FotoWare's Compliance With The Norwegian Transparency Act



As a Norwegian company, FotoWare is obliged to comply with the “The Norwegian Transparency Act”, which came into force on 1 July 2022, and promotes companies' respect for fundamental human rights and decent working conditions.

FotoWare's suppliers, business partners and collaboration partners (together called "Vendors") are central to the ability to carry out our business. It is important that our business relationships are based on trust and transparency, and that our Vendors make good ethical decisions, practice good financial integrity, comply with current laws and regulations, and respect international standards and recognizes human rights.

We are by law obligated to carry out due diligence assessments, and we have hence mapped our own business and supply chain in accordance with The Transparency Act.

About FotoWare

FotoWare is a Norwegian software company that develops and delivers innovative Digital Asset Management (DAM) and Digital Evidence Management (DEM) solutions to customers worldwide, and our areas of operations are development, services, marketing, and sales. All production is conducted in Norway, Sweden, Switzerland, and Australia. FotoWare has more than 100 employees across Europe.

FotoWare's business is organized as follows:

Visual representation of Fotware's company structure including the following entities: FotoWare Holding, FotoWare AS, FotoWare Sweden AB, FotoWare Denmark ApS, FotoWare UK Ltd, Xenario GmbH, FotoWare Switzerland, and Vision Information Transaction Inc.

FotoWare's company structure with the following entities: FotoWare Holding, FotoWare AS, FotoWare Sweden AB, FotoWare Denmark ApS, FotoWare UK Ltd, Xenario GmbH, FotoWare Switzerland, and Vision Information Transaction Inc.

All the companies in FotoWare's business are included in the scope of The Norwegian Transparency Act.

FotoWare is committed to fulfilling its role in society and its social responsibility by acting in accordance with applicable legislation and regulation. FotoWare takes pride i having Vendors who are committed to delivering a high level of quality to our joint customers.

Risk-based and continuous process

FotoWare's framework for due diligence assessments is based on the UN Universal Declaration of Human Rights and the OECD Due Diligence Guidance for Responsible Business Conduct (2018), which is illustrated in the model below. The model describes a risk-based method that starts with ensuring accountability, mapping, and assessing risk, and culminates in establishing measures, reporting, and monitoring.

This is a continuous process in FotoWare where we will identify risks, negative consequences, uncover possible risks, and work to reduce these and implement measures.

FotoWare and our Vendors must have a risk-based approach and work actively to reduce risks of violations of basic human rights and decent working conditions within the business, throughout the supply chain and with business partners. FotoWare and our Vendors must prioritize and implement control measures depending on the level of risk and reduce negative consequences, if there are any. We expect our Vendors to report negative consequences or risks to FotoWare.

OECDs due diligence model

The six steps of the OECD Due Diligence Guidance

Overall, the due diligence assessment model is implemented in FotoWare in the following way:

1: Embed responsible business conduct into policies and management systems

Anchoring of The Transparency Act is conducted through our policies, routines, guidelines, and action plan. It is entrenched in the board that the business must comply with the obligations under The Transparency Act, and the board has given the CEO responsibility for compliance.

2: Identify and assess actual and potential adverse impacts associate with the enterprise’s operations, products or services

FotoWare has establishing an overall risk picture of our Vendors and we have risk assessments based on selected Vendors.

3: Cease, prevent or mitigate adverse impacts

Based on the risk assessment and prioritization of risk in step two, FotoWare will implement measures to stop, prevent and reduce risk of negative impact where this is necessary.

4: Track implementation and results

FotoWare has regular internal and external reviews of our measures and plans to ensure that these have the desired effect.

5: Communicate how impacts are addressed

We are transparent with our risk level conducted in the due diligence assessment and will in a statement report openly and honestly on measures and challenges related to The Transparency Act.

6: Provide for or cooperate in remediation when appropriate

If a deviation has occurred, we will take measures to ensure that those responsible for the breach in our value chain rectify this and help and influence the initiation of measures if required.

Results from the due diligence assessments

In this section, we will report our results from the due diligence assessments in FotoWare’s own business and supply chain.

FotoWare – our business

We have conducted a risk assessment in our own business and based on FotoWare zero tolerance for illegal and unethical business behavior and activities, including bribery and corruption, tax controls, forced labor, child labor, non-decent working conditions, and other breaches of human rights, we have not uncovered any consequences or risks.

We have policies and guidelines with a high focus on diversity and equality and we work continuously with maintain a working environment free of bullying, harassment, victimization, and unlawful discrimination, promoting dignity and respect for all, and where individual differences and the contributions of all employees are recognized and valued.

Even though we have not uncovered any negative consequences or risk in our business, FotoWare has implemented several measures to avoid risks, and to highlight some of these measures we have updated our Code of Conduct for Employees to include Ethical Guidelines, we have created a Code of Conduct for Vendors, we have Vendor review once a year,  we have whistleblower routines and in our Procurement Procedure it is measures to prevent FotoWare from entering contracts, agreements or relationships with Vendors who do not meet our requirements, and this includes requirements for human rights and decent working conditions.

Supply chain

FotoWare has done extensive research of our Vendors and narrowed our supply chain down to a number that is possible to follow up with further risk assessment. We have therefore done detailed risk assessment on 24 of our Vendors who has been selected based on the following criteria:

  • Vendors who are business critical for our operations and delivery to our customers.
  • Vendors that deliver specific services within certain industries are particularly exposed to ethical breaches.
  • Vendors in specific geographical areas are particularly exposed to ethical breaches.

Our Vendors are from Western Europe, USA, Canada, Australia, Israel, and Brazil and can be divided in:

  • Vendors who are resellers of FotoWare's products and services
  • Vendors that FotoWare purchase software, IT solutions and products from
  • Vendors who deliver services to FotoWare in the form of hired consultants.

As a method for collecting data, FotoWare  created a Vendor Survey which was sent to the selected Vendors based on the criteria above. The survey has given us access to large amounts of information from several companies, and the information and results from the survey has provided good information for the following work with the due diligence assessments. We sent the survey in week 10, 2023 with a deadline of 7th of April 2023, and analyzed all information received the following week.

FotoWare has efficient procedures for procurement and yearly audits of our Vendors that prevent us from purchasing software or products from Vendors who do not comply with laws, regulations, and requirements, and we have therefore not uncovered any negative consequences or risk related to vendors and procurement.

Due to employment through external companies in Europe, we have Vendors with employees currently sitting in risk-prone areas due to the war in Ukraine. FotoWare has a good cooperation and dialogue with this Vendor and all the consultants, and after conducting a risk assessment, we can confirm that the consultants are treated well by the Vendor and that the Vendor has initiated effective measures to support and monitor the situation for their employees. The results from our risk assessment confirm that the Vendor comply with legislating law and regulations, and with FotoWare`s requirements.

FotoWare also have a Vendor located in Israel where there is an ongoing conflict. The results from the  risk assessment show that there are no negative consequences or risks with this Vendor.

Industries such as cleaning and canteen may be associated with possible risks. We have also here conducted an extensive risk assessment and can confirm that our Vendors comply with legislating law and regulations, and with FotoWare`s requirements.

The results from our overall risk assessment show that FotoWare does not have any negative consequences or risks in our business or supply chain and considers the general risk level to be low. Therefore, it is not necessary for FotoWare to implement any additional measures at this time, but we will continue to work with risk assessments and monitor all our vendors to ensure that we do our outmost to have a compliant and trustworthy supply chain.