01-04-2022

To our stakeholders:

I am pleased to confirm that Dolle A/S 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 share this information with our stakeholders using our primary channels of communication.

Sincerely yours,

Francois Grimal
CEO

DOLLE supports and respects the protection of internationally pro-claimed human rights within the framework of our influence.

We make sure that we are not complicit in human rights violations.as defined by the International Bill of Human Rights and the core labour rights set out by the International Labour Organisation as reflected in the Declaration on the Fundamental Principles and Rights at Work. We expect our suppliers to share our commitment to these standards.

DOLLE will not accept or be associated with child labour, forced labour or any form of human trafficking. This includes work on a forced contract, slavery and other forms of work that is done against a worker’s will or choice. DOLLE believes that all children have the right to a childhood and an education. We will ensure that no person is employed at an age younger than 15 or younger than the age of completing compulsory education.

it is the DOLLE policy that gender equality must be respected in all matters. Our activities are related to a predominantly male-dominated industry, reflecting the proportion of female employees in the group, which in 2021 amounted to 33%. It is the company policy that the proportion of women in management positions must reflect the total proportion of women in the company and at the same time respect that the best qualified applicants are selected in recruitment and promotion.

Our involvement in risk areas such as China and Ukraine are depending on the ability of our local leadership to carry out activities in accordance with our commitment and principles to respect internationally proclaimed human rights. DOLLE Management has concluded that our local management and business systems are solid and efficient in this regard, and we expect that the ongoing development of our CSR system within the Group will further support the work of our local management.

The engagement in our CSR systems from customers and other stakeholders has been increasing over the past 2-3 years. We welcome the increasing engagement to establish mutual standards and targets and to develop structured systems for current auditing and reporting on our performance in the coming period.

A yearly CSR statement has been included to the Dolle Annual Reports from 2020 as part of the mandatory reporting demands for C-class companies.

A Whistle-blower system has been implemented in 2021 to support the local management systems and employee committees.

A review of the Dolle Group Supplier Code of Conduct has been launched in 2022 with a direct reference to our commitment to the Global Compact principles. It has further been an important task to review our Supplier Code of Conduct to be fully align with the markets expectations as reflected in the Code of Conduct commitments we have given to our key accounts.

The local implementation of updated Supplier Code of Conduct, Supplier Assessment procedures and training of local staff will continue throughout 2022 coordinated by Group CSR in close cooperation with local management.

Dolle will primarily engage with long-term business engagements to support the mutual understanding of the values and performance, which is defining the relations with our business partners. With our major business partners, we normally have access to audit information’s through well-organized business systems supporting their CSR including also public information’s on their policies and performance. Our long-term personal relations with both major and minor business partners is however still having significant importance to the current adaption to the constantly changing demands and focus areas related to the CSR-agenda.

The Russian invasion of Ukraine in beginning of 2022 has demanded for a firm risk assessment both for the local activities as a hole and for the impacts and consequences for our local employees. Risk-assessment planning on our Ukrainian activities has been executed among others to back up our local management in their efforts to continue operations to the extent possible and to offer relevant support to our local employees suffering from the consequences of the invasion from Russia.

The total CSR effort has been frequently debated by DOLLE Management and Board of Directors to conclude our CSR Policy in 2021. All areas related to the CSR system has from 2021 been included in the company risk-assessment scheme, which has been successfully evaluated by DOLLE Management and the Board of Directors

There have been no reports in the past year on incidents related to Human Rights violations neither through internal reporting nor from the Whistle-blower system.

Current audits are conducted on-site from a number of key accounts, however with some limitations due to covid-19 restrictions, where audits have been made virtually. Both internal and external audits performed in the past year has been successful with only minor suggestions for improvement or further documentation, which has been implemented.

The total proportions of female employees remain stable with a small increase from 32% in 2020 to 33% in 2021 and with a proportion of female managers at 30% we therefore consider the target of the proportion of female employees to be fulfilled.

Employees at DOLLE or at our suppliers must be treated within the applicable national or local laws regarding employment.

DOLLE respects the core labour rights set out by the International Labour Organisation (ILO) as reflected in the Declaration on the Fundamental Principles and Rights at Work. We expect our suppliers to share our commitment to these standards.

DOLLE will not conduct business with suppliers that are associated with child labour, forced labour or any form of human trafficking. This includes work on a forced contract, slavery and other forms of work that is done against a worker’s will or choice. DOLLE believes that all children have the right to a childhood and an education.

