OBS-1: Seems to miss cross reference the actions in the risk register to the Action register.
During the verification Claxton could not present a systematic and methodical approach to how mitigating actions from risk assessments are closed. And reviewing documentation received, the verification team does not see that it is clearly stated how to secure that mitigations are implemented and documented.

The Verification team suggest that Claxton update relevant procedures to reflect this and looks into implementing a good way of documenting closure (how and where).

06.09.24: A project risk register review was conducted on 09 August. In attendance was Business Development, Operations Manager, Project Lead and QHSE. The project is running via the rolling action register which captures the relevant mitigation actions. Confirmation is required from the Project Lead that this process is fully aligned to close – since in process, case closed

IMP-1: How Claxton secures that they are updated according to regulations does not seem robust. Very dependent on externals.
Regulatory compliance is secured in the Compliance obligations register (COR). The COR is developed by Antenor OTG, but no review cycle is implemented securing regular updates. Claxton monitor through the Barber index and also have Medco OHS a support for health-related regulatory updates. By the time of the verification Claxton’s legal compliance was 81 %, due to i.a. one NCR related to GDPR (work ongoing).

Claxton should get in place better routines to ensure that new or updated regulatory requirements are caught (Lovdata.no, information letters from Havtil, regular reviews, etc.) and also to secure ownership of the COR.

29.08.24: Status requested.
06.09.24: Procurement are liaising with Lovdata for a subscription, however the VP QHSSE for Claxton, Nathan Darnell is also exploring utilising Barbour Indexes for all sites which includes local legislation. The PO for Lovdata subscription is on hold until the decision has been made on utilising Barbour. Barbour EHS (barbour-ehs.com)
28.10.24: Lovdata subscription has been authorised. We’ve received the log ins and just need to register – case closed

IMP-2: Several open MoCs and NCRs in Intelex.
When receiving documentation before the Verification, the status was 26 open Non-Conformance Reports (NCR) and 19 open MoC for May. The amount has been increasing over the last months, and at the Verification the number had increased further for June.

Claxton should start defining and prioritising the critical ones, and secure that the «quick fixes» (closed, approved, and rejected ones) are marked as closed.

29.08.24: Status requested.
06.09.24: A monthly Intelex meeting has been initiated to address and prioritise open actions. This will be ongoing throughout the next 12 months. Closed

IMP-3: Would be beneficial to have a Norwegian HSE resource.
The position as Regional QHSE Manager is rather new in Claxton and covers both UK and Norway and thereby have a wide range of work tasks. Having a dedicated HSE resource in Norway, would strengthen the company and securing even better management of the QHSE area (ref. also IMP-2).

Claxton is requested to give feedback if this is a resource they will take onboard.

29.08.24: Status requested.
06.09.24: The position of QHSE Advisor has been approved within the Norwegian organisation. Currently progress is interviewing three candidates in the next two weeks or so. Failing this, there is also an appetite to recruit a temporary resource.
21.10.24: We consider this as closed as they are in a process.

IMP-4: Risk Matrix Acteon: The company «accepts» one fatality/death every third year.
The risking of fatalities should be updated in all risk matrices, as Claxton (Acteon) now “accepts” fatalities when they are less frequent. One fatality (death) every 3rd year is considered as a medium and acceptable risk.

The Verification team’s experience is also that the risk differs between countries and projects, especially when it comes to cost. It may also be beneficial to make a Bridging document for securing proper values and proper risking for projects in Norway.

29.08.24: Status requested.
06.09.24: There have been discussions on amending the RCM, but there are at a higher level as the RCM is an Acteon Group tool. This resides with VP QHSSE for Claxton, Nathan Darnell.
21.10.24: Asked for the feedback from Mr. Darell
28.10.24: Nathan is on leave. He’s considering on removing the time period in the risk classification matrix. Closed, as we believe that this matter is followed up

IMP-7: We recommend that Claxton starts preparing for making the Transparency Statement for 2024.
Claxton will be subject to the Transparency Act for 2024 as they tick off at least two of the below requirements:
• Sales revenues above MNOK 70
• Balance sheet total of more than MNOK 35
• Average number of employees in the financial year more than 50
Claxton’s Human rights and Global labour principle policy does not reflect all aspects of the Transparency Act.

The Verification team recommends Claxton to develop a system for reporting according to the Act, to be prepared for the Transparency Statement in 2025. There are several statements available on Norwegian companies websites at it is required to have the statement open for public.

