2023 Transparency Act Statement

For CTS Nordics Holding AS and CTS Nordics AS, NordicEPOD AS, G.T Nordics AS, and Gapit Nordics AS

The purpose of the Norwegian Transparency Act is to promote corporate respect for fundamental human rights and decent working conditions. CTS Nordics Holdings AS is a strong proponent of the Transparency Act. Through due diligence and other actions, CTS Nordics Holding AS ensures both its holdings and its suppliers, sub-contractors, and partner companies are in full compliance with this law thus preserving individuals’ fundamental human rights and providing for the provision of fair working conditions. CTS Nordics Holding AS will continue to support all facets of the Transparency Act in the years to come.

I. Background

CTS Nordics Holding AS is proud that its products and services provide many benefits for society at large. However, CTS Nordics Holding AS appreciates that those benefits come with potential societal risks or costs. CTS Nordics Holding AS believes it must mitigate those risks and costs as they apply to the environment, health, safety, economic equality, and human rights. Therefore, this statement contains the results of our due diligence efforts for the prior year to identify areas of human rights risks within our supply chain and operations as well as our efforts to monitor, mitigate or eliminate those risks. This statement constitutes the annual disclosure as required under the Act Relating to Enterprises and Work on Fundamental Human Rights and Working Conditions (Transparency Act) for CTS Nordics Holding AS and its affiliated holdings CTS Nordics AS, NordicEPOD AS, G.T Nordics AS and Gapit Nordics AS. CTS Nordics Holdings AS publishes this statement annually no later than the 30th of June each year.

II. About the CTS Nordics Holding AS Family

CTS Nordics Holdings AS builds data centers. We specialize in providing turnkey data center solutions at scale in the Nordics. Our headquarters are in Oslo, Norway, but we operate throughout the Nordics with offices planned for Copenhagen, Denmark; Stockholm, Sweden; and Helsinki, Finland under the name of our design and build contracting company CTS Nordics. NordicEPOD manufactures large scale modular electrical back-up power supplies to secure uninterrupted operation of critical infrastructure like data centres. NordicEPOD operates its own manufacturing facilities in Vestfold, Norway. Gapit Nordics is a software company based in Drammen, Norway, which delivers software and industrial automation solutions. Its work ranges from smart energy data management in small buildings to complex monitoring and automation of large industrial sites. G.T Nordics specializes in the design, manufacture and installation of electrical distribution systems, electrical switchboards, and automation systems.

The CTS Nordics Holding AS family of companies provides a turnkey service for our clients through our ability to design and build a data center solution beginning with a conceptual design proceeding through site preparation, building construction, fitting out and commissioning so that our clients are provided with a fully operational data center upon completion of the project. CTS Nordics Holding AS is committed to upholding and promoting human rights in line with the Transparency Act as part of our sustainability goals in order to advance our vision of building better, sustainable Data Center projects Our approach to human rights is guided by our commitment to conduct our business in compliance with the laws of Norway and thus in line with the OECD Guidelines for Multinational Enterprises and the UN Guiding Principles on Business and Human Rights. This approach supports the goals and objectives of the Core Conventions of the International Labor Organization (ILO) and the Universal Declaration on Human Rights.

III. Guidelines and Procedures

Under the Transparency Act, companies must embed responsible business conduct into their policies, and implement suitable measures to cease, prevent or mitigate potential or actual adverse impacts on fundamental human rights. CTS Nordics Holding AS uses a range of measures to ensure we are meeting all of our obligations under the law. Our goal, which is also defined by the Act, is to identify areas of potential human rights risks, as well as any other kinds of potential labor exploitation, monitor those human rights risks and mitigate any potential human rights risks. CTS Nordics Holding AS is taking the following measures to achieve this objective.

