About OCH

Privacy statement

THIS POLICY EXPLAINS HOW OCH ORTOPEDI COLLECTS, STORES AND PROCESSES PERSONAL DATA.

Who is responsible for processing?

The CEO is responsible for the company's processing of personal data. The day-to-day responsibility is delegated to the data processing manager, who is also the company's system manager. The delegation only applies to tasks and not responsibilities. Day-to-day responsibility for patient data is delegated to the head of clinic in each department.

What is the purpose?

The purpose of storing information is to provide correct and effective healthcare to our users. We are required by law to retain some data, but you can provide us with other data voluntarily to enable more effective communication.

What is the legal basis?

Our orthopaedic engineers are authorized healthcare professionals, and thus subject to the Health Personnel Act, Chapter 8 (§§39 - 47) with associated regulations - which regulates the basis for processing patient data.

Telecomputing is our IT service provider. All personal data is processed by Telecomputing. This is regulated by a data processing agreement.

We have similar agreements with Hove Medical (System X), Medilink and Columbus Norway.

What personal data is processed?

Statutory information:

Personal data, including national identity number, for secure identification
Address, telephone number, marital status and occupation
Information about risk of infection, to ensure HSE
Relevant diagnoses in relation to the services we will provide
Guardian or whoever consents on your behalf
Records of our examinations and assessments
Relevant images and/or videos
Epikrises, referrals, decisions and other documents that other healthcare professionals send us in connection with the treatment

Voluntary information:

Additional contact information
for repayment of advance payment
Where is the data collected from? The data is collected from referrals, applications and decisions submitted to us in connection with processing. Or directly from you as a customer. We are not linked to the National Population Register.
Is it voluntary to provide the information? We are required by law to store the statutory data listed in section 4. The voluntary data may make it easier for us to communicate with you.
Is the data disclosed to third parties? In order to ensure that correct and effective health care is provided, it may - upon request or when necessary - be appropriate to share relevant information with other partners. The following third parties may receive information:
The referring doctor or other healthcare professional receives a summary of our medical records (discharge summary). This applies to information that is relevant to the treatment in question.
NAV receives information in connection with the processing of the application, as well as confirmation of completion of the assistive device. This information includes personal data, contact information, current diagnosis and the orthopaedic engineer's assessment.

In some cases, we would like to use images or films in connection with training, courses and the like for other healthcare professionals. If you are identifiable in a photo or film, this may not be used without your prior written consent.

How is the information deleted and archived? According to the Medical Records Regulations, information must be stored for a minimum of 10 years after the last entry in the medical record.

All information is stored on server Telecomputing in Norway according to applicable regulations. Some of the oldest information is stored in a local database that is securely locked and with limited access. This database is not connected to networks or the internet.

What rights does the data subject have and which country's legislation applies? You have the right to access your own medical records as long as the information is not believed to be harmful to you. You can also demand that the information be disclosed.

You may require rectitation or deletion of the voluntary information. As regards the statutory information, you may only require the correction or deletion of incorrect information.

This statement may not limit the rights or obligations arising from Norwegian law. Applicable laws and regulations are the Health Personnel Act, the Patient Rights Act, the Archival Regulations and the Journal Regulations.

How is the data secured? Only OCH employees and our data processors have access to the data. Procedures are in place to ensure that only relevant personnel have access to sensitive data. All employees have signed a confidentiality agreement.

Email post@och.no

Telephone. 23 288200

Postal address: Innspurten 9, 0663 Oslo, Norway

The Transparency Act and due diligence

The Transparency Act is a relatively new law introduced in 2022 and aims to promote companies' respect for fundamental human rights and decent working conditions, and ensure public access to information.

Among other things, the law imposes a duty to provide information and a duty to carry out due diligence assessments that must be accounted for in a report that is submitted.

Under the Transparency Act, anyone can demand information from companies about how they handle actual and potential negative impacts that have been assessed in the due diligence assessments. This is called an information requirement.

A due diligence assessment is a process or a working method to identify, prevent, account for and follow up on how a company manages actual and potential negative impacts of its operations related to human rights and decent work.

