NORTEK GROUP 2022

GRI Reportnortekgroup.com

Nortek GRI Report 2022

CONTENTSThe Global Reporting Initiative (GRI) Standards are the most widely usedsustainability reporting standards and have been used for Nortek’s 2022
sustainability reporting on economic, environmental, and social impacts. The
GRI Standards increase an organization’s transparency, enhance stakeholder
engagements, and help mitigate an organization’s risks.

GRI 102: General disclosures
102 Organization profile
102 Strategy
102 Ethics and integrity
102 Governance
102 Stakeholder engagement
102 Reporting practice

GRI’s mission is to “sustainably improve the world by enabling organizations
to understand and communicate the impacts of their activities on people and theenvironment.” Nortek has mapped its sustainability progress in reference to theUnited Nations (UN) Sustainable Development Goals (SDGs).

MATERIAL TOPICS DISCLOSURESGRI 200 Economic topics
201 Economic performances
204 Procurement practices
205 Anti-corruption
GRI 300 Environmental topics
302 Energy and 305 Emissions
306 Waste
308 Supplier environmental assessment

Unless otherwise noted, this document covers Nortek and its subsidiaries, and allquantitative data covers the period from January 1 to December 31, 2022. Nortek
contributes to several of the SDGs, however we have chosen to the following fivegoals 7,8, 12, 13 and 14 as most important to us.

GRI 400 Social topics
401 Employment
403 Occupational health and safety
404 Training and education
405 Diversity and equal opportunity
406 Non-discrimination
412 Human rights assessment
413 Local communities
414 Supplier social assessment
418 Customer privacy

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Nortek GRI Report 2022

GRI disclosure

Nortek response

GRI 102: General disclosures
Organizational profile
102-1

Nortek AS, org.no. 996 707 415

Name of the organization

Web: www.nortekgroup.com

102-2

Development, production, distribution and service of oceanographic instruments and underwater navigation systems.

Activities, brands, products, andservices
102-3

Nortek’s headquarters is located at Vangkroken 2, 1351 Rud, Norway.

Location of headquarters
102-4

Nortek maintains operations/office locations in the following countries:

Location of operation
NorwayUK
The Netherlands
FranceUSA

BrazilJapan
China
Australia

The manufacturing site is at HQ in Norway. For a detailed list of Nortek’s office locations and agents, visit
https://www.nortekgroup.com/contact
In 2022 Nortek had 11 exclusive agents, business partners re-selling Nortek products. Africa (1), Asia (5), Europe (3), Central
America (1) and Middle east (1)102-5Nortek is a privately held company owned 100% by General Oceans AS, org. no 927 002 264

Ownership and legal form
102-6
Markets served

Nortek products are sold world-wide through our own sales offices and agents.

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Nortek GRI Report 2022

GRI disclosure

Nortek response

102-7

Nortek has 156 employees in 9 different countries. The annual revenue for 2022 was 450 million NOK.

Scale of the organization
102-8
Information on employees and otherworkers

As of December 2022, Nortek employed 133 full-time and 15 part-time staff, along with 5 contractors and 3 trainees. Part-time
employees enjoy the same benefits as full-time staff. The company also collaborates with contractors for diverse business needs
and offers trainee roles to support academic projects and young talents.
Global employment status

102-9

Global employee breakdown by country

Nortek's ISO 9001-certified management system ensures rigorous supplier selection and oversight.

Supply chain
Supplier Code of Conduct
Our code mandates social, ethical, human rights and environmental standards for all suppliers. Regular audits and meetings
enforce these terms. In 2022, over 70% of key suppliers demonstrated a high or medium focus on sustainability. Updated
contracts now include this new code to all suppliers.
Climate action and the environment
We urge suppliers to disclose carbon footprints, set emission-reduction targets, and manage waste responsibly.

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Nortek GRI Report 2022

GRI disclosure

Nortek response
Local suppliers
Nortek supports local communities and local suppliers. Nortek performed an ESG assessment of its 15 largest suppliers whichmake up more than 70% of supplied goods and services to the company. 80% are local suppliers based in Europe, while 20% arein the USA. Of the suppliers based in Europe, 67% are in Scandinavia (Norway, Sweden, and Denmark).
Due Diligence
Our suppliers must adhere to our Supplier Code of Conduct. In 2022 we started to address the topics in supplier meetings andaudits as part of the OECD due-diligence process and the Norwegian Transparency Act. The plan is to continue this process andmonitor ESG risks with key suppliers.

102-10Significant changes to theorganisation and its supply chain

In 2021, Nortek AS became part of the General Oceans Group. The General Oceans Group consists of four operating companies
as of December 2022, Nortek, Reach Robotics, Strategic Robotic Systems and Tritech.
Nortek continues the long-term relationships and open dialogue with our key suppliers.

102-11
Precautionary Principle or approach

In 2021, Nortek formed a Sustainability Task Force to focus on key sustainability initiatives. By June 2022, we unveiled a threepillar climate strategy at our Sales Summit:
1) Cut our emissions by a third by 2030.
2) Offer carbon-neutral products.
3) Promote ocean health through technology and community support.
Throughout the year, we've regularly assessed ESG risks and implemented measures like our Supplier Code of Conduct for a
responsible supply chain. We're also working towards ISO 14001 certification in 2023 to bolster our environmental management.

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Nortek GRI Report 2022

GRI disclosure

Nortek response

102-12

Nortek has adopted or endorsed external sustainability principals, standards and regulations including, but not limited to:External initiatives

E=Environment | S=Social | G= Governance
Description
ISO 9001 Quality Management System

TypeE, S, GISO 14001 Environmental Management

E

Paris Agreement
Greenhouse Gas Protocol

E
E

GRI Standards
Norwegian Transparency Act

E, S, GS, G

Norwegian Accounting Act, § 3-3c – Corporatesocial responsibility
United Nations Sustainability Development Goals

E, S, GInternational Labour Organization (ILO) standards
United Nations Universal Declaration of Human
RightsS, G
S, GSupplier Code of Conduct is based upon ILO principals.
The Code of Conduct and Supplier Code of Conduct are based uponthese principals3.

Report waste consumption to SSB (Norway)

E

Nortek has a waste handling system with tracking of the amount in all
waste categories produced.
Nortek has decided to report according to the GRI standards and will
issue a yearly GRI report.

GRI standards

102-13
Membership of associations

N/A

E, S, GE, S, G

Implementation
Nortek’s overall management system to ensure quality and customer
satisfaction.
New environmental management system integrated with the Quality
Management System.
Our climate goals and plans are based on the Paris agreement 1.
The climate reporting/ CO2 accounting and statistics are based on thisframework.
Nortek’s ESG reporting follows the GRI framework.
New law enforced 01.07.22 to ensure human rights and decent working
conditions in the supply chain2. Covered by the Due-diligenceStatement for Responsible Business Conduct, Supplier Code of
Conduct, management system.
Covered by several company policies and the new sustainability
processes embedded in the management system.
Even though we contribute to several SDG’s, Nortek has selected 5
which we will focus the most onError! Bookmark not defined..

