The Transparency Act – Account of Jensen’s due diligence assessments

About the Business

Hilding Anders Norway AS produces the Jensen brand and is a significant player in the production and distribution of beds, mattresses, and accessories. We have chosen to Swan-label our beds to document our credibility in delivering products that are safe for both people and the environment, feature high quality, durability, and fantastic sleep comfort.

We anchor our responsibility in our values, as well as our quality and environmental policy. This means that we must, always, ensure that the products meet high quality standards and are produced under decent working conditions. All suppliers sign the group's Code of Conduct.

Through our work with due diligence assessments, we focus on uncovering any breaches of human rights and unethical working conditions, particularly in the parts of the value chain involving production and distribution. This includes assessing working conditions at suppliers and subcontractors, as well as ethical guidelines.

The goals we have set are:

• Everyone must have adopted ethical guidelines that at a minimum comply with the requirements of the UN Global Compact and corresponding ILO core conventions, and these must be made known to all employees, their trade partners, and suppliers.
• Establish a strategy for sustainability / social responsibility - no one is too small - everyone can do something.
• Suppliers that fall into the "high risk" category regarding the above will be immediately followed up with physical visits.

1. Business Area Through continuous product development and a focus on craftsmanship, innovation, and sleep comfort, we are one of Norway's best bed manufacturers. Through this work, we demonstrate that we take a clear social responsibility. This means that in addition to focusing on product quality and customer value, we also focus on how the products are made. We actively work to ensure responsible working conditions and respect for human rights throughout our value chain – from the procurement of raw materials to the finished product.

2. Employees and Organization Through systematic due diligence, we map and manage risks related to human rights and decent working conditions among our suppliers and partners. Our international presence reinforces the need for clear ethical guidelines and close follow-up, and we require that all links in the value chain comply with these standards. We view our social responsibility as an integrated part of the business and continuously work to contribute to more sustainable and responsible production – socially, environmentally, and ethically.

3. Geographic Presence Hilding Anders Norway AS is established with a factory in Svelvik, where all production has taken place since 1947. At the same time, the company operates internationally with suppliers and partners in 14 countries. This geographic presence provides access to a wide range of raw materials, while the company strives to use suppliers located as close as possible. The international supplier structure involves varying framework conditions and cultural differences, making systematic follow-up of non-Nordic suppliers in particular central to the work with due diligence assessments.

4. The Supply Chain The company has a total of 56 suppliers in its supply chain. Of these, 23 are assessed as low risk, while 33 are classified as medium risk based on geographical conditions, industry, and type of deliveries. The risk assessments form the basis for prioritizing follow-up measures and due diligence, to ensure responsible working conditions and compliance with human rights in the supply chain.

Methodology

The Transparency Act requires us to map and assess both actual and potential adverse impacts on human rights and working conditions, as well as implement measures to address these impacts. This work is important not only to comply with legislation but also to build trust among our stakeholders, including customers, employees, and suppliers. Through a thorough due diligence process, the foundation is laid for identifying areas of high, medium, and low risk. It is a systematic process to identify, assess, and manage actual and potential adverse impacts on human rights and decent working conditions. These assessments are important because they help ensure accountability at all stages of the value chain, as well as protect both human rights and working conditions. Hilding Anders Norway AS follows the OECD Guidelines for Multinational Enterprises, which provides a structured approach to due diligence through a six-step process.

We use Protencon.ai's digital tool for follow-up and implementation of due diligence in the supply chain. The tool is used for risk mapping, documentation, and systematic follow-up of suppliers in line with the requirements of the Transparency Act.

1. Integration In Hilding Anders Norway AS, responsibility for human rights and working conditions is anchored in our overall guidelines and management systems. This includes our ethical guidelines, which we communicate to all employees. The group's Code of Conduct is also anchored locally and complied with in line with our supplier strategy.

2. Mapping We have developed a process to identify and assess adverse impacts on human rights and working conditions. This includes a systematic mapping of our suppliers and their practices. We prioritize suppliers based on risk factors, such as geographic location and industry, and carry out thorough assessments of high-risk suppliers to uncover potential challenges.

3. Management When we identify risks, we implement measures to cease, prevent, or mitigate adverse impacts. This may involve entering into improvement agreements with suppliers or potentially offering training and resources to help them meet our standards. We actively work to develop processes that address specific arrangements and set clear goals for improvement.

4. Follow-up To ensure that the measures have the desired effect, we monitor implementation digitally but also conduct a handful of audits annually and report the results to management. In this way, we are also able to adjust our strategies and measures as needed.

