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Transparency Act

Report on due diligence pursuant to the Transparency Act for Compello AS.

1. Introduction to the report

This report describes how Compello, as part of the Visma Group, methodically identifies and assesses actual and potential negative consequences for fundamental human rights and decent working conditions in Visma, as well as how Compello works to implement appropriate measures to prevent, limit and/or stop such negative consequences. The report is based on a previous report prepared and published in June 2024, but has been updated with new assessments and surveys in the Group. The purpose of this report is to provide the general public with insight into Compello's and the Visma Group's key findings in the due diligence we have done, and what measures have been implemented.

In March 2025, Visma published its Sustainability Report, which can be read here. The report documents Visma's focus on human rights and the importance of everyone having decent and good working conditions. This statement is largely based on this report.

2. General information about Compello

Compello is part of the Visma Group, and a subsidiary of Visma AS.

The management and board of directors of Compello have broad experience in IT, customer service, marketing, product development, finance and management. For more information about the management of Compello, read here.

Compello has a total of 30 employees, 40% of whom are women. We have physical offices at Visma's head office at Skøyen in Oslo.

At Compello, we are committed to social responsibility, and our goal is to get rid of paper invoices. So far, our customers are saving the environment around 15,000 trees a year, which is a good start. In addition, we are Eco-Lighthouse certified

Compello is a software company that develops solutions for automatic handling of incoming invoice flows. We help customers automate the receipt, posting, accounting and archiving of supplier invoices, converting a traditional, manual paper-based process into a fully electronic process with a high degree of automation.

Most of our customers are in Scandinavia, but the solution is not tied to this region. Our customers are large and medium-sized companies, spread across many different industries, but with an emphasis on trade and manufacturing.

3. Compello's commitment to human rights and decent working conditions

Compello has for several years had a prioritized focus on sustainability and human rights. In April 2024, Visma published our Sustainability Report, which can be read in its entirety here. The information in this statement is largely based on this report.

In addition, Visma has, among other things, the following policies/guidelines for sustainability:

  • Antitrust and Competition Law Policy - read this here
  • Supplier Code of Conduct - read this here
  • Diversity & Inclusion Strategy - read this here
  • Sustainability Policy - read this here
  • Anti-Corruption Policy for external stakeholders - read this here
  • Group Governance Policy - read this here
  • Code of Conduct - read this here

These policies outline the principles for our sustainability profile, efforts and priorities.

4. Mapping and follow-up of internal risks

4.1 Method for mapping and follow-up

To assess internal risks in Compello and at our suppliers, Compello uses, among other things, SmartTrackers and Complete Control. Furthermore, work is done at both Group and company level to ensure that Compello and Visma are a workplace that focuses on and fulfills basic human rights and that all our employees have decent working conditions. Based on this work, Compello and Visma have systematically mapped the potential and actual negative impacts on fundamental human rights and decent working conditions that Visma's internal operations have caused or contributed to.

Visma has set up a sustainability model to ensure that Compello, as part of Visma, works effectively with sustainability. During 2021, we established a sustainability coordinator role, which acts as a point of contact for sustainability-related matters and is responsible for reporting to the Visma Group and for sharing knowledge about sustainability in Compello. In this way, we make sure to build our sustainability culture "from the bottom up".

In order to effectively share knowledge between all companies in the entire Visma Group, all sustainability coordinators have quarterly (or more frequent) meetings with their regional manager, called Sustainability Leads. These meetings bring together all the Sustainability Coordinators from their country or region to ensure a consistent flow of information - from management to employees, from employees to management, and between different departments or companies.

Visma's Sustainability Governance structure is described in more detail in Visma's Sustainability report (section 5).

Overall, the collaboration between those who work for the Visma Group and the various Visma companies contributes to both Visma as an organization and Compello focusing on and working actively with sustainability. The tools we use ensure that we can collect as much data as possible and thus map out which priorities we should make in our sustainability work. The sustainability coordinator role ensures good cooperation between the Visma Group and Compello.