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Nortek GRI Report 2022

GRI disclosure

Nortek response

Strategy102-14
Statement from senior decisionmakerWe are committed to sustainable operations to benefit people, nature, and the climate. We will manage our business andactivities to promote sustainability, conserve and enhance natural resources, prevent environmental pollution, contribute to a fairand equal society and continually improve our performance.
Our goal is to embed sustainability into all our business areas and functions, and communicate our sustainability approach to ourcustomers, suppliers, employees, and other stakeholders to join in together on this journey towards a fair, equal, and lowemission society.
Finn-Ivar Marum, Nortek CEO4.

102-15Key impacts, risks, andopportunities

Nortek's Management Team continually assesses risks and opportunities, recording them in our Management System. Biannual
Management Reviews document departmental risks, and ESG risks are specifically addressed with established KPIs. Our risk
management process is an integral part of this system.

Ethics and integrity
02-16
Values, principles, standards, andnorms of behaviour

Nortek aims to turn our beliefs and strategic plans into action by delivering the necessary informed decision-making that promotes
growth, sustainability, and transparency as a basis for reaching our business goals. These are all founded in our company
policies:
•
•
•
•
•
•
•
•

Code of Conduct
Supplier Code of Conduct
Health, Safety & Working Environment
Quality
Privacy
External environment & sustainability
Communication
Whistleblowing

All employees must sign the Code of Conduct. All suppliers sign the Supplier Code of Conduct or equivalent, as part of the
supplier contractual framework.

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Nortek GRI Report 2022

GRI disclosure102-17
Mechanisms for advice andconcerns about ethics

Nortek response

Reporting system
Nortek's reporting system allows employees to log incidents and feedback, which are then tracked and resolved.
Whistleblowing
We have a confidential external channel, the Nortek Integrity Line, for reporting serious concerns or offenses.

Governance102-18Nortek AS went through a re-structuring process in 2021 and is now 100% owned by General Oceans AS.

Governance structure

Nortek Board of Directors
Comprising the Nortek CEO and GO CEO, the Board of Directors is responsible for setting the overarching strategy and direction
for Nortek. They provide governance oversight and ensure alignment with the company's long-term goals.
Nortek leadership team
Led by the CEO, the Leadership Team is the primary decision-making body for Nortek's global operations. They handle day-today management and are tasked with risk assessment and mitigation. The team also evaluates the company's sustainability
initiatives, generating recommendations for improvements. Throughout the year, they adapt their strategies to address emerging
ESG-related risks and opportunities.
Nortek subsidiary boards
Composed of local directors, the CEO, CFO, and CCO, these boards oversee the management and strategic planning of Nortek's
subsidiaries. They ensure that the subsidiaries are aligned with the overall company strategy and are responsible for local
governance.

102-19See section 102-18.

Delegating authority
102-20

The CEO has the overall executive-level responsibility for ESG in Nortek.
The Quality and Digital Director has the managerial oversight for Nortek’s sustainability and ESG activities, strategic
implementation and heads the Sustainability Task Force.

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Nortek GRI Report 2022

GRI disclosure

Nortek response

Executive-level responsibility foreconomic, environmental, and social
topicsThe CFO oversees the financial area to facilitate for a long-term sustainable growth of the company.

102-21

There is a variety of ways in which stakeholder feedback on ESG topics is provided to the members of the Nortek leadershipteam. These include, but are not limited to, those stated in 102-43.

Consulting stakeholders on
economic, environmental, and social
topics102-22Composition of the highest
governance body and its
committees

Nortek Board of Directors:
Atle Lohrmann, chair
Finn Ivar Marum
Please visit https://www.generaloceans.com/about-us forboard memebers background.
Nortek Leadership Team:
Finn Ivar Marum
Jannicke Koch-Hagen
Ole Dypbukt
Therese Baas
Claire Cardy
Espen Staubo
Stian Mysen

Gender statistics: Nortek Board of Directors
FemaleMale

Gender statistics: Nortek Leadership Team
FemaleMale

Please visit Nortek | Get to Know the Management Team at
Nortek (nortekgroup.com) for Leadership Team background.
There were no board committees in 2022.
102-23Chair of the highest governance
body

2022
0
2

As of 31th December 2022, Atle Lohrmann, is Nortek’s Chair of the Board.

2022
3
4

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Nortek GRI Report 2022

GRI disclosure

Nortek response

102-24

As a private company, Nortek focuses on board members with diverse, entrepreneurial backgrounds.

Nominating and selecting thehighest governance body102-25

There are no known conflicts of interest concerning members of the highest governance body.

Conflicts of interest
102-26
Role of highest governance body insetting purpose, values, andstrategy102-27

The highest governance body is pivotal in shaping the company's purpose, values, and long-term strategy. It provides oversightand direction, ensuring alignment with organizational goals and stakeholder interests. This body also reviews and approves key
initiatives, including those related to sustainability and risk management, to guide the company's future course.
The management on Nortek will present and report on various topics to the Board of Directors on a regular basis.

Collective knowledge of highest
governance102-28No evaluation available in 2022.

Evaluating the highest governancebody’s performance102-29Identifying and managing economic,
environmental, and social impacts

The scope incl. processes and procedures for identifying and managing ESG-topics are embedded in Nortek’s certified
Management System and specific company polices:
•
•
•
•
•

Code of Conduct
Supplier Code of Conduct
Health, Safety & Working Environment
External environment & sustainability
Whistleblowing

Nortek uses a formal materiality assessment to identify key issues affecting our business, communities, and environment, andthat matter the most to our stakeholders. This, along with alignment to UN SDGs, shapes our ESG goals and activities.
102-30Effectiveness of risk management
processes

Led by the leadership team, Nortek incorporates sustainability and ESG factors into our overall risk management. Risks areroutinely evaluated for their scope, impact, and financial and ESG implications. The process's effectiveness is reviewed
biannually during Management Reviews.

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Nortek GRI Report 2022

GRI disclosure

Nortek response

102-31The leadership team regularly reviews and acts on economic and ESG KPIs to refine our strategies and integrate sustainable
solutions into our products and operations.

Review of economic, environmental,
and social topics
102-32Highest governance body’s role insustainability reporting

The CEO formally approves Nortek's GRI Sustainability Report, while the company's sustainability strategy receives endorsementfrom the Nortek Board.

Communicating critical concerns

This is addressed in the Code of Conduct featuring a “Route of escalation” to address critical concerns and in the Whistleblowing
procedure, Ref. 102-17.

102-34

In 2022, one case was reported. The case was handled by the CEO and top-level management in the company.

102-33Nature and total number of criticalconcerns102-35
Remuneration policies

As a private company, Nortek doesn't have set renumeration policies for executive managers or employees. Compensation
follows local guidelines and industry standards, using data from unions. All employees are part of a profit-sharing plan. The
renumeration scheme is approved annually by the board.

102-36

Local HR process for the compensation structure is used to determine the yearly renumeration scheme.