DOLLE Management and our suppliers must ensure that no person is employed at an age younger than 15 or younger than the age of completing compulsory education. Where local legislation permits, workers ages 12-14 may undertake light work a few hours a day provided it is not likely to be harmful to their physical or mental health and development nor to prejudice their attendance at school.

Working conditions, hours, rest periods, leave and wages should be in accordance with local regulations and industry practice and should be at a level that enables a decent living standard according to local conditions. The normal work week must not exceed 48 hours. Overtime work should be voluntary, should not exceed 12 hours per week and should not be requested on a regular basis.

In companies where an organized labour union exists, working hours should be defined through the collective bargaining process. DOLLE and our suppliers must respect its employees’ right to organise themselves and negotiate collective wage agreements. If independent trade unions are either obstructed or restricted, the workers shall be enabled to gather independently to discuss work-related issues.

We expect DOLLE management and our suppliers to ensure that employees must have freedom of association and the right to collective bargaining consistent with applicable laws.

Wages may not be withheld as a disciplinary sanction.

DOLLE and our suppliers are expected to treat employees fairly without discrimination and employees must have equal opportunities and treatment in employment.
DOLLE and our suppliers are expected to respect employees’ right to privacy when gathering or keeping personal information or implementing employee-monitoring practices.

As a manufacturing company, DOLLE has a recognized risk of workplace accidents, and the management will set high standards for the level of safety and well-being of our employees, and thereby make DOLLE an attractive workplace.

Systematic measuring and follow-up on both physical and mental working environment will be carried out to ensure the prevention of accidents and incidents, and DOLLE strives continuously to be in a better position than the average of similar companies within our industry.

A review of the Dolle Group Supplier Code of Conduct has been launched in 2022 with a direct reference to our commitment to the Global Compact principles. It has further been an important task to review our Supplier Code of Conduct to be fully align with the markets expectations as reflected in the Code of Conduct commitments we have given to our key accounts.

The local implementation of updated Supplier Code of Conduct, Supplier Assessment procedures and training of local staff will continue throughout 2022 coordinated by Group CSR in close cooperation with local management.

Most labour related actions are today backed up by ratification of international standards in the local legislation to which we apply in the countries where Dolle is operative. Both corporate and local management at DOLLE is engaged to secure that our procedures are according to standards and legislations at any time.

DOLLE encourage continuous dialogue with our employees both directly and within local workers committees in order to secure a high level of information on company development, to involve relevant employees on working related tasks and to anchor centrally decided legislation or collective bargaining agreements in our local procedures and policies.

Our local Workers Committee and Health and Safety Committee are under responsibility of the local management involved in any breech or incidents where our procedures have been compromised and the committee will decide for relevant corrective actions or initiate an internal audit. Each local committee will decide for a standard meeting frequency (normally 3-4 per year) and is responsible for taking written minutes on their meetings and to secure appropriate information on their decisions. The committee further may decide to include various measurements, questionnaires and other management tools to qualify decisions on working environment, health and safety at DOLLE.

DOLLE encourages our employee to contact your immediate supervisor or workers representative upon experience of wrongdoing or offenses and report the incident. However, should an employee not find this solution appropriate, DOLLE has established a whistleblower scheme, where reporting can be made anonymously.

Besides the internal procedures established by DOLLE to avoid any breech of Health and Safety regulations the company is monitored and eventually controlled by public authorities holding the authority to make suggestions for improvements or issue sanctions to DOLLE in case of major breech.

The consequences of the covid-19 pandemic have since 2020 been influencing all operations of DOLLE, and numerous recommendations from authorities has been implemented and continuously changed as the pandemic developed. With substantial changes on the daily working environment DOLLE management have during the pandemic been focusing both on the physical and mental health of our employees.

The total CSR effort has been frequently debated by DOLLE Management and Board of Directors in order to conclude our CSR Policy in 2021. All areas related to the CSR system has from 2021 been included in the company risk-assessment scheme which has been successfully evaluated by DOLLE Management and the Board of Directors

All DOLLE companies has evaluated the working environment and reported incident related to Health and Safety with the respective workers representatives and committees and taken appropriate actions. There has been no major breech identified during the past 12 months.

The measuring on incidents related to Health and Safety includes major and minor accidents, internal failures and near-by incidents and is under implementation based on figures from 2021 and 2022 to establish a baseline for all DOLLE subsidiaries. With a target of being above average performance in our industry DOLLE must improve to reach maximum 20 registered incidents per 1 million working hours.