OCH's Due Diligence Assessments - Method and Results

The risk assessment assesses for compliance and financial risk. Compliance risks include identification and assessment of beneficial owners, politically exposed persons, sanctions and watch lists, and a wide range of risks related to bribery and corruption, drug trafficking, human rights violations (e.g. forced labor, child labor, slavery), environmental crime, terrorism and business crime (e.g. tax evasion, money laundering, competition). Financial risk includes credit and liquidity risk assessed through consolidated reports from credit information institutions. We have used an automated third-party due diligence tool (Compliance Catalyst) to assess these risks as part of our supplier management framework.

A risk-based approach has been used to select relevant suppliers for the risk assessment. Suppliers in the top 95% consumption threshold were selected, which corresponds to a total of 15 suppliers.

The risk analysis showed that none of the 15 suppliers were associated with significant risks, which means that there is no need to take action due to risks related to human rights and humane working conditions.

For more information, see the report.

Download the report456 KB

Gender equality statement

At OCH Orthopedics, we have a burning passion to help people live lives without limitations.

We value that people have different ideas, perspectives and backgrounds. Our goal is that people - regardless of injuries or congenital mobility impairments - through our professional competence and efforts, get improved mobility, independence and quality of life. Thus, we contribute to active participation in society and social inclusion. We are proud that this represents a good economy.

State of gender equality

Below is available numerical documentation for the gender equality situation for the financial year 2021. Of the total employees in the company, 36% are men against 64% women, and the company has a goal of having a gender distribution of 50/50 in senior positions. Of leading positions today, women make up 60%. Based on the systematic categorization of all positions on the basis of competence, responsibility, working conditions and efforts, the gender distribution is in four position groups: Group 1: 75% women, group 2: 70% women, group 3: 67% women and group 4: 49% women. Group 1 comprises the positions with the lowest score on the above criteria, and group 4 constitutes the positions with the highest score.

Employees in OCH Orthopedics are, as a general rule, employed in permanent full-time positions. In 2021, 24% of the workforce accounted for reduced positions. This is the result of adaptations in accordance with the Working Environment Act's rights with regard to age or care for children, as well as the company's internal personnel policy. A systematic survey conducted in 2022 shows that 0% work involuntarily part-time, and only 3 employees in the workforce have a temporary employment. The average number of weeks of parental leave was 35 for women and 0 for men. There are small differences in wage levels between the sexes. AND Orthopedics is covered by collective agreements for the largest part of the workforce, and the wage survey shows an insignificant difference in the proportion of women in fixed wages and total pay.

Our work against equality and against discrimination

OCH Orthopedics has defined a basic ethical view that provides guidance for how we should take care of our patients, staff and partners. Our organizational culture must be characterized by openness and honesty, and ethical awareness must be characterized by how we carry out our work tasks and processes. We have a goal of a varied and inclusive work environment with equal career opportunities for all.

Our gender equality work is rooted in our business strategy, our values, in our competence framework and in our personnel handbook. For OCH Orthopedics, equality and diversity is a natural part of the business, which means that everyone should have the same rights, opportunities and duties regardless of gender, transgender identity or expression, ethnicity, outlook on life, disability, sexual orientation or age. We believe that employees with different backgrounds and experience generate increased creativity and quality in the organization - and this gender equality and diversity aspect is assessed by selection in all recruitments and is incorporated into our recruitment strategy.

In OCH Orthopedics, there is zero tolerance for harassment, breaches of laws and regulations, ethical norms and guidelines, and in our quality system and in our personnel handbook, reference is made to how employees proceed if situations arise where notification is required. In 2021, no incidents of discrimination or other undesirable incidents were reported through the notification routine.

Through annual employee surveys, the work environment, employee engagement and inclusion culture are mapped. The results are followed up by department and local action plans are prepared

measures for improvement and conservation. The measures are followed up and evaluated annually. These are good results overall for OCH Orthopedics in 2022, and very good results associated with the inclusion culture index.

AND Orthopedics works actively and purposefully with gender equality to ensure an inclusive workplace, and this is a long-term and continuous work. To ensure a good physical and mental working environment, overall and clinical action plans are prepared annually in collaboration with the occupational health service. This includes safety rounds, occupational health examinations and AMU meetings as fixed points. The occupational health service's other service offerings related to individual employees are used.

