Introduction

This document presents King Oscar AS’s account of due diligence assessments in accordance with the Norwegian Transparency Act for the period 1 January to 31 December 2024. The report describes the company’s work to safeguard human rights and decent working conditions, as well as how this is integrated into the company’s organization, guidelines and routines.

King Oscar AS is wholly owned by Thai Union Seafood 1 SA, Luxembourg, and is part of the Thai Union Group – one of the world’s largest seafood companies. King Oscar AS also owns King Oscar Inc. in the USA (100%) and Ægir Sjavarfang ehf in Iceland (50%). In 2024, the company had 28 full-time employees in Norway.

The company offers a wide range of canned fish products and operates in 29 markets, with a main focus on the USA, Poland and Norway. Production takes place in Svolvær and Iceland, while the majority of finished products are supplied by other companies in the Thai Union group.

Human Rights and Labor Conditions

King Oscar has established internal policies and procedures to ensure compliance with human rights and decent working conditions. This includes:

  • Procurement procedures that meet the requirements of the Transparency Act.
  • Commitment to the Thai Union Code of Conduct for all employees.
  • Similar requirements are imposed on all suppliers. All suppliers must approve the Thai Union Code of Conduct before entering into an agreement.
  • Membership in the Grocery Suppliers Association (DLF), where ethical guidelines are integrated into the company’s practices.

Due Diligence Assessments and Training

Due diligence assessments are carried out by:

  • Conclusion of new contracts
  • Acquisitions and product development
  • Annual review of existing suppliers
  • Thai Union also carries out supplier visits and audits, and if any deviations are discovered, we will be notified.
  • All fishing vessels we purchase from must confirm compliance with the Thai Union Fishing Vessel Code of Conduct and Improvement Program.
  • All new suppliers must confirm compliance with the Thai Union Suppliers’ Business Ethics and Labor Code of Conduct. The main principles that must be confirmed are:
  1. The business is run legally and with integrity.
  2. The work shall be carried out on the basis of freely agreed and documented working conditions with legal compliance.
  3. All workers should be treated equally with respect and dignity.
  4. The work must be carried out on a voluntary basis without forced labor.
  5. Child labor shall not be permitted.
  6. All workers should receive fair wages.
  7. Working hours for all workers should be reasonable.
  8. All workers shall have the freedom to exercise their rights to form and/or join trade unions and to bargain collectively where permitted by law.
  9. The health and safety of workers must be protected in the workplace.
  10. Workers should have access to fair procedures.
  11. The business must be run in a way that embraces sustainability and environmental impact.
  12. Progress and compliance should be continuously monitored.

King Oscar’s own employees have been trained in the Transparency Act, and the work is embedded in the board and management team. The company has also established a whistleblowing system – the Thai Union Compliance Reporting Hotline (“Speak Out”).

Risk Assessment and Results

King Oscar works actively to motivate suppliers to document and ensure compliance with human rights. King Oscar assesses risks related to human rights, labor conditions, the environment and anti-corruption. Suppliers with “medium to high” risk – based on geography and purchasing volume – have been identified through surveys. The results showed no identified negative consequences. Some suppliers have not provided written documentation, but have confirmed compliance verbally.

The company recognizes that it is unusual for a business to have no risk or non-compliance associated with its operations, supply chain or business partners, which underscores the need for ongoing monitoring.

Handling of Inquiries and Risk Areas

King Oscar has a contact form available on the website for inquiries from suppliers, customers and consumers: https://www.kingoscar.no/kontakt-oss/

The company has identified risk areas, particularly among foreign suppliers in high-risk countries. These are followed up with annual audits. There have been challenges in obtaining written documentation from some Norwegian and foreign suppliers that are not covered by the Transparency Act.

Actions and Future Commitments

King Oscar is committed to continuous improvement and risk reduction throughout the value chain. This includes:

  • Annual due diligence assessments and reporting
  • Clear requirements for suppliers regarding documentation and compliance
  • Assessment of further cooperation in the event of discovered violations, based on severity

More information about the company’s guidelines can be found on King Oscar’s website: “Thai Union Suppliers’ Business Ethics and Labor Code of Conduct” www.kingoscar.no/

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