Process for determining
remuneration
102-37

Nortek is a privately owned company and there is no stakeholder involvement in the renumeration scheme.

Stakeholder’s involvement inremuneration
102-38Annual total compensation ratio

Nortek calculates the annual total compensation ratio every second year for Nortek AS. It is governed by the Norwegian Equality
and anti-discriminating act. The next calculation will be performed in 2023.

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Nortek GRI Report 2022

GRI disclosure

Nortek response

102-39Will be calculated in the next GRI report issued.

Percentage increase in annual totalcompensation ratio
Stakeholder engagement102-40
List of stakeholder groups
102-41
Collective bargaining agreements
102-42
Identifying and selecting
stakeholders
102-43
Approach to stakeholder
engagement

Nortek engages with a diverse set of internal and external stakeholders through various projects, initiatives, and consultations,which helps form effective partnerships towards better business and solutions. Se statement in 102-43.
All employees in Nortek are free to be organised in a worker’s union.
There are currently no collective bargaining agreements in the company.
The process for identifying and selecting stakeholders is part of Nortek’s Management System and is reviewed on a regularbasis.
Stakeholder dialogue is performed through several different channels to make sure we are aligned. These include, but are notlimited to:
Stakeholder group
Customers

Employees

Stakeholder dialogue•
Conferences, workshops, and events•
Collaborative projects•
Meetings•
Customer satisfaction surveys•
Customer support•
Website•Customer forum and webinars•
Company Intranet, Viva engage, email, meetings, andtown halls•
HSE representative and AMU•
Reporting system (deviations, near-miss, improvements,
positive feedback, whistleblowing)•Working environment survey and HSE tours•
Business resource groups and social committee•
Performance reviews

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Nortek GRI Report 2022

GRI disclosure

Nortek response

Owner(s)Suppliers

Communities
Government, regulators, andpolicy influencers

102-44

•
•
•
•
•
•
•
•
•
•
•
•

Community events
Private shareholder meetings
General Oceans leadership team, town halls, Intranet
Meetings, calls, conferences, and workshops
Supplier audits
Supplier code of conduct
Reporting system
General Ocean foundation
Supporting local community projects
Web-portals: Altinn, export etc.
Legislation and requirements
External audit by regulatory bodies

Key topics in 2022 are sustainability, ESG and the Norwegian transparency act.

Key topics and concerns raised
Reporting practice102-45All Nortek subsidiaries are included in the consolidated financial statements. See financial statement for 2021 and 2022.

Entities included in the consolidated
financial statements
102-46
Defining report content and topic
Boundaries

Nortek’s non-financial materiality assessment identifies key sustainability topics for internal and external stakeholders andbusiness impact. The materiality assessment informs Nortek’s sustainability strategy and reporting content.
This GRI report covers our performance on these material topics in accordance with the GRI framework.

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Nortek GRI Report 2022

102-47
List of material topics

The 2022 materiality analysis was developed with input from employees, management, customers, suppliers, and stakeholders.
Results are displayed in a materiality matrix, showing their position relative to stakeholder interest and business impact. The
materiality matrix:

The issues should not be viewed in isolation as they are interconnected and have an impact on each other. The materiality
assessment is in total a holistic approach on how to manage sustainability in Nortek.
Conducted every other year, it prioritizes issues that have the biggest impact on the business, communities, the environment, andstakeholders.
102-48The 2022 GRI report is the first report developed by Nortek and as such restatements are not applicable now.

Restatements of information
102-49See above, ref. 102-48.

Changes in reporting
102-50
Reporting period

The reporting period is January 1st to December 31st, 2022, unless otherwise stated.

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Nortek GRI Report 2022

102-51This is the first report developed by Nortek.

Date of most recent report102-52

Nortek will release the GRI report annually moving forward.

Reporting cycle
102-53

Nortek invites you to email gdpr@nortekgroup.com with feedback and questions to this report.

Contact point for questions regarding
the report102-54This report has been prepared in accordance with the GRI standards.

Claims of reporting in accordance with
the GRI Standards
102-55

Nortek’s 2022 GRI Report is available on the company’s Sustainability website.

GRI content index
102-56The Nortek 2022 GRI Report and reporting practise have only been verified and reviewed internally and not by any external party.

External assurance

GRI disclosure

Nortek response

GRI 200: Economic topics
GRI 201 Economic performance
103-1
Explanation of the material topic and its
Boundary

The operating profit for Nortek AS in 2022 was 93.5 million NOK, representing a growth of 75% compared to the previous year.
The increase was primarily due to higher operating income. Operating income increased by 45%, from 233.9 million NOK in 2021
to 339.8 million NOK in 2022. The gross margin was 72.2% in 2022, down from 72.6% in 2021.
The profit before tax amounted to 104.6 million NOK, an increase of 44.5 million NOK compared to 2021. The operating profit
increased by 40.1 million NOK, while net financial income increased by 4.3 million NOK.

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Nortek GRI Report 2022

GRI disclosure

Nortek response

103-2

The board believes the annual report and financial statements offer transparency on Nortek AS's assets, liabilities, financial
position, and results. For more details, see Nortek's 2022 Financial Statements.

The management approach and its
components
103-3

Nortek’s Board of Directors oversees the management and overall strategy of Nortek, including its economic performance.

Evaluation of the management
approach

For more details, see Nortek’s 2022 Financial Statements.

201-1

Please refer to Nortek’s 2022 Financial Statement.

Direct economic value generated anddistributed
201-2

Nortek must assess climate-related risks and opportunities to ensure long-term resilience and success.

Financial implications and other risks
and opportunities due to climate change

Climate change brings new material risks (physical and transition) and heightened reputational risks for businesses, impacting
their access to finance.
Climate change risks center on transition, physical, and liability risks.
➢

Transition risk: Climate change and the shift to low emissions create ripple effects impacting business models. Nortek
adapts by updating its Management System with environmental goals and KPIs.

➢

Physical risk: Threatens company assets, including equipment, buildings, and personnel. It can stem from fires, natural
disasters, or equipment misuse, leading to repair costs. Nortek’s HQ and manufacturing site resides in a stable area of
Norway and faces minimal climatic risks.

➢

Liability risk: Rising competition in renewable energy and customer preference for eco-friendly solutions makeemissions costly. Nortek's manufacturing site in Norway does not have emissions to air, water, or land, and uses clean,renewable energy.

Incorporating climate risks into materiality planning enables cost-effective risk management, boosts reputation, and enhances
long-term business resilience and profitability, compared to a passive approach.

