NOAH's report on due diligence assessment

This report covers the entire NOAH Group, including operating companies and subsidiaries. The report applies to the period 01.01.-31.12.2024.

We also refer to the sustainability report and NOAH's website for information on our business og the organization.

Anchoring the Transparency Act in the quality system

The purchasing manager and quality advisor organize the work with the Transparency Act in NOAH. This is an ongoing effort that encompasses the entire group. It is emphasized that the work with the Transparency Act should be included in our existing routines and work processes to the greatest extent possible.

The plan for implementing the Transparency Act was anchored in the board of NOAH AS on June 13.06.2022, XNUMX. A working group worked on several measures in the first two years, including: Revising the sustainability policy, incorporating the information obligation into the procedure for external communication, establishing a self-declaration for suppliers (formerly "Ethical guidelines for suppliers"), introducing separate points about the Transparency Act in the form for supplier audits, establishing a system for due diligence assessments and revising the checklist for new suppliers, contract templates and purchasing routines. Employees have been informed about the new requirements, both via the intranet and in general meetings. An external company assisted with mapping the most relevant human rights, and this overview has been used in the further work on due diligence assessments.

Notification channel

NOAH has integrated reporting under the Transparency Act into the same system as reporting under the Working Environment Act. This can be done, among other things, via our website, which can be used by employees, contractors or external parties. When reporting, we encourage you to fill in your contact information, but it is also possible to report anonymously. See more about this on our websites.

Due diligence assessments in own business

The NOAH Group has existing, good routines for health, safety and working conditions in its own operations, including:

• HSE manuals, safety instructions, personnel manual, ethical guidelines and quality system with procedures, tools for follow-up and documentation.
• NOAH AS and NOAH Solutions AS are certified according to ISO 9001 and ISO 14001, and are conformity assessed according to ISO 45001.
• Annual employee survey with topics such as competence, cohesion/collaboration, headroom, improvements, management, workload, HSE, well-being and motivation.
• Annual employee interviews with follow-up of the individual employee.
• Risk assessments at 1-3 year intervals, both at group level, location level and the individual workplace.
• Safety rounds with mapping of the physical working environment and safety.
• This week's HSE theme, some topics just for Langøya in NOAH Solutions AS and some for the entire group.
• Compliance assessments to verify that the quality system complies with framework conditions.
• System for deviations and suggestions for improvement, which is followed up by a quality and improvement committee.
• Audit group that carries out internal audits and supplier audits.
• Chemical rounds at all operating sites and a separate chemical committee at NOAH Solutions AS.
• Notification procedure and a notification committee.
• Working environment committee (AMU) in NOAH Solutions AS and Rekefjord Stone AS.
• 13 safety representatives, of which three are chief safety representatives.
• Several active trade unions.

In addition, there is an anti-corruption manual and a competition manual, and regular compliance courses with a lawyer are held. A course on compliance with competition rules was held in 2024.

The deviation system is actively used for deviations/unwanted incidents and improvement proposals. There is a low threshold for using the deviation system, and the system is actively used in improvement work. In 2024, there were 826 registrations in the deviation system (incidents, deviations, improvement proposals, operational observations and laboratory observations).

All personal injuries are followed up with root cause analyses, while for incidents with high risk potential, a learning meeting is held and a learning note is created and shared on the intranet.

There were no injuries to employees in Engadalen or at office locations. At the operating locations on Langøya and in Rekefjord there have unfortunately been personal injuries, with one lost-time injury and four injuries requiring medical treatment. This is a lower number of injuries than in 2023.

An investigation was conducted for the incident involving lost-time injury. An employee had his hand pinched while removing a crash barrier behind a storage rack. The employee suffered a pinch injury to his left wrist with a fracture, and had to have surgery on his wrist.

There were two incidents involving medical treatment among our own employees. On Langøya An employee got a possible chemical in the eye (was wearing safety glasses). The person was checked at the emergency room, and the eye has recovered. In Rekefjord, an employee got a small stone in the eye while using a sledgehammer (was wearing a mesh visor). The person received eye ointment from the doctor, and has recovered.

Two incidents of medical treatment were contracted/external on Langøya. An employee in the canteen kitchen cut his finger with a knife while preparing food. A hired worker was electrocuted while disconnecting a fiber connector and went to the emergency room to be checked for electrical current, but he was not injured.

The employee survey in spring 2024 showed very high levels of satisfaction and motivation, and there was good feedback on HSE. Employees particularly highlight the experience of mastery and interesting tasks as the most important thing for their own motivation, and many experience getting this in NOAH. There are variations in the working environment across departments, and work has been done on adapted measures in the different departments. Some areas of improvement that were common to several departments were collaboration across departments and the level of leadership in the organization. Only 64% stated that they had had a performance appraisal the previous year. At the end of 2024, a new personnel system was introduced, which will make it easier to conduct and follow up on performance appraisals.

