We’ve launched a new version of our website with an updated design. Online banking is available as usual.

Transparency Act

Introduction

This statement on due diligence assessments has been prepared by Maritime & Merchant Bank ASA (the “Bank”) in accordance with Section 5 of the Norwegian Transparency Act of 18 June 2021. Through the Transparency Act, we aim to ensure public access to information about how fundamental human rights and decent working conditions are followed up internally and among our suppliers.

Organization of the Business

The Bank is a niche bank that offers loans secured by first-priority mortgages in vessels for the shipping and oil service industries, both in Norway and internationally. We also offer savings accounts to private individuals, which constitute the main source of the Bank’s funding. The Bank has offices in central Oslo and has 27 employees. The Bank is also represented in Athens, Hamburg, and Singapore.

The Bank places strong emphasis on AML work and has a dedicated department for this area, amounting to five full-time equivalents.

The Bank’s Routines Related to the Transparency Act

The Bank fully supports and respects fundamental human rights and decent working conditions in its own operations, and expects its suppliers and business partners to do the same.

The Bank has a human rights policy and routines to safeguard human rights and decent working conditions in its operations and supply chain. Responsibility for the work related to the Transparency Act lies with the COO, while several key persons are involved to ensure a thorough review of the Bank’s working conditions and mapping of suppliers and business partners. The overall framework is anchored with the Bank’s board of directors.

The Bank sets requirements and expectations for suppliers regarding respect for human rights. The Bank has routines for following up and obtaining information from suppliers and business partners, and for assessing human rights risk when entering into new contractual relationships.

The risk of actual and potential adverse impacts on fundamental human rights and decent working conditions in the Bank’s own operations, supply chain, and among business partners is mapped and assessed annually. Additional assessments are carried out on an ongoing basis if circumstances indicate a need. The mapping and assessment are carried out in accordance with approved routines. Measures will be implemented if considered necessary.

All employees are familiar with the Bank’s routines under the Transparency Act as part of the company’s compliance training. The Bank has relatively few employees, short reporting lines, and good information flow. This is an advantage in the work under the Transparency Act.

Process for Evaluation and Follow-Up of Suppliers

  1. An overall risk assessment of suppliers is carried out based on factors including country, industry, and supplier size. Based on this assessment, the Bank obtains an overview of suppliers where there may potentially be a risk related to breaches of human rights and decent working conditions, environmental protection, and anti-corruption. If the assessment concludes that the supplier represents low risk, the process ends here.
  2. A more detailed assessment is carried out for suppliers that received an elevated risk under point 1. The findings from point 1 are assessed against the Bank’s knowledge and documentation about the supplier. Where the supplier manages its risk satisfactorily, the supplier will be given low-risk status. For suppliers where the risk is not managed satisfactorily, further information and documentation is obtained to better map the risk. If the new assessment results in low risk, the process ends; otherwise it proceeds to point 3.
  3. Measures are prepared and planned to reduce the risk identified under point 2. A questionnaire and self-declaration form are sent to the supplier.
  4. After the requested information and documentation have been received, the content is assessed. It must be decided whether the Bank is satisfied with the supplier’s response, or whether risk-reducing measures should be implemented.
  5. In the case of low risk, the result of the due diligence assessment is documented and the process ends. In the case of high risk, measures are prepared and planned to reduce the risk. Necessary internal and external resources are involved, and an action plan with responsible persons is established. The agreement with findings is presented to the board / management together with proposed relevant measures.

Due Diligence Assessments

In spring 2023, the Bank carried out a mapping and assessment of the company’s business operations, supply chain, and business partners. The assessments have subsequently been updated and followed up as necessary.

The risk that the Bank causes or contributes to breaches of fundamental human rights and decent working conditions is considered low. The same applies to the risk to which the Bank is directly linked through its supply chain and business partners, cf. Section 3 d and e of the Transparency Act.

The Bank has relatively few suppliers and business partners, and these mainly consist of reputable companies with their own routines in this area.

The Bank’s due diligence assessments have not uncovered any actual adverse impacts or material risk of adverse impacts. It has therefore not been necessary to implement specific measures beyond the general follow-up of business operations, supply chain, and business partners, as described above.

The statement will be updated no later than 30 June 2026 if there is a change in the risk picture among our suppliers / business partners.