Instabee's Transparency Act Statement, FY 2024
This statement is published pursuant to Section 5 (§ 5) of the Norwegian Transparency Act (2021) and was approved by the Boards of Directors of Porterbuddy Norge AS, Porter AS and Instabox Norway AS on 14 May 2025, covers the period 2024.01.01-2024.12.31 and covers the Group's entire Norwegian operations, including the wholly owned companies Porterbuddy Norge AS, Porter AS and Instabox Norway AS.
Our structure, operations and human rights management systems
Instabee is a leading last-mile delivery provider, founded in 2022 through the consolidation of Budbee and Instabox, including its subsidiary Porterbuddy. We specialize in both home and parcel locker deliveries, with consumers across Europe and locations in Norway, Sweden, Finland, Denmark, and the Netherlands (Belgium serviced through the Dutch organization).
Within Norway, our delivery workforce consists of external contracted employees who utilise the Porterbuddy platform (contracted via Porterbuddy Norge AS), external drivers at courier companies, and internal drivers who drive under the Instabox brand (employed in Instabox Norway AS). Besides our drivers and terminal workers, we have a small office-based workforce based at our Oslo distribution terminal, where the tech team is employed in Porter AS and the rest in Instabox Norway AS.
Instabee is committed to assessing the human rights and sustainability implications of all our business decisions. We remain committed to respecting internationally recognized human rights, as set out in the 'International Bill of Human Rights' and in accordance with the 'UN Guiding Principles for Business and Human Rights'. Our business partner relationships are governed by our Code of Conduct for business partners. This includes specific references to respect for human rights and the prohibition of child and forced labor throughout any part of Instabee's own operations and business relationships. Furthermore, protections for non-discrimination, working conditions and occupational environment, health and safety are also included. Instabee maintains a right to information and audit to ensure compliance with the Code of Conduct and additionally maintains a right to terminate contracts with any business partner for violations of the Code of Conduct.
Instabee is committed to conducting human rights due diligence in accordance with the 'Norwegian Transparency Act' and 'OECD Guidelines for Multinational Enterprises'. This year's statement is based on the holistic assessment that was conducted in 2023, as well as interviews and analyses of improvements and changes since last year. We remain committed to continuous improvement across our own operations and throughout our business relationships.
Instabee's human rights due diligence
In 2023, Instabee conducted a human rights saliency assessment for our Norwegian operations to identify our most salient human rights to focus our due diligence efforts. This assessment reviewed risks associated with the core operational areas of our Norwegian operations and took note of the review from the previous year.
Since the nature of our business is fundamentally the same, we have had no reason to adjust the focus areas of our human rights due diligence efforts and have not identified any specific negative human rights impacts. The main focus areas of the work will remain:
- Health and safety
- Wages and hours
- Privacy rights
- Forced/Child labor
Additionally, a high-level review of our supply chain was conducted, mainly related to the sourcing of our boxes and cages.There was no or little material purchased in 2024 related to our Norwegian business, only transfers of material from the group. We are continuously working to improve transparency. Where potential risks are identified, we will continue to work to reduce our exposure.
Priority issues
For each priority issue, our aim is to stop or mitigate any actual or potential negative impact on people. We will regularly review our priority issues to ensure that we are tackling those most likely to severely negatively impact people.
Health and safety risk management
Our delivery operations involve intrinsic risks which may adversely impact our drivers, including risks stemming from operating vehicles and ensuring driver protection and well-being. Throughout the year of 2024, our drivers were either employed by our courier partners or platform workers using Porterbuddy's mobile platform. As mentioned in previous year, we have during 2024 transitioned towards a fully courier based model and as of November 2024, we no longer have any drivers using the platform.
With the courier model, the drivers are employed by an AS contracted by Instabox Norway AS. All courier partners sign our Code of Conduct, meaning we get increased possibilities to audit working conditions, reimbursement levels and health and safety related aspects for the drivers, as compared to having them on individual assignments as temporary workers. We are planning to conduct such audits during 2025 to ensure compliance. This will also bring transparency into if couriers are leveraging subcontractors, to better mitigate risks related to their respective safety and health.
In 2024, we further improved our internal health and safety management. All managers have conducted Health and Safety Environment (HSE) training and we are working in accordance with HSE targets and plans established in AMU (Working Environment Committee) in Instabox Norway AS. AMU conducted six meetings in 2024, but did not identify any major occupational health risks worth mentioning in the context of this statement. In 2024, we also continued a good collaboration with our occupational health service provider to support us in the above mentioned processes, and to take part in the AMU group's work.
Even though the above mentioned measures mainly target our own employees, we apply the same routines and principles when dealing with suppliers that perform work on our premises. When onboarding new colleagues employed by external partners, we give them access to basic training of our tools and processes. This training is continuously being improved.
