Report on Due Diligence Assessment according to Transparency Act

1. The Transparency Act

The Norwegian Transparency Act shall promote companies' respect for basic human rights and decent working conditions and ensure the public's access to information.

The Act sets out strict requirements for the working relationship and human rights in companies.

• The purpose of the Act is to promote respect for human rights and sound working conditions in companies and imposes a duty on companies to inform and publish how they work to ensure human rights and sound working conditions.
• The law imposes an information obligation on larger enterprises: You may send information requests to which Otello must normally respond within three weeks, and Otello is required by law to carry out due diligence assessments that must be made public every year.

2. To whom the law applies

The Transparency Act applies to larger enterprises, either with a business address in Norway, or foreign companies that offer goods and services in Norway and are liable to tax in Norway.

Companies that are either covered by § 1-5 of the Accounting Act, i.e., public limited companies and other companies subject to accounting obligations whose shares, shares, capital certificates or bonds are listed on a stock exchange, authorized marketplace, or equivalent regulated market abroad, as well as other companies if stipulated in regulations.

Companies that exceed the limits for two of the following three conditions are also considered larger enterprises:

• Sales revenue of above NOK 70 million.
• Balance sheet above NOK 35 million.
• The average number of employees in the financial year is above 50 full-time employees.

Smaller enterprises may also be affected by the law - this applies in particular to those companies that are suppliers to larger enterprises, and who in that connection may face demands to live up to the same standards.

3. Obligation to provide information according to The Transparency Act

From 1 July 2022, everyone has the right to demand information about how Otello complies with the Transparency Act, as well as how Otello handles negative impacts on fundamental human rights and decent working conditions.

• Requests for information must be made in writing. This can, for example, be done by sending an e-mail to this e-mail address transparency@otellocorp.com
• A request for information does not have to be justified, but a justification from the information seeker can contribute to a more comprehensive response to the request.
• The right to information includes both general information about how Otello handles negative consequences, and specific information relating to goods and services.

Companies covered by the Transparency Act must inform anyone who requests it in writing about the analysis of risk and the measures implemented in the event of any findings of violations in regard to human rights and working conditions. Information must, as a general rule, be given in writing, be comprehensive and be understandable. The Act imposes companies a duty to provide information within a reasonable time, and no later than three weeks after the inquiry was received.

4. Refusal of requests for information

Companies that are covered by the Transparency Act must initially respond to all requests for information on how the Company handles negative consequences for human rights and decent working conditions.

Otello can refuse information requests in the following cases:

1. The claim does not provide a sufficient basis for identifying what the claim applies to.
2. The demand is obviously unreasonable.
3. The requested information concerns information about someone's personal circumstances.
4. The requested information relates to information about technical devices and methods or other operating or business conditions which it would be competitively important to keep secret for the sake of the information concerned.

5. Reporting of security breaches/incidents

If someone discovers a breach of security or incidents that could have an impact on security, report it immediately to the Transparency Officer at Otello.

Otello has carried out an assessment which concludes that Otello is covered by the Transparency Act.

Otello is covered by this Act since Otello is a public limited company (ASA).

• If Otello does not fulfill its obligations under the Transparency Act, you may submit a Complaint for breach of the Transparency Act's obligation to provide information (link to the Norwegian Consumer Authority's form).
• First, any complaints should be addressed to Otello. Contact information for the Transparency Officer at Otello is: transparency@otellocorp.com

6. Duty to carry out due diligence assessments

Otello will carry out due diligence assessments which are reported and made public. The first report will be available from this website by 30 June 2023.

The Act imposes that companies submit a report every year by 30 June that explains the due diligence assessments that Otello has carried out.

• Due diligence assessments mean that companies obtain an overview of, as well as analyze, the risk of violations of human rights, and uncover unacceptable working conditions.
• Companies are responsible for stopping, reducing or preventing negative impacts on the working relationship and human rights, both in their own business, with suppliers and with other business partners. Due diligence assessments are not limited to the conditions within one's own business.
• The due diligence assessments must be carried out regularly and in line with guidelines from the OECD. Otello will also carry out assessments of conditions at subcontractors and other business partners.

Otello aims, as far as it is practically possible, to add contract clauses or confirmations from its supplier chain and business partners that ensure compliance with the Act.