5. Communication We communicate about our due diligence work both internally and externally. This transparency statement is an important part of our communication, where we account for our processes and measures. In addition, we share information about our progress and challenges with relevant stakeholders to maintain transparency and trust.

6. Remediation If we discover that our operations have caused or contributed to harm, we have procedures in place for remediation. We collaborate with affected parties to find solutions and ensure that necessary measures are implemented. This can include various forms of support to rectify the situation and prevent it from happening again.

Findings

The mapping of Hilding Anders Norway AS's suppliers was conducted using the digital solution from Protencon.ai. Protencon.ai provides access to external sources such as international reports on human rights and working conditions to strengthen our assessment. We follow up continuously throughout the year. This year, as in previous years, we will also select a handful of suppliers where we conduct physical visits / audits in relation to the answers they have provided. We have good experience with this, resulting in strengthened relationships. Despite having 56 suppliers spread across 14 countries, we have not identified specific high-risk areas requiring immediate attention.

Based on the results of our due diligence assessments, we see that we have not reached the goal that everyone has their own Code of Conduct in place, nor secured this with their subcontractors. We will follow this up continuously after the summer digitally and also conduct physical visits with one or more suppliers. The greatest risk as we see it, is textile manufacturers supplying household textiles, manufacturers of textile equipment, as well as other textiles used in bed production. This is often linked to suppliers and subcontractors being in Southern Europe, as well as in Asia. In these regions, there is a greater risk of violations of working conditions, rights, corruption, and modern slavery.

The findings also show that we have work to do regarding suppliers establishing a sustainability policy and strategy. We know that many are working on individual cases, but it remains to be more formalized, so that they can also work more purposefully in relation to strategy and measures / instruments. There is also a GAP regarding how overall policies and guidelines are communicated to employees.

Measures

As previously noted, we use various methods, including dialogue with suppliers, uploading of necessary documentation, and physical audits. When we audit a supplier against their signed Code of Conduct, we verify that they comply with our requirements for responsible business practices. This includes assessing working conditions, human rights, health and safety, environmental impact, and business ethics. We review documentation, conduct dialogue, and do what we believe is necessary to ensure that requirements are met and that any deviations are followed up with improvement measures. We will conduct a handful of audits throughout the year, as well as digital follow-up meetings.

For suppliers we see need assistance in formalizing their sustainability work, we will actively support them in developing this. We will clarify our expectations, share our own experience and practice, and provide guidance were useful. We will encourage the establishment of concrete goals and measures within environmental, social conditions, and business ethics, and follow up on this. The goal is to contribute to continuous improvement and increased maturity in the suppliers' social responsibility.

Information Requests

The Transparency Act gives anyone the right to request information from enterprises regarding how they address actual and potential adverse impacts on fundamental human rights and decent working conditions. This means that both individuals and organizations can send information requests to Hilding Anders Norway AS to gain insight into our due diligence and measures related to these issues.

Information requests can cover a variety of information, such as our routines for due diligence, identification of high-risk suppliers, and what measures we implement to prevent negative consequences. To submit an information request, one can use our official email address, which is provided on our website. We encourage inquiries to be clearly marked as information requests to ensure efficient processing.

When an information request is received, it is registered immediately, and we begin a thorough processing of the request. Hilding Anders Norway AS is obligated to respond within three weeks of receiving the request. In cases where there are special circumstances, the deadline can be extended to a maximum of two months. It is important to note that our duty to provide information may be limited by considerations of trade secrets and privacy, and we will clarify any such limitations in our response.

In the reporting period dating back to 2022, Hilding Anders Norway AS has never received any information requests. Our internal guidelines shall regardless ensure that our work complies and is in line with the law's requirements. We are committed to maintaining transparency and accountability, and we take all inquiries seriously to ensure that we comply with our obligations under the Transparency Act.

Group Relations

Hilding Anders Norway AS operates both as an independent company and is part of a corporate group. The Transparency Act is not currently part of EU regulations, therefore we who are subject to the Transparency Act have developed and implemented due diligence assessments tailored to our specific circumstances and needs.

The due diligence work is organized internally with a focus on identifying and managing potential human rights risks and decent working conditions in our value chain. At the same time, clear guidelines have been established by the group where all suppliers are obligated to sign the group's Code of Conduct, which sets clear requirements for compliance with applicable legislation, ethical guidelines, and responsible business practices. The requirements include, among other things, zero tolerance for corruption, respect for human rights and workers' rights, as well as requirements for health, environment, safety, and the external environment. Suppliers are also expected to ensure compliance further down their own supply chain and contribute to transparency and collaboration during follow-up and audits.