The Transparency Act

In order to safeguard fundamental human rights and decent working conditions, the 99x Group
is committed to conducting regular due diligence and reporting on 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 subcontractors operate in accordance with relevant
standards for labor rights and human rights.

In our view, due diligence is an ongoing process through which we refine our approach 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 labor rights and
human rights in all markets in which we operate or have partners.

The 99x Group is headquartered in Oslo. The Group's companies in Norway, 99x Technology AS,
99x Solutions AS, Incrementi AS, Clave Consulting AS, Gture AS and 99x Increo AS offer software
development services for the Norwegian market, in cooperation with our group companies 99x
Technology in Sri Lanka, 99x Technology in Malaysia and 99x Tech in Brazil. The commercial
activities for the Norwegian market are mainly run by the Norwegian companies. Delivery and
customer success are jointly handled across Norway, Sri Lanka, Malaysia and Brazil. Our group
company in Portugal, 99x Tech, provides software development services for several markets in
Europe with developers based in Portugal and Brazil. In addition, our Brazilian company serves
US customers with developers based in Brazil. Our group company in Sweden, Republic Factory
AB, specializes in the design and development of digital solutions.

The group’s operations in Sri Lanka employ around 250 people, and local management works
closely with corporate management in all aspects of the business. Agreements regulate the
relationships between the group companies, and there is extensive daily communication among
them all. Staff from Norway also visit the companies abroad on a regular basis.

The 99x Group’s principles for following up on human rights and decent working conditions,
including due diligence of suppliers, are part of the Group's management system. Supplier due
diligence is carried out both centrally and in each subsidiary.

Responsibility for safeguarding human rights and decent working conditions is anchored at the
Board and senior-management level of the 99x Group, and integrated into the operating
procedures and guidelines of the group companies.

Employees and external parties can raise concerns about possible breaches through
transparency@99x.io

The Group conducts its due diligence in line with the OECD Due Diligence Guidance for
Responsible Business Conduct. These assessments are carried out regularly and are
proportionate to the size and nature of our operations, the context in which they take place, and
the severity and likelihood of potential adverse impacts.

 

The 99x Group used its suppliers and supply-chain business contacts as the starting point for
the assessment. The Group has implemented the Transparency Act on a group-wide basis to
ensure responsible supply chains.

As part of the 2025 assessment, the Group mapped and prioritized actual and potential adverse
impacts across its own operations, its subsidiaries, and its suppliers and business partners.
Suppliers were prioritized for closer review based on spend and location.

No deviations from guidelines or any form of negative consequences have been uncovered in the
due diligence assessment in 2025. We remain committed to improving our supplier selection
processes to ensure compliance across the entire supply chain.

This account is published in accordance with the Transparency Act § 5. It is made easily
accessible on the Group's website at www.99x.io , and its location is referenced in the Group's
annual report. The account covers the 2025 financial year and is updated and published by 30
June, in line with the Act.

This account of the 99x Group's due diligence has been considered and approved by the Board
of Directors and the Chief Executive Officer.

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