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Nortek GRI Report 2022

GRI disclosure

Nortek response

GRI 204 Procurement Practices
103-1
Explanation of the material topic and its
Boundary
103-2
The management approach and its
components

Nortek's procurement practices involve sourcing, supplier management, and ensuring the supply of goods and services for
manufacturing operations and supply chain control.
Nortek's procurement strategy aims to maximize value from materials and services based on quality, quantity, timing, location,
and ESG criteria, incorporated into the company’s Management System. Their procurement involves:
•
•
•
•
•
•

Selecting suppliers based on a risk assessment, classifying them into categories A or B for focused management.
Adhering to a Supplier T&C that includes a Code of Conduct, emphasizing ethical practices with adherence required,under the threat of possible relationship termination.
Purchasing from strategic suppliers as needed.
Regularly following up with suppliers via meetings and audits to maintain a reliable and efficient supply chain that upholds
ESG standards.
Receiving goods by verifying against orders and specifications for production approval.
Managing inventory through organized warehousing, labelling, and stock flow.

The procurement process and overall implementation is handled by personnel with logistics and purchasing roles in theorganisation.
103-3
Evaluation of the management
approachContract management••

Contract management entails the systematic administration of supplier agreements, informed by risk evaluations to
optimize performance, and reduce risk.
Procurement analysis focuses on identifying growth opportunities, ensuring profitability, and strengthening supply chain
resilience.

Supplier follow-up••

Regular supplier meetings aim to bolster relationships, secure timely deliveries, and address evolving requirements.
Annual supplier audits, 2-3 per year, focus on ESG compliance within Nortek's ISO 9001 framework, guided by risk
assessments.

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Nortek GRI Report 2022

GRI disclosure

Nortek response

204-1

See also 102-09.

Proportion of spending on local
suppliers

The top 15 suppliers provide over 70% of goods and services, with 80% being local suppliers in Europe and 20% in the USA.
Among European suppliers, 67% are in Scandinavia (Norway, Sweden, Denmark).

GRI 205 Anti-Corruption•

Nortek enforces a zero-tolerance policy on corruption, barring any exchange of valuables to sway decisions or obtain
improper business benefits in all external engagements.

•

Remuneration for agents or consultants is strictly proportionate to services rendered, adhering to Nortek's Code of
Conduct and relevant anti-bribery laws.

•

Nortek mandates strict adherence to ethical norms and its Code of Conduct from all directors, employees, and partners,
extending to suppliers and vendors, particularly regarding anti-bribery and anti-corruption.

its components•

Breaches or unethical behaviour must be reported, with protections against retaliation, through the Nortek integrity line,
which permits anonymous and specific whistleblowing to enable proper investigations.

103-3

•

Nortek strictly enforces its Code of Conduct principles and policies across the organization, with employee training andworkshops for compliance monitoring.

•All employees and directors are required to affirm their understanding and commitment to the Code, which is accessible
on Nortek’s website and Intranet.

103-1
Explanation of the material topic and its
Boundary

103-2
The management approach and

Evaluation of the management
approach

205-2
Communication and training about anticorruption policies and procedures

Nortek ensures new hires undergo training on Anti-Bribery and Anti-Corruption as part of the annual Code of Conduct orientation.

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Nortek GRI Report 2022

GRI disclosure

Nortek response

GRI 300 Environmental topics
GRI 302 Energy and 305 Emissions
103-1
Explanation of the material topic and its
Boundary

Nortek is committed to sustainable operations that benefits people, nature, and the climate, aiming for continual improvement
within the sustainability field. The company seeks to integrate sustainability across all business areas, promoting it internally andexternally, aiming for a just and low-emission future.
Nortek's environmental impact primarily involves greenhouse gas emissions from its facilities, travel, and waste management.
The carbon emissions for 2019-2022 for Nortek is divided into the following scopes:➢➢➢

Scope 1 - Direct GHG emissions: Nortek boat and vehicles
Scope 2 - Indirect GHG emissions: Electricity consumption from operations and electric vehicles
Scope 3 - Indirect GHG emissions: Water supply, waste disposal, business travel and emissions from supply chain
operations

103-2

Nortek’s environmental commitments

The management approach and its
components

Nortek is committed to becoming a leader in environmental and sustainability performance within the Ocean Technology sector,aligning with the expectations of customers, employees, and stakeholders.
Acknowledging inevitable waste and emissions from manufacturing, Nortek aims for net-zero emissions by 2050, in line with theParis Agreement goals.
Nortek actively works to reduce its environmental impact and contribute to climate mitigation. The company’s ambition is basedon three pillars:➢➢➢

Reduce own emissions by 1/3 by 2030 from a 2019 baseline.
Deliver carbon neutral products to Nortek’s customers.
Enable healthier oceans through Nortek’s technology and coastal community support.

An environmental management system is set to launch by late 2023, with details on sustainability efforts available on Nortek's
website.

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Nortek GRI Report 2022

GRI disclosure

Nortek response
Carbon footprint
2019

2020

2021

2022

Carbon footprint Nortek AS[tonnes CO2e]

274

122

159

304

Yearly change (frombaseline year)
9.35 %

Carbon intensity of total
workforce[tonnes CO2e]

2,6

1,0

1,2

1,9

-26,9%

Nortek's carbon footprint was significantly reduced in 2020 due to COVID-19, dropping from 274 tonnes of CO2e in 2019 to 122
tonnes, mainly from less travel and lower operation-related electricity use.
Emissions rose to 159 tonnes in 2021 and further to 304 tonnes in 2022, with increased business travel cited as the cause of the
30-tonne rise from the 2019 baseline.
Despite a growing workforce, the carbon intensity per employee decreased by 0.7 tonnes of CO2e from the 2019 baseline,
indicating effective emission management.
103-3
Evaluation of the management
approach

Nortek’s management approach consists of:••••

Actively involve and engage employees in shaping Nortek's climate strategy and goals.
Embed environmental and sustainability principles in Nortek's management, operations, KPIs, and decisions.
Aim to certify an environmental management system compliant with ISO 14001:2015 standards.
Enhance Nortek's ESG frameworks, with annual reviews and ongoing improvements in sustainability performance.

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Nortek GRI Report 2022

GRI disclosure

Nortek response

Energy consumption
302-1
Energy consumption within theorganization

Energy consumption
Scope 2 – indirect GHG
emissions

2019

2020

2021

2022

Yearly change (from baseline year)

Total electricity fromoperations[tonnes CO2e]

24

23

27

25

4.1 %

Electricity consumption
from company vehicle[tonnes CO2e]

1

3

2

3

66.6 %•••

Scope 2 emissions at Nortek encompass energy emissions from consumed electricity, heat, steam, and cooling, including
electric vehicles, which are only managed by the Netherlands subsidiary.
Global operational electricity consumption trends were stable from 2019-2022, with a slight decrease in 2020 due to
COVID-19 restrictions and a shift to remote work.
The headquarters in Norway account for the highest electricity usage as it is the primary manufacturing site.

Energy intensity
302-3

Energy Intensity

Energy intensity
Energy intensity
Energy intensity all
offices under operational
control [kWh]

2019

2020

2021

2022

Yearly change (from baseline year)

102.81996.640115.688

101.109-1.66 %

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Nortek GRI Report 2022

GRI disclosure

Nortek response
•
•
•

302-4
Reduction of energy consumption

305-1

•
•
•

Nortek's energy intensity, measured by energy consumption for electricity, heat, steam, and cooling, has decreased by
1.66% from 2019 to 2022.
The primary production site in Norway, utilizing clean hydropower, contributes significantly to low CO2 emissions despite
being the main energy consumer.
With renewable energy use, the CO2 footprint remains low, and Nortek aims to reduce emissions by one-third from 2019
levels by transitioning all offices to renewable energy by 2030.

