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.

Organization and operation:

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.

Results from the 2025 due diligence assessment:

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.

Who should I contact for more information?

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