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Statement related to the Transparency Act

Introduction and purpose of the Act
The Transparency Act enters/entered into force on 1 July 2022. The Transparency Act can be
found here:
         - In English: https://lovdata.no/dokument/NLE/lov/2021-06-18-99
         - In Norwegian: https://lovdata.no/dokument/NL/lov/2021-06-18-99
The purpose of the Act is to promote enterprises' respect for fundamental human rights and
decent working conditions in connection with the production of goods and the provision of
services. Further, the Act ensures public access to information regarding how enterprises address




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adverse impacts on fundamental human rights and decent working conditions.
The Act builds on international procedure and consensus about the requirements for responsible
business conduct as well as Norwegian traditions of transparency and access to information.
Together with other measures, the legal requirement shall contribute to Norway’s work to meet
and comply with the UN’s Sustainable Development Goal no. 8 on decent work and economic
growth, as well as goal no. 12 on responsible consumption and production. The core of the law
entails the duty to perform and account for human rights due diligence assessments. Human
rights due diligence assessments mean that companies must identify possible negative
consequences for basic human rights and decent working conditions related to production and
supply chains, implement improvement measures, follow up and report.


About NetNordic
NetNordic is a system integrator delivering managed and professional, services and solutions to
medium and large sized companies with headquartered in the Nordic region, within both the
private and public sector. NetNordic is building and managing IT-Solutions for the future with
strong local regional presence within the business areas Security, Cloud, Network and
Collaboration. The goal is to be the most trusted partner within leading end-to-end digital
enablement and multi cloud & application, in the Nordic region. We want to help our customers
with their digital journey through the design, delivery and management of the next generation IT -
services and solutions. By using market-leading technology, together with our competent advisors
and highly certified IT consultants, NetNordic can help its customers to reach their business goals.
NetNordic – Our Commitment
NetNordic Group AS and its subsidiaries (The Company) are committed to comply with all
applicable laws and regulations in accordance with our Code of Conduct policy and governing
documents such as related policies, procedures and guidelines. The Company opposes modern
slavery and any form of human rights violations, including indecent working conditions associated
with the Company's supply chains.
The Company has implemented a set of governing documents to provide guidance and
instructions on the Company's compliance and commitment to the act relating to enterprises'
transparency and work on fundamental human rights and decent working conditions ("The
Transparency Act" or "The Act", NO: Åpenhetsloven).
The governing documents apply to the Company's subsidiaries and their employees worldwide.




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The Company shall make its best efforts to ensure the implementation of the related governing
documents and compliance with its majority owned companies.
The governing documents in the form of policies, procedures and guidelines will not purport to be
all-inclusive, and it is expected that all Company employees that are involved in processes directly
or indirectly linked to the requirements of the Transparency Act will make their own sound
judgement. Thus, the Company will commit to conduct training for all relevant employees.
The Company will commit to conduct due diligence of suppliers and other business partners under
the Act. Such due diligence will be conducted on a regular basis and be risk based, proportionate
and in accordance with UN's Guiding Principles for Business and Human Rights and the OECD
Procedure for Multinational Enterprises. The due diligence shall comprise the Company's suppliers
(and their sub-suppliers) and other business partners that supply goods or services directly to the
Company (that is not part of the supply chain). The requirements under the Act and the available
risk mitigating tools will, however, be different for the Company’s suppliers and sub-suppliers.
Direct purchases from suppliers that entail an inherent risk of human rights and labor abuse
require a more proactive and cautious approach from the Company in terms of background checks
and follow-up measures, such as audits. When sourcing indirectly through (lower risk) suppliers
that may have high-risk suppliers in their supply chain, the main mitigating tool is to address the
Company's expectations to the supplier through an agreement. Such agreement should include
obligations for the supplier to address, mitigate and report on human rights and labor rights risks
in the supplier's supply chain.
Examples of relevant risks that the Company should identify and mitigate under the Transparency
Act are: Child labor, discrimination, sexual harassment, and violence against women, forced labor,
occupational health and safety (e.g., worker related injury and ill health), violations of the right of
workers to establish or join a trade union and to bargain collectively, non-compliance with
minimum wage and the use of hazardous chemicals.
For the purposes of the Transparency Act, the Company's due diligence commitments mean to:
       a) Embed responsible business conduct into the Company's policies. The Company's Board
          sets the overall “tone from the top” and has the overall responsibility to ensure that the
          Company has in place adequate measures in relation to responsible business conduct. The
          Company's CEO is responsible for the day-to-day implementation of such measures. Thus,
          business ethics is a Board and management responsibility in the Company. Social
          sustainability and human rights are embedded in the Company's framework for
          responsible business.
       b) Identify and assess actual and potential adverse impacts on fundamental human rights and
          decent working conditions that the enterprise has either caused or contributed toward (or




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          that are directly linked with the enterprise's operations, products or services via the supply
          chain or business partners) c) Implement suitable measures to cease, prevent or mitigate
          adverse impacts based on the Company's prioritizations and assessments pursuant to (b).


