Statement of Due Diligence Assessments

Introduction

Businesses subject to the Transparency Act (Åpenhetsloven) are required to report on their due diligence assessments. This report must be made public and easily accessible on the company’s website. It must be updated and published by June 30th each year or when there are significant changes in the company’s risk assessments. The report should be signed in accordance with the Accounting Act, section 3.3. The purpose is to provide the public with insight into key findings from the assessments and the measures implemented.

Due diligence assessments involve a six-step process that is regularly repeated. During these assessments, businesses must identify potential negative impacts they have or may have and implement measures to prevent, mitigate, or limit harm, and follow up on these actions. The law ensures that the public has access to this information so that consumers and stakeholders can monitor the company’s transparency regarding its challenges in the supply chains.

General Information, Our Guidelines and Procedures

Dignity Collective is a Norwegian company headquartered in Kristiansand, with branches in Bergen and Oslo. We support influencers and public figures in developing their own brands, providing product development, production, financing, logistics, online store management, and warehousing. Major brands include Careless and By Lien. Our primary supplier, Elements Production, coordinates production with factories in China and Turkey.

Dignity Collective is committed to sustainable business practices that respect people, society, and the environment. Our ethical guidelines, based on UN and ILO conventions, govern our operations and supplier relationships, ensuring compliance with high standards in human rights, labor practices, environmental protection, and more. Our guidelines must be signed upon partnership initiation and are regularly evaluated and enforced.

Principles for Sustainable Business Practices:

• Forced labor/slavery

• Trade union and collective bargaining

• Child labor

• Discrimination

• Brutal treatment

• Health, safety, and environment

• Wages

• Working hours

In our work with the Transparency Act and the due diligence process, we use Factlines’ digital solution and services. Factlines is a Norwegian-owned independent company specializing in monitoring ethical, social, and environmental requirements in supply chains. Factlines advises, develops, and produces services with digital support to obtain effective and verifiable information directly from suppliers and subcontractors.

We conduct annual information gathering from suppliers in the form of self-reporting. The questions in the self-reporting cover the requirements of the UN Global Compact, suppliers’ chain insights and follow-up practices, as well as their risk assessment related to breaches of ethical guidelines in the relevant production countries. This collection provides the basis for analyzing whether good practices have been established to comply with the Transparency Act.

Our suppliers are made aware of our ethical guidelines and are required to act in accordance with them, including ensuring their own production, procurement, and deliveries. If self-reporting or other indicators signal deviations, these are followed up through inquiries to the supplier. Depending on the scope and risk, deviations may lead to the establishment of improvement projects to create changes in collaboration with the supplier and other actors in the chain.

Due Diligence Assessments:

Most of our product purchases are made through a Norwegian production company. Their Code of Conduct is signed by the factories, and they have established guidelines for all suppliers and trading agents throughout the supply chain. The results from their self-reporting forms from Factlines show that they work thoroughly with their supply chain. They can provide the source and country of origin for our products and are transparent about suppliers and production sites. We are aware that textile production in countries like China and Turkey, which both score high on the ITUC Global Rights Index, involves a risk, and thorough work is done here to ensure the most ethically responsible production possible.

Their sustainability report and work with due diligence assessments can be read here:

https://elements-production.no/baerekraft

In general, we have assessed the risk as low since we base our actions on their reports and guidelines and have not prioritized further measures at this time.

For production where we purchase directly from the factory, we have assessed the relevant suppliers according to our guidelines. When entering into collaboration with new suppliers, we conduct thorough work with the desire for long-term collaboration. We start by mapping how they work with the environment, sustainability, and responsibility through self-reporting forms via Factlines. Our ethical guidelines/Code of Conduct must be signed, and requirements for third-party inspections, such as Amfori BSCI or Sedex, are also imposed. In the past year, we have also conducted factory visits to most of our suppliers, which is an important job for ensuring relationships and also observing the production site and registering any deviations.

Findings from Our Due Diligence Assessments:

Production in China and Turkey, both rated 5 on the ITUC Global Rights Index for 2024 (“no guarantee of rights”), could potentially negatively impact people, society, and the environment. We acknowledge this and are continuously gaining knowledge to identify risks. Based on information from Factlines’ self-reporting forms and our observations during factory visits, we have not uncovered violations of labor or human rights. However, we have identified some actual and potential negative consequences that require further follow-up, particularly in the areas of sustainability and environmental practices, where improvements are needed.

Our Measures:

We have not implemented specific measures to remedy any harm, as we have not yet identified any harm that needs to be addressed. During the reporting year, we experienced significant growth in sales and invested in the development of other product groups, which required us to source new suppliers. This is time-consuming work, but we aim to establish and maintain long-term relationships with these suppliers. We have sent follow-up questions where the self-reporting forms indicated discrepancies and suggested further follow-up. We continue to conduct factory visits to maintain relationships and monitor the implementation of measures. We will prioritize the follow-up of the findings we have identified, as mentioned above, but will also focus on:

• Living wages

• Allowance of trade unions

• The situation of women