Å Energi AS

Governance roles

Reference: page 62. Composition and diversity datapoints (paragraphs 21(a)-(e), 21(d), 23(a)-(b)) are incorporated by reference to the Corporate Governance statement, NUES recommendation 8 (page 26), as recorded in Annex 2 (page 167).

The Board of Directors "has overall responsibility for ensuring that the Group creates value in a way that is sustainable and which takes financial, social and environmental considerations into account" (page 62). The audit committee "assists and advises the Board" and "shall help to improve the Board's management and oversight of the Group's sustainability reporting and its quality assurance". The CEO, together with the senior management team, is responsible for managing the Group and the business areas sustainably; the boards of subsidiaries are responsible for sustainability at their own companies.

Operationally, "sustainability activities are organised under the CFO function" and "operational activities at business areas are supervised by dedicated sustainability officers" (page 62).

Board composition is set by shareholders' agreement: "twelve people sit on the Group's Board of Directors. Six members, including the Chair and Deputy Chair, are elected at the proposal of the municipal shareholders, two members are elected at the proposal of Statkraft and four at the proposal of the employees" (page 26). Executive management is not represented on the Board, and members serve two-year terms. "Each year, the Board performs a self-assessment, in part to ensure it has the necessary expertise, including on sustainability" (page 26).

Information provided to and matters addressed by the bodies

Reference: page 62.

"The Group's Board of Directors, audit committee and senior management team participate in key corporate governance processes in accordance with established procedures" (page 62). For 2025 the statement names what was overseen: "the audit committee and a separate internal sustainability group for the EU's Corporate Sustainability Reporting Directive (CSRD) closely supervised work on the double materiality assessment and reporting process, as well as risk management and internal controls over sustainability reporting" (page 62).

Frequency is quantified in the table "Number of meetings where sustainability was addressed in 2025" (page 62):

The audit committee "reviewed and approved the results of the update to the double materiality assessment in November 2025" (page 64). Stakeholder views reach the Board and senior management "through attendance at shareholder meetings, visits to shareholder municipalities, direct discussions during licensing processes and public consultations, and active involvement in committees" (page 62). Employee survey results "are presented to the Group's Board of Directors and senior management team" (page 135).

Sustainability performance in incentive schemes

Reference: page 230 (Note 29 to the consolidated financial statements) and page 28 (Corporate Governance, NUES recommendations 11 and 12), both incorporated by reference per Annex 1 (page 163).

This is effectively a nil return. Å Energi operates no variable pay for executives in 2025, so no sustainability-related performance can be built into one. Note 29 states: "No members of the senior management team had bonus agreements in 2025" (page 230), and "No members of the senior management team have been granted options, loans or had guarantees issued on their behalf by Å Energi" (page 230). The Corporate Governance statement repeats the position: "Management compensation reflects the Group's guidelines on compensation. The senior management team has no special bonus arrangement for 2025" (page 28).

Board remuneration is likewise not performance-linked: "Members of the Board are paid based on their roles... Their fees are not profit-related. No Board members are entitled to a pension, options or termination compensation from the entity, apart from the entitlements of the employee representatives in their capacity as employees" (page 28). "The Board members are not entitled to any special termination benefits such as bonuses, profit-sharing or options" (page 230).

No percentage of remuneration linked to climate or other sustainability targets is therefore disclosed, and none exists to disclose.

Statement on due diligence

Reference: page 64, with the mapping table "Å Energi's stakeholder involvement and processes for identifying and assessing material impacts, risks and opportunities" on pages 68-69. Annex 2 points the SBM-1 paragraph 30 due diligence datapoint to that table (page 167).

The due diligence account is anchored in Norwegian law rather than a free-standing ESRS table: the double materiality assessment "draws on insights from past materiality assessments, strategic planning, risk management and due diligence for social sustainability in accordance with the Transparency Act" (page 64). The Transparency Act work is reported separately - "Å Energi produces an annual report on the due diligence carried out by the Group in accordance with the Transparency Act. This is available on our website aenergi.no" (page 145).

