PHILIP MORRIS NORWAY AS AND PM TOBAKK NORGE AS TRANSPARENCY ACTSTATEMENT FOR 2023
This is an account of due diligence pursuant to section 4 of the Norwegian Act relating toenterprises’ transparency and work on fundamental human rights and decent working
conditions (Transparency Act or the Act) made in respect of Philip Morris Norway AS(hereinafter, PMN) and PM Tobakk Norge AS (hereinafter, PMT). This statement sets out thesteps taken by Philip Morris International (hereinafter, “PMI”) as a wider group to promoterespect for, and address adverse impacts on, fundamental human rights and decent working
conditions in its business and supply chains.
PMN and PMT submit this statement on behalf of themselves in respect of the period 1
January 2023 to 31 December 2023 (Reporting Period). This statement is based on andshould be read in conjunction with PMI 2023 Integrated Report1.
INTRODUCTION
PMI is a global company engaged in the manufacture and sale of smoke-free products andaccessories, as well as cigarettes, in around 180 markets. PMI is building a future based on
smoke-free products that, while not risk-free, are a much better choice than continuing tosmoke. PMI's ambition is to replace cigarettes with smoke-free products, to the benefit ofconsumers, society, the company, and its shareholders. PMI's smoke-free product portfolio
consists of heated tobacco, snus, nicotine pouches and vapour products. PMI operates 50
production facilities of which 16 are either partially or fully dedicated to the production ofheated tobacco units or oral nicotine products and has a diverse workforce of approximately
73,700 people worldwide.
PMI is committed to continually reviewing and improving its practices in order to take allappropriate steps both to reduce the risk of modern slavery and forced labour in all aspects of
PMI’s business and to promote respect for fundamental human rights and decent working
conditions. In this statement, the meaning of fundamental human rights and decent working
conditions is that defined in the Transparency Act.
PMI’S BUSINESS STRUCTURE, OPERATIONS & SUPPLY CHAIN
A. PMI’s Strategy
PMI is striving to become a company that has a net positive impact on shareholders,consumers, the environment and society as a whole. Such ambition starts with researching,developing, and commercializing less harmful alternatives to cigarettes for those adults whootherwise would continue to smoke, ultimately allowing us to phase out cigarettes and becomea fully smoke-free business. As a next step, PMI continues to explore the potential expansionof its offerings to include products that fill critical unmet needs within the wellness andhealthcare space. To achieve its purpose, a radical transformation of PMI’s business, of its
entire value chain, as well as of the way PMI engages with society is required: sustainability
stands at the core of this transformation.
PMI’s comprehensive strategy thus recognizes the need to address Environmental, Social,and Governance (ESG) issues related to PMI’s products and business operations. In thisregard, PMI must responsibly manage the impacts of the group’s operations throughout thevalue chain. While on the environmental front, this means tackling climate change andpreserving natural ecosystems, from a social standpoint, this includes ensuring fair treatment
1 PMI Integrated Report 2023 – accessible here

