STATEMENT OF DUE DILIGENCE ASSESSMENTS UNDER THE TRANSPARENCY ACT
(JANUARY 1, 2024 – DECEMBER 31, 2024)
STATEMENT OF DUE DILIGENCE ASSESSMENTS UNDER THE TRANSPARENCY ACT
(JANUARY 1, 2024 – DECEMBER 31, 2024)
1. ABOUT CAPPELEN DAMM
Cappelen Damm is Norway's largest publishing house. We develop, convey, sell and distribute knowledge, culture and reading experiences to adults and children.
Cappelen Damm launches analog and digital publications in all genres in the general market and for all educational levels in the teaching markets, where the publisher takes universal design into account, which means taking into account variations in functional ability among users. Cappelen Damm Education prioritizes this by complying with and fulfilling all legal requirements, continuously improving content and design, and incorporating universal design into system development.
In total, the publisher launches about 3000 new releases per year: hardcover first editions, digital teaching aids, audiobooks, e-books and paperback. This accounts for, according to the Publishers Association's industry statistics, almost 40% of all book publications in Norway.
Cappelen Damm AS is 100% owned by the holding company Egmont Holding AS, which in turn is 100% owned by Egmont International Holding AS. This statement applies only to Cappelen Damm AS ("Cappelen Damm"). Therefore, it does not apply to Cappelen Damm's wholly-owned subsidiary Sentraldistribusjon AS. Sentraldistribusjon AS will publish its own statement under the Transparency Act.
2. ABOUT THE TRANSPARENCY ACT AND ITS REQUIREMENTS
The Transparency Act came into force on July 1, 2022, and aims to promote businesses' respect for fundamental human rights and decent working conditions in connection with the production of goods and the provision of services. The public should be ensured access to information about how businesses handle negative consequences for fundamental human rights and decent working conditions. Among other things, the law imposes on businesses an obligation to provide information and a duty to conduct due diligence assessments, which must be accounted for in a report presented annually - the first time by June 30, 2023.
3.
CAPPELEN DAMM'S PROCEDURES FOR WORKING WITH HUMAN RIGHTS AND DECENT WORKING CONDITIONS
3.1 General Strategy
Cappelen Damm has for many years been concerned with, among other things, social rights, and the publisher follows Egmont's ethical guidelines and program for social responsibility where due diligence assessments of our suppliers are carried out in accordance with the Transparency Act. Cappelen Damm follows the advice, recommendations and orders of the authorities with regard to cooperation with suppliers and the use of raw materials that originate in, or are connected to, countries that are subject to trade boycotts by the UN and/or Norwegian authorities.
In this work, necessary priorities are made that help to anticipate, prevent and minimize risk in the value chain. If due diligence assessments identify breaches of ethical guidelines, with subsequent actual negative consequences or significant risk of such, the cooperation may be terminated. Prioritization of the risk of human rights violations is made based on the severity, scope and likelihood of potential negative impact or damage.
The Transparency Act does not apply to foreign companies that are not taxable in Norway, but Cappelen Damm sets requirements for our subcontractors regarding human rights and decent working conditions. Our foreign suppliers and partners who are not obligated by the Transparency Act are still obliged to respect human rights and decent working conditions through our contracts with them, and any other regulations the suppliers are subject to.
Due diligence assessments are part of the publisher's value chain and aim to improve the understanding of markets, strategic suppliers and supply sources, as well as strengthening control over company-specific business and operational risk. The publisher also uses due diligence assessments in prequalification processes for suppliers and other business relationships.
Communicate how the impact has been managed.
Monitor implementation and results.
Identify and assess negative impact/damage based on own business, supply chain and business relationships.
Anchor accountability in guidelines and management systems
Cappelen Damm will initiate appropriate measures to stop, prevent or mitigate the adverse impact and follow up on the measures initiated and the results. Cappelen Damm will ensure to communicate with affected individuals and cooperate on possible remediation and compensation where necessary.
Ensure or cooperate on remediation and compensation where required.
Stop, prevent or reduce negative impact/damage.
If the publisher should uncover reprehensible conditions in its own company, in the supply chain or with other partners, the publisher will account for this, by addressing what has been done and to rectify the situation and strive to influence the outcome in a positive way. This promotes transparency and enables the consumer to make informed choices.
To comply with the requirements of the Transparency Act, Cappelen Damm carries out risk-based and prioritized risk assessments to anticipate, prevent and minimize the risk of potential violations of human rights and decent working conditions in its own operations and value chain.
3.2 How the due diligence assessments are carried out Cappelen Damm's due diligence assessments start by categorizing all suppliers and partners into risk categories. The category in which suppliers and partners are placed is determined by risk factors such as jurisdiction and industry. Statistically, there is a greater risk of human rights violations and breaches of decent working conditions in countries like China and India than in typical Western European countries. At the same time, Cappelen Damm is aware that Western European suppliers may have supply chains in risk-prone countries. Furthermore, there are certain industries that have different risk profiles. Labor-intensive industries with elements of production will have a higher underlying risk of indecent working conditions than, for example, in the consulting and advisory industry.