HR is involved in all parts of recruitment processes in OCH Orthopedics, from needs analysis to reference taking and offers. All positions are advertised, and the company follows the Össur Group's Scandinavian recruitment process and strategy in every selection. It is desirable to contribute to applicants being diversely represented and the company will therefore in future work even more consciously with the use of images and word choice in the job advertisements.

AND Orthopedics wants all employees to be given the same prerequisite for personal and professional development. A number of training sessions in the development interview and employee development will be held in 2022, and active development is being worked on. In 2022, a leadership development program will be developed for professional leaders without personnel responsibilities that includes themes and areas that safeguard diversity and gender equality. The company's process for promotion and development opportunities is transparent and accessible to any employee, and the opportunities are highlighted and must be sought. Here, the same guidelines are followed as in any other recruitment process. We have competitive and stimulating pay and working conditions that are determined through our collective agreements and guidelines. The company has limited opportunities to offer flexibility beyond current practice based on the nature of the business as an orthopedic technical clinic. The main part of the workforce has work tasks and position function directly connected to patient contact or patient work, and is therefore largely tied to the clinic's opening hours.

The responsibility to ensure equality and prevent discrimination is both a manager's and employee's responsibility. The management, HR, shop stewards and employee representatives facilitate, coordinate and evaluate the work. An internal working group has been launched in 2022 to work for this purpose in accordance with the guidelines and tools contained in the activity and reporting obligation. HR leads the working group and the measures will be evaluated annually in collaboration with the above-mentioned contributors.

Sustainable Business Practices Policy

OCH works to have a sustainable business practice that respects people, society and the environment. This policy document, including principles for sustainable business practices, forms the basis for our sustainability work.

OCH sees sustainable business practices as a prerequisite for sustainable development, which means that today's generations will be able to meet their needs without destroying the ability of future generations to have their tyres covered. The UN Sustainable Development Goals are the world's joint action plan for sustainable development. OCH is actively working on the sustainability goals.

OCH is a member of the Orthopedic Technical Association (OVL). OVL is a member of the Ethical Trade Norway. As a way, through its membership in OVL, OCH undertakes to actively work with due diligence assessments for sustainable business practices. Due diligence assessments are a risk-based approach to respecting and safeguarding people, communities and the environment in our own business and throughout the supply chain. We expect our suppliers and partners to follow the same approach.

Requirements for our own operations
OCH recognizes that our business practices can have a potential negative impact on people, society and the environment. At the same time, we recognize our potential to contribute to positive development in the supply chain. With this in mind, we have developed the following principles and requirements for our own operations:

Due diligence
OCH shall conduct due diligence for sustainable business practices. This means: conducting our own risk assessments of negative impacts on people, society and the environment, and stopping, preventing and reducing such impacts.
The measures are monitored and their effects are assessed and communicated to those affected. Where our activities cause or contribute to a negative impact on people, society or the environment, we will stop this activity and we will seek to restore the damage. Where the supplier is responsible for the negative impact/damage, the supplier is also responsible for restoration.

Responsible sourcing practices
OCH considers responsible sourcing practices to be one of our most important tools in our efforts to promote sustainable business practices.
OCH will adapt our own sourcing practices to strengthen, and not undermine, suppliers' ability to deliver on our requirements to ensure good conditions for people, society and the environment. We will strive for long-term supplier relationships with suppliers who show a particular willingness and ability to work with positive development in the supply chain.

Freedom of association and worker representation
OCH supports the right to free association and other forms of democratically elected worker representation. We will involve worker representatives and other relevant stakeholders in our work on sustainable business practices.

Supplier development and partnerships
In dialog with suppliers, we will, if necessary, consider contributing relevant skills development or resources that enable our suppliers to comply with OCH's requirements for conditions in the supply chain. In this way, we lay the foundation for good cooperation with suppliers who show particular willingness and ability to work with positive development for people, society and the environment in the supply chain.

Anti-corruption
OCH, including all employees, must never offer or accept illegal or improper gifts of money or other remuneration to obtain business or private benefits for themselves or benefits for customers, agents or suppliers.