Nortek strives to lower energy use by implementing energy-saving practices, such as switching off lights post-work hours.
The company adjusts heating/cooling during off-hours and uses automatic temperature controls for efficiency.
Nortek is also replacing traditional office lighting with energy-efficient LED lights where applicable.

Scope 1 emissions

Direct (Scope 1) GHG emissions
Scope 1 (tCO2e)
•
•
•
305-2

2019

2020

2021

2022

Yearly change (frombaseline year)

42

24

29

28

-33.33 %Nortek calculates Scope 1, 2, and 3 emissions using the GHG Reporting Conversion Factors for 2022, appropriate forinternational reporting.
The company's GHG inventory accounts for the six Kyoto Protocol gases 5, using Global Warming Potential (GWP)
indices from the Intergovernmental Panel on Climate Change (IPCC)'s AR46 over a 100-year period for accuracy inreporting.
Nortek's Scope 1 emissions, from company vehicles and boats, fell by 33.33% from 2019 to 2022, with continued
reduction efforts planned for 2023.

Scope 2 emissions

Energy indirect (Scope 2) GHG
emissions
Scope 2 (tCO2e)

2019

2020

2021

2022

Yearly change (frombaseline year)

25

25

30

28

12

Nortek's Scope 2 emissions rose by 12% from 2019 to 2022, attributed to increased use of electric vehicles. Conversely, Scope 1
emissions saw a substantial 33% decrease, indicating a shift towards greener vehicles. Aiming for 100% renewable electricity inglobal operations by 2030, Nortek plans more electric vehicle adoption and installing chargers at offices in 2023.

23

Nortek GRI Report 2022

GRI disclosure

Nortek response

305-3

Scope 3 emissions

Other indirect (Scope 3) GHG
emissions

2019

2020

2021

2022

YearlychangeWater supply

0,12

0,11

0,25

0,13

8,33 %

Waste disposal – Residual waste

1,31

0,88

1,2

1,39

6,1 %

Waste disposal – Paper and cardboard waste

2,66

2,45

2.35

2,04

-23,4 %

Waste disposal – Plastic waste

0,61

1,12

0,67

0,62

1,63 %

Business travel - Air

190,04

65,44

90

225

18,42 %

Business travel - Taxi

2,53

1,68

2

3

18,6 %

Business travel - Bus

0,26

0,25

0,22

0,15

-42,3 %

Business travel - Train

1,36

1,10

1,16

1,53

12,5 %

Hotel stay

12,23

7,25

9

14

14,47 %

Scope 3 (tCO2e)

Nortek's Scope 3 emissions are primarily from business travel, with waste disposal next, and minimal impact from water supply.
In 2022, the Boston office had the highest travel emissions, with Australia and Norway following. Business flight emissions grewby 18.52% from 2019 to 2022 and plans for 2023 include reducing travel emissions through increased virtual meetings.
305-4

Carbon intensity

Carbon intensity of total workforce
Carbon intensity of total workforce (tCO2e)

2019

2020

2021

2022

Yearly change (fromtarget baseline)

2,6

1,0

1,2

2,1

-19,23 %Nortek tracks carbon intensity per employee across all subsidiaries, noting the highest per capita emissions in Australia, the UK,
and Brazil due to extensive business travel among a smaller workforce.
Specifically, Australia's high travel emissions result from long-distance travel requirements and a small team spread across Perth,
Melbourne, and Hobart.
Overall, a 19% reduction in total emissions from 2019 to 2022 was achieved, helped by a growing employee base.

24

Nortek GRI Report 2022

GRI disclosure

Nortek response

305-5

Nortek's long-term climate strategy includes reaching net-zero emissions by 2050.

Reduction of GHG emissions

Intermediate targets include a 30% reduction in emissions by 2030 and a transition to 100% renewable energy for all offices
globally by the same year.

GRI 306 Waste (2020)
103-1

Nortek's operations produce waste primarily in manufacturing, supplier packaging, canteens, and offices.

Explanation of the material topic and its
Boundary

The company strives to minimize waste, tracking disposal and recycling rates with Norsk Gjenvinning to identify reduction andrecycling opportunities. Data from Norsk Gjenvinning details sorted waste amounts at Nortek’s Norwegian HQ and manufacturingsite from 2019 to 2022.
Sorted waste amounts, HQ in total:

HQ, Norway:Year

Sum waste [tonnes]

Waste sorting2019

22,54 tonnes

61,7%

2020

31,35 tonnes

50,3%

2021

23,94 tonnes

60,7%

2022

60,09 tonnes

89,1%

Average

34,48 tonnes

65,45%

Nortek's waste production averaged 30.75 tonnes across all locations from 2019 to 2022, with the HQ achieving a 65.45% wastesorting rate. Company growth doubled revenue and significantly increased waste, with the main manufacturing site's waste risingfrom 17.9 to 56.6 tonnes.
Waste disposal ranks as the second-largest contributor to Scope 3 emissions after business travel. While Nortek HQ has efficientwaste disposal via Norsk Gjenvinning, some of its international subsidiaries face challenges in waste infrastructure.

25

Nortek GRI Report 2022

GRI disclosure

Nortek response

103-2

Nortek is committed to sustainable consumption and production, managing waste per local regulations and sorting at source.
Specialized chemists safely handle chemical and hazardous waste, with staff trained in proper disposal practices. The
environmental impact of hazardous materials is minimal due to low usage volumes and secure handling. With Norsk
Gjenvinning's "Green responsibility" tool, Nortek tracks and monitors waste disposal.

The management approach and its
components

The company continuously explores ways to reduce waste and enhance recycling.
103-3
Evaluation of the management
approach306-1
Waste generation and significant wasterelated impacts
306-2Management of significant wasterelated impacts
306-3

•
•
•

Nortek Norway efficiently tracks waste generation.
Starting in 2022, subsidiaries, primarily producing office waste, are reporting on waste, and recycling.
Establishing a baseline in climate accounting for each subsidiary will guide waste reduction and recycling initiatives.

Waste disposal challenges necessitate improved handling, recycling, and energy recovery for ecosystem sustainability. For
details on Nortek's recycling and energy recovery rates, reference document 103-1.
Nortek partners with Norsk Gjenvinning for effective waste management at its headquarters, focusing on recycling manufacturing
and office waste. Global office waste systems vary, with some lacking adequate sorting and recycling services/infrastructure.
Nortek annual Sales Summits encourage offices to propose climate footprint improvements; Brazil's 2022 initiative aims toenhance battery disposal transparency and processes for Nortek's products.
Emissions from waste disposal – Nortek in total
2019

2020

2021

2022

Yearly change (fromtarget baseline)

Waste disposal – Residual waste

1,31

0,88

1,20

1,39

6,1%

Waste disposal – Paper waste

2,66

2,45

2,35

2,04

-23,4%

Waste disposal – Plastic waste

0,61

1,12

0,67

0,62

1,64%

Waste generated
Waste disposal - Scope 3 emissions (tCO2e)

Nortek's waste mainly stems from its production processes, typical of its industry and varying in volume. The supply chain also
contributes to waste through material extraction, processing, electronics production, and transportation to the manufacturing site.
306-4
Waste diverted from disposal

See 103-1 for more info about the recycling and energy recovery rates incl. landfill from waste generated by Nortek.

