Report 2023 – Norwegian
Transparency Act

To uphold fundamental human rights and decent working conditions, the 99x Group is committed to conducting regular due diligence assessments and reporting any findings and actions taken. With companies in Sri Lanka, Malaysia, Portugal, and Brazil, we recognize the importance of thorough due diligence to ensure compliance with the Transparency Act and promote responsible supply chains. We are committed to taking all necessary steps to ensure that our businesses, suppliers, and subcontractors operate in accordance with relevant standards for labor rights, human rights, and environmental considerations.

In our view, due diligence is an ongoing process, and we continuously improve our processes based on new knowledge, experience, and best practices. Our goal is to ensure responsible and sustainable business operations and to contribute to the promotion of workers' rights, human rights, and environmental protection in all the markets we operate in or have partners.

Results from the 2023 Due Diligence Assessment:

The 99x Group has focused on suppliers and business partners related to the supply chain. Our assessments, guidelines, and principles are based on the group's activities in Norway, Malaysia, Singapore, Portugal, Brazil, and Sri Lanka. Sri Lanka constitutes the largest part of the organization with the most employees. The group has implemented the Transparency Act in all subsidiaries to ensure responsible supply chains. The intention is to apply the same guidelines and principles across all companies and business areas within the group.

In preparing the 2023 report, no breaches of our own guidelines have been identified, nor have any negative consequences been uncovered in the conducted due diligence assessment. We continue to focus on improving supplier selection processes to ensure compliance across the entire supply chain.

If you have any questions about our 2023 assessment, you can contact

Organization and Operations:

The 99x Group has its headquarters in Oslo. The group's companies in Norway, 99x Technology AS, Seeds AS, and Incrementi AS, offer software development, primarily with assistance from our subsidiary 99x Technology in Colombo, Sri Lanka, our partner LeanOn in Vittoria, Brazil, and Cleverti in Algés, Portugal. The commercial activities are mainly driven by the Norwegian companies. Development of solutions and customer service are primarily offered from Sri Lanka, Brazil, and Portugal.

99x Technology in Colombo is a company with more than 400 employees, and the company's management works closely with the group management on all aspects of the business. There are agreements regulating the relationship between the various companies, and there is extensive daily communication between all companies. Visits from Norway to the companies are also conducted as needed.

Compliance and certifications: 

The internal processes at 99x are compliant with the following standards.

  • Agile for software project delivery and management

  • ISO 9001:2015 for Quality Management

  • ISO 27001:2022 for Information Security Management

  • ISO 27701:2019 for Privacy Information Management

Occupational Health & Safety (OH&S) Policy:

Our work environment health and safety policy is documented within "F-PL03 Health and Safety Policy" internally. The key points covered in the policy are as below.

  • Management's commitment to providing a healthy and safe workplace for both employees and other personnel who are affected by the business activities of 99x.

  • Roles and responsibilities with relation to maintaining a healthy and safe workplace.

  • Commitment to provide training and other resources to the successful implementation of the policy.

  • Conducting risk assessments related to occupational health and safety and implementing mitigation actions.

  • Reporting and following up related incidents.

  • Commitment to conduct internal and external assessments.

  • Commitment to comply with the related regulations.

Business Conduct:

We have a policy on business conduct under the name "P-PL01 Code of Ethics & Conduct Policy". Our Guiding Principles align with this purpose where, "We delight clients, value each other and become our best!"

We delight our clients:

  • Strive to deliver excellence

  • Innovate and solve problems

  • Push boundaries courageously

We value each other:

  • Elevate one another 

  • Celebrate diversity

  • Nurture trust in an open culture

We grow to become our best:

  • Embrace the freedom to lead

  • Contribute through our passions

  • Learn and improve continuously

  • Become model global citizens

We always behave in a manner consistent with the company's guiding principles. We support and encourage others to comply with the guiding principles.

Bribery and Corruption:

Our corporate conduct policy "P-PL01 Code of Ethics & Conduct Policy" covers the requirements of our commitment against bribery and corruption as given below.

  • We are dedicated to ethical and fair competition.

  • We will make independent pricing and marketing decisions and will not improperly cooperate or coordinate our activities with our competitors.

  • We will not offer or solicit improper payments or gratuities in connection with the purchase of goods or services for 99x or the sales of its products or services.

Our corporate conduct policy "P-PL01 Code of Ethics & Conduct Policy" covers the requirements of our commitment against conflict of interests as given below.

  • We must avoid any relationship or activity that might impair, or even appear to impair, our ability to make objective and fair decisions when performing our jobs. 

  • We must never use 99x property or information for personal gain or personally take for ourselves any opportunity that is discovered through our position with 99x.

Before engaging in any activity, transaction or relationship that might give rise to a conflict of interest, employees must seek review from the 99x management.

Human rights and working conditions:

Our corporate Human Rights Policy "P-PL02 Human Rights Policy" covers our commitment to protect human rights as per the UN Guiding Principles on Business and Human Rights. It covers the following. We strive to respect and promote human rights in accordance with the UN Guiding Principles on Business and Human Rights. Our human rights policy considers the following key areas in it.

  • Health and safety - The health and safety of our employees is of paramount importance. Our policy is to provide a safe and healthy workplace and comply with applicable safety and health laws and regulations.

  • Diversity and inclusion - We are committed to equal opportunity and are intolerant of discrimination.

  • Employment conditions - We abide by the applicable laws and regulations on employment work hours, leave requirements and holidays. We provide reasonable accommodation for qualified personnel based on disabilities and pregnancy/childbirth.

  • Employment benefits - We compensate employees competitively relative to the industry.

  • Child labor - We do not tolerate the use of child labor, forced labor or human trafficking of any kind.

  • Freedom of association - We respect our employees' right to join, form or not to join a labor union without fear of intimidation or harassment.

  • Right to Privacy - We respect the privacy of our employees and business partners who trust us with their personal information.

  • Risk management - We conduct human rights impact assessments at regular intervals, prior to new activity or relationship, prior to major decisions or changes in the operations followed by risk mitigation. 

  • Grievance handling - We respect the employee's right to express their grievances without compromising their position.

  • Community - We conduct timely and sustainable CSR activities that will make a significant and measurable impact on our communities.

  • Environment - We conduct our operations in an environmentally responsible manner, with the intention of reducing our environmental footprint and protecting our global environment.

Diversity and inclusion:

Our anti-discrimination policy "P-PL10 Respectful Workplaces Policy" covers the requirements of our commitment against discrimination at the workplace as given below. Discrimination is any negative action or attitude directed toward someone because of protected characteristics, like race and gender. Other protected characteristics might include:

  • Age

  • Religion

  • Ethnicity / nationality

  • Disability / medical history

  • Marriage / civil partnership

  • Pregnancy / maternity/ paternity

  • Gender identity / sexual orientation

The company will not tolerate any kind of discrimination that creates a hostile and unpleasant environment for employees or any other stakeholders who do business with 99x. We recognize that sometimes discrimination is unintentional, as we may all have unconscious biases that could be difficult to identify and overcome. In case we conclude that an employee unconsciously discriminates, we will support them through training and counseling and implement processes that mitigate bias.

Who should I contact for more information?

Please reach out for any other questions or clarifications at