and empowerment of our employees and improving the lives of people across our supply
chain.
B. Business Structure
Philip Morris Norway AS (Company Number: 988 731 781) (PMN) is a Norwegian company,
with registered office at Dronningens gate 8A, 0152 Oslo.
Philip Morris Norway AS was founded in August 18, 2005 and is a subsidiary of Philip Morris
Switzerland Sarl. PMN’s business is the sale of tobacco products on the Norwegian market.
From December 1, 2010, PMN continued as a pure distributor, while Philip Morris Tobakk
Norge AS took the role of an importer. PMN is responsible for the distribution of some of PMI
brands in Norway. These include our combustible products brands of Marlboro, L&M,
Petterøes, Blue Master and Chesterfield, as well as our snus and nicotine pouches brands
Shiro and Kapten. PMN has ca. 21 employees in Norway.
PM Tobakk Norge AS (Company Number: 993 343 862) (PMT) is a Norwegian company, withregistered office at Dronningens gate 8A, 0152 Oslo.
PMT was founded in September 1, 2008, for the trade of tobacco brands. From December 1,
2010, PMT became responsible for importation of tobacco products into the Norwegian market
and for selling these to Philip Morris Norway AS. PMT is a fully owned subsidiary of Philip
Morris Investments BV, Netherlands.
C. Supply Chains
PMI’s supply chain connects the group with millions of people, from the farmers andfarmworkers who cultivate tobacco and other agricultural products to workers at the suppliercompanies that provide the products and services PMI needs to run the business, impacting
people’s assets, capabilities, opportunities, and standards of living.
This supply chain accounts for a significant portion of potential social and environmental risks
and opportunities. We are committed to collaborating with our value chain partners in
identifying and managing these risks and opportunities responsibly.
PMI’s global supply chain is organized into two main streams —direct spend (focused onmaterials used to manufacture finished products) and indirect spend (goods and services
necessary to operate the business).
PMT imports combustible products and smoke-free products. As a distributor, PMN procures
goods and services for the purpose of distributing these products to wholesale and retailcustomers.
RISKS OF ADVERSE IMPACTS ON FUNDAMENTAL HUMAN RIGHTS AND DECENT
WORKING CONDITIONS IN PMI’S OPERATIONS AND SUPPLY CHAINS
PMI aims to purchase goods and services from suppliers at best value, commensurate withbusiness requirements, while appropriately managing supply, financial, legal, quality, andsustainability requirements. As a group, PMI seeks continuously to identify and address
current and potential human rights risks while also seizing opportunities to create a positive
impact in the communities in which PMI and PMI’s suppliers operate, thereby increasing thesustainability performance of the entire supply chain.

From a sustainability standpoint, and with specific reference to fundamental human rights andmodern slavery, the supply chain areas potentially exposed to the highest sustainability risks
identified to date pertain to our direct spend and include:• Tobacco production, with the main risks associated with working conditions, childlabour, climate change, access to water, and the socioeconomic well-being of farming
communities;• Paper and pulp-based materials, with the main risks linked to deforestation,
biodiversity loss, and climate change• Electronics manufacturing, with the main risks relating to potential social issues on
ethical recruitment, working conditions of migrant workers, and working time.
PMI takes a risk-based approach to identify, prevent, and mitigate incidents related to humanrights and labour rights throughout our supply chain. For this undertaking, PMI collaborates
with key stakeholders — such as suppliers, farmers and farmer associations, civil society
organisations, academics, governments, and the private sector — to more effectively tackle
persistent and systemic issues in the supply chain.
As set out above, PMT is an importer and PMN is a distributor of the products manufactured
abroad by its affiliate entities and contract manufacturers. Below there is a summary of thestrategy developed by PMI to assess and address modern slavery risks throughout its value
chain worldwide. For further reference and more detailed information, please see the PMI
Integrated Report 202.2
ACTIONS TAKEN TO ASSESS AND ADDRESS IMPACTS ON FUNDAMENTAL HUMAN
RIGHTS AND DECENT WORKING CONDITIONS
A. Due diligence process and policy Framework
As part of the global PMI Group, PMN and PMT recognise that respecting human rights isfundamental to operating a sustainable global business.
As described in detail in the latest Human Rights Report 20233, PMI’s approach to humanrights is based on four pillars: (i) a sound policy framework, (ii) rigorous and continuous due
diligence, (iii) remediation - including through grievance mechanism channels, as describedfurther below - and (iv) transparency. In addition to that, PMI’s integration of sustainability andhuman rights into its strategy and activities relies on a formal governance structure, with clear
accountabilities at different levels of the organization.
PMI’s rigorous and continuous due diligence is based on a company-wide saliency mapping,firstly conducted in 2017 and then refreshed in 2020, to reflect changes in the business in thecontext of rapid transformation and heightened understanding of human rights. Like the 2017
mapping, the 2020 refresh focused on key groups of rightsholders: consumers, employees
and contractors, suppliers and supply chain workers, and communities.
Moreover, in relation to the pillar of transparency, PMI is committed to “disclose progress
about (its) work on (the) Human Rights Commitment, and the KPI (it is) using to assess (its)performance in (its) Sustainability Reports, published annually.” By reporting periodically on
progress through an annual, integrated report and targeted, thematic communication, PMI
enables external scrutiny, allowing stakeholders to assess PMI’s transformation, as well as
the work related to our social and environmental potential risks.