26

Nortek GRI Report 2022

GRI disclosure

Nortek response

306-5

See 103-1 for more info about the recycling and energy recovery rates incl. landfill from waste generated by Nortek.

Waste directed to disposal
GRI 308 Supplier Environmental
Assessment
103-1
Explanation of the material topic and its
Boundary

Nortek acknowledges the environmental concerns of stakeholders and is committed to involving suppliers in its goal to achieve
net-zero emissions.
Supplier engagement in decarbonization is key, as most of Nortek's carbon footprint originates from materials, parts, and suppliertransportation.

103-2

Sustainability assessment

The management approach and its
components

Nortek assessed top 15 major suppliers in 2022 based on their environmental practices, by using publicly available information
and annual reports, supplier meetings/site visits and audits.

Supplier sustainability assessment
Sustainability importance based on public information

•
•
•
•

Listed on thestock exchange

High

Medium

Low

6

4

5

5

40%

27%

33%

33%

Suppliers on the stock exchange showed high climate and sustainability focus, with large, multinational companies
involved.
Privately held companies had varied attention to sustainability, with limited data on small suppliers.
70% of suppliers prioritize sustainability, with three aligned with UN Global Compact's principles.
Most top-tier suppliers have ISO 9001 certification, with some also meeting ISO 14001 environmental standards.

27

Nortek GRI Report 2022

GRI disclosure

Nortek response•

103-3
Evaluation of the management
approach308-1
New suppliers that were screened using
environmental criteria

GRI disclosure

Nortek complies with EU conflict mineral regulations, ensuring ethical sourcing of 3TG materials used in electricalcomponents.

Nortek ensures suppliers adhere to environmental standards in its Supplier Code of Conduct. Regular meetings and audits are
conducted to monitor compliance and quality assurance.

Nortek commits to enforcing high environmental standards for suppliers, integral to its sustainability framework. Environmental
criteria for suppliers are detailed in the Supplier Code of Conduct.

Nortek response

GRI 400 Social topics
GRI 401 Employment
103-1
Explanation of the material topic and its
Boundary

•
•
•
•

103-2
The management approach and its
components

Nortek prioritizes customer focus, growth, and workforce adaptability, encouraging employee input and participation.
Key non-financial topics include health, well-being, incentives, risk culture, and skills development, alongside diversity
and inclusion.
The company aims to excel in managing social business aspects, upholding health, safety, equal opportunities, andcommunity support.
Governance focuses on compliance with laws, strategic execution, and best practices in anti-corruption, ethics,transparency, risk management, trade compliance and supply chain responsibility.

Nortek navigates a diverse workforce with varying age groups, education levels, and locations while competing for talent.
However, we continue our investment in our people through talent development for current and future roles, attracting andretaining talents and providing training programs and courses to new employees to empower the organization.

28

Nortek GRI Report 2022

GRI disclosure

Nortek response
Over the course of 2022:••••

Conducted employee satisfaction and well-being assessments in Norway.
Initiated strategy workshops for Group Management and Subsidiary Directors.
Organized multiple Town Hall meetings for all group employees.
Launched Nortek Academy, a one-week induction training for newcomers.

Moving forward Nortek plans to continue its people strategy with the aim of assessing:
•
•
•
•
103-3
Evaluation of the management approach

Employee engagement
•
•
•
•
•

401-1
New employee hires and employee
turnover

Implement talent and succession planning.
Enhance employee branding efforts.
Provide management training programs.
Extend health and well-being surveys to employees globally.

Conduct anonymous employee satisfaction and working environment surveys in Norway, with plans to include allcompany employees.
Global management meeting to discuss strategic topics and way forward.
HR focuses on enhancing managerial roles within the people strategy.
Maintain engagement via regular subsidiary board meetings and a working environment committee with 50% employee
representation.
Management addresses feedback from surveys with immediate and long-term actions.

New employee hires
2019

2020

2021

2022

23

9

28

7

2019

2020

2021

2022

Voluntary turnover

14

6

4

7

Involuntary turnover

0

0

0

1

New employee hires

Employee turnover rates

29

Nortek GRI Report 2022

GRI disclosure

Nortek response
The data includes only Nortek's IT-registered employees in Nortek AS and its subsidiaries, excluding contractors and temporary
staff.

401-2
Benefits provided to full-time employeesthat are not provided to temporary or
part-time employees
401-3 Parental leave

Nortek offers a compensation package with bonuses, insurances, and pensions. The package is tailored to local standards andmarket benchmarks pending location.

Nortek's parental leave policies align with relevant local laws and practices.

GRI 403 Occupational health andsafety (2018)
103-1
Explanation of the material topic and its
Boundary
103-2
The management approach and its
components

Nortek monitors organizational and psychosocial work environments via employee surveys, safety tours and implementation of
SE processes as described in the company HSE-manual.

Nortek Norway adheres to the HSE-manual per the Working Environment Act. The manual covers:
•
•
•
•
•
•
•
•
•
•
•
•
•
•

HSE policies and strategies
Organizational roles in HSE
Sick-leave and injury follow-ups, with prevention tactics
Reporting procedures for serious incidents
Maintenance of a healthy work environment
Compliance with internal control and laws
Mandatory use of safety equipment and handling of chemicals
Fire safety and first aid procedures
Structured HSE planning and emergency response
HSE educational programs
Regular workplace assessments and safety inspections
Thorough risk and job safety analyses
Detailed HSE performance tracking
Incident reporting mechanisms

30

Nortek GRI Report 2022

GRI disclosure

Nortek response•

The AMU and safety inspections provide essential insights for ongoing HSE improvements.

Workplace surveys are utilized to evaluate and prevent potential discrimination.
International offices
Nortek Netherlands operates with a Dutch-specific HSE-manual based on local laws. All global offices adhere to their respective
local HSE legislations and regulations.
103-3
Evaluation of the management approach

The HSE-manual and management system are key for handling HSE incident reports, investigations, and follow-ups. Serious
HSE incidents are reported promptly and assessed in quarterly KPI reviews. Nortek intends to conduct a due diligence on
subsidiaries' social and governance practices.

403-1

The HSE-manual is embedded in Nortek’s Management System. See section 403:103-2 for an introduction to the manual.

