Transparency Act

About Xait

Xait is a Norwegian software company that develops and delivers innovative sales enablement solutions to customers worldwide, and our areas of operations are development, operations, services, marketing, and sales.

Xait has employees in Norway (HQ), UK, USA and France. We also have full time contractors in Cyprus and India. In total, Xait has close to 100 employees worldwide. All subsidiaries of Xait are owned 100%.

All the companies in Xait's business are included in the scope of The Norwegian Transparency Act.

Xait is committed to fulfilling its role in society and its social responsibility by acting in accordance with applicable legislation and regulation. Xait takes pride in having Vendors who are committed to delivering a high
level of quality to our joint customers.

Due Diligence Assessment

Xait's framework for due diligence assessments is based on the OECD Due Diligence Guidance for Responsible Business Conduct (2018), which is illustrated in the model below. The model describes a risk-based method that starts with ensuring accountability, mapping, and assessing risk, and culminates in established measures and procedures for monitoring and reporting.

This is a continuous process in Xait where we will identify risks, negative consequences, uncover possible risks, and work to reduce these and implement measures. Xait and our Vendors must have a risk-based approach and work actively to reduce risks of violations of basic human rights and decent working conditions within the business, throughout the supply chain and with business partners. Xait and our Vendors must prioritize and implement control measures depending on the level of risk and reduce negative consequences, if there are any. We expect our Vendors to report negative consequences or risks to Xait.

Overall, the due diligence assessment model is implemented in Xait in the following way:

1: Embed responsible business conduct into policies and management systems

Anchoring of The Transparency Act is conducted through our policies, routines, guidelines, and action plan. The whole management team and the employees must comply with the obligations under The Transparency Act, and the CEO has given the CFO the responsibility to ensure compliance.

2: Identify and assess actual and potential adverse impacts associated with the enterprise’s operations, products or services

Xait is in the process of establishing an overall risk picture of our Vendors, and we have risk assessments based on selected Vendors.

3: Cease, prevent or mitigate adverse impacts

Based on the risk assessment and prioritization of risk in step two, Xait will implement measures to stop, prevent and reduce risk of negative impact where this is.

4: Track implementation and results

Xait will establish regular internal and external reviews of our measures and plans to ensure that these have the desired effect.

5: Communicate how impacts are addressed

We are transparent with our risk level conducted in the due diligence assessment and will in a statement report openly and honestly on measures and challenges related to The Transparency Act.

6: Provide for or cooperate in remediation when appropriate

If a deviation has occurred, it shall be reported directly to the CFO, and Xait will take the necessary measures to ensure that those responsible for the breach in our value chain rectify this and help and/or influence the initiation of measures if required.

Results from Due Diligence

We have conducted a risk assessment in our own business and based on Xait's zero tolerance for illegal and unethical business behavior and activities, including bribery and corruption, tax controls, forced labor, child labor, non-decent working conditions, and other breaches of human rights, we have not uncovered any consequences or risks.

We have policies and guidelines with a high focus on diversity and equality, and we work continuously with maintain a working environment free of bullying, harassment, victimization, and unlawful discrimination,
promoting dignity and respect for all, and where individual differences and the contributions of all employees are recognized and valued.

Based on current investigations, we have not uncovered any negative consequences or risk in our business. That said, Xait is in the process of implementing several more strict measures to avoid risks, and to highlight some of these measures we will update our Code of Conduct for Employees to include Ethical Guidelines, we will create a Code of Conduct for Vendors along with a Vendor review once a year. Furthermore, we will establish whistleblower routines and in our Procurement Procedure we will establish routines that prevent Xait from entering contracts, agreements or relationships with Vendors who do not meet our requirements.