Transparency Act 2024

Our Guidelines

InflowControl is committed to maintaining transparency and accountability in all aspects of business operations. The company firmly stands by this commitment and will not engage in any activities that cannot be confidently supported. To ensure that we honor the commitments, the roles and responsibilities for each procedure are defined. If a new policy or procedure is implemented, an official meeting and training session is mandatory to make sure that all employees understand the new requirements. Furthermore, all employees will be required to read and acknowledge the policy or procedure.

Internal audits per process area to identify areas for improvement are conducted once a year to ensure compliance with laws and regulations in the relevant countries and to comply with international laws.

     Code of Conduct

The Code of Conduct (CoC) serves as a guide to ensure that the values of the company are reflected in the daily activities and operations. Full compliance with the CoC is required from InflowControl’s board, employees, and hired contractors.

To view and read our Code of Conduct, please click here.

     Anti-Corruption and Bribery Policy

InflowControl takes a firm stance against bribery and corruption, as demonstrated in the company’s Anti-Bribery and Corruption Policy. This policy applies to and is mandatory for all InflowControl entities, employees, and affiliated companies. Each subsidiary is responsible for understanding the consequences of engaging in corruptive actions and the specific anti-corruption laws and guidelines applicable to its operations. Subsidiaries must adopt additional anti-corruption policies as necessary to comply with local laws. In addition to this, InflowControl requires strict adherence to the Norwegian Penal Code and other national anti-corruption legislation, such as the US Foreign Corruption Practices Act and the UK Bribery Act.

To view and read our Anti-Corruption and Bribery Policy, please click here.

     Risk Assessment

As a high-growth company in a fast-moving environment, it is recognized that the business regions may not always be the safest, and that the type of work InflowControl’s employees do can sometimes pose a risk to their safety. Therefore, ensuring employees are kept safe and secure while carrying out their duties is of utmost importance to the company. Hence, risk assessments in all work operations are performed to mitigate potential risks and prevent harm to employees.

The risk management process involves proactive identification, analysis, evaluation, and treatment of possible risks. To ensure that all risks are identified and addressed, it is necessary to define the scope and objectives, clarify the required resources, gather relevant information, and identify potential hazards.

To obtain necessary feedback and information for decision making, it is essential to involve relevant stakeholders in the risk management process. Safety delegates input is highly valued in assessments and Safe Job Analysis that impact HSE (Health, Safety, and Environment), and they are therefore required to participate in these processes.

Lastly, if some risks may still be unacceptable even after the risk mitigation action(s), a contingency plan is in place to address such risks and to guarantee the safety of the employees.

     ISO 9001:2015

ISO 9001:2015 is a standard that outlines the requirement for a Quality Management System (QMS). InflowControl obtained certification in 2020 and adheres to this standard to ensure that the products and services consistently meet customer requirements, and that quality is continually improved.

Along with this, we have taken the necessary steps to ensure the safety and well-being of the employees by implementing HSE policies and procedures.

     Case Handling

In InflowControl’s Management System (TQM Enterprise), employees play a crucial role in ensuring that the company operates smoothly and efficiently, e.g., by reporting incidents that occur within the company. These incidents can range from low to high severity, and employees are required to register any incidents they witness, regardless of their seniority and department.

There are seven types of incidents that can be reported through the TQM platform: HSE incidents, near misses, nonconformities, complaints, improvement proposals, concession requests, and safety inspections. The process owner will then be notified, and in cases of high severity, the CEO will receive an email notification of the case.

By encouraging employees to report incidents through the platform, InflowControl can identify areas in the company that may need improvements, prevent future incidents from occurring, and ultimately ensure the safety and well-being of its employees. One of the quality control objectives, which is reviewed monthly, is to maintain a record of zero absences from work due to work-related injuries. We have successfully maintained this record since 2011.

     Whistleblowing Policy

The policy outlines the steps that employees should take if they become aware of any critical issues within the business. The goal of the policy is to encourage employees to report these issues without fear of retaliation. InflowControl is currently reviewing and updating its whistleblowing policy, which will be communicated to all employees and published on the intranet upon implementation.

     Internal Monitoring

At InflowControl, we recognize the importance of the employees’ satisfaction with their work situation and the company itself. A platform called ‘Winningtemp’ is used to monitor the employee’s satisfaction and well-being, and to allow them to provide feedback on their environment. By using this platform, issues that may be causing dissatisfaction can be identified and addressed. The main objective is to improve productivity and employee retention, ultimately benefiting both the employee and company.

