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The Norwegian Transparency Act

Last updated: October 27, 2025

This document outlines Markular’s compliance with the Norwegian Transparency Act (Åpenhetsloven) and our commitment to human rights and decent working conditions in our supply chains.

Our Commitment

Base 12 AS, through its Markular product, is committed to maintaining the highest standards of ethical conduct and compliance with laws and regulations. We have zero tolerance for illegal and unethical business behavior and activities, including:

  • Bribery and corruption
  • Tax evasion
  • Forced labor
  • Child labor
  • Non-decent working conditions
  • Other breaches of human rights

Compliance with the Norwegian Transparency Act

In accordance with the Norwegian Transparency Act (Åpenhetsloven), enforced on 1 July 2022, we work continuously to:

  1. Identify and assess actual and potential adverse impacts associated with:

    • Our operations
    • Our products and services
    • Operations of our suppliers
    • Services of our business partners

  2. Implement appropriate measures to prevent or mitigate adverse impacts

  3. Track the implementation and results of these measures

  4. Communicate with affected stakeholders about how we address potential and actual adverse impacts

Due Diligence Assessments

As part of our commitment to transparency and ethical business practices, we regularly conduct due diligence assessments that cover:

  • Human rights impact assessments
  • Supply chain evaluations
  • Partner compliance reviews
  • Internal operations audits

2024 Due Diligence Activities

In accordance with Section 5 of the Norwegian Transparency Act, Base 12 AS conducted the following due diligence activities in 2024:

Supplier Assessments:

  • Conducted risk assessments for all critical suppliers and subprocessors
  • Evaluated 6 technology subprocessors for human rights and working conditions compliance
  • All suppliers meet our ethical business standards and GDPR requirements

Findings:

  • No high-risk suppliers or adverse impacts identified in 2024
  • All assessed subprocessors maintain documented human rights policies
  • Microsoft, Sendgrid, Postmark, Freshdesk, Sveve, and Posthog all demonstrate strong commitments to ethical labor practices and comply with international human rights standards

Measures Implemented:

  • Data Processing Agreements with all subprocessors include human rights and ethical conduct provisions
  • Standard Contractual Clauses implemented for transfers to third countries
  • Regular monitoring of subprocessor compliance through documentation reviews

Results:

  • 100% of assessed suppliers meet our human rights and decent working conditions standards
  • No corrective actions required in 2024
  • Continuous monitoring program established for ongoing compliance

2025 Due Diligence Activities

In accordance with Section 5 of the Norwegian Transparency Act, Base 12 AS will conduct due diligence assessments throughout 2025 and publish our annual accountability report by June 30, 2026. Our 2025 activities include ongoing supplier risk assessments, human rights evaluations, and compliance monitoring of all critical suppliers and subprocessors.

Our Suppliers and Business Partners

In the interest of transparency, we disclose our key suppliers and subprocessors:

Technology Subprocessors:

  • Microsoft Corporation (Cloud infrastructure and hosting)
  • Twilio Sendgrid (Email services)
  • Postmark (Email services)
  • Freshdesk (Customer support platform)
  • Sveve AS (SMS notification services)
  • Posthog (Product analytics)

All technology subprocessors have been assessed for compliance with human rights and working conditions standards. For detailed information about our subprocessors, see our Data Processors page.

Other Key Business Partners:

  • Professional services providers (legal, accounting) - all Norwegian-based firms
  • Office facilities and services - compliant with Norwegian working environment regulations
  • IT equipment suppliers - sourced from reputable vendors with documented ethical supply chains

Information Requests

If you have questions about how Base 12 AS works with the Norwegian Transparency Act, you can:

  1. Submit a written request via our contact form at support@base12.no
  2. Specify the information you would like to receive
  3. Include the purpose of your inquiry

We will respond to your request in writing within three weeks. If we need more time to gather the requested information, we will inform you when you can expect a reply.

Reporting Concerns and Grievance Mechanism

We encourage reporting of any concerns regarding potential violations of ethical standards or human rights. All reports will be treated confidentially and investigated thoroughly.

How to Report:

  • Email: hello@markular.com
  • Anonymous reporting available upon request
  • Whistleblower protection policy in effect for all good-faith reports

Investigation Process:

  • All concerns acknowledged within 5 business days
  • Investigation initiated within 10 business days
  • Findings communicated within 30 days of initial report (complex cases may require additional time)
  • Corrective actions implemented as appropriate

Protection and Confidentiality:

  • No retaliation against individuals reporting concerns in good faith
  • Confidentiality maintained to the extent possible under law
  • Option for anonymous reporting to protect reporter identity

Escalation:

  • Concerns can be escalated to management or board of directors if not satisfactorily addressed
  • External escalation to Norwegian authorities available as appropriate

For more information about our ethical guidelines and compliance work, please contact our compliance team at hello@markular.com