To our stakeholders:
To our stakeholders: I am pleased to confirm that Crayon Group reaffirms its support of the Ten Principles of the United Nations Global Compact in the areas of Human Rights, Labour, Environment and Anti-Corruption.

In this annual Communication on Progress, we describe our actions to continually improve the integration of the Global Compact and its principles into our business strategy, culture and daily operations. We also commit to sharing this information with our stakeholders using our primary channels of communication.
Sincerely yours,

Mr Torgrim Takle
CEO Crayon Group

Crayon Group's goal is to ensure all our employees and business partners support and uphold the Human Rights principles. Our Code of Conduct reaffirms this. In addition, our Code of Conduct clearly states our support for the Universal Declaration of Human Rights and our promise to always uphold these. This applies not only to our employees, but also the employees of our suppliers. To ensure compliance with Human Rights when it comes to our Suppliers, we have a dedicated Code of Conduct for Suppliers and Partners, specifically addressing the conduct we demand from any of these. This includes requiring partners and suppliers to adhere to the Global Compact principles on Human Rights.

In addition, we have a robust external whistle blowing system, allowing our employees to report any suspicious incidents to an external third party.

We take human rights related risks very seriously, and ensure our best efforts are always made to prevent them. To ensure our efforts are sufficient, we actively follow the UN Guiding Principles of Business and Human Rights. All our products seek to ensure human rights compliance. A good example of this is “fAIr by design”, an AI framework which Crayon Group is collaborating on along with five other companies as well as two universities. The project aims to provide a toolbox for creating AI that hinders machine learning solutions from making decisions affecting people in a discriminating manner. This includes non-discrimination against gender, race, religion, social status etc. The project Austrian Research Promotion Agency and Crayon Group is proud to bring industry standards to a higher level. This will also ensure the recent proposal for Regulation laying down harmonized rules on artificial intelligence (Artificial Intelligence Act) by the European Commission is upheld. All human rights that are internationally recognized matter to us. Naturally, in our business of technology and more specifically software, there are some human rights more at risk than others. These are what we are actively working to protect by designing, developing, implementing, marketing, and deploying frameworks and products such as “fAIr by design”.

By 2022, we aim to:
- Implement our human rights related risk assessment in our code of conduct.
- Expand the role of senior management with actively engaging in human rights by implementing a quarterly review of the company’s efforts to uphold human rights and prevent human rights breaches.
- Complete mandatory training for all employees relating to the upholding of human rights, assessment of human rights related risks and actions to be taken in situations of suspicion.

To measure how the company performs with regards to this fundamental subject matter, the external whistle blowing party will report back every six months with figures and numbers, making it easier for Crayon to circle in on which issues require more attention. Based on that, we can continue to set new goals and measure them accordingly. In addition, we have recently hired a Chief Compliance Officer, a role which is new at Crayon. The reason behind creating this role is our ongoing commitment to ensure compliance in all our business activities. Our Chief Compliance Officer will play a fundamental role in measuring our human rights efforts.

Crayon Group has taken/is taking the following steps to prevent human rights violations in its work locations:
- Mandatory training and awareness raising among employees, will start the following year and will be conducted annually thereafter.
- A suggestion box has been made available to all our employees electronically, allowing them to submit complaints and/or issues with regards to human rights and potential violation of these in the workplace. These complaints go straight to senior management of Crayon Group and are completely anonymous. Senior management immediately revises any submissions.
- We have outsourced our whistleblowing mechanism to an independent third party, ensuring complete and correct documentation for traceability, which again will help Crayon Group in our measurement of outcomes.
- Implemented measures to promote wage equality.
- Implemented a remediation procedure for identified cases of discrimination and/or harassment.

We aim to continue our strong efforts in working for the upholding of human rights and prevention of human rights violations.

Crayon Group has outsourced our whistleblowing mechanism to an external third party. As part of this outsourcing, Crayon Group will receive statistics relating to numbers of cases reported, number of cases resolved and how these were resolved. We aim to publish these in our annual reports.
Since 2020, we have conducted an annual survey of our employees, checking on their well-being. The results are reviewed by senior management and any results calling for change will be followed up rapidly, implementing necessary changes to ensure the well-being of our staff.

