Document information
Company Nortek AS
Prepared by Therese Baas, Inga Kristine Wegger
Reviewed by Finn-Ivar MarumApproved by Nortek board
Date 21.06.23

nortekgroup.com

Preamble
The actions of companies have significant impact, both positive and negative, on the lives ofcitizens around the world. Not only in terms of the products and services they offer, or the jobs
and opportunities created, but also in terms of working conditions, human rights, health, theenvironment, innovation, education and training.
For this reason, it’s expected that companies understand their positive and negative impacts onsociety and the environment by doing due-diligence exercises. This enables companies to,
identify, prevent, manage and mitigate any negative impact that they may cause, including within
their global supply chain. Living up to this duty is commonly known as 'corporate social
responsibility’ or ‘responsible business conduct' 1.

UN’s 17 Sustainable Development Goals, the foundation for responsible business conduct.
This report covers the company's duty to account for the due diligence assessments conducted in
2023 according to the Norwegian Transparency Act, LOV-2021-06-18-99 2. In the report Nortek
outlines the goals and measures that have been evaluated and implemented to reduce the risk ofnegative impacts from the company's activities and business relationships on fundamental humanrights and decent working conditions.
The company has not identified any violations of human rights or decent working conditions during
the reporting year. Additionally, the company has not identified any new significant risk of such
violations or negative impacts which are not already addressed in the report.
We continuously monitor the achievement of our goals, the implementation of initiated measures,and the resulting outcomes.

Report contact person:

Therese Baas, Quality and Digital Director

Inquiries:

Please complete the contact form on www.nortekgroup.com

www.nortekgroup.com

2

The Nortek board signature
The Transparency Act was endorsed and adopted by the Nortek Board in June 2022.
The Nortek Board and the CEO of the Nortek Group confirm they have received and read thereport titled "Statement for Responsible Business Conduct – Nortek Group 2023."

Nortek Group
21. June 2024, Rud-------------------------------------------Atle Lohrmann
Chair of the Board-------------------------------------------Finn-Ivar MarumCEO and member of the Board

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Table of Contents
1.

DUE-DILIGENCE PROCESS ............................................................................................. 62.

COMPANY OVERVIEW AND KEY INFORMATION ........................................................... 7
2.1

3.

OVERVIEW ....................................................................................................................... 7
SUPPLY CHAIN OVERVIEW ........................................................................................... 10

3.1
3.2

DESCRIPTION OF PURCHASING MODEL AND SUPPLY CHAIN ................................................... 10
KEY INFORMATION .......................................................................................................... 10

3.2.1

4.

Key global supply chains used by Nortek .............................................................................12

DUE-DILIGENCE PLANS ................................................................................................ 13
4.1
4.2

GOALS AND PROGRESS 2023 ........................................................................................... 13
PLANS FOR THE COMING YEARS ........................................................................................ 13

5.
STEP 1: EMBED RESPONSIBLE BUSINESS CONDUCT INTO POLICIES AND
MANAGEMENT SYSTEM .......................................................................................................... 14
5.1
5.2
5.3

POLICY .......................................................................................................................... 14
GLOBAL TRADE COMPLIANCE ............................................................................................ 14
MANAGEMENT SYSTEM .................................................................................................... 15

5.4

ENGAGEMENT WITH SUPPLIERS AND OTHER BUSINESS RELATIONSHIPS ................................. 16

5.3.1
5.3.2
5.3.3
5.3.4

Oversight and responsibility ................................................................................................15
Embed responsible business conduct ..................................................................................15
Sustainability ......................................................................................................................16
Organisation, roles and internal communication ...................................................................16

6.
STEP 2: IDENTIFY AND ASSESS ACTUAL AND POTENTIAL ADVERSE IMPACTS
ASSOCIATED WITH THE ENTERPRISE’S OPERATIONS, PRODUCTS AND SERVICES ........ 17
6.1

SCOPING EXERCISE TO MAP AND PRIORITISE ...................................................................... 17

6.2

IDENTIFY AND ASSESS SPECIFIC ACTUAL AND POTENTIAL ADVERSE RBC IMPACT .................... 19

6.3

RISK EVALUATION AND PRIORITIZATION.............................................................................. 20

6.1.1

RBC risks related to service suppliers .................................................................................17

6.2.1
6.2.2

RBC risk assessment based related to suppliers’ geographical location ............................... 19
RBC risk assessment related to sourced parts/materials and industry .................................. 19

6.3.1

Adverse impacts not prioritized ...........................................................................................20

7.

