Trans­pa­rency Act Report 2023

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 fourteen companies across Norway and owns subsi­diaries in the UK and Chile. With over three hundred 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 environ­men­tally 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.

Climate, Energy and Other
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

Guide­lines and proce­dures for handling actual and potential adverse impacts on funda­mental human rights (HR) and decent working conditions (DWC)

We have continued working on further embedding of respon­sible business conduct (RBC) into the group policies and management systems, during the reporting period. Our approach to RBC is in line with OECD Guide­lines. Therefore, we conducted an Assessment to detect gaps in our existing policies, proce­dures, and management systems, (which are based on our compliance with corre­sponding laws and regula­tions, ISO standards and other. As a result, some of the measures included updating our internal policies and proce­dures, to improve conformity with RBC as defined by OECD.

PTG is certified with ISO quality management system, Environ­mental management system, HSE standard, etc. 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. Both ISO standards and rights around trade unions are considered as good indicators for respecting human rights and decent working conditions. PTG also follows the principles of diversity and inclusion as stated in our internal policies and is against discri­mi­nation in the workplace. As DEI principles- diversity, equity, and inclusion, have clear basis in human rights on part of ensuring non- discri­mi­nation and equal chances and inclu­sivity, we will continue working on their integration into our organization, systems, and policies.

Also, PTG is reflecting on its expecta­tions related to ethical business conduct in documents with suppliers.

PTG aims to write “Code of Conduct for Suppliers and Business Partners,” to set its require­ments for RBC at the side of its suppliers, to prevent risk realization.

The company is committed to other ESG policies.

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.

With regards to the further alignment of our systems and policies with OECD RBC, we had to prioritize some of topics/ key questions from the myriads of categories and diverse human rights, and issues related to DCW. Our decisions draw from the UN Guiding Principles on Business and Human Rights (UNGPs), which suggest starting with issues that have the most signi­ficant impact on people with the greatest certainty, and that can be practi­cally addressed (by the ease of remedying harm). These are also the topics that are at the same time of major concern in the value chains our businesses operate, with reference to HR & DWC – will be discussed hereinafter in the due diligence section. Conse­quently, when we engaged our suppliers to collect data, we used these priori­tized topics as questions in our survey.

Employees of PTG and PTG’s Board of Directors are committed to and work to ensure that company opera­tions and business conduct do not cause or contribute to actual or potential adverse impact on HR & DWC. Both are ingrained in our core values and organiza­tional culture. Also, we see benefits beyond mitigating compliance risk, in the sense of attracting and retaining talent, value creation for our stake­holders- e.g., B2B buyers, and so forth. In that way, though PTG was incor­po­rated as the profit first company, we have added the perspective of value creation for other stake­holders (apart from shareholders).

Accor­dingly, PTG has imple­mented RBC and respect for human rights throughout organization, at the group and entities levels, with a multi-layered approach with engagement of the most senior C‑suite ranks, and all way down to the functional leaders and daily opera­tions. That is why we repeated training on human rights in the business context and more extensive training related to the provi­sions of the Trans­pa­rency Act for employees in roles such as supply chain, finance, people, and organization.

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 matters 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 involves assessing and managing related risks of adverse impact caused or contri­buted by PTG’s opera­tions. Finance function with Chief Financial Officer and Supply chain function are accoun­table for the due diligence process and in colla­bo­ration with the rest of the management team define the areas of business where respon­sible business conduct risks are most likely and signi­ficant, as well as where to cease, 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 RBC risks. As part of the imple­men­tation process of the require­ments of the Trans­pa­rency Act, PTG has 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.

We also plan to set up grievance and remediation mecha­nisms in case of violation of any rights in the next period.

Infor­mation regarding actual adverse impacts and signi­ficant risks of adverse impacts that the enter­prise has identified through due diligence

Due diligence
Due diligence (DD) was performed in proportion to the size of the Group and the context of its opera­tions, and the severity /probability of related actual/ potential adverse impacts. DD was conducted pursuant to the OECD six steps metho­dology (in the picture below) that describes how companies can attain respon­sible and sustai­nable business practices.

OECD model for Due Diligence for Respon­sible Business Conduct 

PTG under­takes due diligence of its own opera­tions and supply chains, as well as business relations/ partnerships, to identify, prevent and mitigate risks / potential adverse impact, and account for and to remediate actual adverse impacts on human rights and decent working conditions. This was done in line with the Trans­pa­rency Act and the OECD Guide­lines, as well as the United Nations Guiding Principle on Business and Human Rights, to apply a risk-based approach/ priori­tization when evaluating risks of related adverse impacts. This involves looking at the location and context of opera­tions, nature of activity, the number of people that are potentially affected, and severity for actual and proba­bility for potential impact.

