Using this framework, 65 key suppliers were selected and onboarded to Prewave. This included our top 21 suppliers by spend, who together, account for 91% of our total procurement on products and raw materials. Two suppliers were included despite having a low annual spend (under MNOK 1) because they operate in higher-risk regions and warranted closer attention. The remaining 32 suppliers were included due to operational dependency and previously assessed suppliers. Of this, 28 suppliers were contacted to conduct the assessment. They received a structured questionnaire covering areas such as child and forced labour, working hours, wages, health and safety, non-discrimination, freedom of association, and the use of subcontractors. This combination of risk monitoring and supplier disclosure forms the core of our 2024 due diligence approach.
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3.3 Preliminary findings
Of the 28 suppliers contacted, 50% responded to the questionnaire. Respondents included both small and medium-to-large suppliers, with 36% classified as medium (50–499 employees) or large (500+ employees). These larger suppliers were asked to respond to an expanded set of questions focused on their internal human rights frameworks and due diligence processes. While this provides an initial data set, the response rate highlights a need to increase engage - ment and improve future participation rates. Across all responses, no supplier answered “no” to any of the risk-based questions asked. While this may indicate a shared baseline commitment to core human rights principles, self-reported data can carry limitations, and absence of negative responses should not be interpreted as absence of risk. Responses from the larger suppliers were particularly encouraging. Several shared internal policies on human rights, ethics, and workplace safety. These were aligned with internationally recognised frameworks, such as the UN Guiding Principles on Business and Human Rights or ISO 45001. Multiple confirmed previously conducted site audits in relation to human rights. In addition to the questionnaire responses, Prewave monitoring revealed no critical incidents among the prioritised suppliers during the 2024 period. No reports were flagged regarding human rights violations, labour disputes, or regulatory breaches in publicly available data. However, the absence of risk signals should be interpreted alongside the limited coverage of publicly reported issues in certain countries and sectors.
3.4 Risk Assessment
Our risk assessment for 2024 combined both self-reported data from the supplier questionnaire and external data from the Prewave platform. Each supplier was reviewed based on a combination of location, sector, response status, and ongoing monitoring results. Suppliers were categorised as follows: 1) Low risk: These suppliers either completed the questionnaire and reported full compliance, or they are based in countries with strong legal frameworks and Prewave detected no external red flags. 2) Moderate risk: This group includes suppliers that did not respond to the questionnaire or only partially completed it. Some are also based in regions where enforcement of labour and human rights protections is less consistent. While no specific incidents were identified, the lack of direct engagement limits our ability to verify practices. 3) High risk: No suppliers were classified as high risk in this cycle. However, this is not a conclusive finding given the partial response rate. Some suppliers may move into higher risk categories in future reviews if monitoring data or direct disclosures suggest otherwise. Results of the assessment show that no breaches of human rights were identified within the supply chain. However, based on the response rate, some risks may remain undetected, and the findings do not show conclusively that a risk does not exist. This reinforces the importance of improving supplier engagement and compliance in future cycles to gain a more complete and reliable picture of risk exposure across the supply base.
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