The Transparency Act Statement 2026-2027

The Transparency Act entered into force on 1 July 2022.

The purpose is to promote companies’ respect for human rights and working conditions in business relationships and in supply chains. As a service company, we are responsible for keeping track of our own supply chain to identify and avoid risks to – and violations of – human rights. This is done through our supplier approval process and regular due diligence assessments.

Upon request, you can send us questions regarding work with human rights and work environment.

If any questions related to these topics, please contact the Business Services Director by E-Mail.

TSC Subsea AS`s organization, area of operations, guidelines and procedures for human rights and working environment.

Legal name: TSC Subsea AS
Organization number: 920538223
Headquarters: Glasskaret 1, 5106 ØVRE ERVIK
Number of employees: 20

Since its founding in 2000, TSC Subsea AS has been a leading provider of subsea non-destructive testing (NDT) inspection services. Our mission is to deliver cost-effective subsea technology solutions that address industry challenges.

We enable our customers to obtain accurate and reliable inspection data of their subsea assets, empowering them to make well-informed decisions to maintain the integrity of their critical assets. Whether it’s up-time rate and on-time reporting metrics, or exemplary Environment, Social & Governance (ESG) practices, we have continually raised the bar for others to clear. Continuous improvement, customer focus, trust and partnership are the pillars of our success.

We integrate ESG and sustainability principles into our decision-making processes, organizational policies, day-to-day activities, and overall business strategy.

Our ESG strategy aims at supporting our growth and value creation while ensuring ongoing alignment with core principles around sustainability. We do this by engaging with our key stakeholders, including our investors, employees, clients, suppliers and industry associations.

TSC Subsea AS is part of the NDT Global Group. NDT Global has established the following policies and governance frameworks:

  • PL-073-en Code of Conduct & Ethics
  • PL-062-en Supplier Code of Conduct & Ethics
  • PL-069-en ESG and Sustainability Policy
  • PL-058-en Whistleblower Policy
  • PL-040-en Diversity & Inclusion Policy
  • PL-052-en Occupational Health and Safety Policy Statement
  • PL-051-en Environmental Policy Statement

Our Board of Directors, together with the assistance of its Compensation, Nominating, Governance and Sustainability Committee, oversees our ESG strategy and initiative.

Our Chief Executive Officer guides our overall ESG strategy.

Our Vice-President, People & Culture oversees the global integration of DEI principles.

The President, with the assistance of senior management, ensure the deployment of our ESG strategy.

Risk Assessment and Due Diligence – Our process

The TSC Subsea AS Risk Management process is applicable for all processes and activities in TSC Subsea, covering the management processes, the core processes as well as the support activities. Specifically, it applies to, but not limited to:

  • Strategic planning & Budgeting
  • Technology Development and Qualification
  • Business Development
  • Business Execution

This implies that the risk management process applies to both continuously operations as running the day-to-day business, as well as projects and risks in projects carried out for key customers.

As part of the process the following topics are considered (but not limited to):

  • Legal compliancy
  • Health, safety and working environment.
  • Impact to external environment.
  • Anti-corruption and ethics
  • Human rights, diversity and inclusion
  • Data security and privacy compliance
  • Purchasing, supplier performance and responsibility

TSC Subsea AS`s main risk areas and measures to cease actual adverse impacts or mitigate significant risks of adverse impacts

  1. Local Human rights and working environment standards.
  • TSC Subsea AS`s practices and measures:
    • Execute a Business Level Risk Assessment on regularly basis to evaluate relevant risk areas health, safety and environment, work environment, financial processes, sales processes, HR processes, etc.
    • Risk and mitigating plans developed and implemented for projects.
    • Country specific Risk Evaluation for all locations we provide services.
  • Compliance with local laws and regulations, and client expectations.
  • TSC Subsea AS`s practices and measures:
    • TSC Subsea AS is committed to meeting the needs of our customers by ensuring a thorough understanding of their expectations. To achieve this, we use a quality management system, which is certified by a recognized international organization, as well as audited annually by an independent certification body to ensure rigorous respect for international quality standards.
    • We also regularly complete compliance evaluation of Laws and Regulations in countries where TSC Subsea AS provides or plans to provide services.
  • Fair Competition and Trade Practices.
    • We make it a policy to value and respect every one of our customers, suppliers, and business partners, by negotiating the terms of all our agreements honestly, fairly and in good faith, as well as with due diligence.
    • It is our policy to do business only in markets where we can operate openly, soundly, and legitimately in accordance with competition laws.
  • Labor Practices.
    • TSC Subsea AS advocate respect for the principles of the Universal Declaration of Human Rights (UDHR) and the core conventions of the International Labour Organization (ILO). Moreover, we believe that every employee makes a unique contribution and that it is the diverse experience and expertise of all our employees – men and women of all backgrounds and nationalities – which together will ensure our ultimate success.
    • We committed to ensuring that all current, former and prospective employees receive equal treatment irrespective of their age, color, disability, ethnic or national origin, gender, gender expression, gender identity, marital status, pregnancy, race, ethnicity, religion or beliefs, or sexual orientation.
  • Supplier performance and compliance.
    • We expect our suppliers to obey all laws requiring them to treat their workers fairly, to provide a safe and healthy work environment, and to protect environmental quality. And by encouraging them to also follow our own guidelines, we help ensure that our relationships with suppliers do not put our own company’s reputation at risk.
    • This expectation is ensured by our supplier evaluation and approval process and performance monitoring.
    • NDT Global AS also audit all critical supplier regularly to verify compliance.

Date: 06.05.2026
Place: Bergen, Norway
Title: Director Business Services
Øyvind Heimli