Agilera Pharma AS acknowledges its responsibility under the Transparency Act (Act on Companies’ Transparency and Work with Fundamental Human Rights and Decent Working Conditions). The Transparency Act entered into force on 1 July 2022 and aims to promote respect for human rights and decent working conditions, as well as ensure that the public has access to information about how companies deal with any negative consequences. The Act requires larger enterprises to carry out due diligence assessments in line with the OECD Guidelines and the UN Guiding Principles on Business and Human Rights. We will also publish an account of our due diligence assessments by 30 June each year, and process information requests from the public within three weeks.
Agilera Pharma AS is a GxP-regulated pharmaceutical company, which was spun off as a separate company from the Institute for Energy Technology (IFE) in 2023. We develop, manufacture, and distribute radiopharmaceuticals, and therefore operate with strict quality requirements and high ethical standards. Our management is strongly committed to compliance with the Transparency Act; the work on responsible business practice is anchored in the management systems and is followed up at senior management level. This statement describes how we meet the requirements of the law, including how we carry out due diligence assessments, measures we implement, requirements we set for our suppliers, and how stakeholders can contact us for access.
Our policy and approach:
Agilera has integrated human rights and working conditions into its business processes. We have established internal guidelines and a Code of Conduct for Business Partners (discussed below) that are based on recognized frameworks: the UN Universal Declaration of Human Rights, the ILO’s core conventions, the UN Sustainable Development Goals, the UNGP and the OECD guidelines. This ensures that our standards are at least in line with the minimum international principles.
Agilera is continuously working for a sustainable and responsible value chain. This involves: (a) Anchoring: The board and the general manager follow-up the work with due diligence assessments. (b) Training: Employees who work with procurement and suppliers are trained in our Code of Conduct and procedures. (c) Communication: We have published contact information regarding our commitment to the Transparency Act on the website and encourage dialogue from the public.
Due diligence – how we do it:
We conduct due diligence following a risk-based approach. Because we have a limited number of suppliers in highly specialized areas (radiopharmaceuticals production, raw material suppliers, equipment, as well as certain services), we can make targeted assessments:
- Mapping: We survey all suppliers and business partners annually. We use a questionnaire and the Code of Conduct for Business Partners to collect information from suppliers about their follow-up of human rights, working conditions, the environment and anti-corruption. Each supplier is assessed for potential risk of human rights violations or decent working conditions. Factors evaluated include geographical location, type of product/service, industry risk, and any known histories. New suppliers undergo a background check that includes pre-contract sustainability and ethics criteria.
After the legal separation from IFE in 2023 Agilera for the first time sent out the Code of Conduct for signing by our critical logistic suppliers in 2024. - Assessment: Based on the survey, the suppliers are classified into risk classes (high and low). High-risksuppliers (e.g. those operating in countries with weak enforcement of labor laws or in labor-intensive industries) are prioritized for closer follow-up.
- Action: If a due diligence assessment reveals actual negative impact or a high risk of this, we take measures. We enter into dialogue with the supplier, we inform them of the findings and expect the supplier to implement agreed corrective actions within a given deadline. In the event of serious or persistent violations, we will consider stronger sanctions – in the extreme case, the collaboration may be suspended or terminated.
- Follow-up: Due diligence is not a one-time exercise. We carry out ongoing checks with high-risk suppliers. This includes regular meetings or reviews, where the supplier is asked to document progress on measures. Our contracts also require suppliers to notify us immediately if they discover breaches in their own operations or chains. Such early warning measures mean that together we can deal with the problem quickly. Internally, the status of due diligence assessments is reported to management (including the board of directors in connection with annual reporting).
- Results 2024: Close to 90% of our critical logistics suppliers signed or confirmed compliance with our ethical requirements in this process. The rest are under being followed up but have indicated in writing that they also share Agilera’s values. However, we identified areas for improvement: Some suppliers needed to document their environmental measures better, and some needed to update their own supplier management policies. We will take such findings into account in the further improvement work.
Requirements for our suppliers:
Agilera sets clear expectations for all suppliers, subcontractors and partners:
- Signing of Code of Conduct: All new (and existing major) suppliers must sign our Code of Conduct for Business Partners when entering a contract. The policy applies to anyone who supplies goods or services to us. We also make them aware that they are obliged to inform their own subcontractors of these requirements. The guidelines are based on recognized conventions and set minimum standards for ethical operations.
- Human rights and working conditions: Suppliers must respect fundamental human rights and workers’ rights. This includes, among other things, zero tolerance for child labor and forced labor, prohibition of discrimination, and demands for freedom of association and decent working conditions. Employees of the suppliers must have legal employment contracts, fair pay (at least in line with local minimum requirements) and working weeks that do not exceed legal limits. The working environment must be safe, HSE standards must be followed, and there must be channels for whistleblowing for employees.