2
3

Phillip Morris International Inc. Integrated Report 2023 – accessible here
Human Rights Report – accessible here.

As such, PMI has developed a strong policy framework comprising a refreshed Human Rights
Commitment, PMI’s revised Code of Conduct4, Agricultural Labour Practices (ALP) Code5 aswell as the Responsible Sourcing Principles6 (RSPs). PMI’s policies, rules and procedures are
set ad applied globally within the wider PMI Group and the operationalized at local level. In
the Reporting Period, PMN and PMT continued to follow these existing policies and processes
to reduce the risk of adverse impacts on fundamental human rights and decent working
conditions in their operations and supply chains.
PMI’s key policies include:1.

Human Rights Commitment

At the end of 2022, PMI published a strengthened Human Rights Commitment whicharticulates PMI Group’s pledge to respect human rights in all its operations and business
relationships. It states that the PMI Group, which includes PMN and PMT, considers forced
labour or modern slavery to be unacceptable. PMI is committed to business practices that
respects internationally recognized human rights upholding the principles as enshrined in the
United Nations Guiding Principles on Business and Human Rights. PMI commits to respect
the International Bill of Human Rights and the International Labor Organization’s 1998
Declaration of Fundamental Rights and Principles at Work, and to endorse the OECD
Guidelines for Multinational Enterprises as well as the OECD Due Diligence Guidance for
Responsible Business Practices.
2.

Responsible Sourcing Principles

The way PMI works with its suppliers is grounded in the RSPs. The RSPs are aligned with
the UN Guiding Principles on Business and Human Rights (UNGPs) mentioned above, theUN Global Compact and the relevant International Labour Organisation Conventions. The
RSPs set out ambitions and expectations for PMI’s suppliers, including human and labour
rights considerations. In 2023, PMI deploys the updated version of its RSPs and related
Implementation guidance documents, enhancing the content and accounting for external
trends and anticipated regulatory developments. The updated version of the RSPs embeds
the results of PMI’s most recent sustainability materiality assessment and priorities andconsiders PMI’s progress in evolving and transforming its business model. Indeed, its scope
was broadened to incorporate additional relevant topics such as: environmental stewardship,
forest and biodiversity; responsible sourcing of minerals; scientific integrity and scientificengagement that will drive improvements in the sustainability performance of PMI’s suppliers.
With regards to decent working conditions, the current RSPs more specifically require
PMI’ssuppliers to:(a)not engage in or condone the use of forced or trafficked labour;(b)to be diligent in order to identify and address any form of modern slavery in theiroperations and supply chain, including prison, bonded, enslaved or any other formof forced labour;(c)arrange loans or salary advancements based on fair terms, clearly explained to theworker and mutually agreed;

4 PMI’s Code of Conduct – accessible here
5 Agricultural Labour Practices Code - accessible here
6 Responsible Sourcing Principles - accessible here(d)not retain or confiscate the personal papers of any worker including their passports;(e)

not allow workers to pay recruitment, processing or placement fees; and(f)agree with all workers on the terms of their employment in writing at the point of
recruitment.

In the Reporting Period, after releasing the updated version of the RSPs, PMI developed arobust roll-out plan to support deployment, focused on raising awareness and building
capabilities with relevant internal and external stakeholders. To ensure all PMI suppliers
comply with the RSPs, a strategic framework was developed, using a two-step approach,addressing significant suppliers through direct engagement and seeking their commitment toimplement mandatory requirements of the RSPs. . Further to this, adherence to PMI's RSPs
is built into PMI’s contractual agreements with suppliers. Suppliers’ performance andcompliance with the RSPs is monitored through self-declarations, online assessments, audits,
or inspections, and through the conduction of appropriate due diligence.
PMN and PMT retain the right to terminate the business relationship with the supplier in cases
where non-compliance cannot be remediated.
3.