29.08.24: Status requested.
06.09.24: Roger Sandanger has raised this with Laura Claxton COO, it has been agreed that a gap analysis is required to be undertaken. This was communicated on 03 September.
21.10.24: Requested status: Any news? As long as this is on Claxton’s agenda, we will close the case.
28.03.24: Status currently is that work is ongoing from Supply Chain to prepare for a report for 2024. Just recently there has been interaction to take synergies from other Acteon Companies established in Norway. Case considered closed

IMP-8: Secure that the requirements in the Transparency Act are implemented in the Vendor Questionnaire.
Claxton has a very good and thorough system for checking and approving suppliers by use of a vendor questionnaire. The Transparency Act requires that the business must assess the risk of violations of or negative consequences of breach of human rights in its supply chain, all the way back to the raw material stage. As per todays, Claxton’s questionnaire does not include relevant requirements related to the Act.

Update the Questionnaire

29.08.24: Status requested.
06.09.24: The Group Supply Chain Manager has been tasked with undertaking a gap analysis on the requirements to be included in the vendor questionnaires.
21.10.24: Feedback: We then consider this case closed.

A-1: Claxton to send presentation

Received 04.05.24.

A-2: DNO to send presentation

Sent 05.08.24

A-3: The status of Falstaff Risk Register was uncertain.

Claxton to send Falstaff Risk register or status on the work, and overview of major risks.

29.08.24: Status requested.
21.10.24: Status requested again…
28.10.24: Received Rolling Action Register – action closed

A-4: Claxton to send Supplier approval and management procedure

Received 04.07.24

A-5: Claxton to share “Digital ideas map” if possible

Received 04.07.24

A-6: Post verification action: Claxton to provide needed SDS’ for chemicals planned used offshore. To be sent to environmental@wellexpertise.com.

Send before operation start

29.08.24: Status requested.
21.10.24: We have not received any SDS’ for the Falstaff operation. Could you please help us provide these ASAP?
28.10.24: Received SDS’ for Rocol and Molykote – action closed

A-7: Claxton to Invite DNO and WE to open day in September (Lazer cutting to be presented)

29.08.24: Status requested.
04.09.24: Invitation received

A-8: Changes of key personnel or suppliers must be reported to WE (Phil Hardy)

Continous in operation
No changes during operation

OBS-1: Seems to miss cross reference the actions in the risk register to the Action register.
During the verification Claxton could not present a systematic and methodical approach to how mitigating actions from risk assessments are closed. And reviewing documentation received, the verification team does not see that it is clearly stated how to secure that mitigations are implemented and documented.

The Verification team suggest that Claxton update relevant procedures to reflect this and looks into implementing a good way of documenting closure (how and where).

06.09.24: A project risk register review was conducted on 09 August. In attendance was Business Development, Operations Manager, Project Lead and QHSE. The project is running via the rolling action register which captures the relevant mitigation actions. Confirmation is required from the Project Lead that this process is fully aligned to close – since in process, case closed

IMP-1: How Claxton secures that they are updated according to regulations does not seem robust. Very dependent on externals.
Regulatory compliance is secured in the Compliance obligations register (COR). The COR is developed by Antenor OTG, but no review cycle is implemented securing regular updates. Claxton monitor through the Barber index and also have Medco OHS a support for health-related regulatory updates. By the time of the verification Claxton’s legal compliance was 81 %, due to i.a. one NCR related to GDPR (work ongoing).

Claxton should get in place better routines to ensure that new or updated regulatory requirements are caught (Lovdata.no, information letters from Havtil, regular reviews, etc.) and also to secure ownership of the COR.

29.08.24: Status requested.
06.09.24: Procurement are liaising with Lovdata for a subscription, however the VP QHSSE for Claxton, Nathan Darnell is also exploring utilising Barbour Indexes for all sites which includes local legislation. The PO for Lovdata subscription is on hold until the decision has been made on utilising Barbour. Barbour EHS (barbour-ehs.com)
28.10.24: Lovdata subscription has been authorised. We’ve received the log ins and just need to register – case closed

IMP-2: Several open MoCs and NCRs in Intelex.
When receiving documentation before the Verification, the status was 26 open Non-Conformance Reports (NCR) and 19 open MoC for May. The amount has been increasing over the last months, and at the Verification the number had increased further for June.

Claxton should start defining and prioritising the critical ones, and secure that the «quick fixes» (closed, approved, and rejected ones) are marked as closed.

