Transparency Act

The Norwegian Transparency Act entered into force on 1 July 2022 and requires businesses to carry out due diligence assessments, report on these assessments, and provide information about their related policies and practices.The purpose of the Act is to promote respect for fundamental human rights and decent working conditions throughout business operations and supply chains.Parts of Wenaasgruppen’s business activities fall within the scope of the Transparency Act pursuant to Sections 2 and 3 of the legislation. The Group is committed to conducting due diligence assessments and to working systematically to identify, prevent, mitigate, and account for actual and potential adverse impacts on human rights and working conditions.
Transparency Act

Wenaasgruppen is committed to maintaining high ethical standards and expects its suppliers and business partners to comply with all applicable laws and regulations. Respect for fundamental human rights and the provision of decent working conditions are essential principles throughout the Group’s operations and business relationships.

Wenaasgruppen’s activities primarily comprise investments in hotel real estate and asset management.

The Group’s head office is located in Måndalen, Norway, where its administrative functions are based. Suppliers to entities covered by the Transparency Act are assessed regardless of whether they provide services to the parent company or subsidiary companies.

Two of the Group’s Norwegian hotels are operated under lease agreements with external hotel operators. Property management and financial asset management are conducted from Wenaasgruppen’s head office. The subsidiary Oslo Plaza Hotel AS operates Radisson Blu Plaza Hotel Oslo under a management agreement with Radisson Hotel Group. Approximately 90 percent of all procurement is conducted through Gress Gruppen. Further information is available on Gress Gruppen’s website:

https://www.gressgruppen.com/accessibility-statement

The Chief Executive Officer holds overall responsibility for compliance with the Transparency Act. The Chief Financial Officer, together with the Group Controller, is responsible for ensuring that due diligence assessments are carried out across the Group’s business areas. Enquiries relating to the Transparency Act may be directed to firmapost@wenaasgruppen.no.

Due Diligence Assessments

Wenaasgruppen has initiated a process to map and assess its suppliers and business partners. Business relationships are classified either as suppliers or business partners.

Business partners are generally assessed as presenting limited risk within the scope of the Transparency Act. For suppliers, however, risk assessments are conducted throughout the supply chain. Suppliers are evaluated and classified using a risk-scoring model ranging from 1 to 10, where 10 represents the highest level of risk.

The overall risk assessments are based on the following criteria:

Industry sector

Service delivery and production activities

Geographic location

Supplier type and size

Suppliers are monitored and followed up through measures appropriate to their risk category. Suppliers with annual purchases below NOK 100,000 are generally not assessed from a materiality perspective.

Requirements for New Suppliers and Business Partners

Prior to entering into agreements with new suppliers or business partners, Wenaasgruppen conducts due diligence assessments based on the criteria outlined above.

Suppliers and business partners identified as high-risk are required, before contract execution, to sign a declaration confirming that they uphold fundamental human rights, provide decent working conditions for their employees, and comply with the requirements of the Norwegian Transparency Act.

These measures strengthen oversight of new business relationships while increasing awareness of human rights and working conditions throughout the value chain.

In addition, Wenaasgruppen performs an annual review of its suppliers and business partners to ensure adequate follow-up and compliance. Based on the findings of these assessments, the Group evaluates whether further measures are required.

The results of the annual due diligence assessment process are published on Wenaasgruppen’s website by 30 June each year.

Status of the Group’s Due Diligence Work

As part of its due diligence work for the 2024/2025 reporting period, Wenaasgruppen has not identified any actual violations of fundamental human rights or decent working conditions among its employees, suppliers, or business partners. The Group’s business relationships consist primarily of Norwegian suppliers operating within well-regulated industries, as well as local small and medium-sized enterprises. Wenaasgruppen currently has two major development and renovation projects underway, and larger contractors and suppliers are monitored and followed up in accordance with the requirements of the Transparency Act.