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Transparency Act<br />

ABOUT THE COMPANY<br />

Haugen-Gruppen was founded more than 100 years ago in Norway.<br />

Genuine passion & curiosity for food and beverage has led us to<br />

work with brands from all over the world. We currently have a strong<br />

presence, with subsidiaries in Norway, Sweden, Denmark and Finland.<br />

We supply supermarkets, service stations, canteens, cafes, restaurants<br />

and the Norwegian state-owned wines and spirits retailer,<br />

Vinmonopolet. Together, we build strong categories and develop new<br />

concepts. Naturally, we comply with international guidelines on the<br />

environment and climate change, as well as ethical business practices.<br />

We also implement our own initiatives that go beyond these.<br />

Description of guidelines and routines for dealing with actual and<br />

potential negative consequences for basic human rights and decent<br />

working conditions:<br />

We are facing ever greater challenges related to climate, environment<br />

and sustainability, and our contribution from a sustainability perspective<br />

is therefore also increasingly important. As a company, we want to<br />

continuously operate with good measures throughout our value chain.<br />

It is central to Haugen-Gruppen’s values that we act responsibly towards<br />

people and the planet, and hereby contribute towards a sustainable<br />

future. Based on the UN’s sustainability goals, we have defined<br />

goals for where we can put in greater effort and make a difference.<br />

These goals form the framework for our sustainability strategy.<br />

Haugen-Gruppen Nordic AS has partners from all over the world and<br />

we want to be a positive catalyst and a driving force for sustainability<br />

throughout the value chain for food and drinks. We welcome the<br />

Transparency Act that came into force during the summer of <strong>2022</strong> in<br />

Norway welcome, as this will drive further measures linked to human<br />

rights and decent work. Despite later implementation of the Act in the<br />

other Nordics market, Haugen-Gruppen Nordic has enabled an earlier<br />

implementation in its subsidiaries in Sweden, Denmark and Finland.<br />

The work with the Transparency Act is anchored in the local management<br />

in each subsidiary, and the CFO has been actively involved with<br />

the due diligence assessments. Together with an external adviser,<br />

we have reviewed our Nordic supply chain, and chosen to follow up<br />

our most critical suppliers, as well as those where we have defined<br />

the greatest risk because of their industry and market. The risk is<br />

assessed in relation to The Norwegian Agency for Public and Financial<br />

Management’s (DFØ) high-risk list.<br />

We have asked the selected suppliers to explain how they work<br />

according to several sustainability considerations and asked them to<br />

document this. This is done for suppliers who have business with<br />

Haugen-Gruppen Nordic AS or any of its subsidiaries in the Nordics.<br />

DISCOVERED ACTUAL AND POTENTIAL CONSEQUENCES<br />

No actual negative consequences were uncovered in our due<br />

diligence assessments.<br />

We have however uncovered some risks of negative consequences<br />

in our supply chain. This is mainly due to the nature of the industry<br />

we operate in, with both food and drinks being considered high risk<br />

industries by DFØ.<br />

We have uncovered risks associated with a lack of described ethical<br />

routines at some of our suppliers. There are also some of our suppliers<br />

who do not have specified requirements to their suppliers related to<br />

labor rights, human rights, the environment and/or anti-corruption.<br />

There are also several of our suppliers who have not carried out their<br />

own due diligence assessments, and there is therefore a risk linked<br />

to a lack of information about their sub-suppliers. We take these<br />

findings very seriously and will follow up these suppliers moving<br />

forward through our digital software tool, in order to lessen the risks<br />

in our supply chain.<br />

OUR MEASURES<br />

Moving forward, we will follow up with our suppliers and ask them to<br />

implement the described ethical routines, as well as to start their own<br />

due diligence assessments. We also want to expand our work going<br />

forward, and follow up with more suppliers, to get an even better<br />

overview of the risks inherent in our value chain.<br />

We have also created a whistleblowing channel where customers and<br />

other stakeholders can notify about any conditions.<br />

We expect that these measures will lead to a lower risk of negative<br />

consequences in our value chain, and also hope that our influence<br />

will lead to our suppliers following up on their own sub-suppliers,<br />

ensuring positive impact on our industry as a whole.<br />

Haraldur R. Jónsson<br />

Chairman<br />

Marino Marinosson<br />

CEO

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