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Transparency Act Declaration

1Introduction

This statement is prepared in accordance with the requirements of the Norwegian Transparency Act (§ 5). It outlines Neodrill AS’ due diligence assessments related to human rights and decent working conditions, as well as identified risks and implemented measures.

Neodrill is committed to conducting business responsibly and transparently, ensuring respect for fundamental human rights and decent working conditions throughout our operations and supply chain.

This declaration is applicable for the financial year 01.01.2025-31.12.2025.

2Description of the Organisation and Area of Operation

Neodrill AS is a Norwegian-based company headquartered in Stavanger, Norway. The company provides innovative, cost-efficient, and CO₂-reducing subsea well foundation solutions for exploration and production wells in the global oil and gas industry.

The organisation consists of the Board of Directors, CEO, and 24 permanent employees.

Our operations include:

  • Engineering and technology development

  • Project delivery in cooperation with subsea system providers

  • Engagement with suppliers and partners globally

 

Neodrill operates primarily on the Norwegian Continental Shelf, with increasing international activity through partnerships.

3Governance, Policies, and Due Diligence Framework

Neodrill has established policies and procedures to ensure responsible business conduct, including:

  • Ethical Guidelines

  • Anti Bribery and Corruption (ABC) Policy

  • GDPR Compliance Policy

  • Human Rights Policy

  • Notification of Unacceptable Work Situations Policy (whistleblower channels)

Our due diligence framework consists of continuous monitoring of our own compliance through internal audits and reporting channels in our QHSE Management System. This may include findings from 2nd and 3rd party audits or any other stakeholders.

Supplier due diligence assessment is first done when the supplier is identified, and thereafter as part of our annual supplier evaluation and audits of selected suppliers. For this reporting period the evaluation was done for 32 tier-1 suppliers. Only one of these suppliers are based in another European country, with the remaining 31 being Norwegian-based and thus required by law to comply with the Transparency Act. 

All findings are reported in our QHSE Management System, and planned corrective and preventive actions are monitored and verified.

The Board of Directors has overall responsibility for ensuring compliance, while management implements and monitors due diligence processes.

4Actual Negative Consequences, Identified Substantial Risks, CORRECTIVE AND PREVENTIVE ACTIONS

During the reporting period 1 actual negative consequence, and 3 substantial risks for negative consequences were identified.

Negative consequence or identified substantial risk

Cause

Implemented actions

Geographical location

Worker received a foot injury when a metal component fell on their foot during work carried out for Neodrill at a supplier facility

Lack of updated procedure

Supplier updated their procedure to include this operation

Norway

Absence of physical barriers while a third party was working at height at supplier facility. The work was not related to Neodrill scope

Lack of procedures for supplier vendors

Supplier updated their documentation outlining how Life-Saving Rules (LSR) compliance should be monitored for external parties

Norway

Neodrill had a chemical that may cause cancer

 

Procedure for annual review of chemicals not followed

Replaced with a less hazardous chemical and risk assessment updated

Norway

Worker exiting a MEWP (mobile elevated working platform) at height while carrying out work for Neodrill at a supplier facility

The supplier was not aware of the changes in national guidelines

Supplier sourced a MEWP with additional safety barrier that allows exiting at height

Norway

 

5Planned Actions

Neodrill has identified the need to improve our due diligence framework and plan to implement the following actions.

  • Establish a Supplier Code of Conduct that will be sent to all existing suppliers and shall be issued to all new suppliers before registration

  • Establish a Supplier Due Diligence Self-assessment form to be included in the Supplier Approval Form for new suppliers

  • Implement more formalized risk-based supplier assessments

  • Continued alignment with partners (e.g., subsea system providers) to ensure industry-wide standards

6Conclusion

Neodrill is committed to responsible business conduct and compliance with the Transparency Act. We will continue to enhance our efforts to ensure respect for human rights and decent working conditions across our operations and supply chain.

7Signatures

This statement has been reviewed and approved by:

 

Board of Directors – Neodrill AS

​

Harald Strand (Chairman)

Arne Wyller Christensen (Board Member)

 

CEO – Neodrill AS

​

Jostein Aleksandersen

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