Further, we conduct monthly employee pulse checks to follow-up on employee well-being related to e.g., satisfaction, stress, and psychological safety. Today this covers internal employees, but in 2025, we will look into the potential to also include external employees for better transparency on everyone’s well-being.
Hours and wages risk management
The cease of our Porterbuddy platform business model for drivers was an important step to mitigate potential negative risks impacting external drivers. In 2023, the Group Leadership Team in Instabee decided to phase out the platform model from our operating system and that process was completed during 2024. Drivers that previously had used the mobile platform were offered to apply for a position with one of our trusted courier partners. Thus, these individuals could keep their jobs, but under new contracting forms. In the past, we have also had on-call framework agreements (sometimes referred to as zero hour contracts) for some box routes but these have now been completely phased out in favor of the courier based model.
In our terminals, we have had a mix of employment forms; own employees; courier employees, and external contracted employees who utilise the Porterbuddy platform. In 2024, approximately 10-20% were employed by Instabox Norway AS whereas 80-90% were external. We continuously evaluate the Porterbuddy platform model for terminal staff but consider the associated risk to be lower than for drivers. This is because our site manager has greater visibility into the well-being of terminal staff, unlike drivers who spend most of their time on the road. Additionally, most Porterbuddy platform workers at the terminal have been with us for an extended period and are well-integrated into the team.
All employees, internal and external, and regardless of employment form, have access to a whistle blow channel to anonymously report any breaches to the Code of Conduct. This is easily accessible in the driver app that both drivers and terminal staff have.
Privacy and information security
Our operations as a delivery provider result in the handling of personal data, as defined under the General Data Protection Regulation (“GDPR”). The two main privacy risks arising from deliveries are: the use of drivers' data when performing routes, and the drivers' access to end-users' personal data. Said risks are relevant for all three Norwegian companies: Porterbuddy Norge AS, Porter AS and Instabox Norway AS.
Following Instabox and Budbee's combination, we launched a new unified driver app (i.e., the digital interface used by the drivers to perform deliveries) in Norway in May 2024. Drivers have access only to addresses and names of the end-users for home deliveries, whereas phone numbers are always hidden in the application. For locker deliveries, drivers only have access to the end-user's name in the application.
In addition, we make sure that drivers only have access to the end-user's personal data for the routes they perform. They receive their routes' summary the same day and can only access the end-user's limited personal data when a route has started. Once a route is completed, they no longer have access to any personal data that may have been included in such a route.
Instabee Group is ISO 27001 certified since 2023. We have implemented policies and procedures to effectively manage and protect Instabee's information, i.e., to ensure confidentiality, integrity, and availability of our information. Every year we conduct onboarding and yearly refresher training for our employees. To further strengthen our focus on this, we appointed a group-level Chief Information Security Officer (CISO) in 2024.
Drivers are supposed to go through training especially related to home deliveries, including the reading of relevant material and taking some tests. In 2024, we rolled out an updated driver training covering, among other things, privacy and data management.
Forced/child labor risk management
Our operations maintain a certain degree of risk related to forced and child labour, although we have not identified any cases of this. The inability to fully monitor any additional individuals present in an external driver's vehicle or fully ensure that it is the registered external driver who is fulfilling the delivery may lead to other individuals (potentially minors) being used to complete deliveries, resulting in either child labor or forced labour. Furthermore, general forced labor risks within the transport industry may lead to abuses in our value chain. These risks are mainly relevant for Porterbuddy Norge AS and Instabox Norway AS.
However, the transition to a courier based model for drivers where all partner companies have signed our Code of Conduct, gives us better control over our value chain and puts us in a better position to set clear demands. In 2025, we plan to do audits of couriers to make sure our Code of Conduct is adhered to and achieve better transparency of our value chain.
Next steps
No specific human rights violations were raised in the prior reporting period. Nevertheless, we remain committed to continuing to improve our policies and procedures as outlined above to continue to actively mitigate potential rights impacts. If any adverse human rights issues are identified either in our own operations or across our value chain, we are committed to communicating these impacts, seeking appropriate remedies for affected stakeholders, and updating our policies and procedures to avoid future negative impacts. The country manager (or the closest higher-ranking person) at Instabee is primarily responsible for this oversight.
Having conducted a saliency assessment to identify our salient human rights issues during this reporting period, we will work towards enhancing policies and management practices in relation to these risk areas in the year ahead. Creating specific action plans for each of these four issue areas will allow us to better manage these human rights risks across our operations.
Requests for information
Requests for information regarding this Transparency Act statement or Instabee's human rights due diligence policies and practices at large can be made to Erik Enfors , Country Manager Instabee Norway.
Signatories
Porterbuddy Norge AS Date: May 14, 2025
Porter AS Date: May 14, 2025
Instabox Norway AS Date: May 14, 2025
