This document has been reviewed and ratified by the Board of Directors during the formal board meeting conducted on April 29, 2025.
Krüger Kaldnes AS is Norway's leading water contractor with activities within total solutions for wastewater treatment, water treatment, rehabilitation and service for municipalities and industries in Norway. Krüger Kaldnes AS is a 100% owned subsidiary of Veolia Water Technologies, which is fully owned by Veolia Environment S.A.
Information regarding Veolia's worldwide organisation and global footprint is available here: URD 2024
Krüger Kaldnes is subject to the Act on Transparency and Work with Fundamental Human Rights (Transparency Act).
This Act is designed to promote respect for fundamental human rights and decent working conditions by businesses in the production of goods and provision of services.
Businesses affected by the Act must identify the potential and actual negative human rights impacts they have contributed to and take steps to mitigate these negative impacts.
Businesses must also report on these due diligence assessments.
This document is such a report for Krüger Kaldnes AS, and applies to the financial year 2024. Due diligence assessments must be carried out in accordance with the OECD Guidelines for Multinational Enterprises. These guidelines set out a six-step model for the assessments, in which businesses must:
1. Embed accountability in the company's policies
2. Identify and assess actual and potential negative impacts on fundamental human rights that the company has caused, contributed to, or is directly linked to through its value chain.
3. Take action to stop, prevent, or mitigate
4. Monitor the implementation and results of the actions
5. Communicate with affected stakeholders and rights holders on how to address the impacts
6. Provide or cooperate on remediation and compensation where required
The following describes how Krüger Kaldnes AS works with each of these steps.
Section 1
Embedding Responsible Business:
Please find enclosed Veolia Group's comprehensive framework detailing the organizational structures established to systematically mitigate human rights violation risks throughout our value chain operations.
ESG Rapport 2024
Section 2
Mapping and assessing negative impact:
Krüger Kaldnes' procurement activities are predominantly conducted within Scandinavia and through internal channels of the Veolia Group, significantly minimizing exposure to modern slavery risks.
The organization's workforce consists primarily of qualified professionals and skilled personnel operating in regulated environments governed by comprehensive policies and procedures. Veolia maintains a robust occupational health and safety program to ensure employee well-being.
The company's Supplier Code of Conduct explicitly prohibits engagement in illicit business practices, including all forms of modern slavery. The supplier contract includes provisions for immediate contract termination should any supplier be found in violation of these standards.
All suppliers exceeding the established financial threshold are subject to mandatory due diligence verification procedures.
To ensure compliance, the organization has implemented an advanced supplier risk assessment system Compliance Catalyst that employs automated intelligence and analytical tools to evaluate our supply chain. This system facilitates comprehensive monitoring of supplier performance across key sustainability metrics, inclusive fundamental human rights and decent working conditions.
Compliance Catalyst
Compliance Catalyst is a complete risk database of adverse media, sanctions, watchlists and PEPs.Compliance Catalyst helps organizations identify and track potential compliance violations and corruption risks, making it easier to prevent problems before they occur.
If a supplier receives a red flag status in the Compliance Catalyst evaluation, the Regional Chief Compliance Officer in France must be notified immediately. Engaging in business activities with any supplier designated with a red flag status is strictly prohibited.
Further actions for the supplier to be undertaken
- Signing and returning Veolia's 'APPENDIX B: Code of Conduct Acknowledgement'
- Completing the "Anti-Bribery and Corruption Questionnaire" and forwarding it to Krüger Kaldnes. This will provide Krüger Kaldnes with the necessary written documentation that confirms the compliance with the requirements established by both Krüger Kaldnes and our parent company, Veolia Water Technologies/Veolia Environnement SA, for their partners/suppliers.
- Receiving Veolia's General Principle for suppliers, which describes the requirements for:
- Health and Safety
- Prevention of corruption and conflicts of interest
- Compliance with competition law
- Human rights and fundamental labor rights
- Environment
- Taxes: Place of taxation
- CSR commitments
And are the basis for the engagement.
Section 3
Stopping, preventing, limiting
Krüger Kaldnes / Veolia maintain stringent behavioral standards for all personnel. To ensure compliance, the organization mandates that all employees (100%) complete comprehensive annual training covering the Ethics Code of Conduct, Competition Law regulations, and Whistleblowing protocols. This mandatory professional development ensures that each employee is thoroughly equipped with the necessary knowledge and tools to address ethical dilemmas and maintain organizational standards in their daily decision-making processes.
In regards to suppliers, the actions described in the previous section also contribute to stopping, preventing and limiting potential violation of fundamental human rights and decent working conditions
Section 4
Following up on implementation/results:
Through the continuous cooperation and dialogue, Krüger Kaldnes / Veolia keeps track of their partners and reevaluates their performance regarding fundamental human rights and decent working conditions. If deemed necessary, the process undertaken at the beginning of the cooperation will be repeated.
Section 5
Communication:
Referring to Section 1 the Global Group Environmental, Social, and Governance (ESG) Report, which delineates the comprehensive framework and established protocols governing ethical practices throughout our value chain operations.
Section 6
Recovery:
In the course of fiscal year 2024, Krüger Kaldnes' monitoring and assessment protocols revealed no instances of human rights violations, including forced labor or child labor, within our operational framework or supply chain network.
Consequently, no remedial actions were necessitated to address adverse impacts related to forced or child labor practices. Furthermore, no compensatory measures were required to mitigate potential income loss to vulnerable households that might have resulted from any corrective actions, as no instances of such labor practices were identified within our operations or supply chain infrastructure.