4.2 SmartTrackers

SmartTrackers is a sustainability platform used by Compello and Visma to collect and analyze sustainability data in the organization. The data collected includes energy use in the office, heat and waste, business and car travel, anti-corruption risks and associated emissions. The information is collected on an semiannual basis. The data is used in the work to achieve Compello's and the Visma Group's climate goals in line with the Paris Agreement, as well as goals related to gender equality and subcontractors.

As part of the annual anti-corruption work in Compello and Visma, we carry out an assessment of corruption risks. In 2024, the Group assessed gifts, expenses, hospitality and influence peddling as the greatest potential risk factors.

In addition, Compello, as part of Visma, is expected to conduct an environmental impact assessment and prepare an action plan to address identified findings.

4.3 Whistleblowing channel - Whistlelink

Visma also has its own whistleblower channel(Visma Whistleblower Channel) provided by Whistlelink, where employees, ex-employees, customers, suppliers and others can report misconduct in Visma and any violations of Visma's obligations to comply with human rights and decent working conditions. The Visma Whistleblowing Channel is a tool that enables anonymous submission of (suspected) violations of local and/or EU/EEA regulations both within Visma and outside, as well as violations of Visma's own policies. The channel ensures confidential communication between the whistleblower and the person handling the complaint internally. We have appointed dedicated case handlers in each Visma company, who will ensure that the case is handled at as low a level as possible, but with the possibility of assistance from Visma's legal department where deemed necessary. Compello is connected to this channel and has a link to it on our website.

4.4 Internal work aimed at equality, diversity, discrimination, decent working conditions, etc.

The continuous work on equality, diversity and non-discrimination takes place locally in Compello.

Compello and the Visma Group's "Diversity & Inclusion" strategy clarifies our position and recommendations in this work. "Inclusive" is one of the company's core values and the Code of Conduct specifies the expected behavior of our employees.

In connection with our annual sustainability report, we report on various figures related to diversity and equality, including gender balance and the results of the monthly employee survey, which includes separate indices related to diversity and inclusion as well as health and well-being.

All new managers in Compello and Visma are invited to an onboarding program where inclusive leadership is one of several important topics.

We use aptitude tests in connection with recruitment to ensure an objective assessment basis for all candidates and that all new hires are made on the basis of relevant competence for the position.

Our internal salary adjustment tool supports managers in ensuring that adjustments are verifiable, fair and that we provide equal pay for work of equal value. Naturally, there will be some inequalities related to education, experience and responsibility, but all differences that cannot be explained are reviewed and adjusted on an annual basis.

Compello and Visma have zero tolerance for discrimination, harassment and bullying. Employees are encouraged to speak up if they experience or witness such treatment, either by contacting their immediate manager, safety representative, CEO, HR or reporting anonymously through our whistleblowing channel as mentioned in section 4.3 (Visma Whistleblowing). 4.3(Visma Whistleblower Channel).

4.5 Climate footprint

Compello works strategically with sustainability in accordance with Visma's sustainability policy.

We define sustainability as the commitment to economic, social and environmental well-being through a just transition that safeguards ecological balance for current and future generations. This applies to both our business and our value chain.

We want to be part of the transition to a more sustainable world and we support the Sustainable Development Goals (SDGs). With this, we commit to protecting the environment, people and society, through responsible management of our business, by meeting or exceeding our environmental and social commitments.

4.6 Training of employees

Visma also uses e-learning courses to train its employees in different types of situations where employees could potentially violate fundamental human rights. These courses must be completed by all employees in the Visma Group on an annual basis. Visma has two annual courses that are mandatory for all employees, within anti-corruption and privacy. In addition, all new employees undergo a course in our Code of Conduct. Feedback on course content is followed up with the individual and suggestions for changes are considered. The two annual courses have been updated in recent years following input from employees. Statistics for annual courses are made available in Visma's annual report, in addition to being reviewed in relevant internal forums.

5. Mapping of risks at suppliers and partners

Compello and Visma map risks with their suppliers by following Visma's Vendor Management Policy, which involves mapping risks by reviewing responses to statements the supplier must respond to before entering into an agreement and otherwise regularly/annually, depending on our internal risk assessment of the individual supplier. It is divided here into two different groups of suppliers:

  • Suppliers that the Visma Group (through Group Procurement) enters into agreements with and that all Visma companies can use.
  • Suppliers that Compello itself enters into with its own suppliers.

