Introduction

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

Organisation of the Business

The Bank is a niche financial institution offering first-priority mortgages on vessels to the shipping and offshore services industry, both in Norway and internationally. We also offer savings accounts to private individuals, which constitute the Bank’s primary source of funding. The Bank is headquartered in central Oslo and has 27 employees. The Bank is additionally represented in Athens, Hamburg and Singapore.
The Bank places significant emphasis on AML work and has a dedicated department for this area, comprising five full-time positions.

 

Procedures Related to the Transparency Act

The Bank fully supports and respects fundamental human rights and decent working conditions in its operations and expects the same standards to be upheld by suppliers and business partners.
The Bank has a human rights policy and procedures to ensure the protection of human rights and decent working conditions in its own operations and in its supply chain. Responsibility for work related to the Transparency Act lies with the COO, with several key employees involved to ensure thorough assessments of working conditions and systematic mapping of suppliers and business partners. The overall framework is anchored with the Bank’s Board of Directors.
The Bank sets clear requirements and expectations for its suppliers with respect to safeguarding human rights. The Bank has procedures for following up and collecting information from suppliers and business partners, and for assessing human rights risks when entering into new contractual relationships.
An annual assessment is carried out to identify and evaluate actual and potential adverse impacts on fundamental human rights and decent working conditions within the Bank’s own operations, its supply chain and among business partners. Additional assessments are carried out when circumstances require it. Mapping and assessment activities are conducted in accordance with approved procedures. Measures will be implemented if deemed necessary.
All employees are familiar with the Bank’s procedures under the Transparency Act as part of the Bank’s compliance training. The Bank’s relatively small size, short reporting lines and good information flow support effective work under the Transparency Act.

Process for Evaluating and Following Up Suppliers

1. Initial risk assessment
An overall risk assessment is conducted based on factors such as country, industry and size of the supplier. This assessment provides an overview of suppliers where there may be risks related to human rights, working conditions, environmental matters or anti-corruption. If the assessment concludes that the supplier represents low risk, the process ends here.
2. Detailed assessment
A more detailed evaluation is conducted for suppliers identified with elevated risk in step 1. Findings from step 1 are reviewed against the information and documentation the Bank holds about the supplier. If the supplier is found to handle its risks satisfactorily, the supplier is classified as low risk. If not, further information and documentation are collected. If the new assessment results in a low-risk classification, the process ends; otherwise, the process proceeds to step 3.
3. Planning of risk-reducing measures
Measures to reduce identified risks are prepared. Questionnaires and self-declaration forms are sent to the supplier.
4. Review of responses
Upon receipt of the requested information and documentation, the Bank assesses the responses. The Bank determines whether the information is sufficient or whether further risk-reducing measures should be implemented.
5. Final evaluation
If the risk is assessed as low, the due diligence result is documented and the process concludes. If the risk remains high, further measures are planned. Necessary internal and external resources are involved, and an action plan is established with clear responsibilities. Cases with significant findings are presented to the Board/management together with proposed measures.

Due Diligence Assessments

In spring 2023, the Bank conducted a mapping and assessment of its business operations, supply chain and business partners. These assessments have since been updated and followed up as required.
The risk that the Bank causes or contributes to violations of fundamental human rights or decent working conditions is considered low. The same applies to risks the Bank is directly linked to through its supply chain and business partners (cf. Transparency Act Section 3 (d) and (e)).
The Bank has relatively few suppliers and business partners, and these generally consist of reputable companies with established procedures in the relevant areas.
The Bank’s due diligence assessments have not identified any actual adverse impacts or significant risks of adverse impacts. It has therefore not been necessary to implement specific measures beyond the Bank’s general follow-up of its operations, supply chain and business relationships, as described above.
This statement will be updated no later than 30 June 2026 if changes in the risk profile of our suppliers or business partners occur.