NWG // SUSTAINABILITY STATEMENT
performance and development reviews, discussions at staff meetings and the ongoing day to day interaction between managers and employees. The dialogue is considered efficient when the issues identified can be addressed and, where necessary, lead to concrete improvement measures related to, for example, health and safety, working conditions or work practices. No formal agreements have resulted from the dialogue, however, the dialogue is used as a basis for decisions and actions in the daily operations.
New Wave Group is aware that efforts to reduce carbon emissions and transition towards more climate neutral and sustainable operations may affect the workforce, particularly through an increased need for skills development. The Group provides training and competence building initiatives for certain employees, primarily within purchasing and product development, to strengthen relevant capabilities in preparation for this transition. No major restructuring or large scale training programs related to the transition have been initiated.
S1-3: Processes to remediate negative impacts and channels for own workforce to raise concerns New Wave Group strives to conduct its operations ethically, with high standards of integrity and accountability, and aims to foster a business culture in which everyone feels safe and encouraged to act against and report any grievances within the Group’ s operations.
The Managing Director of each company is responsible for implementing the legally mandated requirements and the Group’ s policies relating to the workforce, as well as for taking the necessary actions in cases where negative impacts on the workforce are identified.
The Group has channels through which its own employees and other internal and external stakeholders can raise concerns or complaints in accordance with the EU Whistleblower Directive( EU) 2019 / 1937. The Group’ s whistleblower portal enables the anonymous reporting of grievances. The portal is provided through the external online system IntegrityLog.
Reported cases are handled in accordance with the Group’ s whistleblower policy. Each report is managed by New Wave Group’ s Chief Legal Officer, who presents the case to the Audit Committee and provides a recommendation on how the matter should be processed. Decisions are taken by the Committee, which subsequently reports to the Board.
It is prohibited for New Wave Group and its employees to prevent or attempt to prevent reporting, as well as to retaliate against any individual who reports( or against their relatives or any other person connected to the reporting individual). The Group has, at present, not conducted assessments to determine whether individuals are aware of and have confidence in these mechanisms.
If it is established that the Group has contributed to or is linked to serious grievances affecting its own workforce, it is New Wave Group’ s ambition to provide appropriate remedies in the specific case. Each case is handled individually, which means that the form of remediation may vary between cases.
S1-4: Taking action on material impacts on own workforce, and approaches to managing material risks and pursuing material opportunities related to own workforce, and effectiveness of those actions During the reporting year, New Wave Group has not established any Group-wide targets related to its own workforce. The Group’ s HR and health and safety functions are decentralized, with responsibility assigned to each subsidiary. Consequently, material risks and opportunities concerning the own workforce are managed at the local level within each company, with responsibility for implementation, monitoring, and skills development delegated to the respective Managing Director.
Depending on the nature of the operations- for example office based work, warehousing, or manufacturing- specific risk assessments are conducted and action plans for occupational health and safety are established at the local level. These activities are tailored to the operational context and comply with applicable national legislation. In this statement, these actions are referred to as“ actions”, although they do not meet the definition of an“ action” under the ESRS.
The actions apply to employees within each respective subsidiary and are intended to increase their wellbeing. The implementation of the actions does not require significant operating expenditure( OpEx) or capital expenditure( CapEx).
Due to the Group’ s decentralized organizational structure, more specific and time bound measures have not been established at Group level. The Group does not plan to define Group wide, time bound measures, but instead prioritizes allowing each subsidiary to independently manage material impacts on its own workforce. This decentralized approach enables measures and resources to be tailored to local needs, the nature of the operations, and applicable legal requirements.
Simultaneously, certain central support structures and ambitions exist to harmonize processes, training, and skills development across the subsidiaries:
# To address rapid transitions and emerging competencies is training, skills development and knowledge sharing between subsidiaries essential. New Wave Group conducts training initiatives and organizes meetings to facilitate knowledge exchange, with a focus on specific tasks and areas of expertise.
# By striving to prioritize equality, consistent in conditions and safety standards, is the Group able to mitigate impacts and risks relayed to inequalities and variations as well as strengthen its position as an attractive employer in a sustainable global context.
In order to ensure that corrective actions of serious grievances are taken, the Group has a whistleblower policy and an associated whistleblower portal that enables individuals to report concerns anonymously. The process is described in more detail under S1-3: Processes to remediate negative impacts and channels for own workforce to raise concerns.
080 // ANNUAL REPORT