Transparency Act Report

Control Cutters Board sets the overall “tone from the top” and has the overall responsibility to ensure that Control Cutter has in place adequate measures in relation to responsible business conduct. The company’s CEO is responsible for the day-to-day implementation of such measures. Thus, business ethics is a Board and management responsibility in Control Cutter. Social sustainability and human rights are embedded in Control Cutters framework for responsible business conduct.

Our Supply Chain Management Strategy involves looking at the supply chain holistically ranging from the design phase of new products and services, financing, sourcing, production, operation of and finally service and stock keeping.

At Control Cutter, we also strive to ensure our customers and business partners that we follow, understand, and handle negative impacts on society and the environment through responsible business behaviour. This involves, among other things, carrying out thorough due diligence processes for responsible business conduct in line with the OECD’s framework.

Control Cutter has incorporated responsible business conduct expectations into our business relationships. Our Supplier Code of Conduct or Supply Chain Code of Conduct (Code) sets our expectations for our business and for our business partners. It is implemented by requesting our suppliers to sign the Code. Our Code is based on the guidelines set by the ILO Conventions, the UN Universal Declaration of Human Rights, and the UN Global Compact. Suppliers that sign the Code commit to the expectations set by these frameworks, as well as any other specific requirements in our Code.

The company’s requirements to conduct risk-based due diligence measures under the Transparency Act comprise both direct purchase from suppliers as well as indirect purchases from such suppliers. The requirements under the Act and the available risk mitigating tools will, however, be different. Direct purchases from suppliers that entail an inherent risk of human rights and labor abuses, require a more pro-active and cautious approach from the Company in terms of background checks and follow-up measures, such as audits. When sourcing indirectly through (lower risk) suppliers that may have high-risk suppliers in their supply chain, the main mitigating tool is to address the Company’s expectations to the supplier through an agreement. Such agreement should include obligations for the supplier to address, mitigate and report on human rights and labour rights risk in the supplier’s supply chain.

As part of the process to identify & assess adverse impact in operations, supply chains and business relationships, Control Cutter conducted a due diligence assessment of all active suppliers in 2022 during spring 2023.

Control Cutter believe we already have a god, well-functioning, documentable system in place to ensure that our suppliers follow fundamental human rights and have decent working conditions for their employees. As the company evolves, we will ensure that new suppliers comply with our requirements for suppliers with regards to fundamental human rights and decent working conditions.

Questions about how we work with the Transparency Act and how we ensure Responsible Business Conduct relating to human rights and decent working conditions in our Supply Chain?

Please contact!

CEO – Lukas A. David

lukas@controlcutter.com