Pages 68-69 set out, per material topic, the "Due diligence and processes for identifying and assessing material impacts, risks and opportunities" alongside the stakeholder involvement for each: climate (GHG accounting, climate risk analysis, early warning function), biodiversity (licensing assessments, nature risk assessment using the TNFD LEAP methodology), resource use (tender processes, supplier risk assessments), own workforce (works council, employee surveys, safety representatives, whistleblowing channel), value chain workers and business conduct (supplier meetings, supplier management system risk assessments, Transparency Act due diligence).

Risk management and internal controls over sustainability reporting

Reference: pages 62-63.

The statement is unusually candid about where its reporting is weakest: "As part of our learning journey in this area in 2025, we worked systematically to strengthen our processes for data collection and the associated quality assurance. The biggest risks relate to reporting on climate change, nature and resource use, and arise from processes that are not yet fully developed and dependence on data from external parties" (page 63).

One specific weakness is named: "The figures for materials used reported under ESRS E5-4 are mainly estimates due to a lack of underlying data from suppliers, and the fact that historically this type of data has not been required in contracts with suppliers. Efforts to improve the data quality for sustainability reporting will continue in 2026" (page 63).

Wider internal control is incorporated by reference to the Corporate Governance statement, which describes the "three lines of defence model and... 'COSO Enterprise Risk Management - Integrating with Strategy and Performance'", an annual review of internal controls and risk management "in collaboration with the external auditor", annual self-declarations on internal controls by every subsidiary, and an internal audit service with "a mandate to communicate directly with the Board and the Board's audit committee" (page 28).

Strategy, business model and value chain

Reference: page 61, with Our business (page 16) and the CEO's statement (page 19) incorporated by reference per Annex 1 (page 163).

"Å Energi is Norway's biggest renewable energy group, with ownership interests and activities throughout the value chain, including renewable generation, electric power distribution and energy management and trading, as well as electricity retailing in the industrial, commercial and domestic markets" (page 61). The four business areas are Hydroelectric Power, Network, Market, and Customer and Energy Services (page 61). Hydroelectric Power "owns, directly and through joint arrangements, 81 wholly-owned and part-owned hydroelectric power stations... In a normal year, it expects to generate 12.9 TWh", and Glitre Nett has "around 432,000 distribution customers" (page 89).

Page 61 sets out factors of production and dependencies (human resources - "over 2,000 employees"; natural resources - land and water; capital; regulatory environment; suppliers; local community and shareholders; skills) against results and value creation for society, customers, employees, climate, nature and shareholders, noting "70% of the value we create each year is paid out to shareholders through dividends".

Annex 2 records "Not applicable" for involvement in fossil fuels, chemical production, controversial weapons and tobacco (paragraph 40(d)(i)-(iv), page 167).

Interests and views of stakeholders

Reference: page 62, with topic-level engagement at pages 135 (own workforce), 145 (value chain workers) and 150 (affected communities).

"Cooperation and engagement with internal and external stakeholders is important to Å Energi, and we regularly engage with our stakeholders through a variety of communication channels. The insight we gain from stakeholder engagement is used in areas such as risk management, strategy development and licensing processes" (page 62).

The table "Å Energi's stakeholder groups and its stakeholder engagement" (pages 62-63) lists nine groups with channels and topics: customers; shareholder municipalities; municipalities that host infrastructure and the local community; strategic partners (including the partnership with the environmental organisation ZERO, the climate network Skift, the UN Global Compact and Renewables Norway); suppliers and capital markets; government authorities; employees; media; and advocacy organisations.

A limitation is disclosed in the DMA method: stakeholders were not engaged directly for the assessment. "The process of assessing impacts, risk and opportunities has involved representatives of the business areas, as well as relevant internal and external experts... This means that the views of stakeholders are represented through expert insight, as well as existing assessments and procedures" (page 64).

