Åpenhetsloven

Statement in accordance with the Norwegian Transparency Act

Electrolux Home Products Norway AS (the “Company”) is a company within the Electrolux Group (the “Group”). AB Electrolux, the parent company of the Group, is a Swedish multinational home appliance manufacturer, headquartered in Stockholm and listed on Nasdaq Stockholm.

The company shall conduct due diligence in accordance with the Transparency Act each year and publish a report on the assessments and findings. The Norwegian Transparency Act is modeled on the OECD Guidelines for Multinational Enterprises, and its purpose is to promote companies respect for fundamental human rights and decent working conditions.

As a leading global appliance company, the Electrolux Group carries out due diligence pursuant to the OECD guidelines. Electrolux treats social responsibility issues with the utmost care by assessing and monitoring the business impact on social, labor and human rights in accordance with the OECD guidelines, and by taking accountability for the impact Electrolux business operations have on society, directly or indirectly through business partners.

This statement applies to the reporting year 2025 and has been approved and signed by all board members and the managing director.

About the Electrolux Group
The Electrolux Group is a global leader in home appliances, offering solutions for households including products such as refrigerators, dishwashers, washing machines, cookers, vacuum cleaners, air conditioners and small domestic appliances.

The Group has 32 factories on all continents and sells products/solutions to customers in more than 120 countries every year, under brands including Electrolux, AEG and Frigidaire.

In 2025, Electrolux had sales of SEK 131 bn and 39 000 employees around the world.

Governance
The Group’s Code of Conduct incorporates Electrolux’s Human Rights Policy Statement and sets out key principles in areas such as labor standards. The Workplace Policy establishes requirements for labor standards within Electrolux’s own operations. Corresponding requirements are reflected in the Electrolux Supplier Workplace Standard, which applies to suppliers. The Workplace Directive sets out detailed mandatory requirements applicable both to Electrolux’s own operations and to its suppliers. 

In 2019, Electrolux formed the Group’s Sustainability Board led by the CEO, which is the key forum for sustainability governance within the Group. The board proposes actions and targets to Group Management and it is essential in delivering on Electrolux sustainability goals, objectives and targets. It prepares recommendations on sustainability strategy, targets, and actions for decision-making by Group Management and the Board. 

Regular education in and communication about the Code of Conduct and key Group Policies are in place. All office-based staff must acknowledge the Code of Conduct by electronic signature. 

A number of Group functions are responsible for identifying and managing non-financial risks within their respective areas of responsibility. Such risks are reported to Group Management and are incorporated into the materiality process. Key sustainability governance responsibilities include:  

• The Board of Directors holds the overall responsibility for financial and sustainability reporting within the Group.
• Group Management is responsible for integrating sustainability into the overall business strategy and operations.
• The Sustainability Board oversees and provides direction for the Group’s sustainability framework.
• The Group Internal Audit evaluates and contributes to the improvement of governance, internal control and risk management processes.
• The Group General Counsel owns the anti-corruption policy and oversees its implementation and monitoring. The Group Head of Compliance is responsible for its day-to-day implementation. 
• Sourcing Boards are responsible for evaluating current and prospective suppliers. Directors within the Procurement function are responsible for ongoing compliance and performance, supported by the Group’s Social Sustainability team.
• The Ethics & Human Rights Steering Group is responsible for approving and ensuring the effectiveness of the Group’s Ethics Programme, including its approach to human rights and other relevant compliance programs related to business conduct. The Steering Group is also responsible for the Speakup Line (whistleblowing function) and the related processes, with the support of the intra-Group Ethics Coordination Group. 

Oversight of ethics and human rights lies with the Ethics & Human Rights Steering Group, which comprises senior management representatives from Group functions, including Sustainability, Legal, Human Resources & Communications, and Internal Audit. 

Line managers across the Group, are responsible for ensuring adherence with Group policies on human rights as part of our human rights governance structure. 

