Transparency Act – Snow Group

Information regarding Snow Group’s commitment to human rights and fair employment standards

As of July 1, 2022, the implementation of the Norwegian Transparency Act requires Snow Topco AS and its subsidiaries to conduct diligent assessments in accordance with the guidelines set by the OECD for multinational companies. We are also obligated to address information requests from the public and provide an account of our diligence processes. To submit such requests, please contact us at: transparencyact@axogroup.com.

Snow Topco AS is committed to safeguarding fundamental human rights and ensuring fair working conditions throughout the Group’s operations. We believe that transparency and ethical conduct are foundational to long-term success. Our duty extends to both internal practices and the broader supply chains we are connected to across the Nordic region.

About Snow Group

Snow Topco AS is the parent company of a Nordic financial services group operating under two fully owned business areas: Axo Group and Zmarta Group. Axo Group operates a digital platform connecting consumers with financial institutions, while Zmarta Group offers comparison and distribution services for loans, insurance and related financial products. Together, the Group serves millions of users annually across Norway, Sweden, Denmark, and Finland, and employs approximately 300 people.

The Group has grown significantly through strategic acquisitions. In 2021, Axo Group acquired the Danish broker LendMe (MNW ApS), in 2022 the Norwegian credit data platform Defero AS, and in 2025, Zmarta Holding AB and its subsidiaries became part of Snow Group through a corporate acquisition completed in Q1 2025.

Group Structure and Legal Entities

All operating companies in Snow Group are owned through Axo AS, the Group’s main operating and holding company. Axo AS is a wholly owned subsidiary of Snow Topco AS and serves as the legal parent for all business units across Axo Group and Zmarta Group.

The current legal entities within Snow Group include:

• Axo Finans AS (NO)
• Defero AS (NO)
• Axo Finans AB (SE)
• Axo Finance OY (FI)
• MNW ApS (DK) / LendMe
• Zmarta Holding AB (SE)
• Zmarta AB (SE)
• Zmarta AS (NO)
• Zmarta Forsäkring AB (SE)
• Elskling AB (SE)
• Freedom Rahoitus Holdings OY (FI)
• Freedom Rahoitus OY (FI)
• Zmarta Norge Filial (SE)
• Certitidae Norway AS (NO)

All entities operate under the same ethical framework and are subject to the Group’s policies, procedures, and compliance obligations under the Transparency Act.

Group Guidelines and Governance

The Transparency Act applies to multiple independent legal entities within Snow Group, including companies in both Axo and Zmarta Group. All companies in the Group are expected to comply with our core principles for promoting human and labor rights. In line with this, Snow Group is implementing a new Group-wide Code of Conduct rooted in the UN Global Compact. The Code sets the foundation for our expectations in areas such as human rights, labor rights, business ethics, equality and non-discrimination, and environmental sustainability.

Policies and routines will be reviewed and updated in 2025 to reflect the Group’s expanded structure.

Commitment to Human Rights and Working Conditions

Snow Group takes a systematic approach to embedding respect for human rights across all operations. This includes fair wages, regulated working hours, and zero tolerance for child labor, forced labor or discrimination in any form. These principles apply both to internal employees and the suppliers we work with.

The Group continuously assesses risk in our value chains and evaluates potential exposure to human rights violations. With the implementation of our new Supplier Code of Conduct, all key suppliers will be expected to comply with our standards and support continuous improvement.

We apply heightened scrutiny in higher-risk regions and sectors, and seek to prevent any direct or indirect involvement in violations of human rights or labor standards.

Risk Assessment and Due Diligence

Snow Group maintains robust due diligence and compliance processes across all subsidiaries. Risk assessments are conducted to identify areas where human rights or working conditions may be exposed to risk. In connection with the Group’s expansion through acquisitions, updated assessments are being conducted in 2025.

Based on our most recent assessments, we have prioritized the following areas for increased focus:

• Strengthening procurement routines and supplier monitoring.
• Promoting fair labor standards in third-party operational settings.
• Building internal competence on responsible business conduct and human rights.
• Data protection and handling of personal information.

We have internal systems in place to prevent, identify and mitigate potential negative consequences in these areas. This includes whistleblower procedures, supplier audits, data protection protocols, and compliance training. Across the Group, due diligence is a continuous process driven by accountability and improvement.

Planned Actions

To further strengthen our approach to responsible business conduct, Snow Group is initiating the following actions:

• Updating the Group Code of Conduct and implementing it across all subsidiaries.
• Rolling out targeted training in human rights and labor standards.
• Reviewing high-risk supplier relationships and contractual terms.
• Conducting deeper assessments of marketing supply chains.
• Continuing post-transaction risk evaluations tied to the 2025 acquisition of Zmarta Group.

Contact

To submit a request for information under the Norwegian Transparency Act or to receive more information about Snow Group’s work with human rights and working conditions, please contact: transparencyact@axogroup.com.