Report on due diligence June 2024

Introduction

Seltor Gruppen AS is one of Norway's oldest construction companies and is located in Porsgrunn, Tønsberg, Drammen and Oslo. We have the entire Eastern Norway region as our geographical catchment area. Seltor Gruppen AS is a group with a turnover in 2023 of approximately NOK 1.4 billion and 155 employees divided between Seltor AS and Seltor Bolig AS.
Seltor AS is a building and construction contractor, and has assignments in rehabilitation and new construction across central Eastern Norway. This results in a large and varied supplier portfolio within several industries. These include consultancy, technical assistance, subcontractors in building-related trades, recruitment, cleaning, operation and maintenance.
Seltor Bolig AS was established in 2011. Seltor Bolig AS is engaged in residential development in the central parts of Eastern Norway. The company manages all phases of residential development projects, from the purchase of land to the handover of a new home to the buyer.
Seltor Gruppen AS is subject to the Transparency Act and we are obliged to account for our due diligence.

1. General information, our policies and procedures

Our suppliers vary in size, from large national companies to smaller local suppliers.

Seltor is aware of the responsibility that comes with purchasing goods and services, and strives to be a serious and responsible player. We take a clear role and make demands on everyone involved in a procurement process. Seltor respects and supports fundamental human rights, as described in international conventions and Norwegian laws.

Seltor has anchored all aspects of the Transparency Act in Group management and the Board of Directors. Seltor shall be a driving force for compliance with human rights. This includes the Discrimination and Harassment Policy and our Code of Conduct, with an associated internal whistleblowing system. We work continuously to quality assure and anchor this in Seltor.

We take our obligations seriously and want to contribute to accountability within our industry, building and construction. We do this by having good routines for procurement and contract reviews, as well as developing measures in collaboration with suppliers and partners. All to ensure respect for basic human rights and decent working conditions.
Seltor has some focus areas where we believe we can have an impact:

• No discrimination against different groups of job seekers.
• Zero tolerance for any form of racism and discrimination.
• Discrimination is prohibited in all areas, including employment.
• There is a ban on child labor, forced labor and slavery.

Description of Factlines as a system and support for due diligence assessments

In our work with the Transparency Act and due diligence process, we use Factlines' digital solution and services. Factlines specializes in monitoring ethical, social and environmental requirements in the supply chain.

Seltor's business collects information from suppliers annually in the form of self-reporting. The questions in the self-reporting cover the requirements of the UN Global Compact, the suppliers' chain insight and monitoring practices, as well as their assessment of risks related to breaches of ethical guidelines in the relevant production countries. Seltor is qualified for the Factlines Transparency Act Verification Mark and has used Factlines software and methodology to monitor suppliers, conduct risk assessments and document follow-up activities.

In our work with the Transparency Act and the due diligence process, we use Factlines' digital solution and services. Factlines specializes in monitoring ethical, social and environmental requirements in the supply chain.
Seltor's operations annually collect information from suppliers in the form of self-reporting. The questions in the self-reporting cover the requirements of the UN Global Compact, the suppliers' chain insight and follow-up practices, as well as their assessment of the risk associated with breaches of ethical guidelines in the relevant production countries. Seltor is eligible for the Factlines Transparency Act Verification Mark and has used Factlines software and methodology to monitor suppliers, conduct risk assessments and document follow-up activities.

https://verified.factlines.com/no/915617344

If self-reporting or other indicators indicate deviations, these are followed up by contacting the supplier. Depending on the scope and risk, deviations may result in the creation of improvement projects to create changes in collaboration with the supplier and other players in the chain. Read more about Factlines here.

Mapping of suppliers

Mapping of suppliers
Every year we collect information from our suppliers through Factlines' software. The self-reporting is based on the UN Global Compact and the OECD Guidelines for Responsible Business Conduct and is in line with the due diligence process required by the Transparency Act.
The self-reporting includes the following topics

•  Corporate social responsibility, strategy and policies
• Supply chain: monitoring, insight and control
• Risk and due diligence assessments
• Land risk
• Management systems in the business
• Working conditions and rights
• Ethnic groups and the environment
• Conflict minerals
• Anti-corruption
• The data collection provides a basis for assessing whether good practices have been established to comply with the Transparency Act, Section 5 of the Public Procurement Act and the company's own contractual provisions. The survey applies to direct suppliers and manufacturers/production sites, and collects information about their routines and procedures for following up the entire supply chain.

The data collection provides a basis for assessing whether good practices have been established to comply with the Transparency Act, Section 5 of the Public Procurement Act and the company's own contractual provisions. The survey applies to direct suppliers and manufacturers/production sites, and collects information about their routines and procedures for following up the entire supply chain.

Information related to risks in production countries is based on several sources, including ITUC (The International Trade Union Confederation) on labor rights and Transparency International (corruption index).

Furthermore, conditions relating to labor rights, anti-corruption and whether the suppliers themselves have carried out self-reporting, improvement projects and/or inspections at the production site are mapped. We also assess whether suppliers have established routines for quality, health and safety, the environment and corporate social responsibility.

Our suppliers have been made aware of our Code of Conduct and must deliver goods and services that are produced in accordance with it. They are also required to communicate and follow up on the guidelines with their subcontractors.

If self-reporting or other indicators indicate deviations, these are followed up with the supplier in question. The purpose is to be able to prevent and reduce negative consequences in collaboration with the supplier and other actors in the supply chain.

2. Findings from due diligence and risk of negative consequences

The Transparency Act stipulates that all companies covered by the Act must carry out business assessments. Seltor has defined who we consider to be our business partners, and is in a continuous process of conducting business assessments of business partners, where risks are assessed. These assessments are part of the annual risk assessment.
The focus is on the areas where we are a moderate to major customer implicitly where we have influence. Our largest suppliers are in trades such as plumbing, electrical, ventilation, automation, groundwork, steel, concrete and carpentry.

Suppliers in technical disciplines, IT and technology, raw materials such as steel and wood, and clothing production are considered particularly vulnerable. These suppliers are considered particularly vulnerable due to the assumed high proportion of production in countries defined as high-risk countries in relation to human rights and the working environment. Information is requested on how they deal with actual and potential negative consequences in relation to the Transparency Act.

Source of illustration: Transparency International, CORRUPTION PERCEPTIONS INDEX 2023

3. Further work and measures

Actual negative consequences and the risk of negative consequences are revealed through the due diligence assessments. As of June 19, 2024, we have a response rate of 71%, in addition to 12% who are in ongoing processes in the survey for the financial year 2023.

Initiated measures:

In connection with our survey, reminders of measures are sent out to our suppliers based on the self-assessment submitted, including the establishment of internal ethical guidelines and distribution of these, ethical guidelines for suppliers, environmental systems, procedures for supplier follow-up, system for risk assessment of new suppliers, notification procedures, overview of producer countries. Suppliers and partners can submit responses and document measures at any time, so that the due diligence assessments do not become a static document, but a status in the present.

Planned measures:

Measures are directed towards the results of the survey Seltor has conducted. It is specifically in the areas of human rights, the environment and anti-corruption that we see the lowest scores. Through the survey, Seltor has access to routines for notifying suppliers at risk of working in individual areas that are not satisfactory. This is carried out regularly to ensure improvement.
Seltor will publish a "Report on business assessments" in accordance with the Transparency Act by June 30, 2024.
Inquiries related to Seltor's work with business assessments, cf. the Transparency Act, can be sent to endre.christiansen@seltor.no. Please mark the email with the Transparency Act.