Statement on the Transparency Act

About Seal Engineering AS

Seal Engineering AS (SE) is a Norwegian, privately owned corporation established in 1997. The company’s mission is to develop and manufacture sealing solutions for demanding industrial applications. The company’s quality and management system is certified by DNV in accordance with the requirements of ISO 9001:2015. We are continuously working to improve all processes and systems established within the organization.

The company’s main market consists of subcontractors and end users in the energy-producing industry.

Statement on the Transparency Act

Information about the Transparency Act, a new law passed by the Storting to promote companies’ respect for fundamental human rights and decent working conditions, and to ensure public access to information. The Act imposes a duty of disclosure on businesses, as well as a duty to, among other things, conduct due diligence assessments regarding fundamental human rights and decent working conditions, in line with the OECD Guidelines for Multinational Enterprises. The duty to disclose information took effect when the Act entered into force on July 1, 2022. An updated report on due diligence assessments must be published by June 30 of each year. The Act applies to both private and state-owned enterprises that offer goods or services. The Consumer Authority will oversee compliance and may impose coercive fines and penalty fees on businesses for violations of the Act. Seal Engineering AS is subject to these regulations.

Embedding Accountability

SE has procedures and documents that ensure our values and ethical guidelines are communicated to all employees in the company. We are continuously working to embed the requirements set forth in these documents and policies into our operations, including through our training system and by incorporating respect for human rights and decent working conditions into our internal procedures and guidelines. The CEO has overall responsibility for compliance with legal requirements.

The company’s structure, scope of operations, business context, and supply chain

Seal Engineering AS is a family-owned corporation with all operations located at Produksjonsveien 12, 1618 Fredrikstad.

We develop and manufacture a wide range of sealing solutions. Our products are invisible yet critical components in demanding applications in, for example, the oil and gas industry, the hydropower industry, and the chemical industry. We are a knowledge-driven and innovative company committed to offering our customers the best sealing solutions on the market. We are committed to innovation and technology and are at the forefront of developments in the sealing industry. We ensure that projects receive the necessary attention and that we test, document, and manufacture the specified seal or solution.

Our services:

• Development and production of custom sealing solutions
• Testing and analysis of sealing materials and causes of failure
• Research and development of new sealing materials and technologies

Company structure, scope of operations, business context, and supply chain

Our supply chain is primarily centered in Europe. Our key suppliers include manufacturers of semi-finished materials and rubber compounds, suppliers of supplies and packaging, and providers of transportation and logistics services. We have established long-term relationships with many of our European partners. Based on our current knowledge and assessment, our suppliers operate in countries with established legal systems and generally good conditions regarding fundamental human rights and decent working conditions. To date, we have not identified any specific parts of our European supply chain that are particularly exposed to risks related to these areas. Going forward, our focus will be on maintaining dialogue with our suppliers to ensure continued compliance with our expectations and to build a shared understanding of the importance of responsible business practices.

Due Diligence Assessments

SE has initiated work on due diligence assessments, and existing guidelines will be updated in accordance with the requirements of the Transparency Act. We have developed and communicated guidelines to our employees. Based on a mapping exercise and risk assessment, we have also developed guidelines that include requirements for suppliers and business partners. For potential new suppliers, due diligence has been introduced as part of the standard supplier approval process. To obtain acceptance of our procedures, we have developed tools for obtaining consent to our Supplier Code of Conduct , and we monitor the status via a dashboard in our CRM system. If a risk analysis or findings reveal existing or potential negative impacts on human rights, we will use our influence and take the necessary measures to stop or prevent such negative impacts.

Zero Tolerance for Unethical Conduct and Active Relationship Management

We have a clear zero-tolerance policy for unethical conduct at every stage of our value chain, and we are convinced that sustainable and responsible operations require ethical business practices from all our partners. That is why we actively work to build strong and transparent relationships with our suppliers. Through continuous dialogue, clear expectations, and a shared understanding, we seek to prevent and stop any form of violation of fundamental human rights and decent working conditions. Our goal is to ensure ethically sound practices throughout our entire value chain, and we view our suppliers as key partners in this effort.

Responsibility in the Event of a Report or Discovery of Reprehensible Conditions

We take any report or discovery of misconduct relating to our business or value chain extremely seriously. If we receive information about potential or actual violations of ethical standards, human rights, or decent working conditions, we are committed to acting swiftly and thoroughly. This involves carefully investigating the circumstances, implementing the necessary measures to rectify the situation, and, where possible, helping to prevent such incidents.

Future Plans and Specific Goals for the Coming Year

In the coming year, we will further develop and strengthen our due diligence efforts in accordance with the Transparency Act. Our focus will be on the following areas:

• Further mapping and risk assessment: Although we consider the risk in our primarily European supply chain to be low, we will continue to improve our systematic approach to mapping. This includes implementing a more formalized process for regularly reviewing existing suppliers and evaluating new partners. We will focus in particular on obtaining more detailed information about subcontractors in cases where it is deemed relevant.
• Strengthen dialogue with suppliers: We will intensify our dialogue with our key suppliers to raise awareness of the Transparency Act and our expectations regarding fundamental human rights and decent working conditions. This may include developing a joint ethical framework or guidelines that are clearly communicated to our partners.
• Internal capacity building: We will conduct internal training for relevant employees to ensure a broader understanding of the Transparency Act and how due diligence assessments are integrated into our operational processes.
• Targeted investigations: Although we have not identified specific high-risk areas, we will consider conducting more in-depth investigations of selected suppliers based on defined criteria, such as volume or strategic importance.

Relevant policies and documents

DO#600 SE Employee Handbook (including Code of Conduct for Employees)
DO#503 SE Supplier Qualification Questionnaire
DO#2634 Guidance - Supplier Management
DO#10453 Risk and Opportunity Management
DO#16210 Supplier Code of Conduct

Inquiries regarding disclosure requirements: info@sealengineering.no. You can read more about the Transparency Act on the Norwegian Consumer Authority’s website.

Updated: May 7, 2026