New Wave Group Annual Report 2025 2025 | Page 85

NWG // SUSTAINABILITY STATEMENT
Furthermore, the Group’ s Supplier Codes of Conduct establishes that suppliers are expected to implement effective grievance mechanisms and maintain appropriate records in line with Article 31 of the UN Guiding Principles( UNGP). Through confidential worker interviews, third party audits include assessments of workers’ awareness of these mechanisms and the credibility of the grievance mechanisms. This includes systems for handling grievances and detailed documentation of grievances and follow up actions.
To further support workers’ ability to raise concerns, New Wave Group collaborates with other organizations in sourcing regions. Amfori provides an external grievance mechanism for individuals or organizations, which is investigated by the Amfori Secretariat. Additionally, the RMG Sustainability Council( RSC) in Bangladesh offers a platform for reporting health and safety issues, which are investigated by the RSC.
The Group has not yet conducted separate assessments to determine whether value chain workers are aware of and trust these mechanisms.
Taking action on material impacts on value chain workers, and approaches to managing material risks and pursuing material opportunities related to value chain workers, and effectiveness of those actions The New Wave Group CSR and environmental policy describe the Group’ s commitments to responsible and ethical sourcing. This entails assessing suppliers’ potential impacts on human rights and the environment based on the supplier Codes of Conduct( Amfori BSCI and BEPI). Key central activities implemented at Group level are integrated into ongoing operations and carried out continuously; therefore, no specific end dates have been set. The activities focus on workers employed by direct suppliers, referred to as Tier 1 suppliers.
These activities are referred to as " actions ", although they do not meet the ESRS definition of an " action ". The Group intends to define more structured actions together with more developed targets going forward.
Actions:
# Criteria for new suppliers: The Group requires independent third party audits( Amfori BSCI or equivalent) for all suppliers located in high risk countries, as defined by Amfori BSCI.
# Supplier audits: Regular assessments of working conditions that comply with the Group’ s standards. This includes internal audits as well as independent third party audits. An Amfori audit is conducted by professional auditors accredited by SAAS( Social Accountability Accreditation Services). An Amfori audit results in an overall grade from A to F. The audit assesses both actual working conditions and the existence of management systems and procedures for systematic practices. In total, 13 sub areas corresponding to the requirements of the Codes of Conduct are evaluated. The most common rating is C, meaning that the supplier meets an acceptable standard. After the audit is completed, the supplier must submit a corrective action plan for each non conformity. Audits are carried out annually, or every two years if the supplier receives a B or A rating.
# Trainings: Suppliers are expected to participate in the training programs organized by Amfori, the International Accord, and MADE in Myanmar.
In cases of serious concerns or incidents, New Wave Group takes action and communicates with the supplier or its representatives in accordance with section S2-3: Processes to remediate negative impacts and channels for value chain workers to raise concerns.
The actions apply to the upstream value chain related to production and sourcing. They intend to provide suppliers with ethical standards that contribute to improved working conditions. The actions are also expected to mitigate related reputational risks for the Group and to support opportunities linked to responsible sourcing. Effectiveness is assessed through internal and independent audits, which result in measurable ratings and action plans.
The actions are ongoing and are integrated into New Wave Group’ s operations. Associated costs relate to annual fees for initiatives such as Amfori, the International Accord and MADE in Myanmar. These costs are not considered significant in relation to the Group’ s size and ordinary cost base. The measures are therefore implemented without requiring significant operating expenditure( OpEx) or capital expenditure( CapEx).
Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities As early as 2013, New Wave Group began measuring how many factories undergo independent audits each year. The purpose was to reduce negative impacts and manage material risks related to workers in the value chain through the implementation and follow up of ethical standards. In this way, the Group strengthens its due diligence processes and ensures that suppliers and partners respect human rights and international labor conventions.
The target set was that all factories in high risk countries( as defined by Amfori BSCI) should hold a valid independent audit with an approved rating, preferably higher( Amfori BSCI A, B or SA8000). An audit is generally valid for one year, or two years if the supplier has received a higher rating.
The target was formulated by the sustainability department, drawing on experience from global production markets and insights from audited suppliers and multi stakeholder initiatives such as Amfori BSCI. No additional stakeholders were consulted.
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