1. Codes of Conduct:CTS Nordics Holding AS commitment to the Norwegian Transparency Act, begins with formally defining these principles in Codes of Conduct adopted by our Board of Directors and integrated into all levels of management and operations. CTS Nordics Holding AS Codes of Conduct are based on the legal principles contained in the OECD Guidelines for Multinational Enterprises and the UN Guiding Principles on Human Rights. We are in the process of updating these Codes of Conduct.

2. Embedded Policies:CTS Nordics Holding AS takes steps to embed the policies contained in its Codes of Conduct throughout all levels of operations. Embedding our Codes of Conduct ensures that these policies and objectives are followed on a constant basis by prompting and requiring compliance at every level of management. To achieve this CTS Nordics Holding AS has, or is in the process of, implementing the following practices.A. Codes of Conduct; CTS Nordics Holding AS is in the process of updating its Codes of Conducts governing its ethical, environmental, labor and sustainability objectives.B. Integration with Suppliers and Subcontractors; As a matter of internal policy and regulation all subcontractor and substantial supplier contracts are required to contain provisions that they adhere to our Codes of Conduct; or contain comparable provisions based on the OECD Guidelines for Multi-National Enterprises or UN Guiding Principles on Business and Human Rights that are substantially similar to the requirements contained in our Codes of Conduct. Having this contractual commitment from our suppliers ensures that our human rights and labor objectives are clearly understood and followed by the supplier, while providing an enforcement mechanism to compel compliance if necessary.

3. Independent Internal Oversight:CTS Nordics Holding AS and its holdings are structured so that the CTS Nordics Compliance Department is independent of the production and operational departments of CTS Nordics, NordicEPOD, Gapit and G.T Nordics. The CTS Nordics Compliance Department provides compliance support and monitoring for both the holding company and its holdings. This basic structural decision ensures that the Compliance Department supports our overall activities without being subsumed by project management or financing operations. Our Chief of Compliance is part of the senior leadership team. Our Sustainability Officer, who reports to the Chief of Compliance, is responsible for developing and implementing sustainability objectives as they apply to human rights and the Transparency Act on a corporate basis. Our Chief of HSE, who is also part of the senior leadership team, and her department develops, reviews, and maintains the HSE framework, and monitors and enforces compliance of all HSE laws and regulations at the operational level at our project sites, production facilities and offices making it the primary monitor for human rights risks and other forms of labor exploitation.

4. Grievance Mechanism and Requests for Information: Under the Transparency Act, any person has a right to information regarding how we address potential or actual adverse impacts on fundamental human rights. As a matter of law, CTS Nordics Holding AS maintains a transparent method for members of the public as well as employees of CTS Nordics Holding AS or its holdings to enquire about its compliance with the Transparency Act. CTS Nordics Holding AS is also committed to responding promptly to written requests for information received pursuant to the Transparency Act. Any requests concerning the Transparency Act should be sent to Transparency.Act.Requests@cts-nordics.com.

IV. Due Diligence

The Transparency Act requires all enterprises subject to the Act to conduct due diligence in accordance with the OECD Guidelines for Multinational Enterprises. CTS Nordics Holding AS has undertaken a due diligence review of its operations and supply chain to identify any areas of potential human rights risks as required by the Transparency Act. As this is the first due diligence review since the Transparency Act came into effect last year, CTS Nordics Holding AS is also using this process as an opportunity to review its own internal policies and practices regarding human rights and labor exploitation to ensure that we are complying with the law and our Codes of Conduct.

1. Human Rights Assessment for Our Supply Chain: Beginning this year, CTS Nordics Holding AS began an assessment process using the request for information (RFI) requirements under the Norwegian Transparency Act to collect data from our major suppliers and partners in order to analyze our supply chain and identify any human rights risks or areas of concern that may require mitigation.

2. Monitoring and Screening of Suppliers: In the event a risk or violation were identified a formal process managed by our Compliance Department will determine the appropriate course of action depending on the nature of the risk or violation. In most instances we hope that dialogue with the supplier or subcontractor will lead to a timely and satisfactory outcome, however, if the risk is not mitigated or resolved in a manner consistent with the law and/or our Codes of Conduct, CTS Nordics Holding AS will undertake more substantive measures. CTS Nordics Holding AS and its holdings use, with few exceptions, suppliers who are already subject to EEA or EU regulation and must comply with laws and regulations consistent with both the Transparency Act and the OECD Guidelines for Multinational Enterprises.

