Provide a detailed account of the methods and channels utilized to communicate your policies to the relevant individuals, groups, or entities. This includes those expected to implement the policies, such as employees, contractors, and suppliers, as well as those with a vested interest in their execution, like workers and investors. Describe the tools and mediums employed, such as flyers, newsletters, dedicated websites, social media, face-to-face interactions, and workers' representatives, to ensure policy accessibility and comprehension among diverse audiences. Additionally, elucidate the strategies employed to identify and eliminate potential dissemination barriers, including translation into pertinent languages or the use of visual aids.

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The GN Ethics Guide is managed and updated by the Group Business Ethics & Compliance department and applies to all GN employees, including members of the Board of Directors. The GN Ethics Guide is aligned with generally accepted standards of ethical business conduct as well as applicable regulations. It is publicly available on GN’s website in ten different languages via www.gn.com/documents and for employees also via GN’s intranet. All employees and consultants are required to complete the annual mandatory Ethics Guide e-learning. In-person training is also offered where needed. Additionally, all new employees are asked to read and acknowledge the GN Ethics Guide as part of their onboarding.

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ESRS disclosure: S4-1_09

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