STEP 3: CEASE, PREVENT AND MITIGATE ADVERSE IMPACTS ................................ 21
7.1
7.2

MITIGATION PLAN ............................................................................................................ 21
OTHER ACTIONS INITIATED TO MITIGATE ADVERSE IMPACTS ................................................. 21

7.2.1
7.2.2

Sustainability and climate action .........................................................................................21
Combating corruption and bribery in own business and in the supply chain .......................... 22

8.

STEP 4: TRACK IMPLEMENTATION AND RESULTS..................................................... 22

9.

STEP 5: COMMUNICATE HOW IMPACTS ARE ADDRESSED ....................................... 23
9.1

PUBLIC INFORMATION ...................................................................................................... 23

10.

STEP 6: PROVIDE FOR OR COOPERATE IN REMEDIATION WHEN APPROPRIATE... 23

11.

REFERENCES ................................................................................................................ 24

www.nortekgroup.com

4LIST OF ABBREVIATIONS

Abbreviation

Full description

ISO

International Organization for Standardization

CSR

Corporate Social Responsibility

ESG

Environmental Social Governance

GDPR

General Data Protection Regulation

GHG

Greenhouse Gas

GRI

Global Reporting Initiative

HQ

HeadquartersHR

Human Resources

HSE

Health, Safety and Environment

ICT

Information and Communications Technology

KPI

Key Performance IndicatorOECD

Organisation for Economic Co-operation and Development

PCB

Printed Circuit Board

RBC

Responsible Business Conduct

SDG

Sustainable Development Goals

T&C

Terms and Conditions

UN

United Nations

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1. Due-diligence processThis report summarizes Nortek Group’s work on transparency and due diligence to promote andensure fundamental human rights and decent working conditions in its supply chain, as per LOV2021-06-18-992. It is based on the UN Guiding Principles on Business and Human Rights and theOECD Due-Diligence Guideline for Responsible Business Conduct 3.
The due-diligence process, outlined in Figure 1, includes six steps to help companies implement
more responsible and sustainable practices into their business model.

Figure 1: OECD Guideline due-diligence process and supporting measures 3 process should bealigned with the risks and company’s context, such as size, operations, markets and influential
power.
Performing due diligence acknowledges both the positive contributions and the potential negative
impacts on humans, society, and the environment. It encourages transparency about challenges
and collaboration with stakeholders to mitigate adverse effects.
The report structure is according to the OECD model, featuring individual chapters for each step.
Step 1: Embed responsible business conduct into policies & management systems
Step 2: Identify & assess adverse impacts in operations, supply chains & business relationships
Step 3: Cease, prevent or mitigate adverse impacts
Step 4: Track implementation and results
Step 5: Communicate how impacts are addressed
Step 6: Provide for of cooperate in remediation when appropriate

2. Company overview and key information
2.1 Overview
The Nortek Group, hereafter called Nortek, is an ocean technology company providing oceanographic
instruments for current and wave measurements and underwater navigation systems. In addition to
the headquarters and manufacturing site in Norway, the company has a global presence with offices inseven countries and a network of distributors around the world.

Figure 2: Nortek global footprint and presence. 2/3 of all employees are located in Norway.
Nortek is committed to conducting its business in a responsible and sustainable manner, with astrong focus on environmental stewardship and social responsibility. The company has
established science-based targets for emission reduction to benefit people, nature, and theclimate. The company's operations are guided by a set of core values, including a commitment toinnovation, collaboration, and ethical behavior for employees and the supply chain.
The key information is from the Nortek GRI Report 2023 4, following the GRI 102: General disclosures,
Organizational profile section.

102-1 Name of the organization
Nortek AS, org.no. 996 707 415 | Web: www.nortekgroup.com
102-2 Activities, brands, products, and services
Development, production, distribution and service of oceanographic instruments and underwaternavigation systems.