Material impacts, risks and opportunities

Reference: page 74 (E1), page 100 (E4), page 130 (S1), page 142 (S2), page 148 (S3), with the consolidated table on pages 66-67.

The table "Material impacts, risks and opportunities for Å Energi in 2025" (pages 66-67) lists 24 material IROs across seven topics, each tagged own operations (OO) and/or value chain (VC): E1 climate change 6, E4 biodiversity and ecosystems 3, E5 resource use and circular economy 1, S1 own workforce 4, S2 workers in the value chain 4, S3 affected communities 1, G1 business conduct 5. The per-topic tables at the head of each chapter repeat them with an explicit type label and time horizon (pages 74-75, 100-101, 124-125, 130-131, 142-143, 148-149, 154-155).

By type: 13 negative impacts, 3 positive impacts, 7 risks and 1 opportunity. The single opportunity is the "Opportunity to increase profitability by investing more in electrification and renewable energy systems as part of the green transition" (page 75).

Interaction with the business model is stated for each topic, for example "Climate-related impacts, risks and opportunities directly affect our business model, value chain and investment decisions" (page 74), and for biodiversity, "stricter and more complex requirements relating to land use may affect our business model, if they prevent obtaining access to the land we need in order to fulfil our strategy of supplying more renewable electricity" (page 100).

Process to identify and assess material IROs

Reference: page 64, with topic-specific processes at pages 70-71 (climate, nature), 74 (E1), 100 (E4), 124 (E5) and 154 (G1).

"For the 2025 reporting year, Å Energi has updated its double materiality assessment in line with the European Sustainability Reporting Standards (ESRS) and the guidance documents produced by EFRAG. The assessment covers the whole Group, including its own operations, as well as its upstream and downstream value chain" (page 64).

Method (pages 68-69): identification rests on "an analysis of Å Energi's value chain, activities and stakeholders", with identified items "compared against the sustainability matters described in the ESRS, to ensure their completeness". Assessments are "based on inherent impacts and risks, in other words before taking into account the effect of any mitigation measures". Impacts are scored on severity and likelihood, with irreparability taken into account for negative impacts; risks and opportunities on magnitude and likelihood, magnitude measured "either directly in monetary value, or indirectly through impacts on reputation, access to resources or business relationships". "In line with EFRAG's updated guidance and current practice, a matrix has been used to determine which impacts, risks and opportunities are material".

Year-on-year changes are attributed to method rather than substance: "There have been no material changes to the Group's value chain or real changes to potential or actual impacts, risks and opportunities. The changes in the results of the assessment process compared with 2024 are due to more mature processes and a better understanding of the methodology" (page 64).

Climate-specific risk identification and scenario analysis is also presented under E1-2 (2025 ESRS numbering).

Disclosure requirements covered

Reference: pages 162-167 (Annex 1) and pages 166-171 (Annex 2).

Annex 1, "Disclosure requirements in ESRS covered by Å Energi's sustainability statement", is a real content index: each row names the ESRS, the DR code, the name of the disclosure requirement, one or more page numbers and the section title. It lists all twelve ESRS 2 DRs (BP-1, BP-2, GOV-1 to GOV-5, SBM-1 to SBM-3, IRO-1, IRO-2) and then E1-1, E1-2, E1-3, E1-4, E1-6; E4-1 to E4-5; E5-1, E5-2; S1-1 to S1-11, S1-14, S1-16, S1-17; S2-1 to S2-5; S3-1 to S3-5; and G1-1 to G1-5 (pages 163-166).

Annex 2, "Datapoints in cross-cutting and topical standards that derive from other EU legislation", gives the SFDR / Pillar 3 / Benchmark Regulation / EU Climate Law datapoints with a reference or a reason for absence (pages 166-171). It is the source for several explicit exclusions: E1-5 energy consumption and mix, energy from fossil sources and energy intensity are all marked "Not material"; E1-7 GHG removals and carbon credits and E1-1 paragraphs 14 and 16(g) are "Not applicable"; the five E1-9 portfolio and real-estate datapoints are marked "Phase-in requirement"; E2-4, E3-1, E3-4, E5-5 and the S4 datapoints are "Not material".