All employees are required to complete Code of Conduct and Workplace Policy e-learning modules during onboarding and through recurring training campaigns. These modules help ensure employees understand both their rights and responsibilities. The company also provides targeted training on these topics for suppliers.

Due diligence within the Electrolux Group
Electrolux monitors performance and manages risks through internal and external audits, for manufacturing units, local human rights assessments, education, the Ethics Helpline, management-labor dialogue, as well as health and safety committees. Risks in the supply chain are addressed through audits and training efforts as part of the Responsible Sourcing Program and the Conflict Minerals program. Human rights procedures engage many functions throughout the organization, from Human Resources to Purchasing and Group Operations.

Electrolux conducts human rights impact assessments at both Group and local level, in line with the UN Guiding Principles on Business and Human Rights, and the OECD Guidelines forMultinational Enterprises. The methodology for the assessments focuses on identifying the risk of harming people, as a direct or indirect result of Electrolux operations.

The Electrolux Group salient human rights issues include freedom of association, discrimination, working conditions, corruption, and supply chain risks such as occupational safety, forced labor and child labor.

Action plans are established to remediate impacts and risks identified in the local assessments, as well as to address the salient human rights issues. Electrolux continuously works to monitor business operations and the impact these have on social, labor and fundamental human rights, by identifying high risk operations and production countries through risk analysis. The entire Electrolux Group and its direct suppliers are subject to the evaluation and procedures described, including Electrolux Home Products Norway AS.

More information on the assessment of Electrolux social, labor and human rights impacts throughout the value chain can be found on pp.53-58, 64-69 70-76, and 107-124 in the Annual Report 2025 under the Sustainability Reporting section available here.

Additional relevant information is presented in the Conflict Minerals Report 2025, the Electrolux Group statement on modern slavery 2025 and on the Group’s website www.electroluxgroup.com.

The Modern Slavery report revealed nine cases related to indicators of forced labor in the supply chain. Six cases (five in Thailand and one in China) involved workers who were required to get management approval to leave the site during lunch and/or for access to rest rooms, two cases involved suppliers (or their recruitment agency) withholding employees’ passports and one case (Italy) involved a supplier that did not have a clear policy on forced labor. The practices have since been discontinued, and the Social Sustainability team has provided support to the suppliers through training and dialogue.

Due diligence within Electrolux Home Products Norway AS
Electrolux Home Products Norway continuously conducts assessments of the risk of adverse impact on fundamental human rights and decent working conditions linked with the company’s activities and business relationships. In general, due diligence is carried out as follows:

1. Mapping of the company’s supply chain and business partners 
2. Assessing the company’s overall risk profile, including its activities and business conditions (industry sector, products, services, production processes etc.) 
3. Based on the findings in Sections 1 and 2, the company considers appropriate measures to assess and address any adverse impacts on fundamental human rights and decent working conditions. Depending on the severity and likelihood of potential risks, and the company’s level of influence, it implements measures to mitigate such risks. The scope of the company’s responsibility to mitigate risks depends on its connection to the risk, as well as the size, nature, and context of its operations.
4. Where measures need to be implemented, stakeholders, suppliers and business partners are involved. Moreover, the company may consider collaborating with competitors or trade organizations to implement the relevant measures,

Electrolux Home Products Norway is primarily a sales and distribution entity of the Electrolux Group. The company is responsible for marketing, selling and supporting a wide range of household appliances in the Norwegian market, including kitchen and laundry products. While production takes place globally within the Group, the Norwegian entity focuses on commercial operations, customer services and ensuring that products meet local regulatory and market requirements. For Electrolux Home Products Norway the most salient risks are linked to the broader value chain rather than local operations, particularly labor conditions and supplier compliance with human rights standards.

The due diligence assessment conducted for the 2025 reporting year did not identify any actual violations of human rights or breaches of decent working conditions. Furthermore, no significant risks requiring immediate mitigation measures were identified. The company maintains ongoing monitoring and assessment processes and will implement relevant measures should new risks or impacts be identified.