Human Rights Policy

This human rights policy (the “Policy”) applies to all employees and officers of Pareto Securities AS, including our branches and subsidiaries in Norway and abroad (“Pareto Securities”).

The purpose of the Policy is to:

• Outline our commitment to respect internationally recognised human rights as referred to in the Norwegian Transparency Act
• Describe how we work to identify and manage potential human rights risks in our operations and business relationships
• Clarify expectations for employees, suppliers, clients and business partners

This Policy forms part of Pareto Securities’ broader governance framework and complements the Code of Conduct, Anti-corruption Policy, Diversity & Inclusion Policy, and internal procedures related to the Transparency Act.

Pareto Securities is committed to respecting internationally recognised human rights, including:

• The International Bill of Human Rights
• ILO’s Declaration of Fundamental Principles and Rights at Work
• The UN Guiding Principles of Business and Human Rights (UNGPs) as a guiding framework

We aim to avoid causing or contributing to negative human rights impacts through our own activities and to use our leverage, where appropriate and feasible, to encourage responsible practices among suppliers, business partners, and clients.

In line with this approach, we strive to:

• Provide a safe, secure, and inclusive working environment free of discrimination and harassment
• Respect employees’ rights to privacy, freedom of expression, and freedom of association
• Oppose forced labour, modern slavery, child labour, and human trafficking
• Follow applicable laws and regulations on working conditions, non-discrimination, equality, and employment practices
• Pay special attention to individuals and groups who may be more vulnerable to adverse impacts

We expect our suppliers, business partners, and clients to act in a manner consistent with these principles, proportionate to the nature and risk level of the relationship.

Pareto Securities conducts human rights due diligence in accordance with the Transparency Act. Our due diligence is risk-based and proportionate to the size of our business, the nature of our activities, and the risks we identify.
 

3.1 Identifying and assessing risk

We regularly assess potential human rights risks related to:

• Our own operations and working environment
• Suppliers and business partners, based on the nature of the goods or services and relevant jurisdictional risks
• Transactions in our investment banking activities, through established procedures such as the Deal Committee assessments

These assessments help us understand where adverse impacts are most likely to occur and where our follow-up efforts are most needed.
 

3.2 Preventing and mitigating risk

Where risks are identified, we will take reasonable steps to prevent or mitigate them, which may include:

• Seeking additional information or documentation
• Implementing contractual requirements where appropriate
• Conducting enhanced due diligence for higher-risk relationships
• Engaging in dialogue with relevant parties to clarify expectations
• Declining or discontinuing relationships where risks cannot be adequately managed over time
   

3.3 Integrating human rights into governance

Human rights considerations are integrated into existing governance processes, including:

• Anti-corruption and anti-money laundering measures
• Conflicts of Interests controls
• Procurement and supplier selection
• Information-security and data-privacy management
• Investment banking assessments

This ensures that human rights risks are considered as part of a broader compliance and risk-management framework.
 

3.4 Stakeholder concerns and whistleblowing

Employees, suppliers, and business partners may raise concerns through our whistleblowing channel, which ensures confidentiality and protection against retaliation. We also encourage suppliers and business partners to notify us of concerns that may relate to human rights.
 

​​​​​​​​​​​​​​3.5 Improving

We review our approach annually to continually improve our human rights due diligence in a way that is proportionate and practical for our organisation.

The Board of Directors approves this Policy and oversees its implementation.

Management is responsible for integrating human rights considerations into relevant processes.

Employees and officers are expected to act in accordance with this Policy and raise concerns where relevant.

Suppliers and business partners are expected to cooperate with reasonable requests for information and to conduct their activities in a manner consistent with the principles described in this Policy.