Transparency Act Report 2023

TRANSPARENCY ACT
REPORT 2023
Due diligence assessments for sustainable business practices
HAUGEN-GRUPPEN NORDIC
Established: 1916
Adress: Delitoppen 5, 1540 Vestby
NACE-Industry: 46.390 Non-specialised
wholesale of food and beverages
Employees: 282
Contact: Stig Kongsfjell

About us
Haugen-Gruppen was founded more than 100 years ago. Genuine passion & curiosity for food and beverage has led
us to work with brands from all over the world. We currently have a strong presence in Norway, Sweden, Denmark and
Finland. We supply supermarkets, service stations, canteens, cafes, gourmet restaurants and the Norwegian stateowned
wines and spirits retailer, Vinmonopolet.
Together, we build strong categories and develop new concepts. Naturally, we comply with international guidelines on
the environment and climate change, as well as ethical business practices. We also implement our own initiatives that go
beyond these.
This statement includes Haugen-Gruppen Norway, Haugen-Gruppen Sweden, Haugen-Gruppen Finland and Haugen-
Gruppen Denmark.
GUIDELINES FOR RESPONSIBLE BUSINESS CONDUCT
We are facing ever greater challenges related to climate, environment and sustainability, and our contribution from a
sustainability perspective is therefore also increasingly important. As a company, we want to continuously operate with
good measures throughout our value chain.
It is central to Haugen-Gruppen’s values that we act responsibly towards people and the planet, and hereby contribute
towards a sustainable future. Based on the UN’s sustainability goals, we have defined goals for where we can put in
greater effort and make a difference. These goals form the framework for our sustainability strategy.
Haugen-Gruppen has partners from all over the world and we want to be a positive catalyst and a driving force for
sustainability throughout the value chain for food and drinks. We welcome the Transparency Act that came into force
during the summer of 2022 welcome, as this will drive further measures linked to human rights and decent work.
Our dedication to ethical issues has led us to develop a comprehensive set of guidelines for our employees, vendors,
and partners. These guidelines are designed to ensure that our business operations have minimal negative impact on
environmental, social, and governance (ESG) matters.
Our set of guidelines includes:
• Code of Conduct for employees
• Code of Conduct for suppliers
• Whistleblower
• GDPR
Our Code of Conduct for Suppliers is based on the principles of Business Social Compliance Initiative (BSCI). It complies
with the International Labour Organization (ILO) and the U.N Declaration of Human Rights, the UN’s Conventions on
children’s rights and the elimination of all forms of discrimination against women, the UN Global Compact and the OECD
Guidelines for Multinational Enterprises. The BSCI also includes Anti-Bribery and Anti-corruption guidelines.
Methodology for due-diligence assessments
INTERNAL ASSESSMENTS AND BOARD ENDORSEMENT
Haugen-Gruppen is subject to the Transparency Act and, as such, is required to provide accounts of our due diligence
assessments. Our work with the Transparency Act starts with a thorough assessment within our organization and an
extensive review of our supplier network. Following this, we assess the risk of potential violations of fundamental human
rights and decent working conditions. This risk assessment includes evaluating both the severity and probability of any
identified risks.
The responsibility for the implementation and monitoring of compliance with these guidelines has been assigned to our
Chief Financial Officer.

