Transparency Act Report 2023

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