Transparency Act
Geographic Hotels and Adventures AS
Transparency Act Statement
1. The Transparency Act
The Norwegian Transparency Act entered into force on 1 July 2022 and aims to reduce the risk of human rights violations and ensure decent working conditions within an organization’s own operations, throughout its supply chain, and among its business partners. Furthermore, the Act aims to ensure public access to information. All businesses covered by the Act are required to carry out due diligence assessments and report on these annually.
2. Geographic Hotels and Adventures AS
Geographic Hotels and Adventures AS is part of the Flakk Group. The businesses consist of companies operating hotels, restaurants, and travel experiences in Ålesund, Sunnmøre, and Svalbard, Norway. These core activities include nature exploration, fjord and mountain sightseeing combined with stays at luxury hotels.
The group companies operating within this division include:
- 62 Nord AS
- Hotel Union AS
- Storfjord Hotel AS
- Hotel Brosundet AS
- Basecamp Explorer Spitsbergen AS
- Devoldkantina AS
- Sjøbua Ålesund AS
- Flakk AS
In the following sections, we provide further details regarding our approach to due diligence assessments, a brief overview of our supply chain, the mapping and risk assessments carried out, an evaluation of our own operations, and finally our continued work related to the Transparency Act.
3. Our Approach to Due Diligence Assessments
Geographic Hotels and Adventures AS has recently been actively working to strengthen its focus on human rights and decent working conditions in accordance with OECD principles. We are currently embedding these principles throughout our organization, including through our procedures and policies.
As part of implementing the requirements of the Transparency Act, we have:
• Developed our own Supplier Code of Conduct.
• Initiated the development of a procurement policy incorporating a focus on social sustainability throughout the procurement process.
• Developed a supplier self-assessment questionnaire.
• Maintained close dialogue with our procurement cooperative, Nores SA.
Due diligence assessments will be implemented as an ongoing process throughout our operations. Through this process, we seek to identify, avoid/prevent, mitigate, and account for adverse impacts on human rights and decent working conditions occurring within our supply chain or among our business partners.
4. Our Supply Chain
The majority of our procurement is conducted through our purchasing cooperative, Nores SA. Through this cooperation, continuous efforts are made to improve sustainability performance.
The results of supplier assessments for 2025 indicate strong supply chain transparency and monitoring practices. Based on an overall risk assessment, elevated risk may be associated with supply chains connected to Malaysia, China, India, Ukraine, Thailand, Türkiye, Pakistan, Venezuela, Colombia, and the United Arab Emirates.
For purchases made outside our procurement cooperation, local suppliers are primarily used and the risk among direct suppliers is generally considered low. We will continue to map and assess risks throughout our entire supply chain.
5. Mapping and Risk Assessment
Geographic Hotels and Adventures AS is in the process of mapping its supply chain and business partners. We assess human rights and decent working conditions in accordance with OECD guidelines.
Suppliers and business partners are classified using a risk scoring system from 1 to 10:
• 7–10: High risk
• 4–6: Medium risk
• 1–3: Low risk
Risk assessments are based on industry sector, products and services, geography, and type of business.
To date, Geographic Hotels and Adventures AS has not identified any actual breaches of human rights or decent working conditions through its work under the Transparency Act.
6. Our Own Operations
We conduct our business in accordance with Norwegian legislation, including the Norwegian Working Environment Act. We are committed to ensuring equal opportunities and a positive working environment for all employees.
Work environment assessments are conducted regularly through our occupational health service and employee performance reviews. We have not experienced any cases relating to a negative working environment or human rights violations within our own operations.
7. Future Work
The mapping and risk assessment of our suppliers will remain an ongoing process within our business. In addition to monitoring existing suppliers, we will continue to develop procedures related to the assessment and evaluation of new suppliers.
We will maintain close dialogue with suppliers where we identify a risk of human rights violations and/or inadequate working conditions and continue our close cooperation with Nores.
8. Information
If you would like further information regarding how Geographic Hotels and Adventures AS manages actual and potential adverse impacts related to human rights and decent working conditions pursuant to Section 6 of the Norwegian Transparency Act, please contact us at hello@62.no.
The Flakk Group has established a whistleblowing procedure applicable to all companies within the Group. Reports may be submitted to management, the Chair of the Board, or through the Group’s central whistleblowing channel at varsling@flakk.no.
9. Signatures
Adopted by the Board of Directors in Ålesund on 5 June 2026. The document has been electronically signed by the members of the Board of Directors and the CEO.
Chair of the Board: Erika June Flakk
CEO: Ludvig Håndlykken Ström
Board Member: Knut Flakk
Board Member: Line Kristoffersen Flakk
Board Member: Maria Lilly Flakk
Board Member: Lasse Viken Kjønstad