Transparency Act Report 2024

REPORTING YEAR 2024
TRANSPARENCY ACT STATEMENT
Due diligence assessments for sustainable business practices
HAUGEN-GRUPPEN NORDIC
Established: 1916
Adress: Delitoppen 5, 1540 Vestby
NACE-Industry: 46.390 Non-specialised
wholesale of food and beverages
Employees: 285
Contact: Stig Kongsfjell

About us
Haugen-Gruppen was founded over 100 years ago. Genuine passion and curiosity for food and beverages have led us to
collaborate with brands from all over the world. We currently have a strong presence in Norway, Sweden, Denmark, and
Finland, supplying supermarkets, service stations, canteens, cafes, restaurants, and the Norwegian state-owned wines
and spirits retailer, Vinmonopolet.
Together, we build robust categories and develop innovative concepts. We comply with international guidelines on
environmental and climate change, as well as ethical business practices.
This statement includes Haugen-Gruppen Norway, Haugen-Gruppen Sweden, Haugen-Gruppen Finland, and Haugen-
Gruppen Denmark.
GUIDELINES FOR RESPONSIBLE BUSINESS CONDUCT
We are encountering increasingly challenges related to climate, environment, and sustainability. Consequently, our
contributions from a sustainability perspective are becoming ever more crucial. As a company, we strive to continuously
implement effective measures throughout our value chain.
It is fundamental to Haugen-Gruppen’s values that we act responsibly towards both people and the planet, thereby
contributing to a sustainable future. Guided by the UN’s sustainability goals, we have identified areas where we can
intensify our efforts and make an impact.
Haugen-Gruppen has partners from all over the world and we want to contribute positively to sustainability throughout
the value chain for food and drinks.
We have developed guidelines for our employees and vendors. These guidelines are designed to ensure that our
business operations minimize negative impact on environmental, social, and governance (ESG) matters.
Our set of guidelines includes:
• Code of Conduct for employees
• Code of Conduct for suppliers
• Whistleblower
• GDPR
Our Code of Conduct for Suppliers is based on the principles of Business Social Compliance Initiative (BSCI). It aims to
comply with the International Labour Organization (ILO) and the U.N Declaration of Human Rights, the UN’s Conventions
on children’s rights and the elimination of discrimination against women, the UN Global Compact and the OECD
Guidelines for Multinational Enterprises. The BSCI also includes Anti-Bribery and Anti-corruption guidelines.
Methodology for due-diligence assessments
Haugen-Gruppen complies with the Transparency Act, which mandates us to report on our due diligence assessments.
This process involves conducting a self-assessment of our organization and subsequently reviewing our suppliers.
We assess the risk of potential violations of fundamental human rights and decent working conditions. This risk
assessment includes evaluating the severity and probability of any identified risks.
Guidance on risk industries is provided by the Norwegian Agency for Public and Financial Management (DFØ).
The risk-related information is incorporated within Factlines and guided by the International Trade Union
Confederation’s (ITUC) labor rights guidelines and Transparency International’s corruption index.