www.nortekgroup.com

7102-3 Location of headquarters
Vangkroken 2, 1351 Rud, Norway.
102-4 Location of operation
Nortek maintains operations/office locations in the following countries: Norway, UK, The
Netherlands, France, USA, Brazil, Japan, China and Australia. The manufacturing site is at HQ in
Norway. Visit www.nortekgroup.com/about/contact for office locations and agents.
In 2023 Nortek had 11 agents, re-selling Nortek products. Africa (1), Asia (5), Europe (3), Central
America (1) and Middle east (1)102-5 Ownership and legal form
Nortek is a privately held company owned 100% by General Oceans AS, org. no 927 002 264
102-6 Markets served.
Products sold worldwide through sales offices and agents
102-7 Scale of the organization
Nortek had 161 employees in 8 different countries. The annual revenue for 2023 was 543 mill.
NOK.
102-8 Information on employees and other workers
As of December 2023: 140 full-time, 14 part-time, 6 contractors, 1 trainee. Employee distribution:
Norway (98), UK (7), Netherlands (16), France (12), USA (10), Brazil (3), Japan (2), China (9),Australia (4)102-9 Supply chain
Nortek has rigorous policies and procedures in place in our certified Management System toselect, manage and follow-up suppliers.
Supplier and Business Partner Code of Conduct
The codes outline corporate governance, social, and ethical responsibility requirements for all
suppliers and business partners. They include mandates on environmental management,
governance, trade compliance, human rights, and working conditions. These requirements are
enforced through contracts and regular meetings and audits. The updated Business Partner Codeof Conduct was issued in 20245.
Climate action and the environment
Nortek encourages suppliers and partners to disclose their carbon footprint, implement
environmental management systems, and set science-based targets for emission reductions.
Suppliers are also required to establish systems for waste management and recycling.
Local suppliers
Nortek supports local communities and suppliers, conducting an ESG assessment of all service,materials and parts suppliers > 1 mill NOK, which constitute over 70% of supplied goods andservices. Of these, 65% are based in Europe (52% in Scandinavia), 31% in the USA and 4% in
Asia.
Due diligence
Suppliers and partners must adhere to the Supplier6 and Business Partner Code of Conduct5.
These standards are enforced through meetings and audits as part of the OECD due-diligenceprocess. Nortek will continue to monitor ESG risks with key suppliers and partners.
102-10 Significant changes to the organisation and its supply chain (since last update) The
General Oceans Group consists of four operating companies as of December 2023, Nortek,
Reach Robotics, Strategic Robotic Systems, Tritech and Klein Marine Systems.
102-11 Precautionary Principle or approach
Nortek’s ambitious climate strategy is based on three pillars:

www.nortekgroup.com

81) Reduce own emissions with 1/3 by 2030.
2) Deliver carbon neutral products to our customers.
3) Enable healthier oceans through our technology and costal community support.
Throughout the year, ESG risks have been regularly assessed, and processes like the Supplierand Business Partner Code of Conduct have been implemented to ensure a responsible supply
chain. Nortek achieved ISO 14001 certification in 2023.
102-12 External initiatives
Nortek has adopted or endorsed external sustainability principles, standards and regulations
including, but not limited to:
E=Environment | S=Social | G= Governance
Description

Type

Implementation

O 9001 Quality Management System

E, S, G

Ensures quality and customer satisfaction.

ISO 14001 Environmental
Management

E

Integrated with the Management System.

E

Basis for our climate goals and plans.

Greenhouse Gas Protocol 8

E

Framework for climate reporting and CO2
accounting.

GRI Standards 9

E, S, G

Framework for ESG reporting; yearly GRI report.

S, G

Ensures human rights and decent working
conditions; covered by Supplier Code of Conduct
and due-diligence process.

E, S, G

Covered by company policies and sustainability
processes in the management system.

E, S, G

Focus on five selected SDGs.

International Labour Organization(ILO) Standards 12

S, G

Basis for Supplier and Business Partner Codes ofConduct.

United Nations Universal Declarationof Human Rights

S, G

Basis for all Nortek Codes of Conduct.

Report Waste Consumption to SSB(Norway)E

Waste handling system tracks all waste categories.

Paris Agreement 7

Norwegian Transparency Act
Norwegian Accounting Act, § 3-3c –Corporate Social Responsibility 10
United Nations Sustainable
Development Goals 11

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93. Supply chain overview
3.1 Description of purchasing model and supply chain
The central purchasing department at HQ in Norway manages all materials and parts purchases forthe manufacturing site, using a standardized procurement process to handle the global supply chain.

Figure 3. Overview of top-level procurement process••••

Evaluates and qualifies new suppliers. ESG risks and documentation is part of theassessment.
Manages the supplier contractual framework and Supplier Code of Conduct
Identifies and mitigates potential risks associated with suppliers
Manages the procurement process including forecasting and competitive bidding to ensurecost-effectiveness

Local management at each office location collaborates with HQ to follow up on local service suppliers
and business partners.

