Reporting period: 1st October 2024 – 30th September 2025
Published: 30 June 2026
Contact: info@aheadgroup.no
1. About the Company
Ahead Group Norway AS is a Norwegian agency group providing integrated communications, marketing, strategy, creativity, data and technology services. The group is wholly owned by Aller A/S headquartered in Denmark. Ahead Group Norway operates mainly in Norway and serves clients across private and public sectors.
Services span the full communications value chain: brand strategy, digital marketing, CRM and loyalty, content production, advertising, film production, and insights and analytics.
1.1 Scope of this statement
This statement is made pursuant to Section 5 of the Norwegian Transparency Act (Åpenhetsloven) and covers Ahead Group Norway AS and the following Norwegian subsidiaries, all of which are included in the due diligence assessment:
- Oculos AS
- WergelandApenes AS
- Bloom Oslo AS
- 11:11 AS
- AGN Midco AS
The statement does not cover Aller Group entities in Sweden, Finland or Denmark, which are not subject to the Norwegian Transparency Act.
1.2 Governance and internal policies
Responsibility for Transparency Act compliance is anchored at group level. A cross-functional working group with participants from across the organisation meets regularly to review risk findings and implement measures related to the Transparency Act. The working group is led by the COO and reports to group management. The Board of Directors approves this statement annually.
The following internal frameworks govern the company's approach to human rights and decent working conditions:
- Aller Group Code of Conduct: mandatory for all employees and applicable to all directly and indirectly owned subsidiaries, covering human rights and labour rights (grounded in the ILO Declaration on Fundamental Principles and Rights at Work), anti-corruption, data ethics, editorial independence, health and safety, and non-discrimination
- Aller Group Data Ethics Policy: applies across all Aller entities, setting binding principles for data processing: individual self-determination, privacy, accountability, security, and data minimisation
- Ahead Group Supplier Code of Conduct: The requirements of the Ahead Group Supplier Code of Conduct are attached to the contract terms with all new suppliers and business partners upon engagement. The Code covers human and labour rights, health and safety, environmental impact, business ethics, and data protection. An updated version is currently being developed, informed by the results of Ahead Group's Double Materiality Assessment conducted in 2025. Systematic monitoring of signed agreements across the full active supplier base will be formalised as part of the Aller Group's standardised supplier risk assessment and management process, currently under development
- Whistleblower channel: an anonymous reporting mechanism available to employees, suppliers, and other external parties, operated through the Aller Group whistleblower network
- Employee survey: structured assessment of working conditions, culture, and wellbeing conducted twice yearly across all entities
- HSE (Health, Safety and Environment) routines: procedures covering risk assessment, workplace safety, incident reporting, and sick-leave follow-up, maintained in Simployer
2. Risk Identification
The following risks have been identified through Ahead Group Norway's due diligence process. Risk identification draws on: (i) the Ahead Group's Double Materiality Assessment (DMA) conducted in 2025 in accordance with CSRD requirements, which identifies material impact topics for Ahead Group specifically; and (ii) operational review of suppliers and business partners conducted by the cross-functional working group on an annual basis. Risks were identified and assessed based on their potential severity and likelihood.
Ahead Group Norway has not, during this reporting period, documented actual confirmed breaches of fundamental human rights or labour standards in its own operations or direct supply chain. However, the due diligence process has identified the following areas of material potential risk requiring continued attention.
Own operations
- Working time, workload, and work-life balance: Ahead Group's project-based operations involve deadline-driven cycles and variable workloads that can place sustained pressure on both contracted employees and directly engaged freelancers. For freelancers, who form an important part of Ahead Group's workforce, these risks may be more pronounced given the absence of standard employment protections governing working hours and rest periods.
Supply chain
- Health and safety in upstream supply chain: Workers in Ahead Group's upstream supply chain, including event material production and logistics, face physical health and safety risks such as manual handling, machinery operation, and transport. Ahead Group primarily sources these services from suppliers based in the Nordic region.