Our senior management have a quarterly review of human rights related cases. In these meetings, senior management evaluates the past quarter and decides how to move forward in the upcoming quarter.

Crayon Group’s wider Corporate Social Responsibility is evaluated by an independent third party, EcoVadis. In this evaluation, human rights are included as one of the four main areas. Crayon Group’s current rating is Silver, and we are happy to share that, according to EcoVadis. Crayon Group achieves the highest scores within labor and human rights, considerably above the industry average.

In our code of conduct, we state our support for the ILO Core Conventions and further outline how the company works to implement the eight fundamental conventions to ensure our employees’ protection. This of course includes our promise and continuous work to protect our employees’ right to collective bargaining, freedom of association, elimination of forced labour, child labour and employment discrimination.

Crayon Group has a formal written policy on Health and Safety-related matters (Crayon Group HES policy). The document covers a range of topics in detail, but in general it addresses how we continuously work with HES. We also have an HES check list used when the working environment committee makes rounds in the office, and a written policy on how to handle HES deviations. We also have a detailed health and safety related risk assessment in place.

In our Supplier Code of Conduct, we clearly state our demand that all our suppliers and business partners maintain the eight ILO Core Conventions.

In the upcoming year, Crayon Group aims to:
- Implement a defined role description, including benefit & compensation guidelines.
- Implement a suggestion box dedicated to labor related issues.
- Revise our HES policy.

Our Employee handbook is revised annually as part of the annual revision of our quality management system. It outlines the rights of our employees as well as highlight the responsibilities of upper management to ensure compliance with said rights. Our safety representatives in all our subsidiaries conducts annual tours of the offices to ensure employees’ wellbeing at work. This includes both the physical facilities as well as mental health for our employees. In addition, we have quarterly and annual business reviews with employees. These are conducted by the relevant manager and is a place for employees to voice concerns, suggestions and share thoughts on how to improve their well-being in the workplace. All our employees are always welcome to share any thoughts anonymously through the dedicated whistleblowing function.

Comparable pay for comparable work is ensured through our ongoing implementation of the defined compensation guidelines. This will level out the remuneration of our employees and ensure that it is coherent with the work which they provide. We annually revise all employees’ remuneration package individually. The implementation of the pay grade is a useful tool to ensure comparable pay for comparable work.

Operating in the technology industry, an industry which is traditionally male dominated, we are proud to be recognized by the SHE Index, having a score of 79/100. The past year, we have climbed from the 50th place (out of a total of 98 companies globally) to the 28th place (out of a total of 92 companies globally). Our top management now has 40 % female employees, as opposed to 33 % in the past year. Focus on Diversity & inclusion is a high priority for Crayon Group, and we will continue to work on this in 2021 and beyond.

Crayon Group is proud to have seen a positive development on the SHE Index. Our work for diversity and equality can be further illustrated by the demographics of senior management. 27 % of the employees within Crayon Group Management are women, including our CEO, Melissa Mulholland. Furthermore, our senior management team includes Norwegian, Tunisian, American, Swedish, German, Italian, Icelandic, Danish, British and Australian nationals. While 80 % of our senior management are 50 years of age or younger, the remaining 20 % ranges from 51 years to 59 years of age.

Crayon Group is committed to acting and adopting best practices to minimize our environmental impact and improve performance. Our target is to integrate environmental and sustainability objectives into the company strategy and growth ambitions. Even though our business is not one that has a major negative environmental footprint, we do have a written formal environmental policy that identifies ways and actions we can take to reduce the impact of our operation in the areas of waste management, sustainable procurements, and consumption.

Our environmental policy is a part of the Crayon Group’s Quality System that defines processes to improve energy efficiency and minimize harmful discharge, emissions, and waste production in a lifecycle perspective.

ENERGY CONSUMPTION
We focus on keeping our energy consumption low in our offices. Our offices are rented of professional landlords of commercial real estate, thus ensuring compliance with the environmental requirements imposed by the authorities. Routines are in place to ensure that windows are closed, the lights are switched off and ventilation shut down after office hours. We also ensure the use of energy efficient LED lamps with motion detection which automatically switch off the lights in a particular office section without people. In line with recommendations, the indoor temperature should always be between 20 - 22 °C in all Crayon Group offices, except in the summer when the indoor temperature should normally be between 20 - 24 °C.

