Transparency Act

Transparency Act Statement

1. Introduction

The Transparency Act, enacted by the Norwegian Parliament (Stortinget), entered into force on 1 July 2022. The purpose of the Act is to promote respect for fundamental human rights and decent working conditions in business operations and supply chains, while ensuring public access to relevant information. Pursuant to Section 5 of the Act (Act 2021-06-18-99), ANTIMA GROUP is required to publish an annual report on the due diligence assessments conducted under Section 4. This statement covers the financial year from 1 January 2024 to 31 December 2024.

2. Organization and Operational Areas

Established in 2015, ANTIMA GROUP primarily focuses on residential property development and has recently expanded into commercial real estate. The group’s head office is located in Marbella, Málaga. ANTIMA GROUP comprises 13 companies, having sold more than 30 luxury homes and developed a high-value commercial property asset. This report covers all companies within the group, whether or not they are individually subject to the Act.

While our primary operations are in Marbella, we have also developed interior projects in other parts of Spain and abroad.

Key business areas:

  • Property Development: Acquisition, renovation, and sale of properties, working with stakeholders such as builders, banks, suppliers, landscapers, local authorities, legal advisers, and real estate brokers.

  • Interior Design and Furniture Production: Interior design and styling services for group-developed villas and external projects. Furniture is sold both online and offline to strengthen the brand and reach potential buyers.

  • Property Maintenance: Services including cleaning, technical maintenance, pool and landscape care, and furniture upkeep for both group-developed and external properties.

  • Group Management and Administration: Engaging IT providers, marketing agencies, legal advisers, financial system suppliers, and office supply vendors.

  • Commercial Center Operations: Managing the operation and maintenance of a commercial center renovated by ANTIMA GROUP.

3. Due Diligence Approach

ANTIMA GROUP is committed to ensuring its activities do not negatively impact people, society, or the environment. Guided by national and international frameworks for responsible business conduct, as well as our internal Code of Conduct, our due diligence process includes:

  • Contributing positively to the local community and environment.

  • Promoting a healthy work environment and adhering to our Code of Conduct.

  • Maintaining strong relationships with authorities to support balanced and fair regulations.

  • Proactively identifying and addressing potential risks.

  • Avoiding negative impacts through our operations and partnerships.

Due diligence is integrated through our Business Partner Check, evaluating each supplier's administrative robustness, integrity, and regulatory compliance. While it is challenging to monitor every subcontractor’s operational performance, we establish strong contractual frameworks with our primary contractors to set clear expectations for responsible practices throughout the supply chain.

Risk-based assessments prioritize areas where negative impacts are most likely or severe. We leverage national tools like the National Institute of Statistics, real estate and wealth reports, banking analyses, and insights from trusted law firms such as PwC. Local regulations and recommendations from authorities and industry associations guide our activities on the ground.

4. Due Diligence Summary for 2024

Our core suppliers are construction-related contractors and subcontractors (electrical, plumbing, fire safety, insurance, waste management). Despite a large supplier base, a significant portion of our purchases is from fewer than 10 long-term, trusted suppliers with whom we have well-established agreements.

Most suppliers and partners are Spanish companies subject to the same laws and regulations as ANTIMA GROUP, lowering the inherent risks compared to sourcing from international markets. Occasionally, we purchase materials from reputable foreign brands, though this is uncommon.

5. Internal Risk Management

ANTIMA GROUP employs 36 staff members in Spain, mainly at the Marbella headquarters. We continuously work to improve employee working conditions and well-being:

  • We cultivate a diverse workplace and promote merit-based remuneration without discrimination.

  • Safety is paramount, with partnerships like Labour Risk Prevention ensuring compliance with health and safety standards.

  • We support physical and mental wellness through initiatives like Pilates classes and wellness sessions.

  • External advisers support our growth and development.

  • No serious workplace accidents or injuries have occurred since the group's founding.

6. Country and Market Risk Assessment

Our operations are primarily concentrated in Marbella, Costa del Sol. We also maintain minor activities in Belgium, the Netherlands, Sweden, Denmark, and Finland. Marbella’s real estate market is stable and well-regulated, with strong local and foreign investment and a commitment to security and maintenance. Overall, Spain and Costa del Sol present a low risk in terms of political, financial, and environmental stability.

7. Construction Site Risk Assessment

Each construction project has a designated Health and Safety Coordinator responsible for ensuring regulatory compliance. This role has the authority to request documentation and remove non-compliant teams from the site. Main contractors undergo thorough due diligence before contract signing, and contracts specify compliance requirements and necessary documentation.

8. Service Risk Assessment

Although our risk focus is on suppliers, we recognize the influence of our services on human rights and the environment. We offer maintenance services to clients to help prevent illegal employment practices in vulnerable sectors. Our construction managers maintain oversight of renovation and decoration work in our properties and commercial assets, ensuring compliance and responsible practices.

9. Challenges and Violations

No adverse impacts on human rights or working conditions were recorded in 2024. ANTIMA GROUP remains committed to protecting both the workforce and the local environment.

10. Ongoing Measures and Future Plans

Due diligence and risk assessment are integral to ANTIMA GROUP's values and daily operations. Our implemented measures include:

  • A comprehensive Code of Conduct outlining our due diligence processes.

  • Due Diligence Protocols for contractor engagement.

  • Contract clauses mandating regulatory compliance.

  • Appointed Health and Safety and Labor Risk Prevention coordinators.

  • Establishment of the ANTIMA FOUNDATION to support community and environmental initiatives.

Planned initiatives include:

  • Formalizing a whistleblower channel or Ombudsman role.

  • Strengthening the after-sales department to handle complaints and protect reputation.

  • Periodic review and updates to internal policies on ethics, social responsibility, and sustainability.

  • Formalizing supplier due diligence through a standardized Business Partner Check process.

Responsibility for these measures rests with operations and administrative leadership. Compliance with the Transparency Act is a priority throughout all levels of ANTIMA GROUP, ensuring awareness and vigilance across the organization.

In the event of identified violations, ANTIMA GROUP will take prompt action in line with the Transparency Act requirements.

11. Public Information Requests

Under Section 4 of the Transparency Act, ANTIMA GROUP is obligated to respond to public inquiries regarding the handling of actual and potential adverse impacts. In 2024, no such inquiries were received.