The Transparency Act

– account of our due diligence assessments

HomeKey AS

Company reg. no. 933 582 159 / Reporting period: Financial year 2025 / Published: 30.06.2026

1. About the business and its area of operations

HomeKey AS (company reg. no. 933 582 159) is a Norwegian technology company that is part of the Vergence group. The company develops and delivers an AI-based software platform for real estate agents and brokerage chains, covering the entire transaction process in residential property sales – from customer acquisition and marketing to the execution and follow-up of the property sale itself. The company has offices in Norway and the Netherlands. The CEO is Thomas Meyer. In 2025 the company had 10 employees.

HomeKey places strong emphasis on social responsibility and recognises its responsibility to respect and safeguard fundamental human rights and decent working conditions, both within its own operations and at our business partners and suppliers.

2. Policies and procedures

To address actual and potential adverse impacts on fundamental human rights and decent working conditions, HomeKey has established the following policies and procedures:

  • A code of ethics covering human rights and decent working conditions, which all employees are informed about.

  • The company focuses on applying clauses on human rights and decent working conditions in its dealings with suppliers and partners.

  • Responsibility for the work relating to the Transparency Act rests with the board of directors.

3. Due diligence assessment and findings

In accordance with the Transparency Act, HomeKey has carried out a due diligence assessment to identify and assess actual and potential adverse impacts on fundamental human rights and decent working conditions at our suppliers and business partners. The assessment involves identifying the severity and likelihood of violations within the industries and supplier tiers relevant to the company.

The company has no goods production of its own and is not dependent on subcontractors performing physical or labour-intensive work. The risk of violations of fundamental human rights and decent working conditions – such as child labour, forced labour and unacceptable working conditions – is therefore assessed as very low.

HomeKey’s supply chain consists mainly of a small number of large, established technology platforms – including for cloud services, payment solutions and advertising – that are used to deliver the company’s services. These providers are subject to their own extensive policies and reporting requirements on human rights and working conditions, and the adverse impact that could realistically arise through this part of the chain is limited. Through the work carried out so far, HomeKey has not identified any actual adverse impacts relating to its own operations or supply chain in 2025.

4. Measures

HomeKey has implemented, and plans to implement, the following measures to prevent and mitigate the risk of violations of human rights and decent working conditions:

  • Ensuring that ethical guidelines and principles are incorporated into contracts with suppliers and partners.

  • Where appropriate, obtaining information about suppliers’ own due diligence assessments.

  • Further measures include developing a digital whistleblowing channel with associated procedures for handling censurable conduct.

The expected result of the measures is increased transparency and a reduced risk of breaches of the code of ethics.

5. How to request information

Anyone has the right to request information about how HomeKey addresses actual and potential adverse impacts under the Transparency Act. Written enquiries can be submitted through the company’s contact form on the website www.homekey.ai or by email to post@homekey.ai. We respond to enquiries within a reasonable time, and no later than three weeks after the request has been received.