In the last year, Crayon Group managed to reduce energy consumption by 31%.

In addition to this, Crayon Group has focused on ergonomic conditions for its employees. When purchasing office furniture, the workplace must have adjustable tables and chairs where appropriate. The offices must also be arranged in such a way that the lighting conditions are good and in accordance with government requirements.
Open landscape provides increased knowledge sharing and more flexible and well-being-oriented collaboration between employees. The focus is on noise reduction measures such as access to quiet rooms and small partitions or shelves and racks between workstations.

IT EQUIPMENT
Crayon Group's goal is for all ICT equipment to have a lifespan of at least three years. However, some groups of employees (such as developers) need more frequent equipment upgrades. Crayon Group have an agreement with the supplier about recycling, where the supplier shall ensure proper treatment in accordance with environmental considerations and collection of discarded equipment.

It is also possible to sell discarded equipment to employees after the equipment has undergone the security routines available for deleting passwords, user identities, personal information, old documents, photos, customer data, health information - all of which may be sensitive or confidential.

WASTE MANAGEMENT
Good waste management is in place in all our offices worldwide and Crayon Group makes efforts to facilitate for the best practices for waste management in all locations. Our routines comply with recommended guidelines and policies in all countries we operate. We have worked systematically for creating employee awareness in this matter introducing strict measures to reduce office waste. Our waste management routines ensure that all waste is disposed off in a way that does not create pollution or having the potential of hazardous to people, environment, or animals. All employees are responsible for appropriate and waste disposal. There are several sorting containers placed in the office landscape. All these stations are labeled for residual and organic waste, as well as paper. Food waste is handled by canteen suppliers who are trained in Crayon Group’s routines and guidelines.

Moreover, Crayon Group’s has consistently worked with creating awareness on the need to printing documents and encourage employees to work digitally. The printer settings are default black and white and double-sided printing. There are dedicated containers in all the offices for used ink and toners, lightbulbs, and batteries to ensure correct recycling.

TRANSPORT
Crayon Group has implemented specific measures to reduce the amount of CO2 emissions related to business travel. We encourage our employees to consider environment friendly travel alternatives. Crayon Group offices should be located close to public transportation. At our headquarter in Oslo, there is a bicycle parking for employees who want to use their bicycles to and from work. We offer also electric bikes to be used during office hours for transportation to and from client meetings, etc. The electric bikes can be reserved just like our meeting rooms. Additionally, the company covers a monthly travel card for public transport for consultants in projects.

Our policy restricts non-critical business travels. Other alternatives such as video conferencing, available company wide, should be used instead. If travel is the only alternative, the travel companies used during the business trip must be approved by the authorities for the operation of such activities.

We are determined to conduct our business in an ethical manner and expect our suppliers to share our commitment to avoiding pollution, minimizing emissions and waste, and developing and implementing environmentally friendly technologies and processes. This commitment is honored by complying with all applicable environmental laws and regulations, implementing policies to reduce and eliminate waste of all types. We also make sure to obtain, maintain, and keep current all required environmental permits for our operation.

Crayon Group has recently hired a Chief Compliance Officer with the overall responsibility for defining the necessary level of knowledge on existing and emerging regulatory compliance requirements across the organization, including environmental issues, by providing guidance advice, and/or training and educational programs, and to improve business' understanding of related laws and regulatory requirements.

Furthermore, Crayon Group has decided to hire a Sustainability Responsible with a mandate to support the management team in defining the key elements of Crayon Group’s sustainability / environmental strategy and driving key sustainability initiatives that support the company’s strategy.

Crayon Group has taken/is taking the following steps to prevent its environmental impact:
- Energy efficient work equipment.
- We have performed energy audits and carbon assessments.
- Introduced a strict waste management and recycling system in all officed worldwide resulting in reduced waste.
- Raised awareness about “need to print” and waste management.
- Implemented measures reducing CO2 emissions related to business travel.
- Introduced measures to prevent noise level in the open office space and control stress level of employees by providing noise cancelling headphones and call boots.