3.2 Key information
Nortek’s suppliers provide materials, parts, and services to the company. Services are primarily
provided by local partners near our offices, while materials and parts are sourced globally, followinginternational supply chain patterns.
Table 1: Overview of supplier relationships
CategoryType

Comment

Total number of suppliers thecompany had a commercial
relationship with in 2023

497

Subsidiaries notincluded

Type of supplier[Purchased volume]

55% Material and parts suppliers
45% Service suppliers

Table 2: Overview of what is purchased.
Category
Material andparts

Supply chain
Global supply chain

What we buy•••

POM parts (plastic)
Electronics
Metal parts (titanium, aluminium, steel)www.nortekgroup.com

10Category

Services

Supply chain

Local supply chain

What we buy
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•

Cables and connectors
Batteries
Industrial ceramics
Chemicals
Machines and tools
OfficeElectricity
Cleaning
Banking
Groceries
Furniture
Consulting
Cloud services
IT equipment
Software applications

Parts and materials sourced globally
Table 2 is not unique to Nortek. Plastics are derived from oil and gas, precious metals andminerals are mined, and electronics are manufactured in large factories serving companies
worldwide. These supply chains share common extraction and production methods, along withsimilar challenges related to human rights, labor conditions, and environmental impact.

Fossil feedstock

Steam cracking

Polymerization

Processing into
plastic type/granulate

Processing into
final parts

NortekFigure 4. Overview of plastic supply chain

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113.2.1

Key global supply chains used by Nortek

Table 3: Supply chain examples#

A

B

Material/
part

Metals andminerals

Plastic

Supply chain

Mining,extraction,
smelting

Oil/natural gas
extraction,refining,
polymerization

Processing

1.
2.
3.
4.

Mining and crushing ore
Chemical extraction and smelting
Raw materials in bar/granulate form
Machined into final parts

1. Extract fossil feedstock from oil/gas reservoirs.
2. Refine raw materials into ethane and propane,then crack them into ethylene and propylene
using heat and chemicals.
3. Combine ethylene and propylene with a catalyst
to form polymers, extruded into plastic tubes or
granulate.
4. Machine or process further into final parts

Adverse impacts and industry risks
A1) Mineral extraction and processing pose human rights risks, such as forced
displacement, land grabbing, environmental destruction, dangerous conditions,and child labor. Conflict minerals (tin, tantalum, tungsten, gold) are associatedwith violence and abuses in conflict zones.
A2) The chemical industry involves dangerous materials like explosives, gases,
inflammable liquids, and toxic substances.
B1) Oil & gas are non-renewable resources that contribute to high carbon
emissions and climate impacts, along with plastic pollution in sea and land.
B2) Exploration and development risks include land grabbing, geopoliticalinstability, habitat disruption, and oil spills affecting ecosystems and humancommunities.
B3) Workers face dangerous conditions, including fire, explosions, and chemical
exposure.
See A1, A2, B1, B2, B3CDElectronics

Batteries

A+B+
Manufacturing ofelectronic
components 13

A+B+
Manufacturing ofbatteries

1. Raw materials are used to create circuit board
components (microchips, resistors, etc.), which
are then printed onto PCBs.
2. The electronic boards are sold as final parts

1. Sub-suppliers purchase raw materials, plastic,chemicals, and electrical components to
manufacture batteries.
2. Batteries are typically sold through distributors to
end users.

C1) The electronics industry faces issues like excessive working hours, poverty
wages, forced labor, and dangerous conditions. It drives mineral mining,
consuming 35% of global copper and 9% of gold production.
C2) Chemicals are used extensively throughout the electronics manufacturing
process.

See A1, A2, B1, B2, B3, C1

The supply chains for materials and parts may combine the processes above and pass through several distribution channels before reaching Nortek.

4. Due-diligence plans
The 3-year plan to assess the different areas of our supply chain are based on an overall risk
assessment considering:•••

Suppliers which we purchase in volume from on a regular basis.
Suppliers and business partners we may influence the most based on revenue.
Area of the world where the supplier or business partner is located.

Risk and influence increase with the amount purchased relative to the size of the supplier.
Suppliers and partners with revenue below 1 million NOK are excluded from this assessment due
to their low contribution to overall supply chain risk.
Nortek has the most influence over suppliers from whom we regularly purchase in large volumes
and those with the highest revenues.
The focus in this report has been the top tier suppliers > 1 mill. NOK.

