The registered office of Amby AS (“Amby") is Thorvald Meyers Gate 7, 0555 Oslo, Norway. The policies, procedures, and systems described in this Statement have been adopted by Amby. References to “we”, “us” and “our” in this Statement are to Amby, unless otherwise required.

This statement has been prepared in line with the requirements of the Norwegian Transparency Act to explain and document Amby’s work with human and labour rights, including the specific measures undertaken by Amby.

Amby is committed to respecting human rights and decent working conditions as a
fundamental principle in our operations.

About Amby

Amby is a leading embedded recruitment provider, operating through a structured
framework that empowers client companies to scale and succeed in their respective markets. With a dedicated team of approximately 150 professionals, our operations span across Norway and the European Union.

Amby’s capital group consists of interconnected entities working in harmony to deliver comprehensive recruitment solutions. At the core of our structure is Skeil AS, serving as the parent company and providing strategic oversight and guidance to the group. Skeil AS holds controlling interests in both Amby AS, Nixa.io AS, and Kvant Consulting AS, establishing a strong foundation for our operations. Amby AS, a subsidiary of Skeil AS, plays a vital role in delivering tailored recruitment services. Through its wholly-owned subsidiaries, Amby Sweden AB and Amby Poland sp. z o. o., Amby extends its reach and expertise to meet the diverse needs of clients across regions. Additionally, Nixa.io AS, another subsidiary of Skeil AS, significantly contributes to the group's capabilities. Nixa.io AS holds full ownership of Nixa.io Poland sp. z o.o. Kvant Consulting AS is not strongly associated with the operations of Amby AS and Nixa.io AS. Kvant Consulting AS has a subsidiary in the form of Kvant Consulting Norway AS. This interconnected structure within Amby Capital Group allows us to leverage the strengths of our entities, enabling us to offer comprehensive and customized recruitment strategies tailored to the unique requirements of client companies

Our Principles

Amby fully recognizes its duty to uphold human rights and is dedicated to implementing the United Nations Guiding Principles on Business and Human Rights and OECD Guidelines for Multinational Enterprises in all its activities. The dignity of every individual and the significance of their human rights are fundamental principles that guide the conduct we require from every person associated with us, whether as a direct employee of Amby or indirectly through our supply chain. We do not tolerate any kind of discrimination, harassment, or bullying within Amby or our supply chain. In addition, we continually evaluate suppliers' performance and compliance with human rights and working conditions. This involves reviewing supplier policies, conducting audits or assessments, and verifying compliance with international labor standards and applicable laws and regulations.

Our Policies and Procedures

We prioritize suppliers that demonstrate a strong dedication to promoting human rights and ensuring decent working conditions throughout their operations. We identify potential suppliers based on their reputation, industry recommendations, and alignment with our commitment to human rights and decent working conditions.

When a high-risk supplier is identified, we undertake steps to obtain additional assurance that their practices are compliant with the Norwegian Transparency Act. This includes statement and policy reviews, questionnaires, and further meetings with the supplier when appropriate. The results of these supplier assessments will be recorded and refreshed periodically.

Our employees are expected to report any concerns, including those related to human rights violations, to the People & Operations team who will investigate all allegations and take appropriate action. Employees are welcome to be anonymous or self-identify, but it is not a requirement, and the process is designed to respect their privacy and preferences. One of Amby's plans for the 2024/2025 is to introduce a Code of Conduct for suppliers and employees. All employees will be required to complete a Code of Conduct training to ensure adequate awareness and knowledge of our ethical principles including human rights.

Amby will also undertake steps to provide a copy of the Code of Conduct to our suppliers by adding a Code of Conduct clause to Amby’s supplier terms and conditions. If these standards cannot be met, Amby will take reasonable steps to review the relationship and, if necessary, consider whether to continue the supplier relationship if the deficiencies cannot be corrected within a reasonable period of time.

• Industry Risk - This entails assessing whether the supplier operates within industries that pose a higher likelihood of hazardous manufacturing processes, which could have adverse effects on health, safety, and the environment.
• Area of Operations Risk - In this aspect, the evaluation focuses on determining whether a particular supplier conducts operations in countries with elevated risks associated with corruption, law enforcement challenges, and potential concerns regarding labor practices and human rights.
• Reputational Risk - Within this dimension, the assessment centers on appraising the overall reputation of the supplier under consideration

• The risk of adverse impacts on fundamental human rights and decent working
  conditions. The extent of the assessment was based on the magnitude of the risk.
• The consequences of adverse impacts. The assessments were more comprehensive when the potential harm to individuals or groups was more severe.
• The extent of our ability to influence the situation. The evaluations and capacity to exert influence depended on factors such as the size of the business partnership.

• Manufacturing: Industries such as apparel, electronics, and consumer goods often involve complex global supply chains with multiple tiers of suppliers. Risks in these industries may include forced labor, poor working conditions, and violations of labor rights.
• Extractive industries: Industries such as mining, oil and gas, and agriculture may
  involve risks related to land rights, displacement of indigenous communities,
  hazardous working conditions, and environmental damage.
• Construction: Construction supply chains can be susceptible to risks related to
  migrant worker exploitation, unsafe working conditions, and non-compliance with labor regulations.
• Food and agriculture: Supply chains in the food and agriculture sector can have risks related to forced labor, child labor, unsafe working conditions, and environmental issues such as deforestation or excessive use of pesticides.
• Technology and electronics: Electronics supply chains often have risks associated with labor rights violations, conflict minerals, and environmental pollution.