29.08.24: Status requested.
06.09.24: A monthly Intelex meeting has been initiated to address and prioritise open actions. This will be ongoing throughout the next 12 months. Closed

IMP-3: Would be beneficial to have a Norwegian HSE resource.
The position as Regional QHSE Manager is rather new in Claxton and covers both UK and Norway and thereby have a wide range of work tasks. Having a dedicated HSE resource in Norway, would strengthen the company and securing even better management of the QHSE area (ref. also IMP-2).

Claxton is requested to give feedback if this is a resource they will take onboard.

29.08.24: Status requested.
06.09.24: The position of QHSE Advisor has been approved within the Norwegian organisation. Currently progress is interviewing three candidates in the next two weeks or so. Failing this, there is also an appetite to recruit a temporary resource.
21.10.24: We consider this as closed as they are in a process.

IMP-4: Risk Matrix Acteon: The company «accepts» one fatality/death every third year.
The risking of fatalities should be updated in all risk matrices, as Claxton (Acteon) now “accepts” fatalities when they are less frequent. One fatality (death) every 3rd year is considered as a medium and acceptable risk.

The Verification team’s experience is also that the risk differs between countries and projects, especially when it comes to cost. It may also be beneficial to make a Bridging document for securing proper values and proper risking for projects in Norway.

29.08.24: Status requested.
06.09.24: There have been discussions on amending the RCM, but there are at a higher level as the RCM is an Acteon Group tool. This resides with VP QHSSE for Claxton, Nathan Darnell.
21.10.24: Asked for the feedback from Mr. Darell
28.10.24: Nathan is on leave. He’s considering on removing the time period in the risk classification matrix. Closed, as we believe that this matter is followed up

IMP-7: We recommend that Claxton starts preparing for making the Transparency Statement for 2024.
Claxton will be subject to the Transparency Act for 2024 as they tick off at least two of the below requirements:
• Sales revenues above MNOK 70
• Balance sheet total of more than MNOK 35
• Average number of employees in the financial year more than 50
Claxton’s Human rights and Global labour principle policy does not reflect all aspects of the Transparency Act.

The Verification team recommends Claxton to develop a system for reporting according to the Act, to be prepared for the Transparency Statement in 2025. There are several statements available on Norwegian companies websites at it is required to have the statement open for public.

29.08.24: Status requested.
06.09.24: Roger Sandanger has raised this with Laura Claxton COO, it has been agreed that a gap analysis is required to be undertaken. This was communicated on 03 September.
21.10.24: Requested status: Any news? As long as this is on Claxton’s agenda, we will close the case.
28.03.24: Status currently is that work is ongoing from Supply Chain to prepare for a report for 2024. Just recently there has been interaction to take synergies from other Acteon Companies established in Norway. Case considered closed

IMP-8: Secure that the requirements in the Transparency Act are implemented in the Vendor Questionnaire.
Claxton has a very good and thorough system for checking and approving suppliers by use of a vendor questionnaire. The Transparency Act requires that the business must assess the risk of violations of or negative consequences of breach of human rights in its supply chain, all the way back to the raw material stage. As per todays, Claxton’s questionnaire does not include relevant requirements related to the Act.

Update the Questionnaire

29.08.24: Status requested.
06.09.24: The Group Supply Chain Manager has been tasked with undertaking a gap analysis on the requirements to be included in the vendor questionnaires.
21.10.24: Feedback: We then consider this case closed.

A-1: Claxton to send presentation

Received 04.05.24.

A-2: DNO to send presentation

Sent 05.08.24

A-3: The status of Falstaff Risk Register was uncertain.

Claxton to send Falstaff Risk register or status on the work, and overview of major risks.

29.08.24: Status requested.
21.10.24: Status requested again…
28.10.24: Received Rolling Action Register – action closed

A-4: Claxton to send Supplier approval and management procedure

Received 04.07.24

A-5: Claxton to share “Digital ideas map” if possible

Received 04.07.24

A-6: Post verification action: Claxton to provide needed SDS’ for chemicals planned used offshore. To be sent to environmental@wellexpertise.com.

Send before operation start

29.08.24: Status requested.
21.10.24: We have not received any SDS’ for the Falstaff operation. Could you please help us provide these ASAP?
28.10.24: Received SDS’ for Rocol and Molykote – action closed

A-7: Claxton to Invite DNO and WE to open day in September (Lazer cutting to be presented)

29.08.24: Status requested.
04.09.24: Invitation received

A-8: Changes of key personnel or suppliers must be reported to WE (Phil Hardy)

Continous in operation
No changes during operation