Hemnet Group ENG

Risk analysis Hemnet’smost significant risks and theirmanagement are described below. The risks are based on our focus areas but exclude risks linked to combating climate change and creating social change as these are not considered to constitute a significant risk for the company.

An independent and transparent marketplace

SIGNIFICANT RISK Inaccuracies in residential property advertisements on Hemnet or content in advertisements that may give an embellished image of the property for sale can have a negative impact on consumers and home buyers. This can lead to home buyers receiving incorrect information before buying, but also distort competition between real estate agents. Given the volume of information on Hemnet, there is always a risk that situations arise where a seller or buyer does not feel comfortable with or in control of the data we publish. Although we do our utmost to present information relating to cookies and personal data processing as simply and clearly as possible, there is always a risk that visitors will have difficulty assimilating information on, for example, personalisation and data sharing within the framework of advertising networks with which we collaborate.

RISK MANAGEMENT All home listings on Hemnet go through a registered real estate agent whomedia- tes Hemnet’s listing agreement with the home seller. This professional body of certified agents is an important guarantor of Hemnet’s quality, as the content of any home listing is the real estate agent’s responsibility. To ensure common rules for all players, we make publishing rules clear and available to all real estate agents. We also have a function within our customer service organisation that reviews and samples property listings on Hemnet on a daily basis, and contacts real estate agents whose advertisements deviate in various ways from the publi- cation rules. We have established processes in collaboration with the real estate agent industry to ensure that sellers and buyers are aware of what information is publis- hed on Hemnet. Transparency and clarity are key to ensuring that our visitors make informed decisions about personal data processing that requires customer consent. We regularly review our privacy information to ensure this. For more information on howwe work with personal data, see under the heading ”An inde- pendent and transparent marketplace”. RISK MANAGEMENT Hemnet has a great need to recruit developers. Competition for competence in this area is extremely high and during the year we have scaled up our internal recruitment function and resources tomeet our recruitment needs. By being agile in our approach, we can quickly adapt our recruitment resources as needed. We are also increasingly looking for workers outside Sweden, which is made possible by the fact that we have an English-speaking workplace. RISK MANAGEMENT Anti-corruption is an important part of our Code of Conduct that is central to the work of counteracting all forms of bribery, misconduct and corruption within the company. A benefit or advantage offered to an employee by an external person is not allowed if it affects or risks affecting the employee’s objectivity and ability to make commercially sound decisions. The Code of Conduct addresses the company’s internal guidelines on bribery and corruption and provides support to employees in their assessment. Employees are asked to report violations to their manager, their manager’s manager, Hemnet’s HRManager, Hemnet’s General Counsel or to use Hemnet’s whistleblower function. Hemnet takes relevant measures to investigate reported breaches and violations that may lead to legal consequences. RISK MANAGEMENT All development work at Hemnet takes place within the company, which means that we immediately can act upon and handle operational disruptions and other problems that may arise on our platforms. Furthermore, our large developer organisation works daily to improve our products as well as the user experience, to enable the very best conditions for real estate agents and home sellers to list a property on Hemnet. This, together with our strong market position, leads to a maintained and stable volume of listings year to year, where approximately nine out of ten homes sold through a real estate agent have been advertised on Hemnet.

Becoming the best workplace we can

SIGNIFICANT RISK Should Hemnet face challenges in recruiting for certain roles, this could have a negative impact on the rate of development of the company.

Principles of ethics and responsibility are reflected in every part of our business

SIGNIFICANT RISK Failure to comply with laws and regulations against bribery can have serious consequences for Hemnet and for the individuals concerned. Possible situations where violations could occur are, for example, in customer care or representation in the event that activities would go beyond what is considered appropriate, or that a real estate agent or home seller with contacts on Hemnet would manage to gain advantages for their property listing outside the company’s regular processes and routines. In addition to the obvious legal risks, misconduct would potentially be a breach of trust and detrimental to the Hemnet brand.

Enabling market efficiency

SIGNIFICANT RISK If Hemnet as a platformwere to lose its accessibility, supply and quality, it could negatively affect the ability of private individuals and real estate agents to carry out property transactions. Without access to Hemnet, the home buyers’ ability to access the property supply is hampered, as is the home seller’s ability to advertise his or her home - and the real estate agent’s ability to do business.

24 · HEMNET GROUP | ANNUAL AND SUSTAINABILITY REPORT 2021

SUSTAINABILITY REPORT

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