- Privacy and personal data: Ahead Group processes personal data on behalf of clients as part of CRM, loyalty, and digital marketing services, creating risk that inadequate data protection practices in own systems or those of third-party technology sub-processors could result in unauthorised use or exposure of personal data, with potential harm to the individuals concerned.
3. Measures and Results
The following measures have been implemented or are in progress in response to the risks identified in Section 2. Where specific outcomes have not yet been fully evaluated, this is noted. Where measures are insufficient or gaps exist, planned actions are described.
3.1 Working time, workload and work-life balance
Employee surveys are conducted twice yearly across all entities, measuring workload, work-life balance, stress and overall wellbeing. Survey findings are reviewed by group leadership and addressed through local management processes. Where findings indicate elevated stress, sick-leave risk or other concerns, targeted follow-up actions are implemented. Employees also have access to psychological support through Moment organisasjon og ledelse, providing up to 10 hours of counselling per year by agreement with their manager.
In the 2025 employee survey, the question measuring whether employees have sufficient flexibility in their working day scored 4.3 out of 5.0 across Ahead Group Norway. Ahead Group will continue to monitor this indicator across future survey cycles and is evaluating the inclusion of additional questions to enable a more comprehensive and consistent assessment of working time, workload and work-life balance across all entities.
3.2 Health and safety — upstream supply chain
Ahead Group sources production, event materials, and logistics services from a range of suppliers across multiple upstream stages. Supplier requirements, including the Ahead Group Supplier Code of Conduct, extend to health and safety standards and are contractually required before engagement commences.
Ahead Group recognises that its ability to directly verify working conditions is limited. The primary risk mitigation is therefore contractual and procedural: ensuring H&S requirements are embedded in supplier agreements and that new suppliers are assessed before onboarding. The Aller Group is currently in the process of developing a standardised supplier risk assessment, which will enable more structured and consistent evaluation of suppliers going forward.
3.3 Privacy and personal data
Ahead Group Norway operates within the Aller Group Data Protection Framework, a Board-approved compliance structure mandatory for all employees and entities. The Framework encompasses 13 specific policies covering the full GDPR compliance lifecycle. The Aller Group Data Ethics Policy sets binding principles across all entities covering individual self-determination, privacy, accountability, security, and data minimisation.
As an agency group delivering services on behalf of clients, Ahead Group Norway engages third-party technology sub-processors in areas such as campaign delivery and data analytics. All such processors must be subject to written data processing agreements meeting GDPR Article 28 requirements, including prior security vetting and ongoing compliance monitoring. International transfers of personal data outside the EU/EEA require a valid transfer mechanism and, where Standard Contractual Clauses are used, a Transfer Impact Assessment.
Data subjects' rights are supported through established group-level procedures covering access, rectification, erasure, restriction, portability, and objection. All employees are subject to mandatory data protection training tailored by role and refreshed on an ongoing basis.
4. Conclusion
The due diligence process has identified significant risks across the areas described in this report. No violations of fundamental human rights have been identified in own operations or supply chain during the reporting period.
The identified risks are being actively managed through the measures described in this report. Key priorities for the coming period include:
- Continued monitoring of employee workload and work-life balance through twice-yearly surveys, with targeted follow-up where findings indicate elevated stress or sick-leave risk
- Completing development of the Aller Group standardised supplier risk assessment to enable more structured evaluation of upstream suppliers against the Ahead Group Supplier Code of Conduct
- Continuing to strengthen data protection practices across the full GDPR compliance lifecycle, including contractual oversight of third-party sub-processors and ongoing mandatory employee training
- Finalising the updated Ahead Group Supplier Code of Conduct, informed by the results of the 2025 Double Materiality Assessment
Enquiries regarding Ahead Group Norway's work on human rights and decent working conditions can be directed to info@aheadgroup.no and will be answered within three weeks.
Signatures
The statement has been approved and signed by the board of directors and the managing director in accordance with Section 3-5 of the Norwegian Accounting Act.
Managing Director: Kjetil Botten Skogly
Chair of the Board: Morten Krüger
Board Member: Michael Aller
Board Member: Christopher Aller
Board Member: Sascha Aller