NWG // SUSTAINABILITY STATEMENT
# Risk policy: Establishing guidelines for risk assessment and risk management, which includes both financial and non-financial risks.
The policies are in line with established ethical standards and act as support for the Group’ s employees in their decision making.
The risk of corruption and bribery is assessed as the greatest within the Group’ s sourcing operations in countries classified as high risk according to the Amfori BSCI definition, which includes China, Bangladesh, India, Vietnam and Egypt.
The policies apply to the Group’ s own operations and are applicable in all regions in which 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 are appropriate and aligned with the risks and needs of the business.
The policies are aligned 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. The Anti Corruption policy considers the UN Convention against Corruption( UNCAC, UN 127), although full compliance has not been verified. The Group plans to conduct a review to ensure that the policy is aligned with the requirements of the Convention going forward.
The New Wave Group’ s Board holds the ultimate responsibility for the policies and for managing impacts, risks and opportunities. Group Management is responsible for the development and revision of the policies. Group Management, together with the management of each respective subsidiary, is responsible for the implementation of the policies within the daily operations.
New Wave Group is a decentralized organization in which the Group’ s values constitute a common platform for governance and corporate culture. The values are established at Group level and form the foundation for the Group’ s policies, Codes of Conduct and leadership principles. The Managing Director of each subsidiary is responsible for establishing and implementing the Group’ s policies, values and applicable legislation in the daily operations, as well as for developing and promoting the corporate culture through active leadership and exemplary conduct. The corporate culture is continuously developed and strengthened through communication of values, internal guidelines, dialogue in management forums and the integration of the values into decisions, processes and practices. Evaluation of the corporate culture takes place through regular follow up within the Group’ s management and governance processes, including dialogue with subsidiary management teams and monitoring of compliance with the Group’ s policies. The results of these follow-ups are used to identify areas for improvement and, where necessary, to take action.
The policy 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. At present, no additional Group wide training sessions on the Group’ s policies are organized.
G1-2: Management of relationships with suppliers New Wave Group is committed to responsible and ethical sourcing. This means that the Group assesses suppliers’ potential impacts on human rights and the environment based on the supplier Codes of Conduct( Amfori BSCI and BEPI). More information on this is provided under S2-2: Processes for engaging with value chain workers about impacts, and S2-4: 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 action.
The Group has established a strong local presence in high risk countries through its sourcing offices, where its own employees engage in close dialogue with and regularly visit suppliers. This enables close collaboration with suppliers and continuous monitoring of production and payment flows, which reduces the risk of unethical business practices and improves communication and mutual understanding between suppliers and the Group.
As members of Amfori BSCI, New Wave Group is committed to adhering to the principles of responsible purchasing practices, including:
# Integration of responsible purchasing practices into the Group’ s strategy
# Long-term partnership with suppliers
# Production planning that enables suppliers to manage production without unreasonable demands
# Incorporation of sustainability considerations into design and product development
# Cost calculations and price negotiations shall be transparent and shall not compromise working conditions or wages
# Reasonable payment terms, clear contracts and adherence to agreed conditions
# Ensuring adequate competence among those working with purchasing
090 // ANNUAL REPORT