Two gaps are worth noting against the index. E5-4 is absent from Annex 1, yet the statement presents a quantified resource inflows table (page 126) and the GOV-5 text refers to "the figures for materials used reported under ESRS E5-4" (page 63). E5-3, S1-12, S1-13, S1-15, E4-6, E5-6, E1-8 and G1-6 are absent from the index with no stated reason.

Transition plan for climate change mitigation

Reference: page 79.

Å Energi reports E1-1 as a nil return with a work programme behind it. The statement says plainly: "We do not have a transition plan for climate change mitigation in place, but in 2025 we started work on mapping the current status in order to draw up new ambitions, targets and actions that will safeguard our ability to continue supplying electricity far into the future. The new ambitions, targets and actions will involve updating the Group's scope 1-3 GHG emission reduction targets, as well as planning and implementing new climate-related actions. In the meantime, we will be guided by our previously established climate change targets" (page 79).

Annex 2 confirms the two E1-1 datapoints derived from other EU legislation are not answered: paragraph 14, "Transition plan to reach climate neutrality by 2050" (EU Climate Law), and paragraph 16(g), "Undertakings excluded from Paris-aligned Benchmarks" (Pillar 3 / Benchmark Regulation), are both marked "Not applicable" (page 167).

What stands in place of a plan is the existing SBTi-approved Scope 1 and 2 target (page 79, see E1-4), a set of named 2025 actions (page 81) and an adaptation response to physical risk (pages 82-83). The Group also states the tension it is managing: "we face a dilemma: developing new renewable energy capacity can make it challenging to meet our targets for reducing our own GHG emissions" (page 78).

Identification of climate-related risks and scenario analysis

Back-filled from ESRS 2 IRO-1, "Process for identifying material climate-related impacts, risks and opportunities", where this content is disclosed in the FY2025 report (pages 70-71), with the risk descriptions at pages 82-83. This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Classification (paragraph 15). The E1 IRO table separates a "Transition risk arising from an uncertain and unpredictable regulatory environment during the transition to a climate-neutral society" from "Physical climate risk arising from acute and chronic impacts of climate change, which can damage physical installations and infrastructure" (page 75).

Methodology (paragraph 16). "In the autumn of 2023, Å Energi performed an extensive assessment of the Group's exposure to physical climate risk. This included site-specific assessments for around 150 of the Group's own sites belonging to the Hydroelectric Power, Network and Customer and Energy Services business areas... The assessment was done across two scenarios and two time horizons" (page 70). Transition risk was analysed "based on trends and drivers associated with politics, technology, markets and reputation", using two scenarios and three time horizons (page 71). Coverage of own operations is incomplete and said so: "We have not yet assessed the exposure in our other business areas or in the value chain" (page 83).

Scenarios (paragraph 17). Physical: IPCC SSP1-2.6 (warming limited to 2 °C) and IPCC SSP5-8.5 (warming exceeds 4 °C), at 2050 and 2100 (page 70). Transition: IEA World Energy Outlook 2024 Announced Pledges Scenario and Business As Usual, over 0-3, 3-7 and >7 years (page 71). Temperature projections are given per scenario. No 1.5 °C-aligned scenario with no or limited overshoot is used, so paragraph 17(a)(ii) is not met. Time horizons are flagged as non-standard: "These time horizons deviate from the ones specified in ESRS 1" (page 70).

Findings: "the Group's sites are most heavily exposed to acute water-related incidents such as flooding and heavy precipitation. The number of exposed sites increases over time" (page 70), and "none of Å Energi's assets or activities are considered incompatible with that transition" (page 71).

