Transparency Act

- Statement for Geilo Holding AS

Last updated: February 15, 2024

1. About Geilo Holding AS
Geilo Holding AS is a group that works with destination development, leisure property, and lift operations in Geilo, and is subject to the international compliance framework regarding human rights and labor rights. This statement aims to explain and document the work of Geilo Holding AS and its subsidiaries, as well as SkiGeilo AS, concerning human rights and workers' rights, and the measures taken to comply with the Norwegian Transparency Act. We fully acknowledge our responsibility to respect human rights as set out in international human rights law and are committed to implementing the UN Guiding Principles on Business and Human Rights, as well as the OECD Guidelines for Multinational Enterprises throughout our company and operations.
The Geilo Holding group mainly consists of two business areas: property development and ski resort operations. The property development is organized with a management company, SkiGeilo Utvikling AS, and several project companies. The ski resort and its associated businesses, such as the restaurant, ski school, and ski rental, are organized under a single company, SkiGeilo AS, but as different sub-departments

2. Policies and Frameworks
Geilo Holding AS has implemented a set of guidelines in our handbook to ensure respect for human rights and decent working conditions both within our own operations and throughout our supply chain. Our ethical guidelines outline the expected behavior of our employees and stakeholders. We also have policies covering business ethics, anti-money laundering, and anti-corruption, as well as health, safety, and environment (HSE) practices on construction sites. It is a prerequisite that our development gradually transitions to a green shift and that we actively work on issues related to climate, nature, and the environment. To ensure that all our suppliers and partners adhere to our rules for ethical business conduct, we introduced a Partner Agreement in 2023 that must be signed upon contract initiation for new collaborations.

3. Due Diligence and Risk Assessments
A due diligence and risk assessment has been carried out for the property segment of the group, Geilo Holding AS and its subsidiaries, and a due diligence and risk assessment has been conducted for the SkiGeilo segment of the group. This is because these are two different business areas with relatively different suppliers and business partners. The property segment consists of fewer and larger Norwegian suppliers. In the SkiGeilo segment, there is a broader range of suppliers, from smaller local companies to larger Norwegian companies and a few larger foreign companies related to lift and snow production equipment deliveries.
Geilo Holding AS and SkiGeilo AS perform due diligence assessments in accordance with the due diligence process recommended by the OECD, Due Diligence Guidance for Responsible Business Conduct. This involves:

1. Embedding responsibility in the company's policies and management systems
a. 1.1 Develop, approve, and communicate policies for responsibility
b. 1.2 Embed policies in management and governance systems
c. 1.3 Incorporate policies into contracts and agreements

2. Identify and assess adverse impacts related to the business
a. 2.1 Map the company's supply chain and identify risks
b. 2.2 Conduct in-depth analyses of the greatest risks to identify adverse impacts
c. 2.3 Analyze the company's involvement in adverse impacts and identify measures

3. Cease, prevent, or mitigate adverse impacts
a. 3.1 Stop activities that cause or contribute to adverse impacts
b. 3.2 Develop and implement plans with preventive measures

4. Monitor implementation and results
a. 4.1 Monitor the company's due diligence assessments

5. Communicate how impacts are managed
a. 5.1 External communication on routine, measures, and findings

6. Provide for or cooperate in remediation where required
a. 6.1 Ensure that any necessary remediation is carried out
b. 6.2 Provide grievance mechanisms that allow for complaints

Our due diligence process includes a supplier survey sent to all our suppliers with questions related to human rights, working conditions, anti-corruption, climate, nature, and the environment, as well as how our suppliers follow up with their subcontractors. This was carried out jointly with the group, and in 2023, we achieved a response rate of approximately 25%. The responses from the survey, in addition to our assessments and transaction amounts, have been the basis for our risk assessments. The majority of our suppliers are located in Norway with predominantly Norwegian labor. Beyond this, a relatively large proportion of our suppliers are smaller local actors in the Norwegian districts. In our risk assessments for 2023, we have not uncovered any significant breaches but see a tendency for our suppliers to be able to structure and streamline their work around anti-corruption and climate, nature, and environment. To increase awareness and competence among our suppliers on the topics of human rights, working conditions, anti-corruption, climate, nature, and environment, we are introducing a Partner Agreement from Q3 2023 that must be signed by all our suppliers and partners.

4. Competence Building and Training
Geilo Holding AS has reviewed the Transparency Act and its associated legal requirements with all employees internally and has introduced a new common practice for handling new suppliers.

5. Reporting
We strive to create a culture of transparency with continuous dialogue about what is and is not compatible with our values and guiding documents. Employees are encouraged and required to report any suspected or observed violations of law, ethical guidelines, or other guiding documents. Reports should be made to a manager or through our digital deviation reporting system, where anonymous reports can also be submitted. External parties can report by sending an email to [email protected].

6. The Way Forward
The work on due diligence assessments and compliance with the Transparency Act is an ongoing effort that we will actively work to improve year by year. Initially, we will focus on better follow-up with our suppliers and ensuring that they adhere to our ethical guidelines. This includes signing our Partner Agreement, as well as conducting more random checks. Steering meetings with suppliers are an important arena for awareness-raising, competence-building, and follow-up and will be a natural place to include increased focus on compliance with human rights, working conditions, and climate and nature.

7. Board Approval
In accordance with the duty under the Norwegian Transparency Act, this statement is published in accordance with the board's approval.