Agricultural Labour Practices (ALP)

Since 2011, PMI has implemented the ALP programme aimed at eliminating child labour andother labour abuses, achieving safe and fair working conditions, and offering a decent
livelihood for all farmers in our tobacco leaf supply chain.
The ALP Code defines the labour practices, principles and standards we expect to be met by
all tobacco farmers which PMI or PMI’s suppliers have contracts with to grow tobacco. It has
seven principles (including no forced or child labour or human trafficking) and 33 measurable
standards. PMI’s internal Leaf team, tobacco suppliers, contracted farmers, and farmworkers
are regularly trained on the ALP Code.
PMI aims to deliver a set of targets to improve the socioeconomic well-being of tobaccofarming communities, including7:
1. 100 percent of contracted farmers supplying tobacco to PMI make a living income
by 2025;
2. Zero child labour in the tobacco supply chain by 2025;
3. 100 percent of tobacco farmworkers paid at least the minimum legal wage by 2022.
With specific reference to such last aspiration, in 2022, PMI continued to monitor the wagesof 100 percent of the contracted tobacco farmers who hire workers and confirmed retention of
the aspiration, with 99.8 percent of farmers paid their workers at least the minimum wage.
4.

Code of Conduct

Human rights considerations are included also within PMI’s Code of Conduct, which sets clear
standards and expectations and is closely aligned with PMI’s business transformation strategy
and industry best practices. Its mandatory provisions apply to all PMI employees, officers, anddirectors. Key risk areas addressed in this document include, but are not limited to, anti-bribery
7 Note that, in 2020 PMI delivered and reported on the achievement of two ALP targets: 1) 100 percent of tobacco

farmworkers provided with safe and decent accommodation and 2) 100 percent of farmers and workers having
access to personal protective equipment (PPE) for the application of crop protection agents (CPA), and preventionof green tobacco sickness (GTS) for all those working on tobacco.

and anti-corruption, anti-competitive practices, conflicts of interest, information protection
security and data privacy, responsible marketing and sales, scientific integrity, supply chain
responsibility, and workplace integrity, among others. Internal PMI policies provide more
specific guidance on these and other topics.
The PMI Code of Conduct is reviewed and updated annually.