3. Employment and Labor Monitoring: As a design and build contractor focused on large construction projects, CTS Nordics Holding AS understands labor exploitation is an inherent human rights risk within the construction industry. Therefore, CTS Nordics Holding AS takes steps to ensure compliance with all applicable laws and regulations. As part of its risk management process to adhere to the law and to mitigate any human rights and labor exploitation risks as required by the Transparency Act, CTS Nordics Holding AS and its holdings use an established set of internal controls where two separate and independent groups are responsible for monitoring and mitigating these risks. Our project management teams, with support from our Human Resources Department are responsible for complying with all relevant laws and regulations, particularly those related to human rights and labor. Separately and independently, the CTS Nordics’ Compliance and HSE Departments, are responsible for monitoring all project and production activities for compliance with all the relevant laws and regulations.

4. Training: CTS Nordics is developing a formal process for all employees to receive annual and onboarding Code of Conduct training to ensure adequate awareness of all relevant laws, regulations, HSE practices, and our obligations under the Transparency Act.

V. Due Diligence Findings and Future Actions

Under the Transparency Act, enterprises shall identify and assess actual and potential adverse impacts on fundamental human rights and decent working conditions that the enterprise has caused or contributed to. While conducting its due diligence, CTS Nordics Holding AS did not find evidence of any adverse human rights impacts requiring immediate remediation or termination of a business relationship. However, as required by the Transparency Act, CTS Nordics Holding AS has identified areas where there are potential risks for human rights issues that should be monitored and potentially mitigated on an ongoing basis.

1. Supply Chain: In terms of our supply chain, CTS Nordics Holding AS and its holdings procures IT materiel used in the construction of data centers or the production of infrastructure and support equipment for data centers. According to the Norwegian Government and the UN Environment Program, such IT materiels are commonly acknowledged as a significant human rights risk particularly in the earliest stages of the supply chain. To mitigate these risks CTS Nordics uses the processes and policies described in this statement to screen suppliers. Another potential issue in the supply chain is e-waste. According to the UN Environment Program, significant quantities of e-waste are dumped in developing countries where reclamation workers are exposed to hazardous substances and waste may be processed in an environmentally harmful way. CTS Nordics Holding AS mitigates this risk by following Norwegian law by complying with the Waste Act and all relevant regulations related to the disposal of e-waste.

2. Labor: According to the ILO in 2022, the worldwide construction industry accounted for 16.3% of identified forced labor exploitation cases. The construction industry in the Nordic countries, despite high levels of oversight and compliance with labor laws, still experiences challenges in this area. CTS Nordics Holding AS and its holdings are aware of these risk factors. By following all applicable laws and regulations for labor and employment, CTS Nordics monitors the labor practices of any subcontractors providing services to any of our construction projects. As described earlier, our existing internal controls for monitoring the risk of labor exploitation are based on a separation of duties where two separate departments of CTS Nordics are responsible for implementing our Codes of Conduct and complying with all applicable laws and regulations as it relates to human rights risks and labor exploitation.

Signatures to the Norwegian Transparency Act Statement for the Year 2022 Oslo, Norway 20 June 2023

CTS Nordics Holding AS

Ian Paul Wardell, Chair Filip Schelfhout, General Manager and Director


Ian Paul Wardell, Chair Filip Schelfhout, General Manager and Director Morten Molven, Director

Gapit Nordics AS

Ian Paul Wardell, Chair Kjetil Kåsin, General Manager and Director Filip Schelfhout, Director

G.T Nordics AS

Filip Schelfhout, Chair Trond Wabakken, General Manager Geir Mykland, Director Trond Nygård, Director Ian Paul Wardell, Director