Transparency Act

The Transparency Act entered into force on 1 July 2022 and requires businesses to conduct due diligence assessments, account for these assessments, and provide information about the company's work in this regard. The purpose of the act is to promote increased focus on fundamental human rights and decent working conditions. Parts of the Wenaasgruppen's operations are covered by the scope of the act pursuant to sections §2 and §3.

Wenaasgruppen skal ha en høy etisk standard og forventer også at våre leverandører og samarbeidsparter etterlever de lover og regler som til enhver tid er gjeldende. Grunnleggende menneskerettigheter skal håndheves og ansatte skal ha anstendige arbeidsforhold.

The Wenaas Group's business areas mainly include investments in hotel properties and financial management.

The head office of Wenaasgruppen is located in Måndalen where administration is located. Suppliers to the companies covered by the Act are surveyed regardless of whether they are a supplier to a parent company or to a subsidiary.

Two of the Norwegian hotels are leased to external hotel operators. The management of the properties and the financial management is done from the Wenaasgruppen head office. The subsidiary Oslo Plaza Hotel AS operates the hotel on a management contract with Radisson Hotel Group. About 90% of all purchases are made through Gress-Gruppen - see attached link. The remaining suppliers are assessed in the same way as the Wenaasgruppen centrally.

https://www.gressgruppen.com/aktsomhetsvurderinger

The General Manager is generally responsible for following up the Transparency Act. The CFO in cooperation with the controller will ensure that due diligence assessments are carried out in the different parts of the company's business areas. Inquiries regarding the Transparency Act can be directed to firmapost@wenaasgruppen.no.

Wenaasgruppen has started the process of surveying our suppliers and partners. Our business associates will be classified as a supplier or business partner. Our business partners are judged overall not to pose a risk according to the assessments to be made under the Transparency Act. For our suppliers, a risk assessment is made down the supply chain. The identification and risk assessment of the suppliers will be carried out through a classification where each provider is given a score from 1-10, of which ten constitute a high risk. The overall risk assessments carried out have been based on the following criteria:

Industry

Service production

Geography

Type and size of supplier

Providers will be followed up with different measures depending on which risk category they are within. Suppliers with annual sales below NOK 100,000 are not assessed on the basis of materiality.

The Wenaas Group, using new suppliers and business partners, will conduct a due diligence assessment before signing the contract in accordance with its criteria. Suppliers and business partners who receive a high risk score must sign a declaration before entering into a contract certifying that they ensure basic human rights and decent working conditions for their employees and comply with the requirements of the Transparency Act. This will help to better control new suppliers and business partners as well as increase their awareness of human rights and decent working conditions. In addition, the Wenaas Group will review the lists of suppliers and business partners annually to ensure the quality of the follow-up. Based on the status of the survey, an assessment is made on what measures may need to be taken. Results of the survey are published on the website of the Wenaasgruppen by 30.6 each year.

The Wenaas Group has so far in its work on the Transparency Act for the year 2023/2025 have not uncovered actual violations of human rights or decent working conditions for our employees or for our suppliers and business partners. The Group's business relationships are mainly Norwegian suppliers within well-organized industries and local smaller companies. The Group has no major ongoing developments or renovations underway. Against this background, no further action has been taken with regard to the Transparency Act in 2025.