• Code of Conduct for Brav Employees
• Chart of Authority
• Governing Documents
• Brav Portal to ensure transparency and availability of information to all employees
• Whistler-blower channel

Any Partnerships?

• External factory auditing partners.
• External Integrity Due Diligence (IDD) partner.

How do we monitor and report?

• Regular Factory Auditing
• Regular Employee Surveys
• Annual Product Risk Assessment
• Annual Supplier Risk Assessment
• General Risk Assessment in May and November
• Annual  Risk assessment report to the Board of Directors
• Responsibility on the Agenda with the Board of Directors
• Internal Inspections

Ethical trade and anti-corruption

• We work actively to ensure that our products are produced in compliance with acknowledged standards for ethical trade.
• Specifically, we contribute to the extinction of forced labor, child labor, discrimination, unsafe and unhealthy working environments, and wages below the poverty line.
• We have zero tolerance for corruption. Our main external partner is Ethical Trade Norway.

Brav Norway AS (“Brav“) is, as emphasized in our Code of Conduct and underlying procedures, committed to complying with all applicable laws and regulations. 

If our business partners (e.g. suppliers, distributors, consultants, or sales agents) violate ethical standards, this may pose both legal and reputational risks to our company. Our Third-Party Risk Management procedure provides tools to ensure that integrity risks are satisfactorily identified and considered in relation to onboarding and follow-up of our business parties and projects, and that the appropriate level of due diligence is performed. 

This procedure applies to all Brav wholly-owned companies and employees worldwide. Furthermore, Brav shall use its best efforts to ensure this procedure, or procedures that set out the same standards with respect to third-party risk management, are implemented in its majority-owned companies. 

It is the overall responsibility of Brav’s Chief Executive Officer (“CEO”) to ensure that each group company’s management (local manager) implements this procedure.

Risk mapping and categorization
To decide whether, and to what extent, a business partner shall be subject to integrity due diligence, a risk mapping must be conducted. The level of compliance risks (limited, low, medium, or high) associated with the business partner/project will in turn be decisive for the level of IDD required.  In general, our partners are categorized based on contract and factory location and the country’s score on the Transparency International Corruption index, the value of the yearly business, and strategic importance. This categorization is the foundation for Financial Integrity Due Diligence (IDD)  and Social Due Diligence (SDD). Risk assessment is performed before entering into a business relationship, periodically, and/or in case “red flag” incidents.

Brav, including all employees, shall never offer or receive illegal or inappropriate monetary gifts or other remuneration to achieve private or business benefits in their own interest or in the interest of customers, agents or suppliers. Brav has a zero tolerance for corruption. We require full transparency for all business transaction and do not accept bribes, facilitation payments or any other kind of improper private or business benefits to take place between Brav and suppliers, between suppliers and subcontractors, during social audits, quality controls, certifications or transport.

Our policy is further described in the documents Brav Employee Code of Conduct and Brav Supplier Code of Conduct, both policies downloadable under https://www.brav.com/responsibility/social/

Our products must be safe and healthy for our customers and the environment.

Brav is commited to ensure our products at all time are in compliance with the updated chemicals regulations Substances restricted under REACH – ECHA (europa.eu) and other world wide chemicals regulations such as Proposition 65, The Consumer Products Safety Act (CPSA) and TSCA.

All Brav suppliers must read, sign and follow our BRAV Restricted substance list RSL – Version 03.-1.3.2022.

We choose to lean on expert consultancy for double checking and advising on our updates in the regulations.

Brav is member of:

• The Research Institute of Sweden R.I.S.E
• Chemical Check Gefahrstoffberatung (chemical-check.com)

Speaking up and reporting unethical behavior

Brav is committed to building a culture of trust. To support this commitment, we encourage our employees and third parties working with us to raise concerns and report any suspected or potential breaches of laws, regulations or internal company policies.

Concerns may include, but are not limited to:

• Corruption and fraud
• Embezzlement
• Bullying
• Harassment and sexual harassment
• Discrimination in the workplace
• Social dumping
• Substance abuse
• Violation of environmental and human rights

Protection against retaliation

Brav will not tolerate retaliation against anyone who speaks up. There will be no impact on the individual’s professional career for reporting possible violations in good faith.

How to report?

In the whistleblower helpline you can report through the below channels:

• Online: Fill in an online form to report the concern. The form is available in English, but you may write in your native language.
• E-mail: You can send an e-mail to: [email protected] 
• Phone: You can call directly to: +47 406 39 400. This service is available Monday to Friday 09:00-15:30 hours (GMT+1). Your phone number will not be displayed to the receiver of the call.

How will we handle the report?

KPMG will submit the concern to BRAV’s HR Director. The HR Department will, together with KPMG when applicable, investigate and assess the reported concerns and make specific assessments of the handling of your concern, e.g: Who should be involved in the handling of your concern, how can the concern be reviewed and investigated, what measures should BRAV implement based on your concern etc.

If relevant we may request our third-party provider KPMG to assist with an objective follow-up investigation. As far as possible, you can expect to be kept informed about the progress and results of the investigation. 

You also have the right to notify other regulatory authorities or public authorities (e.g. the Labour Inspectorate, Data Inspectorate, Police etc.).

Our fundamental principles for follow-up of reported concerns are:

• All reported concerns are taken seriously and will be given fair and objective treatment.
• All information and factual reports related to a reported concern will be treated as confidential information, unless there is an explicit consent from the whistleblower to do otherwise.
• The handling and storage of personal data will be done in accordance with applicable data protection law
• The legal and human rights of the individual(s) who is (are) the subject of the report will be protected.