Countries under trade boycott
OCH, including our suppliers and partners, shall avoid trading partners that have activities in countries that are subject to a trade boycott by the UN and/or Norwegian authorities.

Requirements for conditions in the supply chain
We expect our suppliers and partners to work purposefully and systematically to comply with our supplier guidelines, including principles for sustainable business practices, which cover basic requirements for human rights, labor rights, anti-corruption, animal welfare and the environment. Our suppliers shall:

Comply with guidelines for suppliers, including principles for sustainable business practices.
Work actively with due diligence, i.e.: conduct our own risk assessments for negative impacts on people, society and the environment, and stop, prevent and reduce such impacts. The measures must be monitored and their effects assessed and communicated to those affected. Where the supplier is responsible for the negative impact/damage, the supplier is also responsible for restoration.
Show willingness and ability to continuously improve for people, society and the environment through cooperation.
At OCH's request, be able to document how they themselves, and any subcontractors, work to comply with the guidelines.
If the supplier, after repeated requests, does not show willingness or ability to comply with the guidelines for suppliers, the contract may be terminated.

Principles of Sustainable Business Practice (Code of Conduct)

These principles of sustainable business practices are based on UN and ILO conventions and set minimum and not maximum standards. The legislation at the production site shall be respected. Where national laws and regulations cover the same issue as these guidelines, the highest standard shall apply.

Forced labor/slave labor (ILO conventions no. 29 and 105)
1.1. There shall be no forced or compulsory labor, slave labor or involuntary work of any kind.
1.2. Workers shall not be required to submit a deposit or identity papers to the employer and shall be free to terminate the employment relationship with reasonable notice.

Trade union organization and collective bargaining (ILO conventions no. 87, 98, 135 and 154)
2.1. Workers shall, without exception, have the right to join or establish trade unions of their own choosing and to bargain collectively. The employer shall not interfere with, obstruct or oppose trade union organization or collective bargaining.
2.2. Trade union representatives shall not be discriminated against or prevented from carrying out their trade union work.
2.3. Where the right to free association and/or collective bargaining is restricted by law, the employer shall facilitate and not hinder alternative mechanisms for free and independent association and bargaining.

Child labor (UN Convention on the Rights of the Child, ILO Conventions No. 138, 182 and 79, ILO Recommendation No. 146)
3.1. The minimum age for workers shall not be less than 15 years and in line with the national minimum age for employment, or; minimum age for compulsory schooling, whichever is higher. If the local minimum age is set at 14 years in line with the exception in ILO Convention 138, this is acceptable.
3.2. New recruitment of child workers in violation of the above-mentioned minimum age shall not take place.
3.3. Children under 18 years of age shall not perform work that is detrimental to their health, safety or morals, including night work.
3.4. Action plans shall be established for the early elimination of child labor that is in violation of ILO Conventions 138 and 182. The action plans shall be documented and communicated to relevant personnel and other stakeholders. Support schemes shall be facilitated whereby children are given the opportunity for education until the child is no longer of school age.

Discrimination (ILO conventions no. 100 and 111 and the UN Convention on the Elimination of Discrimination against Women)4.1. There shall be no discrimination in employment, remuneration, training, promotion, termination or retirement on the basis of ethnicity, caste, religion, age, disability, gender, marital status, sexual orientation, trade union membership or political affiliation.
4.2. Protection shall be established against sexually intrusive, threatening, abusive or exploitative behavior, and against discrimination or dismissal on unfair grounds, such as marriage, pregnancy, parental status or HIV status.

Brutal treatment (Declaration of Human Rights/UDHR)

5.1. Physical abuse or punishment, or threat of physical abuse is prohibited. The same applies to sexual or other abuse and other forms of humiliation.

6. Health, safety and environment (ILO Convention No. 155 and Recommendation No. 164)

6.1. Efforts shall be made to ensure a safe and healthy working environment for workers. Hazardous chemicals and other substances shall be handled responsibly. Necessary measures shall be taken to prevent and minimize accidents and injuries to health as a result of, or related to, conditions in the workplace.
6.2. Workers shall receive regular and documented health and safety training. Health and safety training shall be repeated for newly hired and reassigned workers.
6.3. Workers shall have access to clean sanitary facilities and clean drinking water. If relevant, the employer shall also provide access to facilities for the safe storage of food.
6.4. If the employer provides accommodation, it shall be clean, safe, adequately ventilated and with access to clean sanitary facilities and clean drinking water.