Due diligence assessments for suppliers and other business partners

All suppliers are now entered into the Landax quality system. These are automatically transferred from the Visma financial system, and industry affiliation is transferred from the Brønnøysund register. Those who have not had deliveries in the last two years are set as inactive.

NOAH has 1473 suppliers who have delivered goods or services in the last two years, ranging from a small single delivery to suppliers that are critical to our business. Many of the suppliers we use most are large players, who are themselves covered by the Transparency Act.

In the supplier module, a rough analysis of most suppliers has been carried out. The rough analysis emphasizes factors such as country of origin, industry type and influence. Based on this, an overview is formed of the suppliers that need to be assessed more thoroughly. NOAH has chosen not to use a standardized questionnaire as part of the due diligence assessment, but the suppliers are further mapped through obtaining reports/information, dialogue and/or supplier audits. This is ongoing work. Follow-up of suppliers and the requirements of the Transparency Act is an important task for the procurement department.

In 2024, nine supplier audits were conducted.

The largest share of NOAH's suppliers is from Norway (92%), see figure. Priority is given to using local suppliers in the local communities where we are active.

At NOAH, we have assessed that it is our suppliers in the transport sector, both on land and at sea, that pose the greatest potential for negative impacts in terms of human rights and working conditions. This was highlighted in the 2022 human rights assessment. Companies in the transport sector compete on flexibility and rapid adaptability, which can result in strong pressure on workers, through reduced wages and poorer working conditions (rest breaks, working hours, overtime pay, access to facilities, etc.). The transport sector is particularly exposed to health and safety risks as a result of being a highly competitive industry.

The transport sector is a group for which we have good follow-up routines, both through supplier meetings, supplier audits and ongoing contact. On Langøya is an employee who follows up on drivers and their compliance with safety procedures, among other things. We have conducted supplier audits for several of our carriers in recent years. Labor conditions and human rights are topics for all supplier audits.

Other important supplier groups are contractors and craftsmen. Both on Langøya and in Rekefjord, hired contractors perform a large and important part of the production work, and also have some of the work operations that involve the highest risk, such as rock drilling, blasting and loading/unloading boats. Both contractors have access to NOAH's quality system. There are weekly collaboration meetings with the contractors, where HSE is on the agenda. The contractors conduct regular risk assessments and report if any undesirable incidents occur. Non-conformities that may affect safety are registered in NOAH's non-conformity system, and are followed up in collaboration with the supplier. The contractors are also followed up with regular supplier audits.

So far, no serious violations of human rights or decent working conditions have been identified, but some areas for improvement have been identified. Some suppliers have been identified as not following up on the Transparency Act. Some deficiencies/areas for improvement have also been identified within HSE and the external environment, for example within topics such as risk assessment, non-conformity management, waste management and performance management. All findings are followed up via our non-conformity system, in collaboration with the suppliers.

Goal achievement

Target period	Measurements	Goal achievement
2024	Clarify the role of supplier manager and ensure that all important suppliers have a dedicated supplier manager.	The role of supplier manager has been clarified in the purchasing procedure. Purchasing managers have held meetings in the various companies, where it was clarified who would be responsible for the various suppliers and assigned to Landax.
2024	Further work with the new procurement routines and implementation of changes.	The purchasing procedure has been revised and the process map of the purchasing process has been updated. A purchasing dashboard has been established that provides an overview of procedures, checklists, process maps and other relevant purchasing information.
2024	Improve the due diligence assessment system for new suppliers.	The checklist for approving new suppliers is now well implemented, and forms the basis for due diligence assessments for new suppliers. The due diligence assessments are documented in the Landax quality system.
Running	Ongoing rough analysis of new suppliers	Carried out on an ongoing basis for new suppliers, in connection with supplier approval.
Running	Reduce the number of suppliers	The checklist for approving new suppliers must indicate whether there are already approved suppliers that can be used instead. However, the number of suppliers has increased in the past year, as a result of the establishment of a new company and new investments/facilities.
Running	Due diligence assessment of suppliers, with particular focus on significant supplier groups	In the recent period, priority has been given to appointing supplier managers, implementing purchasing routines and conducting a thorough analysis of suppliers. Several prioritized suppliers have been subject to due diligence, but this is an ongoing work that will continue going forward.

Goals for the coming period

• Decide and implement updated purchasing strategy in the businesses.
• Consolidate multiple purchases from the same suppliers and reduce the number of suppliers.
• Ongoing rough analysis of new suppliers.
• Due diligence assessment of suppliers, with particular focus on significant supplier groups.

Questions regarding this report can be directed to purchasing manager Silvia Hjellestad Kolstad, email silvia.kolstad @ noah.no or mobile 936 20 183.