Resilience in relation to climate change

Back-filled from ESRS 2 SBM-3 and the E1 chapter, where this content is disclosed in the FY2025 report (pages 82-83). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Results of the analysis (paragraph 19(a)). "As an extension of the Group's climate risk assessment and double materiality assessment, we have reviewed the extent to which our strategy and business model are resilient to the identified risks, as well as our capacity to exploit opportunities. Our current resilience was discussed in conjunction with the climate risk assessment in 2024" (page 83). Per AR 9 the analysis need not be annual, so the 2024 discussion is not a deficiency. "The results of the assessment are taken into account in strategic planning, investment decisions and measures to reduce risk" (page 83).

Uncertainty (paragraph 19(b)). "There were no known material impacts on the Group's financial results for 2025, but uncertainty surrounding external factors such as climate change affects the assessment" (page 83). The stated assumption is "that the transition to a carbon-neutral economy will mean greater electrification, higher demand for renewable energy and faster technological advances in storage and flexibility services".

Capacity to adjust (paragraph 19(c), AR 10). Adaptation rests on asset reinforcement and preparedness: "Physical climate risk, such as increasingly frequent flooding and extreme precipitation, requires us to invest in robust infrastructure and to reinforce our dams... Dams whose failure would have major consequences must be capable of withstanding a 1,000-year flood" (page 82). "The most important actions we can take to ensure resilience against the physical impacts of climate change include reinforcing exposed infrastructure and establishing robust contingency plans. This will be vital over both the short and long term, particularly if a high-emission scenario plays out" (page 83). Scope is limited: the resilience assessment "covers assets and infrastructure in our Network, Hydroelectric Power and Customer and Energy Services business areas", and "the Hydroelectric Power business area is currently assessing the Group's overall exposure to climate change risk" (page 83).

Policies related to climate change mitigation and adaptation

Reference: page 76.

Å Energi reports no dedicated climate policy, and says so explicitly: "Other than the guidelines mentioned above, as of 31 December 2025 the Group had no policies that specifically dealt with climate change" (page 76).

What is in place: the Group's Code of Conduct "commits the Group to reducing its carbon footprint and to taking a precautionary approach to climate change"; the guiding principles on sustainability, "which are owned by the Group CFO, state that climate change and the environment shall be taken into account in all relevant decisions"; and the Group purchasing guidelines, which "specify that procurement shall help the Group to meet its targets and requirements relating to sustainability" (page 76). Accountability is delegated: "Managing directors of subsidiaries are responsible for defining and monitoring targets that help the Group to achieve its ambitions".

The Group also relies on an external commitment: "Å Energi has undertaken to comply with the UN Global Compact's 10 principles for responsible business practice, including the ones related to protecting the environment. This means that it must reduce GHG emissions both at its own operations and in its value chain" (page 76).

Actions and resources in relation to climate change policies

Reference: pages 76-79 and 81, with adaptation actions at pages 82-83.

Mitigation through the core business (pages 76-77). "In 2025, the Group produced 13,108,214 MWh of energy, of which 13,103,083 MWh was renewable", up from 12,582,882 MWh in 2024. Grid actions in 2025: "Total substation capacity was increased by 133 MVA over the year... The length of overhead power lines was reduced by 17 km, while the network of underground lines was expanded by 280 km... The number of transformers rose by 89 units" (page 77). New generation: Frøytlandsfoss (9.8 GWh/year) and Godfarfoss (40 GWh/year) power stations were completed in 2025, and construction of Kvernevatn power station in Åseral began in autumn 2025 (1.74 MW, 5.2 GWh/year) (pages 76-77).

Actions on own emissions (page 81). "Requirements for suppliers have been made stricter, including mandatory environmental certification and EPDs for all framework agreements, as well as a requirement to consider low-emission solutions and electric equipment. Glitre Nett and Norgesnett have signed up to an industry-wide agreement on using SF6-free technology from 2026 onwards, with reduction targets leading up to 2030." Also: "Norgesnett completing the transition to a fully electric fleet of vehicles. Glitre Nett has replaced helicopters with drones for inspecting power lines and utility poles". A new environmental calculator for GHG estimates in project design was piloted by Glitre Nett and "will be rolled out in 2026", and a first technical GHG assessment was ordered for the Hannevika-Kjos grid upgrade in Kristiansand under new NVE requirements (page 81).