Wages (ILO Convention No. 131)
7.1. Wages paid to workers for a normal working week shall at least be in line with national minimum wage regulations or industry standards, whichever is higher. Wages should always be sufficient to cover basic needs, including some savings.
7.2. Wage conditions and payment of wages shall be agreed in writing before work commences. The agreement must be understandable to the worker.
7.3. Deductions from wages as disciplinary action are not permitted.

Working hours (ILO conventions no. 1 and 14)
8.1. Working hours shall be in accordance with national laws or industry standards, and shall not exceed working hours in accordance with applicable international conventions. Normal working hours per week shall normally not exceed 48 hours.
8.2. Workers shall have at least one day off per 7 days.
8.3. Overtime shall be limited and voluntary. The recommended maximum overtime is 12 hours per week, i.e. a total working time of 60 hours per week. Exceptions to this may be accepted if regulated by a collective agreement or national law.
8.4. Workers shall always receive overtime pay for working hours in excess of normal working hours (see section 8.1 above), as a minimum in accordance with applicable laws.

Regular employment
9.1. Obligations to workers, in line with international conventions, national laws and regulations on regular employment shall not be circumvented through the use of short-term employment (such as the use of contract workers, casual workers and day workers), subcontractors or other employment relationships.
9.2. All workers are entitled to an employment contract in a language they understand.
9.3. Apprenticeship programs shall be clearly defined in terms of duration and content.

Marginalized populations
10.1. The production and use of natural resources shall not contribute to the destruction of the resource and income base of indigenous peoples or other marginalized population groups, for example by seizing large areas of land, irresponsible use of water or other natural resources on which the population groups depend.

Environment
11.1. Negative environmental impact shall be reduced throughout the value chain. In line with the precautionary principle, measures shall be implemented to continuously minimize emissions of greenhouse gases and local pollution, use of harmful chemicals, pesticides and to ensure sustainable resource extraction and management of water, sea, forest and land, and conservation of biodiversity.
11.2. National and international environmental legislation and regulations must be complied with and relevant emission permits must be obtained.

Corruption
12.1. All forms of bribery are unacceptable, such as the use of alternative channels to secure illegitimate private or work-related benefits for customers, agents, contractors, suppliers or their employees and public officials.

Animal welfare
13.1. Animal welfare shall be respected. Measures should be implemented to minimize negative impacts on the welfare of production animals and working animals.
13.2. National and international animal welfare legislation and regulations must be complied with.

Guidelines for ethical trade

The industry association Ortopeditekniske Virksomheters Landsforbund (OVL) has prepared common guidelines for ethical trade. As a member of OVL, Ortopediteknikk will ensure that the guidelines are followed throughout our business.

Corporate social responsibility of member companies -
ethical trade guidelines

The purpose of the guidelines for ethical trade is to ensure that members of OVL act in accordance with internationally recognized standards in relation to human rights, working conditions and environmental conditions. All member companies in OVL undertake to follow these rules.

The aim of the rules is not to reduce trade, but to help suppliers improve social and environmental standards. OVL requires that the member companies and their suppliers follow the standards and conditions described below:

The ILO's eight Basic Conventions Nos. 29, 87, 98, 100, 105, 111, 138 and 182.
UN Convention on the Rights of the Child, Article 32
All working life-related health and safety legislation in the country of production
Labor laws, including legislation on minimum wages and relevant social insurance schemes in the country of production

Human rights

Suppliers must respect human rights as defined by the UN.

Principles and rights in working conditions

National legislation

All legislation related to working conditions in the country where suppliers have activity must be followed and this defines the minimum requirements for working conditions. If national legislation sets higher requirements than those required by the ILO Convention or the UN Universal Declaration of Human Rights, then national legislation must be complied with.

Stop child labor

Child labor, as defined by the ILO, is not permitted. If child labor occurs, the supplier is responsible for the development of sustainable social and economic alternatives to child labor (for example education).