A survey on the mental working environment has in 2021 been successfully concluded with all employees in Denmark. The survey indicates improvements compared to the latest survey from 2018, but also concluded a need to establish more updated survey methods, which will be tested during 2022.

Due to lock-down periods related to covid-19 the meeting activities and audits has been at a lower level than normally, but still with an ability to perform the required controls, meetings, evaluations and actions through virtual meetings and other relevant communication platforms.

There have been no reports in the past year on incidents related to Labour Rights violations neither through internal reporting, working committees nor from the Whistle-blower system.

It is DOLLE's policy to take active part in environmental protection, take initiatives to promote greater environmental responsibility and encourage the development and deployment of environmentally friendly technologies.

DOLLE is continuously working to reduce the environmental impact of the company's operations, just as DOLLE products are constantly being developed to improve the energy profile, increase the product lifetime and minimize maintenance costs.

National and international law imposes increasing demands and requirements on our activities, and DOLLE will continuously adapt according to the evolution of both institutional and customer-driven requirements.

DOLLE has a long tradition of using wood from sustainable forest management and have in recent years increased the share of FSC-certified wood in our sourcing to meet the increasing demands in the market for sustainable products.

In close cooperation with our key accounts DOLLE will set targets and guidelines for product development in terms of using preferred materials and increase the content of recycled materials. A specific task will be addressed to minimize the use of packaging materials and the environmental impact of these materials.

Our factories are equipped with efficient and environmentally friendly treatment of wood waste, which contributes to a positive impact on our energy consumption, as waste is a valuable source of heating in the factories and the local community connected to our heating system.

DOLLE and our suppliers must comply with local environmental laws, and we expect operations to be carried out with care for the environment and with effort to minimize negative impacts on the environment. We expect an active approach to limit the use of resources. This includes minimizing the use of raw materials, energy and water, handling waste in an environmentally responsible way and recycling materials as much as possible.

DOLLE and our suppliers shall be in compliance with REACH (Registration, Evaluation and Authorization of Chemicals) and RoHS (Restriction of Hazardous Substances).

All suppliers must have a written environmental policy or statement that is appropriate for the size and type of operation.

DOLLE expects suppliers to have an environmental management system, preferably one that is certified in accordance with ISO 14001 or an equivalent Environmental Management System.

The climate impact from DOLLE operations and our products shall be addressed and reviewed during 2022 in order to establish a corporate model for calculation of the carbon footprint of our business

During 2021, environmental and climate factors has been an essential part of the requirements specified in new investments in production facilities, new product development and the development of new product and material standards.

To secure the supply chain on FSC certified wood DOLLE has taken action to increase capacity on critical manufacturing resources with the objective of having a more direct control on the raw material processing and to strengthen our close relations and dialogue with our key raw material suppliers. At the same time Dolle shall from Q4 2022 offer full chain of custody on FSC within all DOLLE Companies.

The market demands for FSC certified wood has increased significantly in the past years and the supply chain is now challenged by
• lack of sufficient capacity from certified suppliers
• an increasing lack of commitment and willingness to certify or re-certify due to increasing certification costs and significant demands for no-FSC logs outside Europe
• the war in Ukraine which unfortunately has contributed to worsen the situation due to the significant part of European timber normally supplied from Ukraine and/or Russia

DOLLE foresee a need to engage even further with our raw material suppliers to secure the demands for timber in general and especially the FSC certified wood needed to reach our target of being 100% FSC wood supplier from 2025.

The substantial consumption of wood in our production is a key source for the heating energy on our factories which secures an important and sustainable energy source both internally and to the local communities nearby the factories, where DOLLE can contribute to central heating systems in the community.

DOLLE will continue to invest in more energy efficient solutions at our factories, which has in the past 12 month included major investment in new heat exchanger system to reduce heating loss from exhausting systems in Denmark and stronger insulation demands set for of new factory building in Romania to reduce heating loss.

DOLLE Loft ladders are currently improved to minimize the heating loss in private houses where the product is installed, and with the patented ClickFix technology DOLLE offers a market leading technology to minimize the heating loss from our products.

Driven by solid standards from key retailers in the business, DOLLE welcomes the efforts to reduce the environmental impact from packaging materials and will based in new development engage to implement new standards for packing materials and packaging procedures. Especially the reduction of plastic materials and implementation of alternative packaging solutions will be addressed with a target of 30% reduction to be met in 2025 combined with exclusion of certain packaging materials.

