Åpenhetsloven

Guideline for response to request according to The Norwegian Transparency Act § 4 in Caiano

Guideline applicable for: All companies fully owned by Caiano AS

Date for approval of this guideline: 20. juni 2022

About the Norwegian Transparency Act
The Transparency Act shall:

• promote enterprises` respect for fundamental human rights and decent working
  conditions in connection with the production of goods and the provision of services, and
• ensure the general public access to information regarding how enterprises address
  adverse impacts on fundamental
  Who can request information?
  Upon written request, any person has the right to information from an enterprise regarding
  how the enterprise addresses actual and potential adverse impacts pursuant to Section

1. In other words anyone who want can require information, for example journalists or
   employees, as long as the request is in writing.

About what?
This includes both general information and information relating to a specific product or
service offered by the enterprise.
Who responds to requests regarding information, what the information shall contain and
what is the deadline for response?
A request regarding information according to The Transparency Act § 4 shall be handled
by the general manager of the compay, who is responsible for provide information within
reasonable time and no later than 3 weeks after the request for information is received. The
information shall be provided in writing and shall be adequate and comprehensible.

Delayed response:
If the amount or type of information requested makes it disproportionately burdensome to
respond to the request for information within 3 weeks, the information shall be provided
within 2 months after the request is received. Please note that the enterprise shall then, no
later than 3 weeks after the request for information is received, inform the person requesting
information of the extension of the time limit in writing of:

• the extension
• reasons for the extension, and
• when the information can be expected.
  When can the company deny a request for information?
  A request for information may be denied if:
  • the request does not provide a sufficient basis for identifying what the request
  concerns
  • the request is clearly unreasonable
  • the requested information concerns data relating to an invididual`s personal affairs
  • the requested information concerns data regarding technical devices and
  procedures or other matters which for competitive reasons it is important to keep
  secret in the interests of the person it concerns
  Remember: The right to information regarding actual adverse impacts on fundamental
  human rights with which the enterprise is familiar, applies irrespective of the limitations
  specified in the bullet points above.
  Remember: The right to information does not cover information that is classified pursuant
  to the Security Act or protected pursuant to the Intellectual Property Rights Act.
  If the company denies a request for information, it shall inform about:
• the legal basis for the denial,
• the right and time limit for demanding a more detailed justification for the denial and
• that the Consumer Authority is the supervisory and guidance body.
  In other words there is not a requirement for simultaneous justification, but any person
  whose request for information is denied may within 3 weeks from the denial was received,
  demand a more detailed justification for the denial. The justification shall be provided in
  writing, as soon as possible and no later than 3 weeks after the demand for a more detailed
  justification was received.