INTERNAL EVALUATION
At Haugen-Gruppen, our commitment to responsible business conduct begins with an initial risk assessment. This
assessment serves as the foundation for our due diligence process. We have undertaken a comprehensive risk
assessment and identified high-risk areas, prioritizing them based on severity and likelihood. We have determined
that the product groups food and beverage are the primary areas for further assessment in 2023. This also reflects The
Norwegian Government Agency for Financial Management (DFØ) High Risk List.
SUPPLIER SURVEY
To ensure we have the most current information on our suppliers’ conditions, we utilize Factlines. Their software and
methodology are well-suited for supplier research, risk assessments, and documenting subsequent actions. Our due
diligence is informed by the findings from these investigations.
Haugen-Gruppen commits to an annual collection of data from our suppliers through self-assessments. These
assessments are designed to meet the UN Global Compact’s requirements and include inquiries about fundamental
human rights and decent work environments, adhering to OECD guidelines. The self-assessment encompasses the
following areas:
1. Corporate social responsibility, strategy, and guidelines
2. Supply chain: follow-up, insight, and control.
3. Risk and due diligence assessments
4. Country risk
5. Management systems in the company
6. Working conditions and rights
7. Ethnic groups and the environment
8. Conflict minerals
9. Anti-corruption
The risk-related information is incorporated within Factlines and guided by the International Trade Union
Confederation’s (ITUC) labor rights guidelines and Transparency International’s corruption index.
We have evaluated all significant suppliers against the high-risk list provided by the Norwegian Agency for Public and
Financial Management (DFØ).
Those matching the risk list have been included in this year’s due diligence data collection. The 2023 survey is
concentrated towards the food and beverage suppliers and suppliers that did not answer previous survey. Most of
these suppliers originate outside of the Nordics.
This data collection is pivotal for assessing risks within our supply chain, utilizing the latest information from our
suppliers. The survey lays the groundwork for subsequent follow-ups. Should the self-assessment or other indicators
reveal deviations, we promptly engage with the concerned supplier. The objective is to collaboratively prevent and
mitigate any negative outcomes.
Findings and results
SELF-ASSESSMENT OF HAUGEN-GRUPPEN
Haugen-Gruppen has conducted a self-assessment in Factlines with a sustainability score of 88/100. No violations of
human rights or decent working conditions have been found in our own business. Potential for improvement has been
identified in policies and guidelines. This is reflected under further work and measures.
SUPPLIER SURVEY
The survey we conducted in Factlines had a cumulative response rate of 31 %. As this year’s survey followed up
suppliers who did not answer last year this is an acceptable response rate. In addition, most of the suppliers originate
outside of the Nordics and have less experience answering these kinds of questions. Most of our suppliers score at low
to medium risk.

Name Recipients Response percent Risk score
Haugen-Gruppen Nordic Group 20 25% Low – medium risk
Haugen-Gruppen Norway 20 40% Low – Medium – High risk
Haugen-Gruppen Sweden 18 22% Low – High risk
Haugen-Gruppen Denmark 43 35% Low -medium risk
Haugen-Gruppen Finland 5 20% Low Risk
Based on the survey, one supplier reports a breach of ethical guidelines, we will contact the supplier in question.
There were no other actual negative consequences.
We have uncovered some common areas of improvement for our suppliers:
1. Lack of ethical guidelines
2. Lack of system, routines for risk assessment of suppliers.
3. Lack of system and routines to be able to check possible violations of human rights and anti-bribery policy.
4. Lack of system for measuring and following up on how they affect the environment.
There are also several of the suppliers who have not conducted their own due diligence assessments, and there is thus a
risk associated with a lack of information about their own subcontractors.
Further work and measures
We want to continue our work and get an even better overview of the risks that lie in our value chain. It is also important
to us that we constantly assess the need for policies and guidelines for our own business.
STATUS ON ONGOING MEASURES 2023 AND NEW MEASURES FOR 2024/25
Activity Start year Information Estimated date of
completion
Lack of ethical guidelines at suppliers 2022/23 We have followed up the suppliers in question for 2022/23 Continuous
Lack of policy addressing human-rights
at suppliers
Lack of routines for Due Diligence at
suppliers
2022/23 We have followed up the suppliers in question for 2022/23 Continuous
2022/23 We have followed up the suppliers in question for 2022/23 Continuous
Update our own ethical guidelines 2023/24 Update with information regarding conflict materials (RMI)
and respect for indigenous groups
Start using Factlines as a prequalification
tool
Look at internal recourses and
ownership of ESG matters incl. supplier
due diligence
2023/24 This will continue
End 2024
2023/24 End 2025
Implement an ESG policy 2023/24 End 2024
Follow up suppliers with High risk 2023/24 End 2024
Consolidate policies at group level 2023/24 End 2024
Vestby, 30th June 2024
The board Haugen-Gruppen Nordic AS
Haraldur R. Jónsson
Chairman of the board
Marino Marinosson
Board member