As a result, in 2023 we continued with data collection and data management necessary for DD. We started data collection from the biggest (in terms of the volume) first tier suppliers as the primary source of data, and from suppliers where we assumed higher likelihood and impact, due to industry and company specific context, we were aware of. As a next step we assigned priority/ risk from mentioned suppliers list for those which belongs to risky sectors, defined by OECD, UNEP FI, PRI, and other sources. As a next step, we adjusted this sectors list to add sectors for which we know due to our web research, that there is high risk because of specific context for human rights and working conditions. For example, in electronic equipment in assembly lines, there is traditio­nally exposure to the HSE issues/ e.g., high rate of injuries. in assembly lines. Therefore, we identified potential risk based on sectors and industries included. Those are:

  • metal processing plants,
  • instal­lation and other hired technical services,
  • electronic equipment,
  • machinery,
  • extrac­tives,
  • and ICT- Infor­mation and commu­ni­cation technology.

For countries of incor­po­ra­tions and opera­tions, as other criteria for risk assessment we identified the suppliers with risk exposure due to their global opera­tions. This year, because of data availa­bility limita­tions, we were not able to conclude risk assessment in terms of high and medium gradation, by countries of opera­tions, in accor­dance with the lists of high and medium risk countries. That is why we plan further actions to collect more data and to map our supply chains, from cradle to gate, to identify hot spots based on sectors and countries across all tiers. After preli­minary analysis, this year we see potential risk based on the sectors criterion we mentioned, as well as because of risk exposure stems from global operations.

On this matter we rely also on web research, and RBC imple­mented and documented at our suppliers’ end, when do assessing.

Regarding our own opera­tions, PTG AS operates in a low-risk environment regarding human rights impact as most of our opera­tions take place in Norway (with subsi­diaries in UK and Chile), which by inter­na­tional human rights indexes has a low risk, and where general and industry specific regula­tions safeguard human rights.

Conclusion of DD and Risk Assessment:
Despite signi­ficant presence in Norway, we remain dependent on global suppliers. Our suppliers’ facilities and opera­tions are often located in countries that are exposed to certain human rights risks. We do recognize the risk of forced and compulsory labor, risk related to safety and security at the workplace and risk linked to migrant workers among our suppliers and across 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 2023–2024:

  • metal processing plants,
  • instal­lation and other hired technical services,
  • electronic equipment,
  • machinery,
  • extrac­tives,
  • and ICT- Infor­mation and commu­ni­cation technology.

Risk mitigation
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.

Regarding selected suppliers we have identified and remedied some gaps in the supplier business management related to safeguarding 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.

As result of DD, we concluded the action plan for the next reporting period:

  • Further engaging suppliers through survey to collect extra primary source data. Revision of the list of questions.
  • Supply chain mapping, to identify hot spots and to collect more data for countries and sectors, to finalize risk assessment in sense of high and medium gradation of risk. SC mapping should be repeated regularly to track changes in supply chains.
  • Suppliers’ segmen­tation, to inform decision where to replace suppliers (in the case of high HR & DCW risk), and where to improve through colla­bo­ration. At this point we will integrate HR& DCW into the Group strategy and ERM- enter­prise risk management, and in parti­cular SC risk management. We were advised by consul­tants on this matter, and further actions and strategy.
  • Setting sourcing strategy by defining criteria for suppliers’ selection.
  • Writing Code of Conduct for Suppliers and Business Partners, to help suppliers on these matters. In that way coupled with training we will allow for PREVENTION and risk mitigation.
  • Tracking imple­men­tation of RBC at suppliers’ side and auditing.
  • Web research and news tracking- to document viola­tions, if any.
  • Inter­viewing vulne­rable groups.
  • Extra training for recently acquired entities, in PTG, as a part of post deal integration.
  • Scenario analysis
  • Adding diversity and inclusion (D&I) to sourcing, when, all else criteria being equal, to commit to social respon­s­i­bility and ethical business practices. This can help to enhance a company’s reputation and attract customers and investors who value these qualities.
  • For suppliers which operate in Norway to strengthen DD on contract workers, foreign workers, DEI e.g., gender equity.
  • Further engagement in industry associa­tions on these matters.
  • Establish grievance and remediation mecha­nisms in case of violation of any rights tackled by Trans­pa­rency Act.

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.

Our policies are regularly reviewed and updated by the Management Team in the annual management reviews.

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