Norwegian Transparency Act

1. The Norwegian Transparency Act The Transparency Act is a shorter name for the “Act on Business Transparency and Work on Fundamental Human Rights and Decent Working Conditions,” which came into effect on July 1, 2022. The purpose of the law is to “promote companies’ respect for fundamental human rights and decent working conditions in connection with the production of goods and the provision of services, and to ensure public access to information on how companies address adverse impacts on fundamental human rights and decent working conditions.”

The law is based on the OECD Guidelines for Multinational Enterprises. These guidelines are recommendations from OECD countries to promote responsible business conduct across all sectors. They set expectations for companies regarding human rights, labor rights, the environment, taxation, anti-corruption, competition law, consumer interests, and transparency. The guidelines expect businesses to carry out risk assessments (due diligence assessments) and take measures to protect the environment, respect human rights, ensure labor rights, and avoid corruption in all its forms.

At Northcom Group, we are committed to being a responsible social actor and we welcome the Norwegian Transparency Act, taking the obligations that follow from this legislation seriously.

2. About Northcom and the Transparency Act Operations, Products and Services The Northcom Group consists of nine legal entities and approximately 150 employees, represented across 12 different locations in Norway, Denmark, Sweden, and Finland. We are a leading provider of critical communication solutions to industries such as police, defense, shipping, energy, offshore, emergency services, and private companies.

Our respect for human rights and decent working conditions is reflected in our Code of Conduct and is followed through regular employee surveys, covering topics such as work environment and employee well-being. If we suspect or uncover possible violations of human rights or decent working conditions, we will immediately implement the necessary measures.

The Norwegian Transparency Act motivates the group to work thoroughly and systematically with social responsibility. Northcom AS and its parent company Northcom Solutions AS (the combination of the two is hereinafter referred to as “Northcom” unless otherwise specified) are among the approximately 9,000 Norwegian companies covered by the Transparency Act. Potential adverse impacts on human rights and working conditions, as well as our efforts to prevent such impacts, are described below.

NORTHCOM Gjerdrums vei 4 | NO-0484 Oslo | Norway Telefon +47 215 55 600 | northcom.no | kundeservice@northcom.no

Equality, Diversity and Inclusion Northcom Norway and Northcom Solutions have a combined total of 36 employees, 33% of whom are women—an increase from 28% last year. Women make up 25% of the management team. The relatively low percentage of women, particularly in the technical department, aligns with the gender-divided educational and labor market for technical skills in Norway.

Based on frequent anonymous employee surveys, resignations, complaints, or reported concerns, there are no indications of discrimination.

However, Northcom acknowledges that discriminatory structures exist in society. We express our clear zero-tolerance policy on discrimination in our Code of Conduct and will continue to work to ensure awareness of equal treatment, diversity, and inclusion in our recruitment, leadership development, promotion, and salary processes.

Privacy Northcom’s products enable surveillance, which could be misused to violate privacy rights.

This lies outside of Northcom’s control, as we do not regulate customer use or authorize surveillance.

Northcom’s processing of personal data is limited to employees and representatives of customers. To ensure privacy rights are respected, Northcom is in the process of establishing improved structures and routines. A system owner role has been established, requiring each owner to define the need for personal data. This is managed within our quality management system and is monitored continuously and at least once annually by the system owner.

Health, Safety and Environment, Workplace Risks Everyone has the right to a safe working environment. At Northcom, safety risks exist for employees installing communication equipment in challenging locations. Risks are minimized through HSE routines, safety committee (AMU) meetings, including occupational health services, and training. Our track record indicates these measures are effective, with few incidents and no serious events in the past years. The risk is therefore considered low.

Freedom of Speech, Concerns and Whistleblowing Procedures Our frequent anonymous employee surveys, safety committee meetings (with and without occupational health services), and employee communication provide opportunities for staff to voice opinions and concerns. Northcom will continue to assess the need to establish formal whistleblowing procedures to further strengthen employees’ rights to raise issues that management must consider.

Supply Chain and Business Partners For over 40 years, Northcom has practiced responsible procurement and has solid experience in selecting suppliers based on criteria such as quality, delivery reliability, sustainability, and labor and human rights. We are aware that all trade involves different types of risk, and we strive for a simple and transparent supply chain.

While our main suppliers are primarily located in Europe, some have production in regions where human rights and working conditions are weaker. Northcom has therefore chosen to follow up a risk-based selection of our largest suppliers. While some of the assessed suppliers publicly commit to human rights and decent working conditions and explain their actions, others provide limited information, indicating a higher risk. These suppliers require more dialogue and additional measures such as audits or other control and reporting mechanisms.

Our shared group management system now enables us to monitor our suppliers in a more structured way than before. Recently, we have undertaken the following:

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Established a supplier group to manage and monitor compliance with legal requirements. This has strengthened collaboration with existing suppliers and ensured we work toward common goals in sustainability and responsibility.

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Developed evaluation criteria for assessing suppliers' ethical guidelines, working conditions, and environmental practices. Employee training and competence building are also prioritized to ensure the organization is well-equipped to meet transparency requirements.

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Sent inquiries to potential new suppliers to expand our network and ensure cooperation with partners who share our values. This helps uncover potential risks before entering a collaboration.

Through these efforts, we have raised supplier awareness about the importance of transparency, resulting in significant improvements in reporting and compliance with established criteria.

Summary Overall, our assessment is that the likelihood of Northcom causing negative impacts on human rights and working conditions is limited, but with room for improvement. Therefore, we have identified the following areas for further focus:

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Strengthening our guidelines and internal understanding of supplier risk management through dialogue, due diligence, and follow-up

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Enhancing dialogue with suppliers, particularly regarding subcontractors in the most vulnerable regions

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Ensuring initiatives to increase competence and awareness of equality, diversity, and inclusion

Conclusion The status of our efforts is promising and helps uncover potential hazards and risks among suppliers in vulnerable regions. We will continue to evaluate and improve our actions to ensure our supply chain remains robust and transparent in the face of future challenges.

* For document signed by the board; please see the Norwegian version of the Transparency Act