Due Diligence

     I.
During the supplier and agent due diligence process, a risk assessment is conducted along with a comprehensive questionnaire to evaluate potential partners. However, an oversight has been identified in the summaries. The summaries did not focus on human rights, social responsibilities, and environmental policies. To ensure that the company is conducting proper due diligence, it is critical that these factors are implemented in the summary to certify that the partners are aligned with the company’s values and ethical standards.

Although the summary did not include human rights, social responsibility, and environmental policies as explicit criteria, it has always been an important consideration during agent interviews.

The questionnaire sent out prior to the summary review focuses on integrity management and compliance policies, history of legal or regulatory issues, financial information, and the organization’s key personnel. The potential partner must provide documentation of proof to support the claims, and an explanation of why if they answer “no” to any of the questions. This is required to gain a clear understanding of the parties the company may potentially do business with.

In the event of any breaches of the aforementioned policies or controversies that go against the approved policies and company’s standards, InflowControl reserves the right to decline or terminate a contract. Currently, all the agents abroad have a proper code of conduct, anti-corruption and bribery policies, human rights, and social responsibilities, as well as environmental policies in place. Suppliers are evaluated yearly to attest that they continue to meet the standards and are aligned with InflowControl’s principles and ethics.

     II.
InflowControl previously had a subsidiary located in Russia. However, due to the ongoing war, the company deemed it unethical to continue operating there. The decision to cease all its operations was made on the first working day after the war became official. Due to bureaucratic procedures, the subsidiary was liquidated on December 31st in 2022 and officially deregistered from the company registry (selskapsregisteret) on March 26th in 2023.

The Way Forward

     
     Supplier and Agent Risk Assessment

During the due diligence, we discovered a limitation in the summary document for evaluating potential partners. Although the questionnaire inquired about their human rights, social responsibilities, and environmental policies, the summary document did not adequately emphasize these crucial factors. The necessary steps are taken to implement these policies in the partner selection document.

InflowControl is committed to promoting these principles in all business operations and seeks to align with organizations that share the same commitment. To ensure that the partners are committed to these principles, yearly evaluations and assessments of suppliers are conducted.

     API Spec Q1

InflowControl is in the process of obtaining API Spec Q1, that specifies the quality management system requirements for manufacturers of oil and gas equipment. It provides quality requirements for designing, manufacturing, and testing equipment, and mandates for maintaining accurate documentation and record-keeping. Compliance with API Spec Q1 is often required by customers and is considered a benchmark for quality in the industry.

     Discrimination and Equality (ARP Reporting)

At InflowControl, a diverse and skilled team is seen as a key competitive advantage in meeting the clients’ needs. Each team member brings unique qualities and perspectives to the table. By empowering and valuing its employees, the company can continuously improve and innovate.

The Code of Conduct stipulates that all must treat everyone with fairness, respect, and dignity. The need for a specific policy addressing discrimination and gender inequality in the workplace is recognized. This is especially important in the oil and gas industry where men traditionally make up a greater proportion.

The Duty to Report on Equal Status (ARP) obligates all companies in Norway to promote equality actively and systematically and to prevent discrimination, as stipulated in Section 26 of the Equality Act. The ARP aims to prioritize diversity and equality in company operations and to prevent discrimination and ensure equal opportunities for all. InflowControl strongly supports the ARP and is committed to creating a policy that reflects the company’s values and dedication to eliminating possible discrimination in all operations. This policy is a crucial step towards creating an even more inclusive and equitable workplace for all team members. The company is in the process of writing the policy and will update the site as soon as the policy is implemented.

Contact Us

InflowControl is devoted to complying with the Transparency Act, as well as all applicable laws and regulations. We encourage everyone to contact InflowControl if they have any questions or concerns regarding our compliance efforts. The company takes transparency seriously and is committed to ensuring that the business practices are always in line with the values and ethical standards for business practices. To ensure that these values are upheld, everyone is encouraged to report any potential policy violations.

If there are any inquiries or concerns on these matters, please send an email to: apenhetsloven@inflowcontrol.no.
In accordance with the Transparency Act, the response time will be less than three weeks after receiving inquiries. However, depending on the nature and complexity of the matter, it may be necessary to request an extension of up to two months for further internal and/or external assessment(s).

June 30, 2023

The Board of Directors of InflowControl AS