Trans­pa­rency Act Report 2022

This report has been prepared in accor­dance with the Norwegian Trans­pa­rency Act (the “Trans­pa­rency Act”) section 5 and summa­rizes the policies and proce­dures in Perfect Tempe­rature Group AS (“PTG”) with respect to safeguarding of human rights and decent working conditions and provides infor­mation on the imple­men­tation and results of due diligence conducted by PTG.

About PTG
PTG companies develop and deliver environ­men­tally friendly solutions for refri­ge­ration, freezing and enhancing energy efficiency. We are a substantial supplier to the grocery sector in Norway and to the seafood market natio­nally and inter­na­tio­nally. Our products help to cut energy consumption and increase profi­ta­bility for our customers in the marine, industrial, commercial and air conditioning markets. We are a complete supplier of sustai­nable tempe­rature and energy solutions.

PTG was created by initially integrating the companies Kulde­teknisk, FrioNordica, Kjøle­service Helgeland and Multi Kulde (Bodø). Today, PTG conso­li­dates more than ten companies across Norway and owns subsi­diaries in the UK and Chile. With over 300 employees and annual turnover of roughly NOK 1.0bn, Perfect Tempe­rature Group has grown into Norway’s largest center of expertise for tempe­rature management.

The value of perfect temperature
PTG contri­butes to signi­ficant reduc­tions in energy and emissions by delivering energy-efficient solutions which improve the climate. We create added value for our customers through perfect tempe­rature management along the whole value chain. Our products are developed for low energy consumption and heat recovery. By tailoring energy consumption to the refri­ge­ration requirement, we protect the environment and our customers from unnecessary emissions and costs.


We know that the end-product value increases when fish are chilled and frozen while at their freshest and when their nutrient content is at its best. Our solutions also improve operating economics by cutting fuel consumption and working time. In partnership with our customers, we identify the perfect tempe­rature and solutions which are cost-efficient and environment friendly.

Our marine customers:
White fish vessels, pelagic vessels, well boats and suppliers of factories and processing plants.

Our knowledge of efficient production and high quality provides customers with the perfect tempe­rature and the best results. Seeing the overall picture in close coope­ration with customers allows us to help enhance end-product value.

Our industrial customers:
Aquaculture, processing of white and pelagic fish (filleting, packing, and freezing), abattoirs, bakeries, food on the go, studies and research, power generation, breweries, and suppliers of factories and processing plants.

Our refri­ge­ration and heat pump solutions help to keep food fresh and healthy in a cost-effective and environ­men­tally friendly manner. In coope­ration with our customers, we develop forward-looking solutions which suit stores of all sizes in the grocery sector.

Our grocery customers:
Individual stores, chains and construction companies.

Together with customers, we develop environ­men­tally friendly air conditioning and heating solutions which help to cut energy consumption and improve profi­ta­bility. We take care of the environment and the customer’s values in a secure manner and provide the best service and follow-up from the first conver­sation and throughout the system’s commercial life.

Our climate customers:
Construction companies, pipework and sanitary equipment contractors, property devel­opers, computer rooms, public and private buildings, hospitals, and housing associations.

Commitment to human rights and decent working conditions
PTG works to ensure that our opera­tions and business conduct do not have actual or potential adverse impact on human rights and decent working conditions. In 2022 and conti­nuously, PTG AS worked proac­tively to safeguard human rights and decent working conditions. Some of the measures included updating our internal policies and proce­dures related to human rights and conducting analysis of our actual and potential risk of adverse human rights impacts. We conducted assess­ments of human rights protection at suppliers in 2022 and identified risks and mitigating measures as part of the due diligence process for 2022–2023. We also provided general human rights training to employees and more extensive training related to the provi­sions of the Trans­pa­rency Act for employees in roles such as supply chain, finance, people and organization.

Reporting under the Norwegian Trans­pa­rency Act
The Norwegian Trans­pa­rency Act entered into force on July 1, 2022. The purpose of the Act is to promote enter­prises’ respect for funda­mental human rights and decent working conditions in connection with the production of goods and the provision of services and ensure the public access to infor­mation regarding how enter­prises address adverse impacts on funda­mental human rights and decent working conditions.

The reporting requires a general description of the following:

  1. General description of the organization, operating areas, markets and products;
  2. Guide­lines and routines for dealing with actual and potential negative conse­quences for funda­mental human rights and decent working conditions;
  3. Infor­mation on actual negative conse­quences and signi­ficant risk of negative conse­quences that the enter­prise has discovered through its due diligence assessments;
  4. How the work with the due diligence assessment is organized; and
  5. Specific infor­mation on actual negative conse­quences and substantial risk for negative conse­quences which enter­prises have identified through their due diligence assess­ments and measures the enter­prises have taken or plan to take to stop actual negative conse­quences or to limit substantial risk.


PTG’s reporting is based on the UN Guiding Principles on Business and Human Rights and the OECD model for Due Diligence for Respon­sible Business Conduct.

Due diligence metho­dology has the following six steps (in the picture below) that describe how companies can work for more respon­sible and sustai­nable business practices.

OECD model for Due Diligence for Respon­sible Business Conduct

Guide­lines and routines for handling Human Rights Due Diligence
At PTG, we recognize our respon­s­i­bility to minimize the adverse impact of our opera­tions, supply chains and other business relation­ships. Therefore, respon­sible business conduct (RBC) is strongly embedded in our policies and management systems. We embrace our obligation to perform assess­ments of impact on human rights and conduct due diligence to under­stand and mitigate adverse impact and ensure that PTG does not contribute to adverse human rights impacts.