Innovation actions (page 78). A hydrogen pilot plant at Pikerfoss power station began construction in June 2025, due for completion in Q3 2026; the H2 Fleks project with Technip FMC concluded in Q3 2025; the Frequency Containment Reserve project began in March 2025.

Planned actions (page 77). "The Hydroelectric Power business area has set itself the ambitious target of increasing electricity generation by 1,000 GWh and raising installed capacity by 1,000 MW by 2032."

No CapEx or OpEx figures are attached to these actions in the sustainability statement.

Targets related to climate change mitigation and adaptation

Reference: page 79.

The stated target: "To reduce absolute direct GHG emissions (Scope 1) and indirect GHG emissions from energy consumption (Scope 2, market-based) by 50% by 2030, using 2019 as the base year" (page 79). The GHG accounts carry it as a milestone column, "↓50%" by 2030 with a 6% "target for annual reduction" for Scope 1 and for Scope 2 (pages 80-81).

Third-party validation is disclosed: "In 2021, what was then Agder Energi had its GHG emission reduction targets reviewed and approved by the Science-Based Targets initiative (SBTi). After the merger in 2022, Å Energi has had the approval for this science-based target extended to cover the whole Group" (page 79). Annex 2 points the paragraph 34 GHG emission reduction targets datapoint to this section (page 167).

The target is in transition and the statement says so: "In line with the SBTi criteria and ESRS requirements, Å Energi has recently calculated emissions for 2023 as its new base year, and the new GHG emission reduction targets will be based on this. This has been done to ensure that the base year is representative of the nature of the Group today. When calculating emissions for the new base year, the organisational boundaries were extended, and additional emission sources were identified and included" (page 79).

No Scope 3 reduction target is disclosed, even though Scope 3 was 133,149 tCO2e in 2025 against Scope 1 of 5,918 tCO2e (pages 80-81). No adaptation target is given; adaptation is handled through dam safety regulation and contingency planning instead (pages 82-83).

Gross Scopes 1, 2, 3 and total GHG emissions

Reference: pages 79-81, with reporting principles at pages 84-87. Annex 2 points the paragraph 44 and paragraphs 53-55 datapoints here (page 168).

Scope 1 is split by consolidation basis as required: financial control 5,918 tCO2e and operational control 0 tCO2e, with 19% of Scope 1 "Covered by the EU ETS" in 2025 (up from 11%) (page 80). Biogenic emissions are reported separately: Scope 1 10,200 tCO2, Scope 2 24,574 tCO2 (page 80). Intensity is given as 5 tCO2e per NOK million location-based and 15 tCO2e per NOK million market-based, on operating revenues of NOK 35,998 million (page 81).

Three Scope 3 categories are reported as significant: 1 purchased goods and services 105,019 tCO2e, 3 fuel- and energy-related activities 12,315 tCO2e, 15 investments 15,815 tCO2e, with the other twelve categories individually explained as excluded (pages 80, 85-86). Data quality is disclosed: "None (0%) of the emissions in category 1 are calculated based on primary data", the same for category 15, and 67% primary data for category 3 (page 86).

Restatement: 2023 and 2024 "have been recalculated to account for the group's acquisition of Fredrikstad Energi and its subsidiaries, as well as parts of Orkla's hydropower portfolio" (page 81).

Transition plan and compatibility with protecting biodiversity

Reference: page 100, as listed in the Annex 1 content index (page 164).

