Identifying risks

Human rights due diligence is embedded as part of our risk management process and integrated into our ERM. We assess the risk of human rights violations, as SMG’s business activities can influence labour rights and workplace conditions both internally and across our supply chain.

In 2024, we addressed the issue of human rights, focusing on due diligence and transparency principles regarding child labour. Given the nature of our operations in the digital sector and the services provided by our suppliers, primarily software development, SMG faces a limited and indirect risk of human rights violations such as child labour. As a result, our overall risk rating remains low based on our business model and employees’ activities.

In line with the DDTrO,²⁴ we conduct an annual review of child labour risks across our operations and supply chain. The 2024 assessment, found no indications or suspicions of child labour within our business operations or supply chain. These findings were communicated to our RAC in March 2025.

Although risks are limited, SMG maintains accessible and effective reporting channels for employees to raise potential human rights concerns (see the section Whistleblowing process). These mechanisms are integral to our commitment to accountability and transparency.