B. Training and awareness raising focused on fundamental human rights andmodern slavery
Beside the policy framework, embedding an ethos of respect for human rights in PMI’s
corporate culture starts with awareness-raising and training and remains a core goal for thegroup.
For this, PMI globally developed a Business and Human Rights e-learning programme withthe aim to bring the ‘Human Rights Commitment’ to life by giving all employees a clear
understanding of what human rights are, how they relate to the business, to each employee
and the wider value chain, and their role in helping to safeguard them. This e-learning isavailable in multiple languages to facilitate its accessibility and increase the number ofcolleagues across global operations who can learn about human rights and PMI’s updated
Commitment in 2023.
Additionally, under the PMI Code of Conduct, the Compliance team launched a series of six
e/learning courses (available in 31 languages) in 2023, to build understanding andcommitment around key areas of ethics and compliance within PMI. In 2023, 86,4% of PMI
employees received these trainings, supplemented by regional and local compliance officers
in person training sessions to address compliance risk topics to the respective region(s) andmarket(s). These areas include human rights considerations and the PMI business policy.
Moreover, beside a dedicated training on the RSPs fundamentals accessible to all PMI
employees and mandatory for relevant functions having regular interaction with suppliers, atthe end of 2023 additional advanced training was also developed and launched to deep diveon key principles, case studies, roles and responsibilities, and the six steps due diligenceframework in line with UNGPs.
ASSESSING THE EFFECTIVENESS OF PMI’S ACTIONSHuman rights risks are incorporated into our overall integrated risk assessment, ourSustainability Index8, our compliance program, our supplier due diligence and evaluation
processes, and our ALP monitoring and remediation system deployed on the tobacco farms
contracted by PMI and our suppliers. We periodically conduct human rights risk assessments
to proactively identify and mitigate potential adverse human rights impacts across our value
chain. While for PMN and PMT, Norway is not indicated as a high-risk market in terms ofpotential human rights violations and no specific evidence of modern slavery was identified,
PMI’s evaluation of effectiveness of its actions comes from enhanced due diligence programsand third party assessments at global level. These will form the foundation of further initiatives
at local level to be rolled out in future reporting periods.
1. Human rights impact assessments
PMI worked with Article One to conduct a human rights risks saliency mapping, as mentioned
above. Article One are leading advisors in the business and human rights arena. This saliency
mapping confirmed our existing assumptions about our supply chain but also identified some
8 Please refer to pgs. 34-35 of PMI 2023 Integrated Reportless apparent risks. PMI used this mapping and assessed it against our current risk-mitigation
instruments, and subsequently developed recommendations to strengthen our risks
identification and response instruments.
Furthermore, in order to strengthen the due diligence framework, proactively identify risks andmitigate potential adverse impacts along its operations and value chain, PMI has set an
ambition to conduct human rights impact assessments (HRIAs) by 2025 in the 10 highest-riskcountries in which it operates. The list of high-risk countries is determined — and periodicallyreviewed — based on PMI’s footprint (e.g. presence of manufacturing operations and type of
supply chain) and the country’s human rights risk profile, as determined by internationallyrecognised indicators such as the Heidelberg Conflict Barometer, the Freedom House
Freedom of the World Index, the U.S. Trafficking in Persons Report, and Transparency
International. These HRIAs are carried out by independent expert organizations and follow aformal process, aligned with the UNGPs. They result in tailored action plans, which are thenimplemented, monitored and reported on.
In 2023, PMI completed its eight HRIA since 2018 in Pakistan.
An innovative feature of this HRIA was the incorporation of a gender lens into the assessment.
Conducting a gender-sensitive HRIA recognizes that human rights risks can affect groups ofpeople in unique and intersecting ways and considers the impact of particular risks facing
people of different genders. Moreover, it enables the development of recommendations toaddress particular risks, and provides support to ensure women’s rights can be consistently
respected in the group’s operations and supply chain.
In addition, in late 2023, PMI initiated a follow-up assessment from the HRIA conducted in2020 in Mozambique. This assessment, to be completed in 2024, will include extensive
engagement with local suppliers to assess initiatives and systems in place to manage risks,
as well as field visits to validate progress since the previous assessment through participatory
techniques with farmers. A particular focus will be given to priority risk areas, including childlabour.
Regarding past HRIAs, action plans have been fully implemented in Mexico, the Philippines,
and Russia. Moreover, the monitoring of the implementation actions recommended byprevious HRIAs in Mozambique, Turkey, Brazil, and Malaysia continued throughout 2023.
Leveraging on learnings from previous pilots, in 2023 PMI further developed its selfassessment tool, intended for its low to medium risk country affiliates to self-identify salient
human rights risks within their organizations and then develop action plans to address them.
During the year, PMI organized dedicated training sessions with over 60 sustainability
coordinators across all markets to foster understanding and usability of the toolkit, and to build
capabilities. The toolkit was tested in Germany in late 2023, and, while the work is still ongoing,
initial feedback was very positive on the usability and the guidance provided.
2. Sustainable supply chain
As part of the PMI 2022 Modern Slavery Statement, PMI noted as a future action that it would
continue to use due diligence tools to assess performance and compliance of suppliers andsupport them in progressing towards sustainable practice. As such, in 2023, PMI continued touse its due diligence tools to assess performance and compliance of suppliers and support
them in progressing towards more sustainable practices. More specifically, for its electronics
suppliers, PMI continued to leverage resources from the Responsible Business Alliance (RBA)
and gathering data through the Validated Assessment Program (VAP) and Customer
Managed Audits (CMAs) during the year. These highlighted that the most common social

