Transparency Act Report
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The Norwegian Transparency Act Report
In alignment with the Norwegian Transparency Act, which became effective from July 1, 2022, Chooose AS (“Chooose”) is committed to promoting respect for fundamental human rights and decent working conditions in connection with its operations and services. This report describes how Chooose addresses human rights in its operations and supply chain as well as how Chooose will work with human rights and decent working conditions going forward.
Date: 22.04.2026
Reporting period: 01.01.2025 - 31.12.2025
Contact information: If you have any questions regarding this report, it can be directed to legal@chooose.today.
Description of business:
Chooose provides a Software-as-a-service (SaaS) lower carbon products platform.
Both employees and Chooose pledge to adhere to international standards and applicable local regulations that safeguard human rights.
Further, when conducting business, Chooose endeavors to ensure that its partners and vendors act ethically and respect human rights. Within this context, Chooose sees three main business areas within which it aims to monitor the protection of human rights and decent working conditions:
- Carbon Unit Suppliers
- Commercial Partnerships
- Service Providers
Carbon Unit Suppliers are defined as companies that supply carbon products that Chooose utilizes in its solutions, typically carbon credits, biofuel environmental attributes, carbon emission allowances etc. Chooose primarily conducts business with companies that act as intermediaries between the issuer or producer of the carbon products and the general market.
Commercial Partners are businesses, mostly within the transportation sector, that Chooose provides its service to or through.
Service Providers are businesses that deliver goods or services directly to Chooose without being part of Chooose’s service and product offering.
Internal guidelines:
Chooose and all team members are required to adhere to the Chooose Code of Conduct and confirm acceptance annually.
Chooose does not compromise on requirements set out in applicable law or standards with regard to worker safety and human rights. Chooose employees are not deprived of their human rights, or subject to mental or bodily harm in their labour. Chooose does not, directly or indirectly, use forced labour or other forms of involuntary labour.
Chooose’s approach to due diligence
Chooose aims to implement a commitment to fundamental human rights in accordance with the OECD Due Diligence Guidance for Responsible Business Conduct and as highlighted in the Norwegian Transparency Act (the “Transparency Act”).
This involves:
- The Company’s Management and Board of Directors maintain ultimate oversight and responsibility.
- All team members are made aware of their obligations and roles in relation to the Transparency Act.
- Chooose regularly assesses Carbon Unit Suppliers, Commercial Partners, and Service Providers to the best of its abilities.
- Chooose aims to establish procedures for regular assessments and reporting in line with the Transparency Act.
- Chooose aims to monitor any potential negative impacts on and significant risks to its employees and others affected by its operations.
Measures to limit risk in the supply chain
Carbon Unit Suppliers
Chooose aims to mitigate risk of buying carbon products from a Carbon Unit Supplier where there's a risk to human rights and / or improper working conditions by:
- Ensuring that all new and existing providers of carbon products have been screened against sanction lists.
- When necessitated based on risk level, having the supplier complete Chooose's supplier declaration form highlighting the UN Global Compact principles.
If violations of fundamental human rights and decent working conditions among suppliers
or subcontractors, or significant risk of such violations, are detected, Chooose should be
informed immediately, as required in Chooose’s standard contracts with the suppliers. If
potential or actual violations in the supply chain are uncovered, Chooose follows up through dialogue with the relevant supplier and stakeholders. Violations that are not
addressed within a reasonable timeframe may result in contract suspension/termination.
Chooose also aims to limit risks associated with the Carbon Projects that Chooose works
with; specifically, in addition to regular assessment of its Carbon Unit Suppliers as
entities, Chooose also – to the best of its abilities – evaluates human rights and working
conditions related risks within the Carbon Projects that Chooose sources Carbon Units
from.
“Carbon credits” represent one of the core Carbon Unit types Chooose works with.
Chooose only sources carbon credits from Carbon Projects that are third-party certified
according to internationally recognized carbon standards and are listed on associated
registries. In order to achieve such certification, Carbon Projects need to meet the human
rights standards set forth by their respective carbon standards. For example, in order to be
certified, such projects are assessed by a third-party based on:
Projects listed on Gold Standard¹
- Human rights: Projects must respect internationally proclaimed human rights and
avoid complicity in any human rights abuses as per the Universal Declaration of
Human Rights. Discrimination on grounds such as race, gender, ethnicity, disability,
or indigenous status is prohibited. Projects must not undermine national or regional
development rights and must uphold principles of accountability, participation,
inclusion, equality, and non-discrimination. - Gender equality: The standard promotes gender equality and women’s
empowerment, aligning with SDG 5. Projects must not reinforce gender-based
discrimination or inequalities. - Community health and safety: Projects must avoid adverse impacts on
community health and safety, including pollution and disease risks. They must
provide safe and healthy working conditions, prevent accidents, and comply with
national laws and good international practices. - Labour rights and working conditions: Gold Standard requires no forced labour
and compliance with national labour laws and International Labour Organization
(ILO) fundamental conventions. Workers must have documented agreements
covering working hours (max 48 hours/week), remuneration including overtime,
health insurance, contract termination terms, annual leave, maternity leave, and
safe accommodation, where provided. Equal opportunity and fair treatment are
mandatory, including for migrant workers.
Projects listed on VCS²
- Human rights and social safeguards: Projects must respect human rights and
avoid harm. Since March 2024, projects must formally analyse risks to vulnerable
groups such as women, children, minorities, and marginalized groups. The “No Net Harm” clause mandates identification and mitigation of any negative social or
environmental impacts. - Stakeholder engagement and grievance mechanisms: Projects must
meaningfully engage stakeholders throughout the project lifecycle and maintain
grievance redress procedures to resolve disputes. - Labour conditions: VCS prohibits forced and child labour, demands equal pay for
equal work, and forbids economic displacement. Projects must comply with local
laws and international human rights standards. - Transparency and verification: Projects undergo independent auditing, public
comment periods, and verification to ensure compliance with social and
environmental safeguards including human rights and decent working conditions.