Occupational health and safety
management system403-2

Company level

Hazard identification, risk assessment
and incident investigation

Nortek's Emergency Preparedness Plan outlines responses for crises, ensuring accident and incident readiness. Preparednessaligns with Dimensioning Hazards and Accidents (DHA) the company must manage.
DHA1: Fire
DHA2: Burglary
DHA3: Fraud
DHA4: Fire
DHA5: Threats/violence
DHA6: Environmental accidents
DHA7: Personnel accidents / deaths
DHA8: Accidents when travelling for work
DHA9: Leakage of sensitive information or personal data
DHA10: Criminal data activities
DHA11: Production stop
DHA12: Crisis management/ accident subsidiary31

Nortek GRI Report 2022

GRI disclosure

Nortek response
DHA13: Pandemics
Department level
Hazard and risk assessments are conducted at the department level, focusing on manufacturing and workshops.
Incident investigation
Incident investigations adhere to standard procedures using techniques like root cause analysis, 5 whys, fishbone and FMEA.

403-3

Occupational health services are provided to Nortek Norway by external partner BHT-Gruppen, https://www.bht-gruppen.no

Occupational health services

Subsidiary offices may obtain occupational health services on a need to basis.

403-4

Manufacturing site in Norway

Worker participation, consultation, andcommunication on occupational healthand safety

Nortek has a Working Environment Committee with elected employee representatives. The committee’s main objective is toensure a healthy and sound working environment in the company. The committee’s tasks include:
•
•
•
•
•
•
•

Engaging in occupational health services and HSE work
Providing training and instructions on working environment issues
Evaluating plans for investments, rationalisation and changes that may affect the working environment
Evaluating and advising on HSE incidents, accidents, near misses, sick leave, and other working environment factors
Evaluating and advising on HSE training
Advising and facilitating the working environment for employees with health-related issues
Documenting the committee’s work in a yearly report

Employee engagement and participation is also described in section 102: 102-43 Approach to stakeholder engagement.
403-5
Worker training on occupational healthand safety
403-6
Promotion of worker health

HSE training follows the HSE-manual plan, which covers topics like chemical handling, protective equipment, machines,
workshops, company vehicles, etc. All employees must take first aid training.
The promotion of worker health in Nortek is described in section 403: 103-1 to 403: 103-3 and in 403: 403-1 to 403: 403-5.

32

Nortek GRI Report 2022

GRI disclosure

Nortek response

403-7

Expectations to the working environment, HSE and occupational health are addressed in the Supplier Code of Conduct. Nortek
will apply a similar policy to its business partners.

Prevention and mitigation ofoccupational health and safety impacts
directly linked by business relationships
403-8
Workers covered by an occupational
health and safety management system
403-9

HSE and occupational health are integrated into Nortek’s Management System for all workers. Nortek Norway and theNetherlands use local HSE-manuals, while other branches comply with local HSE laws.
Zero work-related injuries were reported in 2022.

Work-related injuries
403-10

Zero work-related ill health cases were reported in 2022.

Work-related ill health

GRI 404 Training and education
103-1
Explanation of the material topic and its
Boundary

At Nortek, all staff must be trained and knowledgeable to perform their duties effectively, adhering to the following criteria:••••

Position: Align with their specific role profile.
HSE: Ensure safety, preserving life, health, and the environment.
Management System: Comply with Nortek’s Management System.
External Requirements: Follow any applicable regulatory standards.

Details on Training and Competency procedures are available in Nortek’s Management System.
103-2

Nortek provides comprehensive training programs for its employees:

33

Nortek GRI Report 2022

GRI disclosure
The management approach and its
components

Nortek response
•
•
•
•
•
•

103-3

On-boarding training: New employees undergo an online on-boarding program, complemented by the Nortek
Academy's classroom and practical training at the headquarters in Norway, enhancing global expertise.
HSE training: Role-specific health, safety, and environmental training for all employees.
On-the-Job training: Practical learning within the relevant work processes and applications, crucial for skill
development in both practical and office roles.
Management training: A management training programmed is in the works.
Governance training: Mandatory for all, covering GDPR, Code of Conduct, cyber security, etc.
External courses and education: Encouragement and support for external courses and education relevant toemployees' roles, with special programs for career growth and development.

Evaluation of the management approach

Nortek's management acknowledges the importance of training and has developed a company-wide training program for both
new and existing employees over the past three years. This program undergoes an annual evaluation to explore ways toenhance and expand it.

404-1

This KPI is currently not measured within the company.

Average hours of training per year per
employee
404-2

See section 404:103-2. There are currently no formal transition assistance programs within the company.

Programs for upgrading employee skills
and transition assistance programs
404-3

All employees, 100%, receive annual performance reviews within the company held by their line-manager.

Percentage of employees receiving
regular performance and careerdevelopment reviews
GRI 405 Diversity and equal opportunity and 406 Non-discrimination
103-1
Explanation of the material topic and its
Boundary

Nortek values an inclusive and diverse workplace, recognizing that a variety of experiences, backgrounds, and opinions is crucial
to its success. This commitment is reflected in the company's Code of Conduct. With substantial international operations, Nortek
benefits from diverse perspectives and actively fosters diversity at all organizational levels. The company strives to ensure
respect, inclusion, and empowerment for all employees, from leadership to new team members.

34

Nortek GRI Report 2022

GRI disclosure

Nortek response

103-2

Nortek's Code of Conduct emphasizes non-discrimination and diversity, with a zero-tolerance policy for harassment or
discrimination of any kind. Key areas include:

The management approach and its
components

Recruitment: Candidates are assessed based on their merit and competence. personal characteristics and competence. Teamcomposition needs such as behavioral profile, age, and gender are considered when candidates are otherwise equally qualified.
In 2022, three (43%) women were recruited. The proportion of women in the company has increased by three percentage points,from 26% in 2021 to 29% at the end of 2022.
Wages and working conditions: Salaries are determined by job type, responsibility, and competence, with gender-neutral
evaluations. Salary increases are made annually based on location, industry statistics, assessment of individual achievements
and contribution to the company's strategy/results. All employees have equal opportunity for salary development.
Career development: The company offers growth opportunities through training, educational activities, transfers, andinternships.
Work-home balance: Nortek strives for flexible solutions, including home-office options and flexible on-site workdays, tomaintain work-life balance.

103-3
Evaluation of the management approach

The business has succeeded in achieving ethnic diversity among its staff in terms of both language, culture, and citizenship. By
the end of 2021, there are 82 employees that represent nine different nationalities.

405-1

Gender statistics management

Diversity of governance bodies andemployees

Board: 2/2 male
Level 1: Group management team: 3/7 female
Level 2: Global management team 8/23 female
As of 2022, the proportion of female employees within the Nortek group was 29%.

405-2
Ratio of basic salary and remunerationof women to men

Nortek's compensation philosophy is firmly rooted in equitable and fair pay for all employees. As detailed in the "wages andworking condition" section, salary assessments are based on job type, level of responsibility, and competence requirements,
ensuring a gender-neutral approach. The company upholds the principle that all employees, regardless of gender, should haveequal opportunities for salary growth and development.

