This Code of Conduct is HMH’s key governing document which describes the ethical principles that guides our business operations. This Code of Conduct is the road map that puts our values into action and ensures continued success and safeguards our reputation. It is the guidepost for acting responsibly and with integrity in all our business operations.

The Transparency Act is a new Norwegian law which shall promote enterprises’ respect for fundamental human rights and decent working conditions in connection with the production of goods and the provision of services and ensure the public access to information regarding how enterprises address adverse impacts on fundamental human rights and decent working conditions as well as secure public access to information. 

The Act applies to larger enterprises that are residents in Norway and that offer goods and services in or outside Norway. The Act also applies to larger foreign enterprises that offer goods and services in Norway. 

The Act imposes enterprises to establish guidelines, perform human rights due diligence, establish actions to mitigate risk, monitor results, stakeholder dialogue and access to remedy. The Act entered into force on 1st of July 2022. 

HMH has established guidelines and routines to safeguard human rights and decent working conditions throughout its operations. Core governing documents for HMH’s management and compliance of human rights and decent working conditions are:  

• Code of Conduct
• Governing Sustainability Policy
• Know Your Customer Policy
• HMH Supplier Declaration
• Human Rights Risk Assessment
• eLearning course on Human Rights
• HMH Whistleblowing Channel

HMH has a whistleblowing channel available for external reports. HMH has not received any grievances or whistleblowing concerning human rights and decent working conditions. HMH does conduct risk assessments, and with a global presence there is an inherent risk that it may occur breach of human rights and decent working conditions in the supply chain. However, HMH  has not identified any actual adverse impacts or significant risk of adverse impacts through its risk assessments or the due diligences of business partners.

HMH’s policies and procedures, contractual terms and conditions, due diligence while onboarding and ongoing monitoring of business partners is key risk mitigating measures for addressing significant risks of adverse impacts.

HMH has recently completed the Transparency Act Report after conducting a thorough due diligence process involving assessing the presence of any adverse impacts on human rights or decent working conditions within supply chain. The report provides information about the assessment process and its outcomes.