DOLLE will engage with our suppliers to increase the use of recycled materials in our products and to improve the current documentation of environmental impact from our materials.

DOLLE has established systems for waste handling and sorting in order to support highest possible re-use or recycling of waste materials from our own activities.

The total CSR effort has been frequently debated by DOLLE Management and Board of Directors in order to conclude our CSR Policy in 2021. All areas related to the CSR system has from 2021 been included in the company risk-assessment scheme which has been successfully evaluated by DOLLE Management and the Board of Directors

There have been no reports in the past year on incidents related to Environment violations neither through internal reporting nor from the Whistle-blower system.

Even though not all customers are yet demanding FSC wood DOLLE decided from 2021 to establish a supply chain, who are able to support the target of sourcing 100% FSC in 2025, and consequently the share of FSC wood supplied to our factories increased from 60% in 2020 to 94% in 2021.

DOLLE has in beginning of 2022 concluded a specific policy on packaging materials setting targets for improvements in our packaging concept in terms of sustainability, recycling, preferred materials and reduction of plastic materials in the packaging. The new packaging policy will be implemented in all new product developments from 2022 and shall be fully implemented in all products from 2025. This will include 100% FSC on all paper and cardboard materials, 25% reduction of plastic materials (by weight) in packaging and increasing recycled content in plastic materials up to 30%.

Investments made in both Denmark and Romania has in 2021/2022 contributed to more efficient heating by reducing heating loss from buildings and exhausting systems. Consequently, the volume of waste material used for heating can be reduced and preferably used to increase supplies to heating centrals in our local communities.

A pilot project on a new corporate reporting standard in DOLLE on our energy consumption and carbon footprint has been initiated based on data from the Danish operation and will be concluded during 2022.

DOLLE works against corruption in all its forms, including bribery and facilitation payments.

DOLLE has established policies that do not allow corruption in any relationship where personal interests are mixed up with those of the public service, such as bribery, mandate fraud and favouritism. None of the company's employees are allowed to give undue benefits to national, foreign or international officials or employees in the private sector or receive undue benefits.

We are constantly working to ensure transparency in our business system, and frequent reviews are conducted through both internal and external audits and controls, which to a large extent is executed with either international laws or standards as a reference.

DOLLE's operational activities are characterised by long-term and stable partnerships and relationships who are familiar with our business values and that fully comply with the Code of Conduct for our external suppliers.

We expect that our suppliers do not engage in any form of corrupt practices, including bribery, extortion, or money laundering, whether directly or indirectly. This means that a supplier must never, directly or through intermediaries, accept or offer bribes. Suppliers shall also refrain from offering expensive gifts or extravagant entertainment to DOLLE employees to influence business decisions.

All suppliers must act in compliance with national and international competition legislation and regulation.

We expect suppliers to maintain adequate procedures for preventing employees, subcontractors etc. from undertaking any illegal behaviour regarding corruption.

Review of Dolle Group Supplier Code of Conduct has been launched in Q1 2022 in order to include direct reference and commitment to the Global Compact anti-corruption principles.

With the launch of a corporate whistle-blower system DOLLE has strengthened the organisational responsibility and procedures to handle anti-corruption.

Our involvement in risk areas such as China and Ukraine are depending on the ability of our local leadership to carry out activities in accordance with our commitment and principles regarding anti-corruption. DOLLE Management has concluded that our local management and business systems are solid and efficient in this regard, and we expect that the ongoing development of our CSR system within the Group will further support the work of our local management.

The total CSR effort has been frequently debated currently by DOLLE Management and Board of Directors in order to conclude our CSR Policy in 2021. All areas related to the CSR system has from 2021 been included in the company risk-assessment scheme which has been successfully evaluated by DOLLE Management and the Board of Directors

There have been no reports in the past years on incidents related to anti-corruption violations neither through internal reporting nor from the Whistle-blower system.
Dolle Management has reviewed and concluded that our local management and business systems are robust and effective in this regard and has not identified in 2021 any conditions in the form of corruption, bribery, fraud or extortion.

The rate of implementation and executing of external supplier audits by DOLLE has been limited by the Covid-19 restrictions in 2021. The ongoing control and dialogue with the company's primary suppliers has not given rise to any remarks or significant deviations from the applicable agreements.