Transparency Statement

Last updated 07.06.2024

The registered office of Amby AS (“Amby") is Thorvald Meyers Gate 7, 0555 Oslo, Norway.
The policies, procedures, and systems described in this Statement have been adopted by
Amby. References to “we”, “us” and “our” in this Statement are to Amby, unless otherwise

This statement has been prepared in line with the requirements of the Norwegian Transparency Act to explain and document Amby’s work with human and labour rights,
including the specific measures undertaken by Amby.

Amby is committed to respecting human rights and decent working conditions as a
fundamental principle in our operations.

About Amby

Amby is a leading embedded recruitment provider, operating through a structured
framework that empowers client companies to scale and succeed in their respective
markets. With a dedicated team of approximately 150 professionals, our operations span
across Norway and the European Union.

Amby’s capital group consists of interconnected entities working in harmony to deliver
comprehensive recruitment solutions. At the core of our structure is Skeil AS, serving as the
parent company and providing strategic oversight and guidance to the group. Skeil AS
holds controlling interests in both Amby AS, AS, and Kvant Consulting AS,
establishing a strong foundation for our operations. Amby AS, a subsidiary of Skeil AS,
plays a vital role in delivering tailored recruitment services. Through its wholly-owned
subsidiaries, Amby Sweden AB and Amby Poland sp. z o. o., Amby extends its reach and
expertise to meet the diverse needs of clients across regions. Additionally, AS,
another subsidiary of Skeil AS, significantly contributes to the group's capabilities.
AS holds full ownership of Poland sp. z o.o. Kvant Consulting AS is not strongly
associated with the operations of Amby AS and AS. Kvant Consulting AS has a
subsidiary in the form of Kvant Consulting Norway AS. This interconnected structure within
Amby Capital Group allows us to leverage the strengths of our entities, enabling us to offer
comprehensive and customized recruitment strategies tailored to the unique requirements
of client companies

Our Principles

Amby fully recognizes its duty to uphold human rights and is dedicated to implementing
the United Nations Guiding Principles on Business and Human Rights and OECD Guidelines for Multinational Enterprises in all its activities. The dignity of every individual and the
significance of their human rights are fundamental principles that guide the conduct we
require from every person associated with us, whether as a direct employee of Amby or
indirectly through our supply chain. We do not tolerate any kind of discrimination,
harassment, or bullying within Amby or our supply chain. In addition, we continually
evaluate suppliers' performance and compliance with human rights and working conditions.
This involves reviewing supplier policies, conducting audits or assessments, and verifying
compliance with international labor standards and applicable laws and regulations.

Our Policies and Procedures

We prioritize suppliers that demonstrate a strong dedication to promoting human rights and
ensuring decent working conditions throughout their operations. We identify potential
suppliers based on their reputation, industry recommendations, and alignment with our
commitment to human rights and decent working conditions.

When a high-risk supplier is identified, we undertake steps to obtain additional assurance
that their practices are compliant with the Norwegian Transparency Act. This includes
statement and policy reviews, questionnaires, and further meetings with the supplier when
appropriate. The results of these supplier assessments will be recorded and refreshed

Our employees are expected to report any concerns, including those related to human
rights violations, to the People & Operations team who will investigate all allegations and
take appropriate action. Employees are welcome to be anonymous or self-identify, but it is
not a requirement, and the process is designed to respect their privacy and preferences.
One of Amby's plans for the 2024/2025 is to introduce a Code of Conduct for suppliers and
employees. All employees will be required to complete a Code of Conduct training to
ensure adequate awareness and knowledge of our ethical principles including human

Amby will also undertake steps to provide a copy of the Code of Conduct to our suppliers
by adding a Code of Conduct clause to Amby’s supplier terms and conditions. If these
standards cannot be met, Amby will take reasonable steps to review the relationship and, if
necessary, consider whether to continue the supplier relationship if the deficiencies cannot
be corrected within a reasonable period of time.

Due Diligence and Risk Assessment 

At Amby, we recognize the significant impact our supplier chain has on human rights and
working conditions. To assess the high-risk areas within our supply chain, we conducted a
comprehensive due diligence process that involved gathering specific information about our suppliers and business partners, and the regions in which they operate. This included
conducting assessments, utilizing external resources or tools to evaluate potential human
rights risks, and engaging directly with those suppliers that potentially pose a higher risk of
poor human rights and labor practices.