Projects listed on American Carbon Standard³
- Human rights and labour standards: Projects must meet national laws and
international standards related to labour rights and human rights. - Transparency and oversight: ACR maintains transparent registry systems and
verification processes to ensure projects meet social and environmental
requirements, including decent working conditions and human rights protections.
Beyond initial certification, these Carbon Projects are required by their standards to
monitor and report on ongoing developments on a regular basis. The resulting reports are
made publicly available by the respective registries.
Chooose facilitates transactions of Sustainable Aviation Fuel (SAF) Environmental
Attributes, another type of Carbon Unit. Chooose aims to mitigate exposure to SAF
Environmental Attributes where there's a risk to human rights and / or improper working
conditions by ensuring that SAF Environmental Attributes that are sold via Chooose
managed software are certified under one of the following sustainability criteria:
- ISCC CORSIA, ISCC EU, ISCC PLUS: The ISCC EU System Basics, ISCC CORSIA
System Basics, and ISCC PLUS System Document all have Sustainability
Requirements which include compliance with human and labour rights and health
and safety, compliance with applicable laws and relevant international treaties, good management practice.⁴ - RSB ICAO CORSIA, RSB EU RED, RSB Global: RSB’s Principles & Criteria RSB-
STD-01-001 Principle 4 Human and Labour Rights: Operations do not violate human
rights or labour rights and promote decent work and the well-being of workers.⁵
¹ SAFEGUARDING PRINCIPLES & REQUIREMENTS
⁴ ISCC-PLUS_v3.4.2; ISCC CORSIA 201 System Basics; ISCC_EU_201_System_Basics_v4.2
⁵ rsb-principles-criteria-std-01-001-v4-1
Commercial Partners
Chooose works with well-renowned international companies that practice a high standard
of commitment to the principles set forth in the UN Global Compact list. As part of
partner onboarding, Chooose screens all new partners against different sanctions lists. All
potential commercial partners are assessed, which includes assessment of various relevant
risk categories such as country-based risk and industry risk associated.
In cases in which higher risks are identified, Chooose conducts supplementary
investigations and categorizes the company based on the level of risk, ranging from low to
high. Based on these assessments, Chooose implements appropriate follow-up measures
that correspond to the assigned risk category of each company.
Service Providers
Chooose procures services and goods from companies and providers that are well known
and deliver from jurisdictions that have a lower risk of violation of human rights and
decent working conditions. When Chooose acquires a new service, it reviews the code of
conduct or similar documents from the provider and Choooose maps out potential risk
factors such as line of business, the type of product/service, geographical factors, and
potential previously discovered risks.
Result of due diligence
Our due diligence on Carbon Unit Suppliers has revealed the following findings in 2025:
Risk Category Low:
No. of Carbon Unit Suppliers: 11
Planned mitigations: No mitigation required.
Risk Category Medium:
No. of Carbon Unit Suppliers: 0
Planned mitigations: Self-declaration form.
Risk Category High:
No. of Carbon Unit Suppliers: 0
Planned mitigations: Self-declaration form as well as further due diligence (questions, follow-up, and documentation).
Identified violations of human rights/decent working conditions:
No violations of human rights/decent working conditions were found.
Substantial risk of violation of human rights/decent working conditions:
No substantial risk of violation of human rights/decent working conditions were found.
Based on the findings, Chooose has implemented the following actions to prevent, stop, and
mitigate negative consequences:
Identified risk of violation of human rights/decent working conditions:
Country/geographical areas with high risk may need further assessment of risk.
Measures:
We review and conduct yearly assessments of our suppliers and partners.
Goal for 2026:
Maintain an overview and control over our suppliers, partners, and their due diligence of third parties.
Status:
Work in progress.
Mitigating actions and continuous surveillance measures
To date, Chooose has not identified any actual or potential adverse impacts on fundamental
human rights or decent working conditions that Chooose has caused or that are directly linked to Chooose’s operations, products, or services through its supply chain or business partners.
The promotion and respect for fundamental human rights and decent working conditions is a
continuous process. In support of ongoing compliance with the Transparency Act, Chooose will
immediately investigate reported concerns and take appropriate remedial actions to address any violations of Chooose’s policies or Code of Conduct. Chooose will also encourage feedback from employees and stakeholders to continuously improve its due diligence processes and transparency efforts.
Chooose’s priority for 2026 will be to:
- Conduct human rights training and awareness raising for all team members
- Continue to incorporate enhanced contract clauses into contracts with suppliers and
business partners - Engage with high-risk suppliers (questionnaire), if any, to further analyse the risks of these
suppliers having an adverse impact on human rights and decent working conditions - Consider establishing an external whistleblowing channel
- Formalize a specific process for handling information requests under the Transparency
Act, in order to ensure such requests are dealt with in a timely and compliant manner.
Chooose will maintain a diligent focus on international best practices on human rights and fair working conditions, to ensure compliance internally and externally. Chooose recognizes the mportance of collaboration with not just its suppliers and business partners but all relevant stakeholders, to collectively foster a culture of respect and responsibility within the industry. Chooose strives to proactively address challenges, mitigate risks, and protect human rights and the well-being of all stakeholders involved now and going forward.
Christian Thommessen - Chairman of the Board
Jill Tully - Board Member
Katherine Keating - Board Member
Andreas Slettvoll - Board Member
Jessica Marshall - Board Member
Ashley Chan - Board Member
Øystein Skiri - Board Member
Joseph Beaudin - CEO