1. ABOUT THE COMPANY'S OBLIGATIONS UNDER THE TRANSPARENCY ACT

The report describes the main features of the company's due diligence assessments under the Transparency Act in line with the requirements of section 5 of the Act.

The Transparency Act entered into force on 1 July 2022 and requires companies covered by the act to carry out due diligence assessments where risks of violations of human rights and decent working conditions throughout the company's supply chains, including business partners, are identified and handled based on a risk-based and proportionate approach. In addition, the company must explain the due diligence assessments and respond to information requests from anyone.

In this statement, the "Company" is defined as the companies in Omega AS's group structure that are covered by the Transparency Act, namely: Omega 365 Solutions AS, Omega 365 Consulting AS, Omega 365 Property AS, Omega 365 Admin AS, Omega 365 Areal AS, Omega Subsea AS, Omega 365 Design AS and Omega AS. The Omega AS group is marketed as the Omega 365 group.

The group has initiated work to comply with the obligations of the law. The statement is made available on the company's website, and is shown in the company's annual report.

2. GENERAL INFORMATION ABOUT THE COMPANY

2.1 Organization and operations

The Omega 365 group consists of 24 subsidiaries, 10 of which are registered in Norway. Omega AS is the parent company.

Omega 365 streamlines project implementation by providing expert personnel, software and additional services.

2.2 The company's routines for work with human rights and decent working conditions

In line with the law's obligations, the company works systematically to ensure decent working conditions in the business and that other human rights are safeguarded. As part of this work, management has revised guidelines for the company's work with human rights and decent working conditions. These have been adopted in a board resolution of 14 June 2023.

The guidelines are designed to ensure awareness of human rights and decent working conditions throughout the company, the supply chain and with business partners, as well as being a guideline in all business operations. The company updates the guidelines when necessary.

The company has introduced/revised guidelines to prevent and reduce the risk that the company contributes to a negative impact on human rights and decent working conditions in its operations. Among other things, the company has updated the routines for engagement with new suppliers and associated ethical guidelines. The routines are designed to enable the company to map and handle negative consequences for human rights and decent working conditions.

2.3 Liability

The company's management has appointed CFO, Kjell Tore Helgeland as responsible for following up that the company's representatives and employees are familiar with the routines and implement them in practice. The CFO reports to the board.

In line with the requirements of the Transparency Act, the company carries out regular due diligence assessments in its own operations and supply chain.

3. OMEGA'S RISK ASSESSMENT AS OF JUNE 2023

3.1 Overall risk assessment

In light of the transparency act's obligations, the company has carried out an overall risk assessment of its own operations and parts of the company's supply chain. The aim of the assessment is to map the risk of violations of the human rights of people in and around the company's operations.

In this assessment, the company has particularly focused on three risk areas: industry risk, risk at business level (linked to suppliers and business partners), geographical risk.

Industry risk

The company operates within software development, consultancy and specialized project service testing which the company has assessed to be low-risk industries. There is no general risk that the company considers prominent. However, the company has certain suppliers who deliver services and products to us. These suppliers are associated with an inherent risk of breach of breach of requirements for decent working conditions.

Risk at business level

The company has a high proportion of turnover from in-house production and a low proportion of material and services from supply chains. The suppliers are mainly in Norway, but also some outside Norway. Based on the company's due diligence assessments, the risk of breaches by suppliers is assessed as low. There are no known human rights violations related to the suppliers' operations, but some risks have been identified.

Geographic risk

The company does not consider itself exposed to risk due to its, or its suppliers', geographical location. As mentioned under point 1, the company has local offices in various countries, but based on the company's assessments there is no widespread risk of human rights violations in these regions. The company will nevertheless carry out regular assessments in order to be able to take measures if the risk picture changes.

3.2 Specific risk assessment as of June 2023

The company carries out regular risk assessments related to negative consequences and risks for people in and around the business.

The company has not revealed that the company's operations have caused or contributed to a significant risk of violations of human rights or decent working conditions. There have been no reportable changes in the business or the risk picture since the previous reporting period.

4. MEASURES TAKEN TO PREVENT RISK OF VIOLATIONS OF HUMAN RIGHTS AND DECENT WORKING CONDITIONS

In light of the company's risk categorization described in point 3, the company has implemented proportionate measures to prevent and manage the risk of indecent working conditions and violations of human rights.

The following measures have been implemented/will be implemented from June 2023.

• Adopted overall guidelines for the company's work with the Transparency Act. See section 2 here for a more detailed description of the guidelines.
• Adopted plan for risk evaluation of supply chains in the Company
• Conducted dialogue with suppliers in the form of documentation collection
• Contract terms
• Carry out regular surveys about, for example, working conditions

The company will follow up and examine the measures implemented, and assess how the measures have contributed to reducing or rectifying the risk of or actual negative consequences.

As of June 2023, the company has not planned to implement further measures. However, the company assesses risks continuously and will take measures if the situation requires it.

This report is signed by the board and the group's CEO. The statement will be updated annually and otherwise in the event of significant changes to the information that appears here.