Transparency Act

INTRODUCTION

The Act relating to enterprises transparency and work on fundamental human rights and decent working conditions (the „Transparency Act“) entered into force on 1 July 2022. This statement is Onyx Norway Holding AS and its subsidiary Onyx CenterSource AS (referred to as “Onyx”) report on the due diligence assessments pursuant to § 5 of the Transparency Act.

The statement includes the due diligence assessments we have conducted for the period 1 July 2023 to 1 June 2024.

The statement is issued in English, ref. the Accounting Act § 3-4 (3).

ORGANISATION AND AREA OF OPERATION

Onyx CenterSource AS (OCS) is the leading provider of commission reconciliation services representing travel agencies in multiple countries.

OCS is a professional e-commission company that offers a main commission tracking reconciliation and payment solution for travel management companies, travel agencies, online travel agencies and other accommodation bookers. When a hotel stay is booked through a travel agent, it is common practice in the industry that the travel agent is entitled to a commission for the referral, based on the hotel room revenue. The commission is due following the actual stay of the guest at the hotel. OCS offers an advanced software solution and services coordinating this process for travel agents.

The history of OCS traces back to the late 1990s when the founders identified that travel agents struggled with collection of commissions from hotels. The travel agents co-ordinate a large number of hotels in numerous jurisdictions, and the administrative burden led to reduced commission revenues. There was no solution to simplify this process in the market, and having identified this gap in the market Net Trans Services AS was born in 1999.

Net Trans Services AS expanded by establishing a subsidiary in the Philippines and opening its Manila office in 2002. In September 2014, Net Trans Services AS was acquired by Onyx.

The product offered from Norway is called RecoverPro which is operated from an own developed system called AC (Active Commision). This product helps travel agents reconcile commissions owned from hotels.

GUIDELINES AND ROUTINES

Onyx has for several years had a code of conduct applicable for employees on our intranet. Onyx CenterSource stands for honesty, open communication, fairness and trustworthiness. These high business standards are part of our Guiding Principle and serve as the basis for our Code of Conduct. The Code of Conduct and Employee Handbook, where our basic employment procedures, policies and practices are described, has been made available for all.

All employees are required to become familiar with these documents and to sign and return the acknowledgment form to Human Resources.

THE DUE DILIGENCE ASSESSMENTS

• Our due diligence work started with an overall analysis and gathering of information for our business, suppliers and business partners. The purpose was to identify which areas pose the highest risk of negative impact on fundamental human rights and decent working conditions.
• We obtained a complete list of suppliers and business partners (hereinafter collectively „Suppliers„) during the relevant This overview was compiled by obtaining lists of Suppliers to whom we have had payments during the period.
• After the total number of Suppliers had been identified, an assessment was made of which Suppliers should be followed up in further mapping.
• The list of suppliers was then further limited according to criteria such as the size of payments from us, industry (group and product category), geography (place of production and place of origin), whether the Supplier itself is covered by the Transparency Act, whether the Supplier was individual (one-off purchases and Suppliers we no longer have a relationship with were removed).
• The purpose of the limitation was to create a starting point for further mapping. In the further mapping, we first looked at publicly available information on the risk of violations of fundamental human rights and decent working conditions, related to the geography and industry of the relevant Suppliers.
• We noted that the Suppliers are, with very few exceptions, large companies. The majority of such Suppliers are also themselves subject to the Transparency Act or have their own policies to reflect sustainability, diversity, ethics etc.
• We have in our due diligence assessments in 2024 not identified actual negative consequences or material risk of negative consequences through our due diligence We have therefore not implemented any concrete measures to halt any relevant negative consequences or significant risk of negative consequences that the business has uncovered through its due diligence assessments.

Approved by the board of directors for Onyx CenterSource AS on June 17th 2024