Whistleblowing and complaint mechanism At Kverneland Group, including KGON, it is essential that our employees, suppliers, and business partners can report potential and/or actual breaches of our policies, guiding documents, and values. To facilitate this, we have established a robust whistleblowing policy that outlines our procedures for the safe management of reports concerning breaches of our guidelines and harmful practices, both internally and with external partners. Our whistleblowing system, particu- larly for matters under the Transparency Act and other ESG-related issues, is accessible via the email address esg.transparency@kvernelandgroup.com. We encourage all stakeholders to use this channel to reach out with any concerns, questions, or suggestions regarding potential human rights violations within our operations or supply chain. We strictly prohibit any form of retaliation or intimidation against individuals who use the whistleblowing mechanism.
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3. Due Diligence of KGON Suppliers
3.1 Background
In 2024, KGON took further steps to strengthen its supply chain due diligence practices, in line with the requirements of the Norwegian Transparency Act (§4), which mandates companies to carry out and report on human rights due diligence. While we have long had policies in place to promote ethical conduct among suppliers, this year marked a move toward a more formalised and structured process. The focus was on improving how we identify, assess, and monitor risks related to human rights and decent working conditions within our supply chain. As part of this process, KGON began working with Prewave, an AI-driven risk monitoring platform. Prewave scans thousands of publicly available sources (such as media, social networks, reports from NGOs, and government records) to assess supply chain risks. It flags potential concerns such as child labour, forced labour, workplace safety issues, or discrimination connected to suppliers. Additionally, it enables for a more diligent risk assessment, based on industry and country risk, to be conducted for all our suppliers. By using Prewave, KGON aims to monitor supplier-specific risks more proactively and to rely less on static questionnaires and manual data collection. This new capability allows for earlier detection of risks and a more continuous approach to due diligence. Alongside Prewave, we launched a targeted supplier engagement effort to collect self-reported data through a structured questionnaire. This two-tiered system—external risk monitoring paired with direct input from suppliers—was designed to provide a more complete view of risk across our most critical supply relationships. We recognise that effective due diligence also requires engagement with affected stakeholders. Where relevant, KGON seeks to include worker voices and local community perspectives through dialogue with suppliers and civil society partners.
3.2 Method
KGON works with a global network of 662 suppliers (at time of writing), spanning a wide range of materials, components, services, and geographies. To focus our efforts, we applied a risk- based selection model to identify a subset of suppliers for assessment in 2024. The selection process was based on five main criteria: 1) Annual spend – suppliers with a spend of over kr4,7mil were prioritised 2) Operational dependency – focusing on suppliers that are integral to product delivery or cannot be easily replaced. 3) Geographic risk – considering country-level human rights indicators and governance risks. 4) Results of previous internal risk reviews – including supplier history and past performance. 5) Nature of goods supplied – giving attention to suppliers of raw materials and manufactured components, where labour risk is typically higher.
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