Due Diligence Assessment Report (2023)

ZURHAAR

THE TRANSPARENCY ACT Statement of due diligence assessments for Zurhaar AS

ZURHAAR

The Transparency Act Statement of due diligence assessments by Zurhaar AS The Act on Business Transparency and Work with Basic Human Rights and Decent Working Conditions came into force on 1 July 2022.

The Transparency Act must promote businesses’ respect for basic information. In §§2 and 3 of the act, it is determined which types of businesses the act applies to, and Zurhaar AS is obliged by law to carry out due diligence assessments relating to suppliers and business relationships.

Section 4 of the Transparency Act requires us to carry out due diligence assessments with the aim of identifying actual and possible negative consequences for basic human rights and decent working conditions. In accordance with §5 of the Act, the results of the due diligence assessments must be made public through an annual report.

This report contains an overview of due diligence assessments Zurhaar AS has made up to 2024.

The purpose of the report is to be open about insight into key findings from the due diligence assessments.

The report has been processed and approved at the board meeting on 28 June 2024 Finn Atle Haldorsen Chairman

Rune Birkeland Board member and CEO

Ragnfrid Haldorsen Board member

Mette Zurhaar Board member

ZURHAAR

About Zurhaar AS Zurhaar AS is a group with significant activities in property, contracting and industry. Our head office is located in Nesttun, Norway. We operate globally with properties and industrial enterprises, including Sweden, Denmark, Poland, the USA and the UK. Sustainability is a natural driver for Zurhaar’s ownership and forms the basis of the group strategy, business philosophy and value base.

• • • •

Zurhaar must have a broad and comprehensive understanding of sustainability as an overall strategic driver Zurhaar shall develop the group, the people and the working environments with respect and equality, for the good of the individual and society Zurhaar will create lasting value and profitability in a long-term perspective Zurhaar must adhere to honest and healthy attitudes, based on high ethics and morals

Sustainability is the overall, strategic driver for Zurhaar and all branches of the group, which includes property, contractors and industry, both nationally and globally. All the companies in the group must be certified as EcoLighthouses (or equivalent) over the next few years.

The business philosophy of Zurhaar has been built up through our history and stands as a robust foundation for the development of the group. The value base contains the group’s values, and explains the framework within which the group and the group’s companies can operate.

Within our business philosophy, we have an ambition to strengthen and lead the employees and the company in a healthy and productive direction. Our philosophy is to continuously seek improvement in all aspects of the group’s operations.

Our business philosophy shall contribute to: • Seek optimal management of all resources: • Ensure that we manage all resources (materials/people/values) as favorably as possible • Make the right decisions Make decisions that contribute to creating the right, the best and the lasting solutions for the future and globally • Searching for holistic solutions Be opportunity- and solution-oriented in everything, with a holistic mindset at the bottom • Ensure open, transparent processes Work actively for openness, transparency and the fight against corruption in all blocks in the value chains

ZURHAAR

The Transparency Act Due diligence assessments (kilde: OECD Due Diligence Guidance for Responsible Business Conduct)

1: Embed responsible business conduct into policies & management systems 2: Identify & assess adverse impacts in operations, supply chains & business relationships 3: Cease, prevent or mitigate adverse impacts 4: Track implementation and results 5: Communicate how impacts are addressed 6: Provide for or cooperate in remediation when appropriate

ZURHAAR

1: Embed responsible business conduct into policies & management systems Zurhaar’s values are ​​ based on a fundamental respect for people and the environment. At Zurhaar and the group’s companies, we work for equality, trust and respect, within a business culture that is based on a positive and a good working environment. This guides our business conduct and how we relate to the people and environments we surround ourselves with, collaborate with, and how our operations are organised. Zurhaar must be a safe, robust and honest business partner and employer. We set high standards for ethical and moral business conduct and expect mutual trust and respect in employer relationships and in all forms of collaboration. At Zurhaar, quality and healthy business development are a prerequisite for operations. We must be proper, honest and fair in everything we do, and this must be reflected in our attitudes and actions.

Zurhaar must be a social actor who takes social responsibility, beyond what is expected. The group complies with society’s requirements, laws, rules and expectations, and expects the same attitude in all collaborations. Zurhaar has internally corresponding guidelines for conscious, clear, reasonable and enforceable business practices. Zurhaar takes human rights seriously, and works according to a business philosophy that emphasizes honesty, equality, zero tolerance for bullying, a good and healthy internal culture, and the development of people inside and outside the organisation.

Zurhaar guidelines The group’s strategy for ESG and social responsibility is laid down in a separate board resolution of 24 November 2022.

The Transparency Act is incorporated into relevant management documents and annual reports.

Our ethical guidelines lay down guidelines for how employees should behave both externally and internally. All the Norwegian companies were certified as Environmental Lighthouses in 2023, and at the same time a common HRM system was introduced through Simployer.

Areas of responsibility and distribution of tasks The CEO of Zurhaar AS has the overall responsibility for following up Zurhaar AS’s compliance with the Transparency Act, including the implementation and publication of due diligence assessments in accordance with §§4 and 5 of the Act. The individual contract manager must ensure that a sufficient due diligence assessment is carried out in accordance with the group’s routines for procurement.

ZURHAAR

2: Identify & assess adverse impacts in operations, supply chains & business relationships Mapping of the supply chain Zurhaar AS has updated its overview of suppliers and business partners that are relevant for reporting under the Transparency Act in our companies. The list consists of individual suppliers and suppliers with a framework agreement. In addition, a list of a selection of tenants has also been drawn up.

