3.5 Limitations & Future Directions
2024 is the first year for which we employ Prewave and our first cycle combining both automated risk screening and supplier self-assessment. As with any new system, there were challenges: • Some suppliers needed more time to understand and respond to the questionnaire. • Internal onboarding to Prewave took longer than expected. • Without complete historical data, trend analysis and benchmarking were limited. Despite these challenges, we see clear potential to scale and improve the process. In 2025, we plan to: • Increase supplier response rates through earlier communication and integration into procurement workflows. • Expand risk screening to a broader supplier group, particularly those involved in higher risk industries. • Provide clearer guidance and training materials for suppliers as well as our internal procurement team. • Continue integrating Prewave alerts into yearly supplier reviews.
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4. Measures, Actions, and Continuous Improvement
4.1 Mitigation
In 2024, KGON focused on strengthening its human rights due diligence process in line with §4 of the Norwegian Transparency Act. Our efforts centered on building a necessary foundation for future mitigation by improving our capacity to identify and monitor human rights risks across our supply chain. A key advancement during this reporting period was the implementation of Pre- wave, a digital risk monitoring platform designed to scan public data for potential ESG-related concerns, including labour violations, unsafe working conditions, or human rights breaches. The platform was deployed to monitor our top 65 prioritised suppliers and will serve as a key tool in our ability to assess and compare risk exposure across different supplier categories and geographies. This marks a shift away from a manual spend-based approach to a more detailed and responsive risk assessment process, consistent with OECD Guidelines on Responsible Business Conduct. While no new formal mitigation measures were implemented in 2024, the introduction of Prewave represents a step forward in how we track and understand supplier-specific risk. However, we acknowledge that risk identification alone does not meet the full due diligence obligation under the Transparency Act as mitigation and follow-up actions are essential components of this process. In the coming year, the platform will enable us to take more targeted actions, engage more effectively with suppliers, and begin developing supplier-specific mitigation plans where risks are identified.
4.2 Remediation & compensation
At the time of this report, KGON has not identified any confirmed instances of adverse impacts within the scope of the suppliers assessed This reflects the current findings based on available data but does not rule out the presence of hidden or unreported issues. Consequently, no remediation or compensation actions were triggered during the 2024 reporting period. None- theless, we have previously established internal protocols for handling such cases should they arise (see due diligence report 2023). These protocols are aligned with the UNGPs and include engagement with affected stakeholders, transparent communication, and support for corrective actions in collaboration with suppliers.
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