4.1 Goals and progress 2023
Table 4: Goals and progress 2023
Year

Goal

Status2022

Perform due-diligence of top 15 material and parts suppliers > 1
mill. NOK

Completed2022

Establish templates and framework for the OECD due-diligenceprocess within Nortek

Completed

2023

•
•
•
•

Include ESG topics in the supplier risk assessment process andauditsPerform due diligence of top tier services suppliers > 1 mill.
NOK
Establish framework for Business Partner audits
Established framework for global trade compliance

Completed

4.2 Plans for the coming years
Table 5: Due-diligence plans
Timeline

Supply chain area

Comment

Year 3:2024•

Conduct due diligence of top business
partners and suppliers with revenues > 1
million NOK.

Business partners are mainly
resellers of Nortek's products inregions without our own presence.

•

Establish a Business Partner Code of
Conduct for top-tier partners to sign.

•

Review the risk indicators used

Top-tier service suppliers, primarily
in Norway and Scandinavia, areconsidered low-risk in terms of ESG
aspects.

Continue the OECD due-diligence process and the supplier/business partner risk assessment for
all suppliers and partners above the 1 mill. NOK threshold.

5. Step 1: Embed responsible businessconduct into policies and management
system
5.1 Policy
Ref. OECD Due Diligence Guidance for Responsible Business Conduct section 1.13
Responsible business conduct is integrated into the Nortek’s Group Policies. Currently, we
operate eight policies and one whistleblowing procedure:
•
•
•
•
•
•
•
•
•

Code of Conduct
Supplier Code of Conduct
Business Partner Code of Conduct
Health, Safety & Working Environment
Quality
Privacy & GDPR
External Environment & Sustainability
Communication
Whistleblowing Procedure

Social responsibility and governance topics are part of all policies. The policies have beencommunicated to the company's employees and are available on the company's intranet. The
company regularly conducts awareness training related to the ethical guidelines and policies.
Nortek’s Codes of Conduct are based on the UN declarations, core ILO conventions, UN Global
Compact’s 10 principles for sustainable development, and the OECD Anti-Bribery Convention.
They address:
•
•
•
•
•
•
•
•
•
•
•
•
•

Laws and regulations
Trade compliance
Labor rights and working conditions
Child labor and forced labor
Freedom of association and the right to organize
Corruption, business integrity, and reporting
Environment, sustainability, and reporting
Resource efficiency, recycling, and clean energy
Health, safety, and working environment
Responsible materials sourcing and conflict minerals
Information disclosure and cooperation
Non-compliance
Supplier and business partner declarations

Nortek's major suppliers and business partners must sign the applicable Nortek Code of Conductor provide documentation proving they meet the requirements.

5.2 Global trade compliance
Increased sanctions and embargoes from the EU/USA as well as the US/China trade war haveplaced heightened requirements on Nortek. To address these challenges, Nortek focused on tradecompliance to support global business growth, ensure supply chain efficiency, and maintain
operational integrity.

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5.3 Management system
Ref. OECD Due Diligence Guidance for Responsible Business Conduct section 1.23

5.3.1
•
•
•
5.3.2

Oversight and responsibility
The CEO is responsible for the company's ethical guidelines, which were last updated on
August 21st, 2023.
The Quality Department is responsible for the due-diligence process
The Group Senior Management is responsible for ensuring compliance with the ethicalguidelines within their respective departments.
Embed responsible business conduct

Nortek acknowledges that our business model and supply chain impact both people and theenvironment. We are committed to embedding sustainability and responsible business conduct into
our strategy and operations through Nortek’s ESG framework.
Nortek’s ESG framework, as shown in Figure 5, is guided by our policies. The business processes
ensuring daily activities and the OECD due-diligence process are detailed in the company’s
Management System.

Figure 5: Nortek’s ESG framework is based on the company policies
Nortek operates a management system to manage activities at all organizational levels, certified to
ISO 9001:2015 (quality) and ISO 14001:2015 (environment). This system complies with statutory
regulations for health, safety, and the environment, and meets the requirements of public authorities,
customers, and business partners.
Specific ESG KPIs are tracked by the Group Management Team. Risk management is also overseenby the Group Management Team which initiates mitigating actions when adverse effects are detected.
They are responsible for establishing plans and stopping or adjusting activities that do not align with
Nortek’s ESG framework, company policies, laws, or local regulations.

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5.3.3 Sustainability
Nortek is committed to sustainable operations, managing its business to promote sustainability. Every
two years, Nortek conducts a materiality assessment to prioritize issues impacting the business,
communities, and the environment.
A responsible supply chain is crucial for:•Long-term sustainability, ensuring ethical and sustainable sourcing to minimize environmental
impact. By reducing carbon emissions, conserving resources, and promoting eco-friendly
practices, Nortek contributes to mitigating climate change.