- Health, safety and the environment (HSE): Our suppliers must ensure a safe and secure working environment for their employees, with the necessary procedures to safeguard health, safety and the environment. We also expect them to work to reduce their environmental impact. This means, among other things, that they comply with all environmental legislation and take initiatives to minimize emissions, waste and energy consumption. Suppliers are encouraged to have an environmental management system (e.g. ISO 14001) in place.
- Business ethics and anti-corruption: Agilera operates under a zero tolerance for corruption policy. Suppliers must comply with all applicable anti-bribery and financial crime laws. They must have internal controls that prevent corruption, and their employees are prohibited from giving or receiving improper gifts or benefits on behalf of the supplier. Any conflict of interest must be handled openly and proactively. We make it clear that any form of bribery, kickback, or unethical influence constitutes a breach of contract.
- Subcontractors: If the supplier uses its own subcontractors to deliver to us, we require that the same ethical requirements are continued down the value chain. Suppliers must ensure that their partners also follow the principles set out in our guidelines. This point is important – many challenges with human rights globally arise further down the chains. Therefore, we expect our direct suppliers to exercise similar diligence towards their suppliers. [
- Follow-up and audit: We reserve the right to ask for documentation of compliance. Our agreements allow us to conduct audits or request access if necessary. The suppliers are obliged to cooperate with such inspections. All our suppliers have so far shown openness when we have asked questions, and several of them have themselves reported on their on-going green initiatives and improvements.
- Consequences of breach: Should a supplier violate our ethical requirements, it will be considered a breach of contract. In that case, we will either ask for immediate remediation or consider sanctions. Our agreements give us the right to suspend or terminate the contract in the event of serious breaches. However, the goal is always improvement and we will primarily seek to solve the problem in cooperation with the supplier.
Code of Conduct for Business Partners:
This document, which is sent to all suppliers, covers in detail the requirements mentioned above. It consists of chapters on:
– Human rights and labor rights: Prohibition of child and forced labor, requirements for non-discrimination, freedom of association, regular employment, working hours, wages, and a safe working environment.
– Environment: Requirements for environmentally responsible operations, compliance with environmental laws, measures to minimize pollution and climate footprint, as well as a recommendation for an environmental management system.
– Anti-corruption and ethics: Clear prohibitions against corruption and bribery, rules for gifts and hospitality (only modest gifts, no cash, not in tender situations), and requirements to avoid conflicts of interest.
– Compliance and sanctions: Clarification that the supplier must be able to document compliance, that Agilera can conduct audits, and that breaches can lead to termination of the contract.
Access requests (information pursuant to the Transparency Act):
The Transparency Act gives everyone the right to ask Agilera for supplementary information about how we handle actual and potential negative consequences for human rights and decent working conditions. We welcome such open dialogue. On our website, it is stated that requests for access can be sent in writing to post@agilera.no (mark the subject with “Transparency Act”). Alternatively, inquiries can be sent by letter to our postal address.
When we receive an information request, we will respond in writing within three weeks from receipt of the request according to the law. The response should be designed so that it is comprehensive and understandable for the sender. If the question concerns matters that are already covered in our published report, the answer may point to this and elaborate if necessary. If the request concerns a broad or complex topic that requires more time (e.g. extensive documentation), the deadline for response may exceptionally be extended by up to two months. In that case, we will inform the sender of the delay within the three-week deadline for an information request.
Please note that the law allows certain types of information to be exempted from open access: this applies to trade secrets, personal information and details of production sites. If an information request touches on such matters, we will still stive to provide a response that satisfies the information requested as much as possible without disclosing confidential information.
The person who has submitted the claim then has the right to request a more detailed explanation within three weeks of the rejection, and we will then provide a more detailed explanation as soon as possible (and no later than within another three weeks). In addition correspondents have the right to appeal: the sender can contact the Consumer Authority if he or she believes the refusal was not justified.
As of today (October 2025), Agilera has not received any formal information requirements under the Transparency Act. Our goal is to handle all inquiries efficiently, transparently and within the deadlines. We see information requirements as a positive opportunity to demonstrate our commitment to transparency in practice.
Agilera Pharma AS will continue to develop its work with responsible supply chains. As a relatively newly established company, we build on IFE’s experience while establishing our own best practices. We are committed to annually updating the report and improving our due diligence assessments. Any questions about this report or our work under the Transparency Act can be directed to the contact person mentioned above. We thank you for your interest and for the fact that together we can promote transparency and responsible business conduct.