Complete Control is a contract system where all supplier contracts are uploaded and which provides a good overview of the current suppliers. Functionality for sending out questionnaires to suppliers was implemented in Complete Control during the first half of 2024.

Compello and Visma are working on building a new system for assessing their suppliers, having recently phased out the use of a previous Vendor Management tool. In the new system, different types of assessments will be sent out for suppliers to complete and answer a series of questions related to human rights and decent working conditions. The supplier's answers will further identify various risks that need to be addressed before a contract is signed. Suppliers are then followed up annually. The questions posed to suppliers are updated as needed.

Supplier Code of Conduct. All suppliers must initially accept Visma's Supplier Code of Conduct, which Compello also uses. The supplier must respect and support the protection of internationally declared human rights (Universal Declaration of Human Rights, International Labour Organizations (ILO) and Declaration on Fundamental Principles and Rights at Work). Visma does not tolerate violations of human rights among our suppliers, partners, customers and other stakeholders. The Supplier Code of Conduct sets requirements for Compello and Visma's suppliers to follow applicable regulations, non-discrimination of employees, fair and equal pay for equal work, corruption follow-up and fulfillment of human rights and more.

In the Supplier Code of Conduct, Compello and Visma require suppliers to map their supply chains in order to assess particular product-related or geographical risks of negative impact on human rights, including risks related to forced labor and modern slavery, child labor, freedom of association and the right to collective bargaining among workers. Visma has reserved the right to audit suppliers to confirm that they meet the requirements of our Supplier Code of Conduct.

If the supplier does not accept our Supplier Code of Conduct, further investigations are carried out to determine whether the supplier nevertheless has processes that essentially correspond to the obligations in our Supplier Code of Conduct.

Country-specific risk. In addition to asking basic questions related to the Transparency Act, we have also mapped where our suppliers and partners operate, and compared this with the overview of specific risks in different countries. This enables us to follow up on suppliers and partners in countries with a higher risk of negative impacts on fundamental human rights and decent work.

Further investigations. Finally, further investigations of suppliers and partners are also carried out. This includes investigating whether the individual supplier or partner can be linked to negative publicity in the media or among other partners regarding the relevant risks identified under the Transparency Act.

On the basis of the processes mentioned above, we have identified potential risks at suppliers and partners.

6. Identified risks, negative consequences and priorities

In the mapping process Compello and Visma have carried out in connection with our work on sustainability, it has been central to look at which parts of Compello and Visma's business represent the greatest risk. Compello and Visma have therefore created an overview of the countries in which Compello and Visma operate and specific risks associated with these based on various indices and reports. Based on this overview and other relevant risk factors, Compello and Visma have mapped potential risks internally.

Based on the nature of Compello's and Visma's business as a software supplier, we consider the risk of human rights violations in our value chain to be relatively low, and Compello and Visma have not identified any actual negative consequences for fundamental human rights and decent working conditions in our mapping process mentioned above. More information about the basis for this assessment can be found in our Sustainability Report.

Compello and Visma do not manufacture or sell products or services in markets that are subject to monitoring, blocking, content filtering or censorship by authorities. However, we must ensure that we take adequate measures to prevent and mitigate any risk throughout our value chain due to the severity of the risks associated with such violations.

Compello and Visma will continue to work actively with basic human rights and decent working conditions and have in our Sustainability Report listed the following areas that we will prioritize working with going forward:

  • Energy and greenhouse gas emissions
  • Diversity, equality and inclusion
  • Business ethics and anti-corruption
  • Human rights
  • Security and privacy

Our priorities are based on our materiality analysis, which was conducted in 2021. The analysis identified our key focus areas within sustainability. We gathered input through questionnaires and interviews with CEOs and HR representatives from across the organization, and discussed the topics with representatives from several stakeholder groups, including our owners and other industry experts. Our plan is to conduct another such analysis by summer 2025.

More information about Compello and Visma's sustainability priorities and the various focus areas mentioned above can be found in the Visma Sustainability Report.

7. Contact us

If you have any questions about the Transparency Act or sustainability, please contact jorilp@compello.com.

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