Crayon Group shall make every effort to promote environmental care, increase understanding of environmental issues and disseminate good practice in all environmental matters. We shall also strive to comply with all national environmental legislation.

Crayon Group’s goal is to define key elements of our sustainability / environmental strategy, as well as to support global and local initiatives that help us as a company to reach our environmental objectives.

Our ambition is to create a set of KPIs for all Crayon Groups office-locations and have a systematic sustainability reporting channel on environmental matters.
Crayon Group’s wider Corporate Social Responsibility is evaluated by an independent third party named EcoVadis. In this evaluation, Environment is included as one of the main areas, and according to EcoVadis, Crayon Group scores considerably above average with regards to environmental issues within the same industry.

Crayon Group also operates in locations exposed to inefficient governmental bureaucracy, lack of transparency of the public procurement process, corruption and bribery, Therefore, Crayon Group anti-corruption policy is developed with the purpose of describing our standards and expectations with respect to anti-corruption.
According to the anti-corruption policy, corruption is unacceptable business conduct, constitutes a threat to fair competition and undermines legitimate business activities. Any violation within our organization may subject both Crayon Group and individuals to criminal liability and would represent a risk to our reputation. Therefore, we are committed to making a positive contribution to society and environment by implementing responsible business practices that allow us to deliver financial success while conducting our operations in a responsible manner.

Crayon Group does not tolerate unethical behavior, including but not limited to bribes, kickbacks, or extortion of any kind. We comply with applicable anti-corruption laws in all countries we operate, and we expect everyone in our organization to understand what types of payments, transfers and business activities may expose Crayon Group to corruption risk. Corruption includes conflict of interest, bribes, confidentiality, and other ethical issues. All managers are required to sign the anti-corruption policy, as well as attend management ethics training (Course title; Ethics guidelines for managers).

We expect our suppliers to conduct their business with integrity and their operations must comply with all applicable law and regulations. Partners must comply with all relevant anti-bribery, anti-kickback, and anti-corruption laws. Partners must never promise, offer, request, authorize or accept a bribe, either directly or through a third party.

Crayon Group vets each partner/supplier using our Due Diligence procedure with a special focus on corruption and sign a Personal Data Processing Agreement, including any sub-processors. All customers and subcontractors are screened to verify registration data, legal status + VAT number, analyze cybersecurity risks, and verify all 3rd Party service agreements are legally justifiable.

Crayon Group practices a strict “four eyes” principle, meaning that no single employee can accept or perform any payments or expenses.

To counter the high risk of becoming a victim of corruption, fraud and/or data theft, or breaching data privacy and anti-corruption laws, Crayon Group has hired a Chief Compliance Officer (CCO). The CCO has an overall responsibility to further develop the annual compliance work plan, oversee and monitor the implementation of the compliance programs, as well as develop policies and programs that encourage managers and employees to report suspected fraud and other improprieties, without fear of retaliation. Furthermore, the CCO shall provide guidance, advice, and/or training and educational programs, to improve business' understanding of related laws and regulatory requirements, in addition to coordinate efforts related to audits, reviews, and examinations.

Crayon Group ensures a clear and well-documented whistleblower policy across the company. To enable full anonymous reporting of any irregularities, we use an external third party so the employees can safely report violations, suspicious behavior, or their concerns.

Crayon Group has taken/is taking the following steps to prevent human rights violations in its work locations:
- Mandatory training and awareness raising among employees, starting the following year will be a training conducted annually.
- We have outsourced out whistleblowing mechanism to an independent third party, ensuring complete and correct documentation for traceability, which again will help Crayon Group in our measurement of outcomes.

A set of relevant KPIs for this area will be developed and introduced throughout the company with a goal of a successful implementation of relevant activities. The outcome will be systematically reported to the Board.

A new mandatory training program for all employees covering anti-corruption issues will be introduced in 2021. The program is also a part of the onboarding of new employees. However, all Crayon Group’s existing employees will have to take the training annually too.

Crayon Group’s objective is also to further develop policies and programs that encourage managers and employees to report suspected fraud and other improprieties, without fear of retaliation and remind them about Whistleblower service in our internal channels.