INFORMATION ON THE NORWEGIAN TRANSPARENCY ACT

Due to being a part of the Caiano Group and in recognition of the importance of respect of fundamental human rights and decent working conditions, the Qubus Hotel chain implemented certain aspects of the Norwegian Transparency Act.

The implementation took place in 2022-2023 and primarily focused on introduction of internal regulations within the Qubus Hotel chain, such as ‘Caiano Code of Conduct’ and ‘Caiano Ethical Guidelines for Suppliers’, to ensure that the values arising from the Transparency Act are duly taken into account at every level of the organisation. In addition, a due diligence was conducted on compliance of the suppliers and other contractors of the Qubus Hotel chain with the requirements of the above Act.

These efforts made it possible to transfer the purpose and spirit of the Transparency Act, particularly in terms of protecting human rights and ensuring decent working conditions, to the legal and corporate environment of the Qubus Hotel chain. It is worth emphasising here that in the case of ensuring respect for workers’ rights, efforts covered not only the issues of Qubus Hotel chain’s own employees, but also employees of suppliers and other business partners.

The Qubus Hotel chain is making efforts that are in line with these requirements and aim to consolidate the implementation of the Transparency Act. These efforts are based on the chain’s own procedures and tools as well as on institutions of the Polish statutory law which, on the one hand, provide a legally binding framework for Polish law entities and, on the other hand, can be helpful in achieving goals of the Transparency Act in the Qubus Hotel chain.

The first group includes tools such as provisions in contracts concluded with the chain’s suppliers confirming that the business partners of the chain know and accept the ‘Caiano Ethical Guidelines for Suppliers’ as well as questionnaires for the key suppliers regarding the issues covered by the Transparency Act.

In the second group, several legal institutions should be mentioned, of which crucial are the regulations preventing child abuse, the provisions concerning protection of whistleblowers (being a consequence of implementation of European regulations in this area) or an important tool – Central Register of Beneficiary Owners – which helps to identify business partners with beneficial owners in ‘risky’ jurisdictions.

It is also impossible to overlook the high level of protection afforded to employee rights by Polish labour law and European standards in this regard. In case of entities based in Poland or other EEA countries, this allows for an initial assumption of the business partner’s compliance with the profile resulting from the Transparency Act. This accelerates and facilitates the identification of whether the counterparty shows concern for human and workers’ rights.

The Qubus Hotel chain has been operating on the Polish market for over 30 years and during this time has had the opportunity to create a group of trusted suppliers who not only offer noteworthy products and services, but also do not raise any concerns in terms of compliance with the law and principles of community life. These suppliers operate in a legal environment created by Polish and European law, are subject to control by public authorities, including sometimes regulatory bodies (e.g. in case of banks or insurance companies), which allows us to make the assessment of their compliance with the Transparency Act somewhat less meticulous. However, this does not mean that this assessment is only superficial or negligent then – as mentioned above, compliance with Transparency Act principles is a continuous process that requires a constant level of attention, even in case of trusted suppliers.

This level of attention should be definitely higher in the case of new suppliers or suppliers from outside the EEA. In 2025, however, the Qubus Hotel chain did not notice the appearance of such key suppliers in its environment.

The Qubus hotel chain has implemented internal policies and procedures to ensure respect for fundamental human rights and decent working conditions within its operations. These measures are based on Polish labor law, the CAIANO Code of Conduct, human resources policies, and a management framework that establishes standards for working conditions, occupational health and safety, equality, and non-discrimination across all hotels and administrative departments.

In conclusion, it should be stated that both the implementation of the provisions of the Transparency Act and the ongoing assurance of the presence of the spirit of this regulation in the operations of the Qubus Hotel chain have gone well and reached a satisfactory level.

In the near future, the Qubus Hotel chain plans to focus on investment activities involving the acquisition or construction of new hotels. This will involve adapting the procedures currently in force with regard to the Transparency Act to the specifics of the above activities, such as cooperation with suppliers from the construction and real estate sectors (construction companies, real estate agents, etc.).

Document on the subject: Information on the subject of the Norwegian Transparency Act in the Qubus Hotel chain in 2025