Delayed responses are registered continuously, but findings related to these will only be published in the next report.

In the event of very serious findings and a changed risk picture, the report will be updated outside of the annual update in June.

Method and mapping of risk The selection of suppliers and tenants is categorized according to the high-risk list of Anskaffelser.no, which defines industries with a high risk of violations of basic human and labor rights. Based on this, Zurhaar AS has assigned risks to the companies based on which consumer category they each belong to.

•

There is a high to medium risk of poor pay and working conditions as well as a lack of HSE in the supply chain associated with the purchase of IT hardware. This also applies to services within the operation and maintenance of properties, cleaning services, production of work clothes, travel (hotel and transport).

•

According to Swedwatch’s risk analysis of building materials and products, ventilation and electronics have the highest risk of violations of labor and human rights. The risk is very high for both products in raw material extraction, while electronics also have a very high risk in the production phase. The risk associated with ventilation products applies in particular to steel and iron ore from China and Brazil, bauxite, copper and zinc from China, India, Zambia and Chile, and electrical components and motors from China. The risks include illegal overtime, forced labour, dangerous workplaces and social dumping. With the development of smarter ventilation solutions, the use of electronic components increases, which leads to a higher risk of negative consequences in the value chain.

Several of the companies in the group are in the construction industry, which is known as a high risk industry and is one of nine industries in Norway that has a minimum wage to prevent underpayment of foreign labour.

•

Hiring labor is traditionally an additional risk linked to HSE on construction sites/facilities and the complex value chains for materials and products. After the regulations for the hiring of labor were tightened, the risk associated with hiring is considered to have been reduced.

•

The global value chains in the industry are characterized by poor traceability and little transparency. Based on information from the Directive for Administration and Financial Management (FDØ), the risk associated with various building materials is linked to which countries they are produced in and where the raw materials are sourced from. In general, metal has a high risk. Products containing metal should therefore be prioritized in further due diligence assessments until next year’s reporting.

In mapping the list of suppliers for 2023, 6 suppliers or business partners with a high risk were identified. The figure for medium risk was 6.

Suppliers with high/low/medium risk had only minor deviations, and are followed up more closely.

All significant suppliers are surveyed annually.

ZURHAAR

3: Cease prevent or mitigate adverse impacts Zurhaar AS operates in Norway, Sweden, Denmark, UK, Poland and the USA. In 2023, both the property division, Rubbhall AS, Hallmaker AS and O.B.Wiik AS were mapped.

For Zurhaar AS, the result of the investigations was that it was the purchase of IT hardware, electronics, ventilation, steel and work clothes that had the highest risk.

No other potential negative impact from our supply chain was identified.

The group’s purchasing routine requires that all new suppliers are assessed with regard to risk and must answer our questionnaire and self-declaration form before entering into a contract. In this way, we ensure compliance with the requirements of the Transparency Act before entering into a contract.

Available measures Which measures are suitable to counteract negative consequences for basic human rights and decent working conditions depends on whether the risk lies with the supplier or further down the value chain.

Possible measures are action plans, internal controls, audits, stricter contractual obligations and possible sanctions in case of breach of contract.

Dialogue and good cooperation with our suppliers is one of our most important measures to ensure a more responsible supply chain. Risk is best handled by the person closest to the risk. As a group, we rarely buy products directly from raw material producers or manufacturers, but rather through wholesalers or suppliers. In future updates to our due diligence assessments, we will include assessments of our suppliers’ own due diligence assessments, as they have the best knowledge of the risks in their own business and value chain. This will help to strengthen our own understanding of the risks and contribute to continuous improvement of our own routines and practices.

4: Track implementation and results Zurhaar AS knows most suppliers and partners through established cooperation over many years.

We have established a procurement routine in the group that lays down clear guidelines for which matters are important to focus on in a procurement process where assessments related to sustainability (ESG) are also defined.

In addition, the procurement routine requires follow-up by suppliers and partners.

If violations of human rights or basic standards for decent work are discovered by a supplier, business partner or subcontractor, or a significant risk of such violations, the group must be informed immediately and the necessary actions will be taken.

ZURHAAR

5: Communicate how impacts are addressed In line with the Transparency Act, Zurhaar AS carries out due diligence assessments for our own operations and supply chain. This must be published annually in a separate report.

We are obliged to respond to requests for information in relation to how Zurhaar AS works to ensure respect for human rights and decent working conditions in our supply chain.

Zurhaar AS shall publish the status of sustainability work and our potential and actual negative impact on people, the environment and society.

This is done today in the annual report, as well as in the Statement of Due Diligence Assessment.

6: Restoration or replacement where required If potential or actual breaches in the supply chain are discovered, Zurhaar AS will follow up through dialogue with the supplier and other relevant stakeholders.

Violations that are not addressed within a reasonable time and that are of a significant nature can lead to the termination of a contract.

This requirement is clearly communicated in “Zurhaar ethical guidelines - Suppliers”

Contact: For questions about this statement and the group’s approach to basic human rights and decent working conditions, contact us by e-mail: firmapost@zreiendom.no

Kilder: OECD Due Diligence Guidance for Responsible Business Conduct Anskaffelser.no - The high-risk list Anskaffelser.no – Risk analysis of building materials and products Forbrukertilsynet – The Transparency Act Lovdata - The Transparency Act Transparency International