•

Uphold fair labor practices and worker welfare. Nortek collaborates with suppliers and partners
to ensure safe working conditions, fair wages, and respect for workers' rights through its Codeof Conduct, external ESG audits, supplier meetings, and qualification processes.

•

Enhancing resilience and reducing risks. By holding suppliers and business partners
accountable for quality, ethics, and legal compliance, Nortek minimizes risks related to productdefects, legal issues, and reputational damage.

5.3.4

Organisation, roles and internal communication

Functions, departments and roles involved in the due-diligence assessments.
Seniormanagement:• Annually reviews ESG strategy, KPIs, and results.
• Oversees employee training in the Group’s Code of Conduct’s andPolicies.

Quality
department:• Manages governance, compliance, risk management, and internal
control.
• Oversees Sustainability and ESG efforts, including due-diligence andauditsProcurement
department:• Operates the Nortek Integrity Line whistleblowing channel.

HR department:•

Ensures compliance with Transparency Act communication
requirements via the company website.

Financedepartment:•

Manage financial control and compliance of Business Partners

5.4 Engagement with suppliers and other business relationships
Ref. OECD Due Diligence Guidance for Responsible Business Conduct section 1.33
The company's supplier and business partner qualification process evaluate quality, costs, and supply
chain risks, including ESG topics.
The procurement department holds regular meetings with key suppliers to mitigate supply chain risks
and ensure responsible business conduct.
The Quality and Finance departments manage business partner due-diligence processes and audits.

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6. Step 2: Identify and assess actual andpotential adverse impacts associated withthe enterprise’s operations, products andservices
6.1 Scoping exercise to map and prioritise
Ref. OECD Due Diligence Guidance for Responsible Business Conduct section 2.13
The exercise is performed in Nortek’s due-diligence tool based upon the requirements of theOECD due-diligence guidelines. The overall risk mapping as shown in the dashboard on the next
page, covers risks related to the geographical location of the supplier, exposure by industry
sector, purchasing volumes and certifications/policies. Publicly available information sources andsupplier feedback have been used in the assessment.
The primary focus has been on the top material and parts suppliers / service suppliers > 1 mill.
NOK, Ref. section 4.
The risk is further broken down and presented in the following sections:
•
•

6.1.1

RBC risks concerning primary suppliers based on geographical location
RBC risks concerning primary suppliers based on industry. Also addressing thecomplexity of the supply chain and parts/materials used.
RBC risks related to service suppliers

The top tier service suppliers were included in the 2023 assessment. The RBC risk, based on
their geographical location (primarily in Norway) and industry (see Table 2), is considered very
low compared to the materials and parts suppliers.
Given the low RBC risk profile of the service suppliers, they are not prioritized further in the RBC
risk assessment.

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17

Figure 6: Nortek’s Supplier due-diligence dashboard 2023

6.2 Identify and assess specific actual and potential adverse RBC impact
Ref. OECD Due Diligence Guidance for Responsible Business Conduct section 2.2 and 2.33

6.2.1

RBC risk assessment based related to suppliers’ geographical location

In 2023, Nortek’s top primary suppliers came from Europe (65%), North America (31%) and East
Asia (4%). According to the Global Rights Index 14, 60% came from very low-risk countries(Norway, Denmark, Sweden, and Switzerland), while 35% were from medium-risk countries (UKand USA) and 4% from high-risk countries (China).
Nortek’s primary suppliers have multiple sub-suppliers and business partners. One-third of allpurchased materials and parts came from Norwegian primary suppliers. Norwegian suppliers andNortek HQ are following strict regulations under the Norwegian Working Environment Act 15 andHSE-Internal Control Regulation 16.

6.2.2 RBC risk assessment related to sourced parts/materials and industry
Table 6: RBC risk assessment
Industry
Electronics

Risk assessment
The electronics industry's rapid growth and complex supply chain may
expose workers to human rights abuses due to weak regulations, including
forced displacement, land grabbing, dangerous working conditions, andchild labor, especially in gold and copper mining.

Adverseimpacts
Ref. Table
3, #C

Workers also face health risks from production chemicals linked to
miscarriages and cancer. Additionally, the increase in e-waste is a major
global environmental concern.
Machinedparts(minerals,
metals)
Machinedparts(plastic)

The supply chain for machined metal parts is less complex and often
traceable to raw material extraction. However, metal extraction shares
similar human rights and environmental challenges as described above.