We utilize Factlines as a due diligence tool, their software and methodology are well-suited for supplier research, risk
assessments, and documenting subsequent actions. The assessments in Factlines are designed to meet the UN Global
Compact’s requirements and include inquiries about fundamental human rights and decent work environments,
adhering to OECD guidelines. The self-assessment encompasses the following areas:
1. Corporate social responsibility, strategy, and guidelines
2. Supply chain follow-up, insight, and control.
3. Risk and due diligence assessments
4. Country risk
5. Management systems in the company
6. Working conditions and rights
7. Ethnic groups and the environment
8. Conflict minerals
9. Anti-corruption
The responsibility for the implementation and monitoring of compliance with the Transparency Act has been assigned
to our Chief Financial Officer.
SELF-ASSESSMENT
To assess our own organization, we have answered the same self-assessment survey as our suppliers. This determines
our own high-risk areas and prioritizing them based on severity and likelihood.
SUPPLIER SURVEY
We have chosen to focus this year’s survey on suppliers who:
• did not respond to last year’s survey
• are new suppliers
• suppliers in selected industries
In addition, we included the results from 3 suppliers who responded after the deadline last year. In total, 16 suppliers
form the basis of 2024 Transparency Act statement. Most of these suppliers originate outside of the Nordics and all
are in the food industry which is considered a high-risk industry according to The Norwegian Government Agency for
Financial Management (DFØ) High Risk List.
In previous years, we created one survey per office, i.e. Haugen-Gruppen Norway, Haugen-Gruppen Sweden, etc. This
year, we have consolidated this into one data collection survey.
This data collection is pivotal for assessing risks within our supply chain, utilizing the latest information from our
suppliers. The survey lays the groundwork for subsequent follow-ups. Should the self-assessment or other indicators
reveal deviations, we engage with the concerned supplier. The objective is to collaboratively prevent and mitigate any
negative outcomes.
Findings and results
SELF-ASSESSMENT OF HAUGEN-GRUPPEN
Haugen-Gruppen has previously conducted a self-assessment in Factlines with a sustainability score of 87/100.
This year we updated our self-assessment due to updates on internal policies. This resulted in an increase of the
sustainability score to 92/1oo. No violations of human rights or decent working conditions have been found in our own
business.
SUPPLIER SURVEY
The survey we conducted in Factlines had a cumulative response rate of 46 %. This is an increase from last year, and
highlights our efforts on supplier engagement. Most of the suppliers originate outside of the Nordics and have less
experience answering these kinds of questions. The majority of our suppliers are scored with low risk. The cumulative
sustainability score for suppliers is 82/100. This is an indication that our suppliers work well with sustainability matters
such as governance, human rights, and environment.
One supplier was scored with a high risk, mainly due to lack of policies and assessment of suppliers. We will follow up
the supplier in question.

The other suppliers scored low risk for violation of human rights and decent working conditions and no actual negative
consequences have been revealed in the due diligence assessments.
However, we have uncovered some common areas of improvement for our suppliers:
1. Lack of whistleblower routines
2. Lack of supplier assessment routines
3. Working hours in accordance with national laws
Further work and measures
We want to continue our work and get an even better overview of the risks that lie in our value chain. It is also important
to us that we constantly assess the need for policies and guidelines for our own business.
STATUS AND MEASURES FOR 2024
Activity Start year Information Estimated date of
completion
SUPPLIER
Lack of ethical guidelines at suppliers 2022/23 We have followed up the suppliers in question for 2022/23 Complete
Lack of policy addressing human-rights
at suppliers
Lack of routines for Due Diligence at
suppliers
2022/23 We have followed up the suppliers in question for 2022/23 Complete
2022/23 We have followed up the suppliers in question for 2022/23 Complete
Follow up suppliers with High risk 2023/24 We have followed up the suppliers in question for 2023/24 Complete
INTERNAL
Start using Factlines as a prequalification
tool
Update group internal ethical
guidelines
2023/24 This will continue Continuous
2023/24 New ethical guidelines will be implemented Q2 2025
Implement an ESG policy 2023/24 This will be subject for 2025 End 2025
Consolidate policies and policies at the
group level
Look at internal recourses and
ownership of ESG matters incl. supplier
due diligence
2023/24 This will be subject for 2025 End 2025
2023/24 Sustainability and Quality Director is hired Complete

NEW MEASURES FOR 2025/26
Activity Start year Information Estimated date of
completion
SUPPLIER
Follow up supplier with High risk 2025 2025
Work with suppliers missing whistleblower
routines
Work with suppliers missing supplier
assessment routines
Work with suppliers regarding working
hours
INTERNAL
Implement an ESG policy
Establish and consolidate policies at
group level
Implement group internal ethical
guidelines
2025 2025
2025 2025
2025 2025
Transferred
from 23/24
measures
Transferred
from 23/24
measures
Transferred
from 23/24
measures
End 2025
End 2025
New ethical guidelines will be implemented Q2 2025
Vestby 25.06.2025
The board of Haugen-Gruppen Nordic AS
Haraldur R. Jónsson
Chairman of the board
Marino Marinosson
Board member