Norrøna Sport AS policy for responsible business conduct (RBC)

Responsible business conduct (RBC) is an expectation for ourselves and all partners we do business with, including our ambassadors. Norrøna Sport actively supports The UN Sustainable Development Goals (SDGs) and works actively with the SDGs when defining our 2029 responsibility road map. Our RoadMap, together with this policy document (RBC) and the Code of Conduct guides the foundation of our sustainability work.

Aligning with the UN Guiding Principles on Business and Human Rights (UNGP) we commit that people have an inalienable right to be treated with dignity, human rights are inherent in all human beings, whatever their nationality, place of residence, sex, national or ethnic origin, colour, religion, language, or any other status, every individual is entitled to enjoy human rights without discrimination. These rights are all interrelated, interdependent and indivisible. Norrøna has a zero tolerance policy so any violation of these human rights must be corrected immediately with a solid plan towards compliance or Norrøna will be forced to cease cooperation with the breaching party.

As a member of Fair Wear, we commit to Fair Wear Code of Labour practices and standards, which will be used as a framework to identify human rights risk.

We will continuously update this policy when any material changes occur which affect how we are working with sustainability. This policy is endorsed and approved by senior management, and communicated to all Norrøna employees and suppliers, as well as the public through our website. While the principles outlined within this document are not exhaustive, these responsibilities and expectations are integrated into our business practice through a range of company policies. Critical for integration into our supply chain procedures is our Code of Conduct and the Human Rights Due Diligence Policy.

Norrøna Sport AS acknowledges that our business conduct can potentially have a negative impact on people, society, and the environment. Norrøna Sport AS will strive to be a source of positive change through active participation and engagement.

• We will be transparent and are responsible for the respect and well being of the people (society and environment) affected by our decisions and actions.
• We will annually assess our salient risks pertaining to countries of operation, the facilities we operate in and our products' impact on human rights and social welfare.
• Norrøna commits to transparently use a form of internal risk assessment through the Higg Index Brand & Retail Module to continuously improve our social and environmental strategies, processes and actions.
• Norrøna Sport AS will engage with organisations and/or collaborations which most effectively drive measurable improvements that reverse the damage and suffering our industry has caused.
• We see the potential to contribute to positive development in the supply chain.

With this in mind, we have compiled the following principles and criteria guiding our own business.

Norrøna Sports AS commits to conduct human rights due diligence ( HRDD) and work actively with OECD due diligence for responsible business conduct, including the OECD Due Diligence Guidance for Responsible Supply Chains in the Garment and Footwear Sector. We expect our suppliers and partners to follow the same approach.

• This involves routinely conducting human rights due diligence to prevent or mitigate actual and potential adverse human rights impacts and to remediate any findings, paying particular attention to the risk. A due diligence report will be made available on our web page to external stakeholders.
• Norrøna is committed to follow a gender-responsive due diligence process. This ensures that Norrøna will systematically consider gender when assessing risks.
• Engage and cooperate with other Fair Wear brands and non-member brands in risk identification, prevention, mitigation, and remediation.

Norrøna Sport AS considers responsible purchasing practices to be one of our most important tools for responsible business conduct.

Norrøna Sport AS shall adapt our purchasing practices in order to strengthen, and not undermine, our suppliers’ ability to deliver on our requirements related to people, society and the environment, using the principles of The Common Framework for Responsible Purchasing Practices. We strive towards lasting supplier relationships with suppliers who show a particular willingness and ability to create positive developments in the supply chain. Responsible purchasing practices at Norrøna strives to include:

• A certain percentage of goods are produced outside the peak season.
• Close dialogue with all our suppliers and manufacturers to gain the best possible production cycles per season.
• Long and reliable partnership.
• Fair prices for the product we purchase.

Norrøna aims to work with suppliers that share our ambitions and values regarding sustainability. We strive to maintain a long term relationship with our suppliers, based in a limited number of countries.

• In dialogue with suppliers we will consider, if needed, to contribute with capacity building or resources that enable our suppliers to comply with Norrøna Sport AS`s Code of Conduct and Fair Wear Code of Labour Practices, and help our partners to actively engage with Fair wear, the Higg Index FEM (facility environmental) & FSLM (facility social/labour), or other approved 3rd party social and labour verification, to ensure responsible business conduct on all levels in the value chain.This way we lay the foundation for collaboration with suppliers that show the willingness and ability to work on positive development for people, society, and the environment in the supply chain.
• We support the right to freedom of association and other forms of democratically elected worker representation. We are committed to support training to the workers in our supply chain, and we encourage our partners to include worker representatives in decision making.
• Norrøna is committed to engage in stakeholder engagement, and our focus will be on fortifying our relationships and connections with the workforce at the facilities we are working with, trade unions, Fair Wear and relevant organisations. Stakeholder engagement should be facilitated by Fair Wear, where possible, to reduce the burden on individual stakeholders.
• Norrøna is committed to establish collaboration with like-minded brands, particularly those within the Fair Wear membership, who operate in shared production locations. This collaboration allows us to combine our knowledge and expertise, amplifying our joint influence within these factories. Furthermore, we aim to streamline assessments and processes to avoid duplication and improve overall efficiency.

To ensure our employees feel their concerns and grievances can be communicated effectively and without fear of retaliation, we have multiple pipelines in place for employees to report issues both internally and externally. Annually we conduct an anonymous employee survey through Great Place to Work.

Normally, workers are encouraged to first inform their supervisor of concerns and grievances and the supervisor should escalate as necessary. If the employees feel uncomfortable raising the issue with the leader or his/her leader, other channels are available (i.e. employee representative, AMU, Legal, HR). The internal complaint mechanism allows the individual making the claim to remain anonymous. This also applies to the Norrøna factory.

As a Fair Wear member, we commit to abide by Fair Wear's complaint procedure when dealing with grievances raised through Fair Wear complaints helpline. Fair Wear’s complaint procedure gives workers access to remedy in the case of grievances. It allows workers, their representatives, including trade unions and civil society organisations, to present complaints about working conditions and violations of the Fair Wear Code of Labour Practices at factories supplying Fair Wear members. Norrøna also commits to following up on substantiated complaints raised through suppliers’ internal grievance mechanisms and other external grievance mechanisms. Norrøna's own factory is expected to follow this.

Norrøna Sport AS, including all employees, shall never offer or receive illegal or inappropriate monetary gifts or other remuneration to achieve private or business benefits in their own interest or in the interest of customers, agents, or suppliers.

Norrøna Sport AS anti-corruption policy states that we must never engage in any kind of corruption.

Corruption occurs when a person requests, receives or accepts an offer or an improper advantage or reward in connection with his or her position. As a general rule, an advantage is considered to be improper if it may influence the receiver’s ability to make sound, objective business decisions.

Since Norrøna is headquartered in Norway, we must all abide by Norwegian anti-corruption laws as well as the local laws effective in the countries where we operate. It is important to note that the provisions of Norwegian law affect both the person giving and the person receiving the improper advantage.

Norrøna Sport AS, including all our suppliers and partners, shall avoid trading with partners that have activities in countries where a trade boycott is imposed by the UN and/or Norwegian Government authorities.