In order to safeguard fundamental human rights and decent working conditions, the 99x Group is committed to conducting regular due diligence and reporting of any findings and measures. With companies in Sri Lanka, Malaysia, Portugal, and Brazil, we recognize the importance of conducting thorough due diligence assessments to ensure compliance with the Transparency Act and promote responsible supply chains. We are committed to taking all necessary steps to ensure that our businesses, suppliers and our subcontractors operate in accordance with relevant standards for labour rights, human rights and environmental considerations.

In our view, due diligence is an ongoing process, improving our processes based on new knowledge, experience and best practices. Our goal is to ensure responsible and sustainable business operations and to contribute to the promotion of labour rights, human rights and environmental protection in all markets in which we operate or have partners.

Results from  the 2024 due diligence assessment:

The 99x Group has taken suppliers and business contacts related to the supply chain as its starting point. Our assessments, guidelines and principles are based on the Group's activities in Norway, Malaysia, Singapore, Portugal and Sri Lanka. Sri Lanka makes up by far the largest part of the organization with the most employees. The Group has implemented the Transparency Act in all subsidiary cases to ensure responsible supply chains. The purpose is to apply the same guidelines and principles to all companies and business areas in the Group.

In the work on the report for 2024,  no violations of its own guidelines have been identified or any form of negative consequences have been uncovered in the due diligence assessment. We remain committed to improving our supplier selection processes to ensure compliance across the entire supply chain.

If you have any questions about  our 2024 assessment, please contact transparency@99x.io

Organization and operation:

The 99x Group is headquartered in Oslo. The Group's companies in Norway, 99x Technology AS, Seeds AS, Incrementi AS and Clave Consulting AS, offer software development, mainly with assistance from our subsidiaries 99X Technology in Colombo, Sri Lanka, our partner LeanOn in Vittoria, Brazil and Cleverti in Algès, Portugal. The commercial activities are mainly run by the Norwegian companies. Solution development and customer service are mainly offered from Sri Lanka, Brazil and Portugal.

99X Technology in Colombo is a company with more than 400 employees and the company's management works closely with the corporate management in all aspects of the business. There are agreements that regulate the relationship between the various companies and there is extensive daily communication between all the companies. Visits are also made from Norway to the companies if necessary.

Compliance and Certifications:

The internal processes at 99x comply with the following standards.

• Agile for software project delivery and management
• ISO 9001:2015 Quality System
• ISO 27001:2022 Information Security
• ISO 27701:2019 Privacy Information Management System

Health and Safety Policy (OH&S):

Our occupational health and safety policy is documented in the company's own "F-PL03 Health and Safety Policy". The main points covered in the policy are:

• Management's commitment to providing a healthy and safe workplace for both employees and other personnel affected by the business of 99x.
• Roles and responsibilities for maintaining a healthy and safe workplace.
• Commitment to providing training and other resources for the successful implementation of the policy.
• Carry out occupational health and safety risk assessments and take mitigating measures.
• Reporting and follow-up of related incidents.
• Obligation to conduct internal and external assessments.
• Commitment to comply with the related regulations.

Leadership and Behavior:

We have a policy for business conduct under the name "P-PL01 Code of Ethics & Conduct Policy". Our guiding principles align with this purpose where, "We excite our customers, value each other and become our best "I"!"

We delight our customers:

• We work hard to deliver above expectations
• We innovate and solve problems
• We show courage and push boundaries

We value each other:

• We help each other
• We contribute to diversity
• Builds trust through an open culture

We develop to become our best "I":

• Excited by the freedom to lead
• Cultivating passion
• Continuous learning and development
• Become role models and global fellow human beings

We always act in a way that is consistent with the company's values. We support and encourage others to follow these values.

Bribery and corruption:

Our business conduct policy "P-PL01 Code of Ethics & Conduct Policy" covers the requirements of our commitment against bribery and corruption:

• We are committed to ethical and fair competition.
• We will make independent pricing and marketing decisions and will not cooperate or coordinate business activities with our competitors.
• We will not offer or solicit inappropriate payments or tips in connection with the purchase of 99x's goods or services or the sale of its products or services.

Our Business Conduct Policy "P-PL01 Code of Ethics & Conduct Policy" covers the requirements of our conflict of interest commitment:

• We must avoid any relationship or activity that could impair, or even appear to impair, our ability to make objective and fair decisions when performing our jobs.
• We must never use 99x property or information for personal gain or personally take for ourselves any opportunity discovered through our position with 99x.

Before our employees engage in any activity, transaction, or matter that may give rise to a conflict of interest, employees must obtain an assessment from 99x management.

Human rights and working conditions:

The company's human rights policy "P-PL02 Human Rights Policy" covers our commitment to protecting human rights in accordance with the United Nations Guiding Principles on Business and Human Rights. It covers the following:

We strive to respect and promote human rights in accordance with the UN Guiding Principles on Business and Human Rights. Our human rights policy takes into account the following key areas of it.

• Health and Safety - The health and safety of our employees is of utmost importance. Our policy is to provide a safe and healthy workplace and comply with applicable safety and health laws and regulations.
• Diversity and inclusion – We are committed to providing equal opportunities and are intolerant of discrimination.
• Terms of employment - We comply with applicable laws and regulations regarding employment, working hours, leave requirements and holidays. We offer affordable accommodations for qualified personnel based on disabilities and pregnancy/childbirth.
• Employee benefits - We compensate employees competitively in relation to the industry.
• Child Labor – We do not tolerate the use of child labor, forced labor, or human trafficking of any kind.
• Freedom of association – We respect our employees' right to join, form or not join a union without fear of threats or harassment.
• Right to privacy - We respect the privacy of our employees and business partners.
• Risk management - We conduct human rights impact assessments at regular intervals and before major decisions or changes to operations, followed by risk mitigation measures
• Complaint handling - We respect the employee's right to express their complaints without compromising their position.
• Community – We implement timely and sustainable CSR activities that will have a significant and measurable impact on our communities.
• Environment – We conduct our business in an environmentally responsible manner, with the intention of reducing our environmental footprint and protecting our planet.

Diversity and inclusion:

Our anti-discrimination policy "P-PL10 Respectful Workplace Policy" covers the requirements of our commitment against discrimination in the workplace as set out below. Discrimination is any negative action or attitude directed at someone because of protected characteristics, such as race and gender. Other protected properties may include:

• Age
• Religion
• Ethnicity/Nationality
• Disability/medical history
• Marriage/civil partnership
• Pregnancy / maternity / paternity
• Gender identity/sexual orientation

The company will not tolerate any form of discrimination that creates a hostile and unpleasant environment for employees or other stakeholders doing business with 99x. We realize that discrimination is sometimes unintentional, as we can all have unconscious beliefs that can be difficult to identify and overcome. In cases where we conclude that an employee is unknowingly discriminating, we will support them through training and counselling and implement processes that reduce behaviour.

Who should I contact for more information?

Please contact us for other questions or clarifications on transparency@99x.io