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.

Regular management review meetings ensure that the target and KPIs are continually aligned with regulatory requirements and industry best practices. Vigilance processes are aligned with national and international regulatory requirements, where specific deadlines dictate the timeline for reporting incidents. We employ a trigger-based monitoring approach for CAPA (Corrective and Preventive Actions), where certain thresholds (e.g., exceeding specific KPI limits) automatically initiate a root cause analysis.