issues relate to working time, wages and benefits, and emergency preparedness.
Engagement with RBA proved crucial when, during 2023, PMI was made aware of concerns
related to labour practices at one of the electronic suppliers in Malaysia, immediately
commissioning a Specialty Vendor Assessment Program (SVAP) audit to the RBA. The
remediation of the findings of the SVAP audit is key for PMI to continue working with the
supplier and resume the projects that were suspended to reflect the gravity of the situationand enable the supplier to prioritize necessary and effective corrective measures.
In relation to its direct material suppliers, PMI continued relying on the partnership with
EcoVadis (a leading global provider of online ESG supplier assessments), to monitor andassess their sustainability performance. In 2023, PMI's critical suppliers of direct materials
assessed in EcoVadis achieved an average Social score of 61 out of 100. To address theissues identified, PMI engaged with suppliers showing lower sustainability performance,
organizing deep-dive review sessions of their corrective action plans (CAPs) before theirreassessment.
Understanding the importance of engaging and aligning with suppliers, in 2023, based on arisk assessment methodology, PMI started piloting two initiatives to foster opportunities toimprove suppliers’ sustainability performance:(i)the Responsible Factory Initiative (RFI), which focuses on helping suppliers withlower maturity in sustainability topics to identify potential misalignment of theirpractices with the RBA Code of Conduct and address them accordingly. Pilot
started in mid-2023 and is expected to run for 12 months;(ii)

the Responsible Labor Initiative (RLI), which aims to build and strengthen thecapabilities of PMI’s suppliers and their recruitment agencies through targetedtraining and support, raising awareness on how to identify and address potential
forced labor issues. Pilot started in mid-2023 and is expected to be completed by
July 2024.