NetNordic – What we do
The Company has and will continue to implement third-party risk management, several preventive
and mitigating measures in the supply chain. During 2024 the company has improved its routines
to ensure compliance with the law, including:
I.         Implemented the following updated governing documents for the Company: Code of
           Conduct Policy, Counterparty Management Policy, Sanctions and Export Control Policy,
           Anti-Corruption Policy, Third-Party Risk Management Procedure, Guideline for Supplier
           Code of Conduct.
II.        New onboarding procedure of new suppliers including background checks of medium and
           high-risk suppliers with subsequent follow-up actions and dialogue with suppliers.
III.       Ensure that new supplier contracts contain sufficient compliance clauses, including the
           company's expectations of the suppliers' working conditions and compliance program, the
           duty to inform about breaches and the company's right to carry out audits.
IV.        The "Supplier Code of Conduct" as an appendix to supplier contracts that ensures the
           suppliers' obligation to comply with the company's ethical guidelines.
V.         Regular risk assessment and audit of existing suppliers.
All employees in the Company, directly involved in purchasing goods, have been introduced to the
new onboarding procedure of new suppliers as well as Supplier Code of Conduct and standard
compliance clauses. The Company conducts annual employee surveys in which one of the targets
is to identify breaches of the company's ethical guidelines including fraud, human rights and
working conditions. During 2025, the company will continue the training of all employees to
ensure adequate awareness and knowledge of our ethical principles including human rights.
Several businesses omit or have insufficient descriptions of what discoveries they have made and
significant risks that have been uncovered. If due diligence finds no issues, the report should
reflect that the assessments were conducted. For several businesses, it may be the case that no
actual negative consequences are uncovered, but that the business is nevertheless exposed to
significant risk, e.g. in the supply chain. In such cases, it is important that these risks are disclosed.
The core of the law entails the duty to perform and account for human rights due diligence
assessments. Human rights due diligence assessments mean that companies must identify
possible negative consequences for basic human rights and decent working conditions related to
production and supply chains, implement improvement measures, follow up and report. The




                                                                                                             Penneo document key: 152S2-ZQR9G-5PKXK-BVKJ8-OVM65-2PCZW
Company has not identified any significant risks of negative consequences for basic human rights
and decent working conditions related to its supply chain in its assessments, audits and employee
surveys conducted in 2024.




                                        Lysaker, June 11th, 2025




    [navn skjult]                    [navn skjult]                         Marina Lønning
           Chair                        Board member                           Board member




      [navn skjult]                      Petri Kairinen                          Jarl Øverby
     Board member                       Board member                             Group CEO
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     ERIK AXEL HELGE HEILBORN                                                            [navn skjult]
     Underskriver                                                                        Underskriver
     On behalf of: [navn skjult]                                                         On behalf of: [navn skjult]
     Serial number: 024466ec76837a[…]3ff257dd56fa1                                        Serial number: no_bankid:9578-5995-4-124384
     IP: 81.227.xxx.xxx                                                                  IP: 172.225.xxx.xxx
     2025-06-13 11:43:53 UTC                                                             2025-06-13 11:50:12 UTC




     [navn skjult] F Holme                                                           Øverby, Jarl Henning




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     Underskriver                                                                        Underskriver
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     IP: 188.95.xxx.xxx                                                                  2025-06-13 13:06:27 UTC
     2025-06-13 12:18:45 UTC




     [navn skjult]                                                                      PETRI OLAVI KAIRINEN
     Underskriver                                                                        Underskriver
     On behalf of: Marina Lønning                                                        On behalf of: Petri Kairinen
     Serial number: d049d19c-4146-41d5-8c16-8ecc8ad22192                                 Serial number:
     IP: 212.10.xxx.xxx                                                                    _tupas:nordea:_8-ozFR3pt-ra0s4qVt7z_BrgdhnY8SGbEJbizWGW8E=
     2025-06-13 13:09:33 UTC                                                             IP: 89.27.xxx.xxx
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