region has been offset through close consultation with the landowners, by mutually beneficial agreements.

Our wind power plants also support local events and associations, for example through a permanent sponsorship agreement with the Kvitfjell Ski Association and the construction of a new barbecue hut for the kindergarten on Sommarøy.

Environmental Responsibility

The environmental impacts from the wind power plants are thoroughly analyzed in the project planning phase. The results can be found here. Operation of wind power plants in Norway is generally subject to very strict environmental requirements.

The responsibility during the operative phase consists in following the mitigating measures that have been developed from the analysis and possibly carrying out adjustments in case of further impacts.

Through agreements, our partners undertake to comply with the applicable laws and regulations on waste management and treatment in connection with the operation of the wind power plants. Incidents or nonconformities with consequences on the external environment are handled in accordance with the regulations and in a timely manner. The incidents are continuously monitored and reviewed in terms of prevention.

Tromsø Vind AS and Raudfjell Vind AS prepare annual greenhouse gas accounts to measure, document and implement targeted measures to reduce greenhouse gas emissions from its operations.

Due diligence in the supply chain

The companies had around 45 key business partners in 2022, most of which are well-known, Norwegian companies, and a large part of which have drawn up internal policies and guidelines on sustainability and social responsibility. The subcontractors are domiciled in Norway and other countries where companies are subject to strict requirements relating to environmental issues, employee rights, equality, anti-corruption, etc. in the exercise of their business activities, and which the subcontractors are consequently bound by.

In accordance with the Norwegian Transparency Act, Prime Capital AG carried out a due diligence of the key business for the year 2022. The assessment is an ongoing process and will be carried out on a yearly basis in a for the business suitable scale. The risk assessment focusses on an overview of the Sustainability and Human Rights policies of our key suppliers, their compliance with their respective national and international regulations and is underlined by review of implemented business certifications and standards.

This years’ results showed that our business partners are clearly aware of their responsibilities for the observance of human rights and associated fair working conditions, the avoidance of child labor and equal opportunities, etc.

In the event of a breach of our guidelines, either internally or with one of our business partners, immediate measures will be taken to address and rectify the situation, to ensure strict compliance with the established guidelines.

Code of Conduct

Our Code of Conduct serves as a guiding framework for ethical behaviour and sets the standards of conduct for our organization and our suppliers. It outlines our company’s values and expectations for ethical behaviour, compliance with laws and regulations and accountability in all our interactions and decision-making processes. You can download the Code of Conduct here.

Approval of these Statements by the Board