NWG // SUSTAINABILITY STATEMENT
G1-3, G1-4: Prevention and detection of corruption and bribery New Wave Group has instructions and procedures in place to manage and address suspected cases of corruption and bribery, for which the Group has zero tolerance. This work is supported by the Anti corruption policy and the Whistleblower policy, which are described under G1-1: Corporate culture and business conduct policies and corporate culture. More detailed information on the whistleblower portal and the procedures for managing and reporting cases is provided under S1-3: Processes to remediate negative impacts and channels for own workers to raise concerns.
Furthermore, preventive work against corruption and bribery is carried out within the supply chain through the implementation, auditing and follow up of supplier Codes of Conduct, as well as through the implementation of system support for traceability and transparency. The supplier Codes of Conduct are described under S2-1: Policies related to value chain workers.
Follow up is conducted through on site visits- primarily by personnel working at the Group’ s sourcing offices- as well as through inspections, preliminary assessments and regular audits by independent third parties. The independent audits are described in more detail under 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.
At present, no formal Group wide training on anti corruption and bribery is provided for the own workforce. To ensure that all individuals within New Wave Group are aware of the principles of the anti corruption policy, the Managing Director and management of each subsidiary are responsible for communicating the policy to all employees in a manner that ensures understanding of its content.
The Group’ s Board and Audit Committee possess the necessary competence to handle matters related to corruption and bribery. This competence is ensured through experience, internal guidelines and ongoing reporting, enabling effective governance and monitoring of associated risks.
New Wave Group’ s stakeholders are encouraged to report any concerns via their immediate manager, the anonymous whistleblower portal or other appropriate channels such as Group Management, the Legal Department, Internal Audit or the Sustainability Department. Each case is initially handled by the channel that received it for a preliminary assessment. Serious concerns are escalated to the parent company, for example through the respective subsidiary board meetings, directly to the Group’ s Legal Department or through sustainability reporting. The Audit Committee is kept informed by the Group’ s General Counsel regarding cases received from subsidiaries and through the whistleblower portal and decides on further handling and any reporting to the Board.
During 2025, New Wave Group was not subject to any convictions related to breaches of anti corruption or anti bribery legislation. The Group also did not become aware of any violations of its internal procedures or standards in these areas.
G1 MDR-T, MDR-M New Wave Group has a decentralized structure and has therefore not established any Group wide targets or quantitative metrics for responsible business conduct beyond the existing policies. Nor has the Group defined a level of ambition or indicators for evaluating progress. The Group is working to assess opportunities to develop relevant targets and indicators over the coming years that can support more consistent monitoring and governance of responsible business conduct at Group level.
Despite the absence of formal Group wide targets, the Group continuously monitors the effectiveness of policies and actions related to material impacts and risks through internal reports, department specific indicators and regular reviews by the Board, which enables the identification of areas for improvement and prioritization. The data has not been validated by any external party.
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