35

Nortek GRI Report 2022

GRI disclosure

Nortek response

406-1

One incident was reported in 2022. The incident was resolved with the parties involved.

Incidents of discrimination and corrective
actions taken
GRI 412 Human rights Assessment
103-1
Explanation of the material topic and its
Boundary

Nortek’s commitment to operating in an ethical and lawful manner, including safeguarding human rights, serves as thefoundation for the relationships with the employees, customers, and suppliers, as well as the people in the different countries andcommunities in which Nortek operates. The commitment to act in an ethical and lawful manner includes protecting the basic
dignity and human rights of its employees and the people in its supply chain.
For more information, refer to Nortek’s:➢➢➢➢

Responsible business conduct statement (Norwegian Transparency Act). Full report available here.
Code of Conduct
Supplier Code of Conduct
Business Partner Code of Conduct

103-2
The management approach and its
components

103-3
Evaluation of the management approach

412-2
Employee training on human rights
policies or procedures

Nortek is dedicated to upholding human rights and decent working conditions, both within its own operations and throughout its
supply chain. Suppliers and business partners, including their own suppliers, are expected to adhere to the standards outlined in
the Nortek Supplier Code of Conduct and Business Partner Code of Conduct, which emphasizes social, environmental, andethical responsibilities. The company is committed to treating all workers respectfully and with dignity, ensuring safe working
conditions, and operating in an environmentally responsible and ethical manner.
Nortek requires its suppliers and sub-suppliers to comply with its Supplier Code of Conduct, emphasizing the importance ofunderstanding and managing their impacts on society and the environment. This commitment to due diligence is a key aspect of
Nortek's approach to corporate social responsibility and responsible business conduct, focusing on mitigating negative impacts inareas like human rights, working conditions, and environmental stewardship.
New employees at Nortek must adhere to the Business Code of Conduct and other company policies, which are covered in the
Code of Conduct training session.

36

Nortek GRI Report 2022

GRI disclosure

Nortek response

GRI 413 Local communities
103-1
Explanation of the material topic and its
Boundary
103-2
The management approach and its
components

Nortek's commitment to corporate social responsibility (CSR) involves contributing to society through philanthropic, educational,
or charitable activities, as well as supporting or engaging in volunteering, social outreach, and ethically oriented practices.
The most important way we can practice social responsibility is by developing innovative technology that enables people to gain
new knowledge that will help them contribute to societal, environmental, and economic progress.
Nortek’s core strategic priorities are:Enabling people through innovative technology
Nortek aims to empower researchers and scientists to make new discoveries and deepen their understanding of the aquaticworld. By developing and introducing innovative, efficient, and cost-effective technologies, Nortek is making it easier to study andsurvey the natural environments of oceans, lakes, rivers, and estuaries.
Working ethically by complying with Nortek’s Code of Conduct
Every employee at Nortek is personally responsible for adhering to the company's Code of Conduct. This Code underscores thecommitment to conducting business with integrity, respecting laws, cultures, and the dignity and rights of individuals in all thecountries where Nortek operates.
Work experience for students (Internships)
Nortek has a longstanding practice of offering opportunities to young individuals with limited work experience by regularly hiring
students and offering internships. This approach allows them to acquire valuable, relevant work experience in their respective
fields of study. Read more Nortek | Nortek internships pave the way for students in a growing… (nortekgroup.com)
Giving students access to Doppler technology
Nortek supports student teams in robotics and underwater navigation. An example of this is their assistance to Vortex NTNU
students in building an autonomous underwater vehicle (AUV). Nortek provided a Doppler Velocity Log (DVL), a crucial tool for
subsea navigation, enabling the students to compete in an international technology competition.

103-3
Evaluation of the management approach

Nortek is committed to supporting local communities through environmental, philanthropic, and educational initiatives. This
dedication to social responsibility is central to their aim of being recognized as a leading international company.

37

Nortek GRI Report 2022

GRI disclosure

Nortek response

413-1

Several local community initiatives were executing during 2022. Please see Nortek webpage for more details.

Operations with local community
engagement, impact assessments, anddevelopment programs
413-2
Operations with significant actual andpotential negative impacts on local
communities

Nortek minimizes its environmental impact in office workplaces and small-scale manufacturing by producing negligible emissions
to air or water. The company adheres to local guidelines for waste management, sorting waste at the source. This approachensures the waste poses no danger and mitigates landfill concerns, thereby reducing impacts on local communities.

GRI 414 Supplier social assessment
103-1
Explanation of the material topic and its
Boundary
103-2
The management approach and its
components
103-3

Nortek maintains strict ethical standards and legal compliance, expecting the same from suppliers and agents in alignment with
its Supplier Code of Conduct, and prioritizes addressing social issues with its suppliers.

Nortek requires its suppliers to commit to human welfare, ensuring they adhere to the Supplier Code of Conduct. This code
protects basic human rights, addressing issues such as child and forced labour, health and safety, fair wages and working hours.
Among Nortek’s top 15 suppliers, 100% have signed the Supplier Code of Conduct.

Evaluation of the management approach
414-1

All the top 15 suppliers are screened using the social criteria.

New suppliers that were screened usingsocial criteria
GRI 418 Customer privacy
103-1
Explanation of the material topic and its
Boundary

Nortek prioritizes cybersecurity and customer privacy, ensuring personal data safety with secure IT systems and mandatory
cyber security training for all employees. The company's privacy policy details how personal information is managed and used,also providing customers with options to exercise their privacy rights. Additionally, Nortek complies with GDPR regulations andintegrates these practices into its Management and IT-systems.

38

Nortek GRI Report 2022

GRI disclosure

Nortek response

103-2

For product or service purchases, Nortek collects and stores necessary customer information, including name, address, contact
details, and bank information. The company retains customer data during the active customer relationship and adheres toaccounting regulations by storing it for a minimum of five years from the last invoice.

The management approach and its
components

Evaluation of the management approach

To further evolve our company’s transparency, Nortek discloses the use of personal data to build deeper trust and retain loyal
customers. See Nortek’s Privacy Policy

418-1

For more information, see Nortek’s Privacy Policy.

103-3

Substantiated complaints concerning
breaches of customer privacy and lossesof customer data

1

United Nations (2015), Paris Agreement.
Act 18. June 2021 nr. 99 relating to enterprises' transparency and work on fundamental human rights and decent working conditions (Transparency Act). Act relating
to enterprises' transparency and work on fundamental human rights and decent working conditions (Transparency Act) - Lovdata
3
United Nations (1948), Universal Declaration of Human Rights.
4
Nortek Group (N.D.) Sustainability. Nortek | Nortek Sustainability (nortekgroup.com)
5
United Nations Framework Convention on Climate Change (1998), Kyoto Protocol to the United Nations Framework Convention on Climate Change.
6
Intergovernmental Panel on Climate Change (IPCC) (2007), Climate Change 2007: The Physical Science Basis. Contribution of Working Group I to the Fourth
Assessment Report of the IPCC. Cambridge, United Kingdom and New York, NY, USA: Cambridge University Press.
2