Amby places its primary emphasis on evaluating supplier risk through three main

  • Industry Risk - This entails assessing whether the supplier operates within
    industries that pose a higher likelihood of hazardous manufacturing processes,
    which could have adverse effects on health, safety, and the environment.
  • Area of Operations Risk - In this aspect, the evaluation focuses on determining
    whether a particular supplier conducts operations in countries with elevated risks
    associated with corruption, law enforcement challenges, and potential concerns
    regarding labor practices and human rights.
  • Reputational Risk - Within this dimension, the assessment centers on appraising the
    overall reputation of the supplier under consideration

During our assessment process, we considered the following three conditions:

  • The risk of adverse impacts on fundamental human rights and decent working
    conditions. The extent of the assessment was based on the magnitude of the risk.
  • The consequences of adverse impacts. The assessments were more comprehensive
    when the potential harm to individuals or groups was more severe.
  • The extent of our ability to influence the situation. The evaluations and capacity to
    exert influence depended on factors such as the size of the business partnership.

We have mapped our suppliers and business partners and conducted research on human
rights and labor risks that may be associated with our business and supply chain. We do
not manufacture goods, equipment or procure raw materials. Our business partners are
primarily globally recognized organizations that provide their services via the Internet. They
span a wide range of market sectors that include but are not limited to Cloud Productivity
and Collaboration, Document Automation, Recruitment Software, Remote Work Solutions,
Team Communication and Collaboration, Data Visualization, Online Surveys and Forms,
Web Hosting and Domain Registration, Design Software, Organizational Management and
Leadership, Telecommunications, Online Learning and Education, Customer Relationship
Management (CRM), Insurance, Risk, Talent, Project Management, and Human Resources.

Our sourcing regions include countries mainly from Europe (e.g., Ireland, Norway, Greece,
Germany, Poland, The Netherlands, and Spain), North America (e.g., the United States of
America and Canada), and Australia. Amby also has some of its business relationships in
South Africa.

We have identified common industries that may pose higher risks of human rights abuses in supply chains:

  • Manufacturing: Industries such as apparel, electronics, and consumer goods often
    involve complex global supply chains with multiple tiers of suppliers. Risks in these
    industries may include forced labor, poor working conditions, and violations of labor
  • Extractive industries: Industries such as mining, oil and gas, and agriculture may
    involve risks related to land rights, displacement of indigenous communities,
    hazardous working conditions, and environmental damage.
  • Construction: Construction supply chains can be susceptible to risks related to
    migrant worker exploitation, unsafe working conditions, and non-compliance with
    labor regulations.
  • Food and agriculture: Supply chains in the food and agriculture sector can have risks
    related to forced labor, child labor, unsafe working conditions, and environmental
    issues such as deforestation or excessive use of pesticides.
  • Technology and electronics: Electronics supply chains often have risks associated
    with labor rights violations, conflict minerals, and environmental pollution.

When assessing the regions where these industries are prevalent, we considered regions
known for weak labor protections, inadequate regulation, political instability, or a history of
human rights abuses. Examples may include certain countries in Southeast Asia, South
Asia, Africa, and parts of Latin America.

Our evaluation also included a reputation assessment through external search and research
on suppliers' policies and practices.

Our assessment supported by an exhaustive analysis concluded that Amby has a low risk
of using or being part of supply chains that do not respect human rights and decent
working conditions. In 2024/2025, we did not detect that any of our suppliers posed a
higher risk of poor human rights and labor practices.

We will continue to assess and monitor our suppliers to ensure they align with our values
and meet our expectations regarding human rights and working conditions.


Amby has prepared this Statement in line with the requirements of the Norwegian
Transparency Act. Amby is committed to conducting business with the highest ethical
standards and according to applicable laws, rules, and regulations. This Statement will be
made available at by 30 June of each year and otherwise in case of
significant changes to the enterprise's risk assessments.

Upon written request, any person has the right to information from Amby regarding how
Amby addresses actual and potential adverse impacts pursuant. You can send your request


Amby AS
Thorvald Meyers Gate 7
0555 Oslo

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