Åpenhetsloven
Executive Summary
This report details Senergia’s compliance with the Norwegian Transparency Act, focusing on our due diligence processes and efforts to address human rights risks within our solar panel supply chain. It reflects our commitment to upholding fundamental human rights and ensuring decent working conditions across our operations.
About Senergia
Company Structure: Senergia is a leading distributor in the Solar PV sector, specializing in the distribution of solar panels, batteries, inverters, mounting material, EV chargers, and related products. From our start in 2018 our operations now span across multiple countries in the Nordics, such as Sweden, Norway, Finland and Denmark.
Senergia focuses on being a full-service partner with a strong emphasis on technical support and training. Senergia’s approach includes significant investment in training and certifications. With our focus on distribution, local presence, swift service and growth, Senergia aims to be a robust partner through all of our relationships.
For more information, please see: https://senergia.com/about-senergia/
Identified Risks and Adverse Impacts
Senergia is sourcing goods from Sweden, EU and China. Amongst these, China is where we identify the main risks as it is considered a challenging context according to OHCHR. We have identified the following risks of high concern in our value chain connected to the specific risks of sourcing from China.
- Challenging contexts: China is considered a challenging country due to the lack of freedom of association and concerns of forced labor targeting minorities. As a major hub for technology production related to renewable energy, there are few alternative sourcing countries capable of meeting the demand for solar panels, batteries, and inverters.
- Working Conditions: The working conditions are deemed satisfactory by an international standard. Apart from the production of polysilicon, working conditions are considered good with a general good adherence to ILO’s guidelines. Risks that can be identified in the value chain are discrimination, excessive overtime and wage deductions with the major issue being the lack of freedom of association.
- Forced Labor Risks: There is evidence that forced labor is used in the production of polysilicon. Senergia is not sourcing from any supplier with known facilities in Xinjiang. It is further up the value chain with the sub-suppliers where the risks are. With a lack of transparency, we cannot guarantee that forced labor has not been involved in the value chain.
- Transparency: The transparency of the whole value chain is inadequate, with the main issue of polysilicon as this can be traced to forced labor. The traceability of polysilicon is problematic because mixed-origin materials are often combined during production, making it difficult to determine the source. As a result, solar panels can contain a mixture of polysilicon from Xinjiang and other regions not involved in forced labor.
| Type of risk | Severity | Extent | Comment |
|---|---|---|---|
|
Challenging contexts |
High |
High |
Senergia is mainly sourcing its goods from China which is considered as a challenging context. Main concerns relate to the restrictions on freedom of association and with forced labor. |
|
Working conditions |
High |
Low |
While the working conditions are deemed satisfactory in general the main risk is connected to the lack of freedom of association. |
|
Child labor |
High |
Low |
There are no known signs of child labor during production in the value chain. |
|
Forced labor |
High |
High |
Significant concerns exist regarding the use of forced labor in the upstream supply chain, especially in the region of Xinjiang. |
|
Transparency |
High |
High |
No, or very little transparency in the value chain. |
This report mainly focuses on the value chain of solar panels as this is where we see the main risks of human rights abuses. Risks associated with mounting materials concerns is the use of iron and steel from Russia which is under EU sanctions. This is considered a low risk as we have received documentation of origin from our suppliers as well as a heightened focus from customs on this issue.
Risks associated with inverters, batteries, and EV chargers are relevant to the risks mentioned above, as China is the primary country of origin for these components. Notably, polysilicon is not part of this value chain; instead, there is a risk of conflict metals being used. Due to limited transparency, this lack of information is considered a significant risk that requires further mitigation efforts.
No actual negative impact has been identified for Senergia to remedy.
Measures to Mitigate Identified Risks
Senergia has established a comprehensive set of guidelines and procedures to identify, prevent, and mitigate potential adverse human rights impacts.
These include:
- Supplier Code of Conduct: All suppliers are required to adhere to our strict code, which mandates compliance with labor rights and human rights standards.
- Supplier Evaluations: Regular assessments to ensure compliance with our sustainability standards.
- Stakeholder Engagement: Ongoing dialogue with suppliers to advocate for improved labor conditions.
- Transparency and Traceability Initiatives: Efforts are made to increase the transparency of the value chain through continuous dialogue with our suppliers as well as sourcing for new suppliers that can live up to this.
- Sustainability policy: Senergia’s sustainability policy guides every decision made in the company.
- Senergia General Procurement Terms: All suppliers delivering goods to Senergia have approved our procurement terms which also address our sustainability standards.
Future Commitments and Continuous Improvement
Senergia is committed to continuously improving our human rights due diligence processes. Future plans include exploring alternative sourcing locations and increasing transparency in the value chain.
Conclusion
Senergia remains dedicated to upholding the highest standards of human rights and decent working conditions across our operations. This report demonstrates our ongoing commitment to transparency and ethical practices in compliance with the Norwegian Transparency Act. We actively engage with multiple stakeholders, including NGOs and local communities with the aim to not only mitigate risks but also to remedy negative impact that has occurred.
Attachments:
- Supplier Code of Conduct – https://senergia.se/wp-content/uploads/2024/06/2024-09-A-Senergia-Supplier-Code-of-Conduct-2023.pdf
- Sustainability Policy – https://senergia.se/wp-content/uploads/2024/06/Hallbarhetspolicy.pdf
- Supplier Evaluation Report – https://senergia.se/wp-content/uploads/2024/06/Supplier-Qualification-Form.pdf
- Senergia General Procurement terms – https://senergia.se/wp-content/uploads/2024/05/General_terms_procurement_Senergia_AB.pdf