Cappelen Damm's work under the Transparency Act is based on the principles of a risk-based approach and proportionality. The higher risk category we assign to our suppliers and partners, the more measures we implement to ensure that they respect human rights and decent working conditions. This can range from surveys, conversations with the suppliers, background checks of companies and their owners, to audits (physical inspections) carried out by neutral third parties.
If reprehensible conditions are discovered within our own business, in the supply chain or with other business partners,
4. CAPPELEN DAMM'S RISK ASSESSMENTS AS OF DECEMBER 31, 2024
4.1 The Transparency Act and Cappelen Damm's various suppliers and partners
The publisher's value chain is extensive, complex and diverse, and consists of suppliers, business partners and contributors. The publisher's "supply chain" consists of suppliers and subcontractors who deliver or produce inputs that are part of Cappelen Damm's delivery of goods and services to end users. Cappelen Damm's "business partners" are partners who deliver goods or services to Cappelen Damm, but who cannot naturally be said to be part of the company's supply chain. Examples are lawyers, auditors and landlords. Cappelen Damm's contributors are typically authors, consultants, translators, illustrators, proofreaders and designers etc. Cappelen Damm has carried out risk assessments of its partners in accordance with the principles set out in section 4.2 below.
4.2 Risk categorization
Cappelen Damm has systematically worked to categorize its suppliers and business partners according to a defined scale. The categories range from high-risk suppliers in China to lowrisk suppliers such as public companies and agencies (both production and administration - state and province/region). It is the high-risk suppliers that will be the focus of Cappelen Damm's due diligence assessments from now on.
Cappelen Damm has a few suppliers in high-risk countries like China and India. These are typically printers that Cappelen Damm is either in direct contractual relationship with, or that are used by collaborating publishers in co-productions. Cappelen Damm has on some occasions observed that the risk of indecent working conditions associated with these businesses is particularly high. More thorough investigations have been initiated for these suppliers; also to follow up on possible breaches. Through the publisher's due diligence assessments in the prequalification process for suppliers and other business relationships were identified at two suppliers potential deviations compared to the risk assessment. The publisher chose not to continue further negotiations with these actors. No deviating conditions were uncovered in connection with the risk assessment 2024.
Cappelen Damm has a particular focus on risk associated with co-productions. In co-productions, Cappelen Damm purchases the rights to publish books in the Norwegian market, while it is a foreign publisher that handles the printing. These publishers can use suppliers in high-risk countries like China for production.
In co-productions, one often faces longer supply chains, which means that Cappelen Damm has a more indirect (yet important) influence on ensuring decent working conditions in the "lowest link". Recognizing that it can be difficult to identify supply chains and inherent risk in co-productions, Cappelen Damm categorizes suppliers and partners within co-productions as high-risk. In co-productions, we set strict requirements for our direct partner (the foreign publisher) to ensure that human rights and decent working conditions are respected. Cappelen Damm has focused on this even before the introduction of the Transparency Act.
Generally, partners in the "contributors" category will represent a low risk of violations of human rights and decent working conditions.
5. ENVIRONMENT AND CLIMATE
Although environment and climate are not at the core of what the Transparency Act seeks to protect, there is a connection between environment, climate and human rights. Damage to the environment and climate can have consequences for fundamental human rights such as the right to life and health, as it can affect people's access to clean water, shelter and food. This is especially true for people in already vulnerable situations such as children and indigenous peoples. This is why Cappelen Damm include our work with issues regarding environment and climate in this the statement.
Our goal is to spread knowledge and introduce measures internally in the organization. We want to cooperate with nature and climate measures in the industry. We want to facilitate far
better circular solutions and we want to do our part so that our customers can make informed choices. Cappelen Damm wants to contribute by spreading knowledge and creating debate through our publications, and by taking responsibility for ensuring that the publications create the least possible climate impact.
Lower emissions occur either by making current materials and production methods less polluting, or finding new and lower emission alternatives. This is done by risk assessing products, supply chains, geographical conditions and company-specific risk factors.
Cappelen Damm also has a special focus on risks associated with the production of paper. A book consists of various raw materials, and these have different value chains and different procurement structures. This makes a uniform approach unsuitable. Several valuable and critical raw materials can only be obtained from a few geographical areas. These may include resource-rich areas characterized by corruption, conflict, weak rule of law and lack of enforcement of labor laws, and are risk assessed.
Read more about our environmental and climate work in our climate and environmental reports here: https://cappelendamm.no/baerekraft/sustainability
The document is digitally signed by the board and the CEO in March 2025.