Ref. Table
3, #A

Plastic production involves hydrocarbons like oil and gas, making it difficult
to trace the supply chain back to the origin due to the mixing of raw
materials. Oil and gas extraction often occurs in non-democratic countries,
posing risks for human rights breaches, land exploration, extensive
chemical use, and environmental concerns.

Ref. Table
3, #B

Chemicals

Although used in small amounts, chemicals in production always pose
health and environmental risks.

Ref. Table
3, #A-A2

CablesCables consist of metals, plastic, and chemical coatings. Refer to the risk
assessments for metals and plastic.

Ref. Table
3, #A, #B

Ceramics

Industrial ceramics contain lead oxide, a toxic compound. About 50% of
lead is mined in Asia, posing significant risks similar to other mining
activities.

Ref. Table
3, #A

Battery

Batteries contain chemicals and rare metals like lithium. Non-rechargeable
batteries contribute to growing e-waste, while rechargeable batteries are
crucial for renewable energy storage.

Ref. Table
3, #D

Packaging

Packaging materials include paper/cardboard, plastic, and reusable woodboxes. Wood is renewable and helps absorb carbon dioxide. Paper andcardboard can be recycled. Refer to the risk assessment for plastic.

Ref. Table
3, #B

6.3 Risk evaluation and prioritization
Ref. OECD Due Diligence Guidance for Responsible Business Conduct section 2.43

Based on the risk evaluation of adverse impacts, we considered geographical location andindustry ESG factors. Figure 7 illustrates the prioritization of our efforts, highlighting the suppliers
and industries that warrant our attention in relation to Responsible Business Conduct (RBC).

INDUSTRY RISK BASED ON MATERIAL

Electronics

Machined parts C
Batteries
Machined parts A
Ceramics A

Ceramics B

Sensors

Cables &Connectors
Machined parts B

Chemicals
Packaging

GEOGRAPHICAL RISK
Figure 7: Material risk plot. A and B is used when the same material/part is supplied from different
geographical locations of the world.
6.3.1

Adverse impacts not prioritized

The extraction of raw materials used in Nortek instruments, such as plastic, titanium, lithium,copper, tin, gold, tantalum, and cobalt, may involve ethical and human rights concerns.
Nortek requires suppliers to adhere to its Supplier Code of Conduct and obtain sourcing
certificates. However, very limited influence and information access prevent further prioritization ofthese extraction risks.

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7. Step 3: Cease, prevent and mitigate adverse
impacts
Ref. OECD Due Diligence Guidance for Responsible Business Conduct section 3.13

7.1 Mitigation plan
Table 7: Mitigation plan, see also the Due Diligence Plan in section 4
What
Supplier andBusiness
Partner Codeof Conducts

ESG audits

Conflict
Minerals
Training

Cease, prevent, mitigate - Goals

StatusThe Codes of Conduct ensure that Nortek’s
suppliers and business partners adhere to high RBC
standards, including safe working conditions,workers' rights, human rights, anti-corruption, andother ethical practices.

All top tier primary
suppliers and business
partners have signed the
document.

An ESG audit evaluates the environmental, social,and governance risks of a supplier's or business
partner’s operations, ensuring the accuracy ofreported information.

ESG audits are part ofNortek’s annual audit
program.

Nortek has a process for handling conflictminerals 17, which are only indirectly sourced.

Top primary electronics
suppliers address
Conflict Minerals

The company regularly conducts awarenesscampaigns and training related to the ethicalguidelines.

Yearly campaigns andtraining

Other actions initiated to mitigate adverse impacts

7.2

Ref. OECD Due Diligence Guidance for Responsible Business Conduct section 3.23
Other cross-cutting measures to stop, prevent, or reduce negative impact on people, society andthe environment in the supply chain.
7.2.1
•
•

•

•
•

Sustainability and climate action
In 2023, Nortek implemented the ISO 14001-certified Environmental Management System.
We are adopting a circular economy model to reduce waste, maximize resource efficiency,
and promote sustainability through:o Sorting and recycling. 95% of materials in a Nortek instrument is recyclable.
o Conducting life cycle assessments of products to reduce our carbon footprint.
o Developing durable, repairable, high-quality instruments with long life expectancy.
Nortek’s technology measures adverse climate impacts from currents and waves, erosion,
ice melting, water management and increased temperatures in the ocean, helping
scientists and nations in understanding climate impact on humans, animals, andlivelihoods.
Nortek has set science-based climate targets aligned with the Paris Agreement's 1.5degree goal.
Our climate accounting meets the GHG protocol requirements.