3. ALP Programme
PMI has have a robust due diligence framework in place to evaluate the implementation of the
ALP Code, enabled by the traceability at farm-level provided by an integrated production
system and systematic monitoring of farms by field technicians, employed by suppliers or
PMI’s own Leaf operations, whose role is to visit the farms, oversee and support the crop
production, and monitor the implementation of social and environmental practices.
In the Reporting Period, 3,121 field technicians systematically monitored the implementationof the ALP on 94% of all tobacco volume purchased by PMI. PMI uses a risk-based approachto prevent, identify, mitigate, and address human rights and labor rights incidents in the
tobacco supply chain. This entails ongoing collaboration with key stakeholders—including
suppliers, farmers and farmer associations, civil society organizations, academics,
governments, and the private sector—to tackle persistent and systemic issues in the
agricultural sector. Guided by long-term strategic partner on the ALP program, Verité, andtogether with other key stakeholders (local NGOs, and governments), PMI has developed andis implementing action plans to address recurrent issues. The vast majority of our relationships
with contracted farmers feature a shared commitment to continuously improve addressing
social issues. In the event of noncompliance and continued failure to address gaps, we may
end our business relationship with that farmer.
The internal farm-by-farm monitoring is complemented by external assessments performedby Control Union, an independent third-party auditor who checks ALP programimplementation and progress (from a management system perspective) and by local
specialized third parties that verify social practices in high-risk markets.
At the forefront of PMI’s approach to continuously strengthen the ALP program is PMI's
Sustainable Tobacco Supply Chain (STSC) framework, a comprehensive approach initiatedin 2022. The aim of this approach is to address sustainability risks and impacts in the countries
where PMI sources its tobacco. In this respect, during 2022 past results from internalmonitoring and various external assessments were analyzed and it was decided to revisit themethodologies to become more stringent in all purchasing practices.
It is important to note that, while the data reported (i.e. in PMI’s Integrated Report 2023)
confirms that the tobacco purchased is almost completely free from key labour issues, thisdoes not mean that labour issues, including child labour, do not continue to exist in the
tobacco-growing areas from which PMI sources. Hence, during 2023, PMI further refined its
controls and systems to monitor these volumes and ensure they do not exceed 10 percent of
the total purchased volume in any given year.
4. Grievance Mechanisms
Providing access to remedy to potentially impacted stakeholders relies on the provision of aneffective grievance mechanisms both for PMI’s operations and across its supply chain – acore element of PMI’s due diligence approach, aligned with the UNGPs. PMI maintains clear
policies, runs regular training and works to ensure that robust processes are in place toencourage employees to speak up if they become aware of any suspected potential or actual
violations of law, the Code of Conduct, or any of PMI’s policies. and to suggest improvements.
As an example, in 2023, PMI trained over 10,000 employees on PMI’s new RSPs, reinforcing
the importance of speaking up in the organization. There is a robust speaking-up culture at
PMI, with most employees communicating directly with the Compliance department andvoluntarily disclosing their identity when doing so. Specifically, in 2023, only 19 percent of thereports received by Compliance were submitted anonymously.
PMI offers the following mechanisms in place internally:
1. The individual’s supervisor, department head or affiliate or function leadership;
2. PMI Compliance key contact, for example Regional Directors and Local Compliance
Officers;
3. PMI Global Compliance confidential email address; and4. PMI Compliance Helpline (online or by telephone) which is operated by a third-party
and available 24/7 in all languages spoken at PMI. Individuals may use the PMI
Compliance Help Line anonymously, subject to local laws and regulations.
The same applies to PMN and PMT’s supply chain, where everyone should have a voice andbe able to seek help. The RSPs specifically ask suppliers to provide their workers with easily
accessible ways to raise concerns, free from risk of retaliation. Moreover, ALPC states that'workers should have access to a fair, transparent, and anonymous grievance mechanism'.
Such mechanisms are available in some countries where PMI sources tobacco.
Moving forward, PMN and PMT will continue efforts to provide better access to grievancemechanisms throughout their operations and supply chain.

PLANS FOR FUTURE ACTION
Our Human Rights Roadmap helped us establish strong foundations and a more structured
approach in our work related to human rights. The maturity acquired so far helped us establish
ambitious targets across all functions to be delivered by 2025. Although the focus will be toachieve these targets, we will continue listening to our stakeholders, learning from our current
control mechanisms, reinforcing our due diligence and remediation processes, and staying up
to speed with external and internal developments.
In the year 2024, PMI intends to:•Continue rolling out the updated RSP, ensuring RSP adherence requirement is effectively
included in all contractual commitments with suppliers at local level and suppliers’
compliance is continuously monitored;•

Conduct a local, human rights impact assessment using the self-assessment tool;•

Refine its due diligence tools in light of latest relevant regulatory developments andcontinue to use them to assess performance and compliance of suppliers and support
them in progressing towards sustainable practice in some instances conducting.

More information on PMI’s approach and performance on environmental, social and corporate
governance issues, including modern slavery and human trafficking, can be found in PMI’s
Integrated Report.
APPROVALThis statement was approved by the Board of Directors of Philip Morris Norway AS and PM
Tobakk Norge AS on 28 June 2024.

Anette Rosengren…………………………………………………

Anette Rosengren (Jul 2, 2024 18:02 GMT+2)

Anette Rosengren
Philip Morris Norway AS and PM Tobakk Norge AS

Benedikt Næspe

………………………………………………..

Benedikt Næspe (Jul 2, 2024 12:10 GMT+2)

Benedikt Naespe
Philip Morris Norway AS and PM Tobakk Norge AS………………………………………………..

Tamara Milovanovic (Jul 2, 2024 11:43 GMT+2)

Tamara Milovanovic
Philip Morris Norway AS and PM Tobakk Norge AS

2024.06_Norway_PMI 2023 Transparency Act
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