Transparency Act

Statement pursuant to the Transparency Act for Xait AS

Xait AS is subject to the Transparency Act and has initiated work on due diligence
assessments in accordance with the Act’s requirements. The board has resolved that the
company shall comply with its obligations as defned in the Transparency Act, and that
guidelines concerning responsibility for human rights and working conditions shall be
applied.

Below follows Xait AS’s statement regarding due diligence assessments:

1. Organization and Business Area

Xait AS (org. no. 982 339 243) is a Norwegian technology company headquartered in
Stavanger. The company develops and delivers software solutions (SaaS) for document
automation, collaboration, and process improvement, aimed at the corporate market in
Norway and internationally. Xait AS is a wholly owned subsidiary of Xait Holding AS.

As a software company without physical production and with most of its value chain in low-
risk areas, Xait AS assesses the general risk of violations of human rights and unacceptable
working conditions in its own operations and supply chain as relatively low. Nevertheless,
we recognize our responsibility to ensure that our suppliers and business partners also
operate in accordance with fundamental human rights and ethical standards.

2. Due Diligence Assessments and Identified Risk Areas

In line with the Transparency Act and the OECD Guidelines, Xait AS has begun establishing
routines for due diligence assessments. In 2025, we will systematically map and assess
risks in the supply chain, with particular focus on conditions that may negatively impact
human rights and working conditions.

No actual violations have been uncovered so far, but potential risks have been identifed
related to suppliers connected to high-risk geographies and sectors (for example,
subcontractors providing IT services and data processing in third countries).

3. Planned Measures and Follow-up

As part of the implementation of the Transparency Act, Xait AS will develop and establish
the following measures during 2025:

• Ethical procurement routines: We will develop guidelines that impose
  requirements on suppliers’ working conditions, human rights, and sustainability.
• Systematic follow-up of suppliers: Procedures for documentation, evaluation, and
  regular assessment of supplier compliance will be introduced.
• Whistleblowing channels: A whistleblowing scheme will be established to enable
  employees and external parties to report concerns related to ethical matters.
• Risk classification of suppliers: All suppliers will be mapped and categorized into
  one of three risk classes:

• • Red – High risk: Requires thorough assessment and close follow-up
  • Yellow – Moderate risk: Requires regular assessment
  • Green – Low risk: Minimal follow-up obligations

The purpose of these measures is to ensure a more responsible and transparent supplier
relationship and to help prevent negative consequences in our value chain.

4. Availability and Updates

This statement is published in accordance with Section 5 of the Transparency Act. The
statement will be updated annually by June 30, or earlier if there are significant changes to
the assessments or measures. Download the Transparency Act here.

Date: June 2, 2025

Eirik Gudmundsen
Chairman of the Board and CEO, Xait AS

Frank Skavland
Board Member