Elimination of forced labor

Use of forced or compulsory labor is not accepted.

Elimination of discrimination

Discrimination based on ethnicity, gender, religion, social background, disability, political opinion or sexual orientation shall not occur.

Brutal treatment

Physical abuse or punishment, or the threat of physical abuse is prohibited. The same applies to sexual or other abuse and other forms of humiliation.

Decent pay and working hours

Wages shall be paid on time and in full directly to the employee. The lowest acceptable salary corresponds to the minimum wage according to national legislation.
Weekly working hours must not exceed the legal limit and overtime pay must always be paid.

Regular hires

Obligations to workers, in line with international conventions, national laws and regulations on regular employment shall not be circumvented through the use of short-term employment (such as the use of contract workers, casual workers and day workers), subcontractors or other employment relationships.
All workers are entitled to an employment contract in a language they understand.
Apprenticeship programs shall be clearly defined in terms of duration and content.
Freedom of association and collective bargaining (ILO 87 and 98) In countries where freedom of association is restricted or under development, the supplier will ensure that the employee can meet with company management to discuss wages and working conditions without negative consequences.

Corruption

All forms of bribery are unacceptable, such as the use of alternative channels to secure illegitimate private or work-related benefits to customers, agents, contractors, suppliers or their employees as well as public servants / women.

Environment

The supplier will work to reduce energy and resource consumption as well as waste and emissions to the atmosphere, soil and water. Chemicals must be handled so that they do not harm people or the environment.

Marginalised populations

The production and use of natural resources shall not contribute to destroying the resource and income base for marginalized population groups.

Health and safety

The supplier must ensure a safe working environment that complies with international standards. Employees must be informed of health risks as a result of their work. All employees must have access to the use of appropriate safety equipment.

Animal welfare

General requirements for animal welfare (conditions and production nationally and internationally):
Breeding, living environment, transportation and killing must meet the requirements of Norwegian legislation for the species, or EU regulations and OIE guidelines when the species is not mentioned in Norwegian legislation. Alternatives to animal products must be considered and selected in the event of ethically unacceptable farming methods.

Management system at suppliers

Management system is central to the implementation of ethical guidelines. OVL's member companies emphasize the importance of the supplier having systems that support the implementation of these. The expectations are clarified by:

The supplier should appoint a person responsible, centrally in the organization, for the implementation of the ethical guidelines in its own business.
The supplier shall make the guidelines known in all relevant parts of its organization.
The supplier must obtain consent from OVL's member companies before production or parts of production are outsourced to a subcontractor / contractor where this has not been agreed in advance.
The supplier must be able to account for where goods ordered by OVL's member companies are produced.

Correspondence

The members of OVL must ensure that the supplier and relevant subcontractors comply with the rules in this document.

Ethical guidelines for the industry

Ethical guidelines for members of the National Association of Orthopedic Engineering Companies (OVL)

The members of the trade association OVL (Ortopeditekniske Virksomheters Landsforbund) are suppliers of orthopaedic aids. The industry aims to deliver high quality products and services and is concerned about the safety and quality of the products for users and patients.
The members shall comply with Norwegian laws and regulations and ensure that the requirements for good business practice are followed. Ethical guidelines are in addition to and go beyond applicable legislation. An action may therefore be legal, but still unethical.
Violations of the Code of Conduct must first be reported to the member in question and then, if necessary, to the OVL Board of Directors. Members who violate the Code of Conduct may be excluded in accordance with §2-4 of OVL's Articles of Association.

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Guidelines for suppliers

Adopted by the Board of Directors of OCH Ortopedi AS (OCH) 25. November 2020.

OCH works to have a sustainable business practice that respects people, society and the environment and we have therefore prepared guidelines for suppliers as a complement to our own policy.

In order to achieve a sustainable business practice, we want to work closely with our suppliers and business partners. Co-operation in the supply chain is a prerequisite for responsible business practices, and for meeting the UN Sustainable Development Goals.

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OCH ́s VISION

Leading activities in orthopedic aids

OCH ́s GOALS

OCH ortopedi AS shall, through:

OCH should: