NWG // SUSTAINABILITY STATEMENT
operations, as the assessment is that no part of the Group’ s own activities is at risk of such practices.
Besides the Corporate Governance policy, the identified impacts and risks related to the own workforce are considered in following policies:
# Whistleblower Policy: Establishes the commitment to ensuring that employees, shareholders, consultants, suppliers and other stakeholders have access to a safe and effective mechanism for reporting severe grievances. Protection against retaliation applies to all individuals submitting a report. Reported cases are handled through investigations and, where applicable, corrective actions.
# Risk policy: Defines guidelines for risk assessment and risk management, which include both financial and non financial risks.
The policies apply to all companies and employees within the Group, including various forms of temporary employment, and are applicable in all regions where the Group operates. The policies are subject to annual follow up, review and approval by the Board. During the review process, feedback and recommendations from key stakeholders, including internal departments and other relevant actors, are also considered to ensure that the policies remain effective and adopted with the risks and needs of the business.
The policies are in line with globally recognized frameworks such as the UN Guiding Principles on Business and Human Rights, the ILO Declaration on Fundamental Principles and Rights at Work, the OECD Guidelines for Multinational Enterprises and the UN Global Compact.
For information on procedures and measures for remediating potential human rights impacts, see S1-3: Processes to remediate negative impacts and channels for own workforce to raise concerns.
The Board of New Wave Group holds the ultimate responsibility for these policies and for the management of impacts, risks and opportunities. Group Management is responsible for the development and revision of the policies, with input from the Group’ s sustainability department. Group Management, together with the management teams of each subsidiary, is responsible for implementing the policies within the operations.
The policies is available on the intranet. The intranet is currently automatically accessible to all employees in subsidiaries whose IT systems fall under the Group’ s central IT department. Newly acquired companies are therefore, for example, not included in this automatic access. Employees without automatic access can be granted access upon request. New employees are informed about the policies as part of the onboarding process. The Whistleblower policy is also accessible on the Group’ s website.
Regarding company specific HR related guidelines, each subsidiary within the Group is responsible for establishing a local HR manual, which must comply with applicable local labor regulations and legislation and form part of the day to day routines maintained by each unit. Each subsidiary is also responsible for systematic health and safety management and for maintaining established procedures to prevent workplace accidents, in accordance with the legislation applicable in each respective country.
The Group currently does not have a Group-wide policy or management system for preventing workplace accidents, nor specific policy commitments related to inclusion or positive measures for groups within the own workforce that may be particularly vulnerable. However, the Group applies general principles of equal treatment, non discrimination and equal opportunities for all employees.
S1-2: Processes for engaging with own workers and workers’ representatives about impacts At Group level, dialogue and communication with the own workforce primarily take place through internal communication channels such as email and the intranet, and mainly concern Group wide guidelines, policies and matters related to working conditions and health and safety.
The overall responsibility for engaging in dialogue with employees and for managing actual and potential impacts on the Group’ s own workforce lies with the Managing Director / CEO of each company. Employees are encouraged to actively participate in dialogues and to provide feedback, suggestions and ideas for improvements. The Group strives to foster an inclusive corporate culture in which employees are given opportunities to express their views and be involved in matters affecting their working conditions.
Dialogue with the own workforce takes place on an ongoing basis through the following main channels:
# Internal communication: Through internal channels such as newsletters, the intranet and digital platforms, the companies continuously share updates related to the own workforce.
# Regular staff meetings: The companies hold recurring information meetings in which matters related to health and safety, working conditions and business development are discussed.
# Individual performance and development reviews: All employees are offered annual meetings with their immediate manager to discuss matters related to their work situation, working environment and skills development.
# Daily interaction: Informal check ins and continuous contact between managers and employees.
# Employee surveys: Several of the companies conduct annual employee surveys,( however, not at Group level).
These forms of dialogue serve as a contribution for identifying, preventing and managing actual and potential impacts on the Group’ s own workforce, including those parts of the workforce that may be more exposed to negative impacts.
The efficiency of the dialogue is assessed within the framework of the Group’ s regular management and employees’ processes. This includes feedback provided during individual
ANNUAL REPORT // 079