PTG’s Board of Directors has the oversight respon­s­i­bility of the management of the company. The strategic direction is confirmed by the Board of directors, where environ­mental, social and gover­nance issues are an integral part of the strategy process.

The CEO holds the respon­s­i­bility for managing ESG including impacts on human rights and decent working conditions, supported by the management team, which is accoun­table for ensuring the effec­ti­veness of the management processes and review of mitigation efforts for identified impacts. This includes assessing and managing risks of adverse impact on human rights and decent work related to PTG’s operations.

Finance function with Chief Financial Officer and Supply chain function have respon­s­i­bility to carry out the due diligence process and in coope­ration with the management team define the areas of business where respon­sible business conduct risks are most likely to be present and most signi­ficant, as well as stop, prevent and mitigate adverse impacts.

Management team has the respon­s­i­bility for imple­menting aspects of the policies across relevant depart­ments such as human resources, supply chain, IT, sales, service, technical, with parti­cular attention to those workers whose actions and decisions are most likely to increase or decrease risks related to respon­sible business conduct.

As part of the imple­men­tation process of the require­ments of the Norwegian Trans­pa­rency Act, PTG estab­lished a procedure for handling infor­mation requests. The supply chain and finance functions are respon­sible for regular monitoring and follow-up of incoming requests for information.

PTG’s approach to managing human rights risks and promoting decent working conditions
Our overall approach to ensuring respect for human rights and decent working conditions throughout our opera­tions and supply chain includes stake­holder involvement and coope­ration through industry initia­tives. PTG supports employees’ rights to form and join trade unions, and their right to remain non-unionized. Employees are informed of their trade union rights during onboarding and unions may promote themselves freely. PTG also follows the principles of diversity and inclusion as stated in our internal policies. PTG is reflecting on its expecta­tions related to ethical business conduct in documents with suppliers. PTG recog­nizes an obligation to carry out human rights due diligence pursuant to the OECD Guidelines.

We are committed to carrying out our business in a way that supports and respects the protection of inter­na­tional proclaimed human rights. We do not engage in or support the use of child labor and fully support the elimi­nation of all forms of forced labor.

The Company has estab­lished relevant policies and proce­dures, which set out how we manage issues related to human rights and decent working conditions in our supply chain that support and respect protection of inter­na­tio­nally proclaimed human rights, labor rights, rights to freedom of association and non-discri­mi­nation. All policies and proce­dures are available for our employees in the Management System RMT+. Our policies are reviewed and updated as necessary by the Management Team in the annual management reviews. The company is committed to ESG policies through infor­mation sharing and the devel­opment of recom­men­da­tions across depart­ments and functions.

Due diligence on human rights and decent working conditions
PTG under­takes due diligence to identify, prevent, mitigate, and account for adverse impacts on human rights and decent working conditions. In line with the Trans­pa­rency Act and the OECD Guide­lines, as well as the United Nations Guiding Principle on Business and Human Rights, we apply a risk-based approach when evaluating risks of adverse impact on human rights and decent working conditions. This involves looking at the location and context of opera­tions, nature of activity, the number of people that are potentially affected and severity and proba­bility of impact.

In 2022 we started mapping our suppliers and business partners to identify risks of actual and potential adverse impacts associated with our opera­tions. We assessed and evaluated these impact areas in our risk assessment process. The procedure is based on the six steps of the UN Guiding Principles on Business and Human Rights and the OECD model for Due Diligence for Respon­sible Business Conduct. Mapping and assessment of risks is a conti­nuous process where our target is to implement measures where the risk of adverse impacts and our opport­unity to influence is the greatest. Relevant elements that we based our risk assessment on are the following: Country, type of product and/or service, turnover of contractual party, industry.

The risk assessment takes its starting point in the general risk for adverse human rights impact related to geograp­hical location and industry sector. PTG AS operates in a low-risk environment regarding human rights impact as most of our opera­tions are located in Norway (with subsi­diaries in UK and Chile), which on inter­na­tional human rights indexes has a very low risk, and where general and industry specific regula­tions safeguard human rights. Despite signi­ficant presence in Norway, we remain dependent on global suppliers. Our suppliers’ fabri­cation yards are often located in countries that are exposed to certain human rights risks. We do recognize a risk of forced and compulsory labor, risk related to safety and security at the workplace and risk related to migrant workers among our suppliers and the supply chains of our suppliers, parti­cu­larly in Asia and Eastern Europe.

Based on our risk assess­ments, PTG has defined the following key risk areas for human rights due diligence for 2022–2023:

  • Metal processing plants
  • Instal­lation and other hired technical services
  • Electronic equipment


Mitigation of risk
Based on our risk analysis, we have not identified actual adverse impacts on funda­mental human rights and decent working conditions linked to our own opera­tions. Human rights due diligence assess­ments of selected suppliers have identified and remedied some gaps in the supplier business management related to safeguarding of human rights and decent working conditions. We are working to mitigate these gaps by imple­menting corrective action plans together with suppliers. Measures imple­mented consist of a combi­nation of direct dialogue with the supplier, our own research, and formal actions.

Tracking imple­men­tation and results
The supply chain function is respon­sible for tracking imple­men­tation and results of mitigating actions. This will be done through audits and commu­ni­cation with suppliers.

We use cookies to provide you the best possible experience of our homepage. By closing this message, you agree to our use of cookies. To learn more about how we handle and process the personal data we collect on this website, please see our Data Protection Declaration.