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7.2.2•••

Combating corruption and bribery in own business and in the supply chain
Nortek has zero tolerance for corruption and bribery, as stated in the Group's policy.
The Code of Conduct applies to all employees, with mandatory annual training.
Violations can be reported via the Group's Integrity Line and are followed up.

8. Step 4: Track implementation and results
Ref. OECD Due Diligence Guidance for Responsible Business Conduct section 4.13

The company has not identified any violations of human rights or decent working conditions during
the reporting year. Also, the company has not identified any new significant risk of such violations
or negative impacts not already addressed in the report.
During the reporting year, no one has requested information on how Nortek complies with therequirements of the Transparency Act.
We aim to enhance knowledge and opportunities for implementing appropriate measures through:•••Dialogue with stakeholders (suppliers, customers, business partners, and employees)
Regular KPI reviews
Audits and third-party assessments

For roles and responsibilities see section. 5.3.4

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9. Step 5: Communicate how impacts are
addressed
Ref. OECD Due Diligence Guidance for Responsible Business Conduct section 5.13

9.1 Public information
The report is publicly available at:Transparency act inquiries:

www.nortekgroup.com/company/sustainability
Complete inquiry form on the webpage

10. Step 6: Provide for or cooperate inremediation when appropriate
Ref. OECD Due Diligence Guidance for Responsible Business Conduct section 6.13
If we find evidence of violation of human rights or breaches of the Nortek Codes of Conduct, we
will take immediate action to protect the individuals involved and work to improve the conditions
wherever possible.
If our policies are continued violated, we will terminate the contract.

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2311. References
1 European Commission, “Corporate social responsibility & Responsible business conduct”,
Internal Market, Industry, Entrepreneurship and SMEs https://single-marketeconomy.ec.europa.eu/industry/sustainability/corporate-social-responsibility-responsiblebusiness-conduct_en
2 Act 18. June 2021 nr. 99 relating to enterprises' transparency and work on fundamental humanrights and decent working conditions (Transparency Act)
https://lovdata.no/dokument/NLE/lov/2021-06-18-99
3 OECD (2018), OECD Due Diligence Guidance For Responsible Business Conduct
4 Nortek Group (2023), Nortek GRI Report 2023.
5 Nortek Group. Nortek Group Policy: Business Partner Code Of Conduct.
6 Nortek Group. Nortek Group Policy: Supplier Code Of Conduct.
7 UN (2015), Paris Agreement.
8 World Resources Institute and World Business Council for Sustainable Development. (2004).
The Greenhouse Gas Protocol: A Corporate Accounting and Reporting Standard (Revised
Edition). World Resources Institute and World Business Council for Sustainable Development.
Available at: https://www.ghgprotocol.org/ (Accessed: 6 June 2024).
9 Global Reporting Initiative (2020), GRI Standards. Global Reporting Initiative. Available at:https://www.globalreporting.org/standards/ (Accessed: 6 June 2024)
10 Norwegian Accounting Act 1998, § 3-3c – Corporate Social Responsibility. Available at:https://www.lovdata.no/dokument/NL/lov/1998-07-17-56/KAPITTEL_2-1#§3-3c (Accessed: 6 June2024).
11 United Nations. (2015). Transforming our world: the 2030 Agenda for Sustainable Development.
A/RES/70/1. Available at: https://www.refworld.org/docid/57b6e3e44.html (Accessed: 6 June2024).
12 International Labour Organization (2021). C190 - Violence and Harassment Convention, 2019(No. 190). Available at:https://www.ilo.org/dyn/normlex/en/f?p=NORMLEXPUB:12100:0::NO::P12100_ILO_CODE:C190(Accessed: 6 June 2024).
13 Make ICT Fair (2021), Human rights risks in the ICT supply chain.
14 ITUC (2024), 2023 ITUC Global Rights Index
15 Act. 17. June 2005 nr. 62 relating to the working environment, working hours and employment
protection, etc. (Working Environment Act) https://lovdata.no/dokument/NLE/lov/2005-06-17-62
16 Regulation 6. December 1996 relating to systematic health, environmental and safety work inbusinesses (Internal Control Regulation) https://lovdata.no/dokument/SF/forskrift/1996-12-061127
17 Make ICT Fair (2021), Human rights risks in the ICT supply chain.

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Public information about Sustainibility and the Transparency Act isavailable on www.nortekgroup.com.
Please use the contact form on our website for external inquries.

nortekgroup.com