Å Energi reports no biodiversity transition plan, and frames the absence as work in progress: "In order to mitigate any long-term consequences of this risk, it is important to take a systematic and holistic approach to the natural environment. We wish to place our approach to nature within a wider context, in line with national ambitions. Therefore, in 2025 we have worked on mapping the current status as a basis for establishing the ambitions, targets and actions that will guarantee our ability to supply electricity far into the future" (page 100).

Compatibility of the business model with protecting biodiversity is addressed qualitatively, and the trade-off is stated rather than smoothed over: "we recognise that building and operating renewable electricity systems and associated infrastructure has a negative impact on nature. Altering the natural environment can disrupt the habitats and living conditions of species and ecosystems. This means that going forwards it will be an important strategic priority for the Group to balance the need for more electricity against the need to protect vulnerable and pristine natural environments" (page 100). "Minimising our negative impact on nature is an integral part of how we operate. We are continuously adapting our strategy and business model to ensure that we do this" (page 100).

Over the longer term, "stricter and more complex requirements relating to land use may affect our business model, if they prevent obtaining access to the land we need in order to fulfil our strategy of supplying more renewable electricity", with the white paper on nature management (Meld. St. 35) named as a signal (page 100).

Policies related to biodiversity and ecosystems

Reference: page 101, as listed in the Annex 1 content index (page 164).

As with climate, there is no dedicated group policy and the statement says so: "Beyond the above guidelines and recommendations, as at 31/12/2025 we had not drawn up a separate governing document at the Group level covering impacts and risks related to biodiversity and ecosystems. The need for a document of this kind will be reviewed in conjunction with establishing our ambitions, targets and actions" (page 101).

What is in place: the UN Global Compact commitment, "including the ones related to supporting a precautionary approach to environmental challenges, promoting greater environmental responsibility and developing environmentally friendly technologies"; and five management-adopted recommendations - "In 2023, the senior management team adopted five recommendations relating to our approach to nature. These involve systematically mapping our impact on nature through a nature risk assessment, developing ecosystem accounting, using the mitigation hierarchy in project models and seeking dialogue with stakeholders at an early stage" (page 101).

Licence conditions do much of the policy work: "The terms of our licences require us to perform a variety of actions to minimise our negative impacts on biodiversity, and we also perform a number of voluntary actions. We adhere to the mitigation hierarchy in order to prevent and minimise any harm in so far as possible. None of our actions in 2025 included the use of biodiversity offsets" (page 101).

Annex 2 records the SFDR policy datapoints as outside scope: paragraph 24(b) sustainable land and agriculture practices "Not applicable", paragraph 24(c) sustainable oceans and seas and paragraph 24(d) deforestation both "Not material" (page 168).

Actions and resources related to biodiversity and ecosystems

Reference: pages 104 and 108, as listed in the Annex 1 content index (page 164).

Actions are organised around the two material negative impacts.

Construction (page 104). "These impacts are managed through systematic risk assessments during licensing processes and by minimising the alterations to the land. Our new ambitions, targets and actions will provide clear guidance on how to better protect the natural environment during construction work."

Licensing as the principal control mechanism (pages 102-103). "Thorough environmental impact assessments are therefore carried out ahead of new construction projects. These provide information about the area's ecological condition and an assessment of potential impacts. Specialist experts and local stakeholders are actively involved in the process, from the initial assessment through to the design and oversight of mitigation measures." When a licence is granted "it comes with detailed requirements as to how the companies shall minimise environmental impacts, both during construction work and once it starts operating". Responsibility is allocated: "Responsibility for planning, assessing and overseeing licences lies with the licence coordinator, in consultation with the project manager and environmental coordinator" (page 103).

Species protection (page 108). Contractors are given place-specific information about nesting areas, breeding grounds and growing sites "which is not made public".

Risk management (page 103). The regulatory risk "is managed through our standard risk management procedures, and our Regulatory Affairs Department continuously monitors changes to regulations and political guidance."

No CapEx or OpEx amounts are attached to the biodiversity actions.

Targets related to biodiversity and ecosystems

Reference: page 100, as listed in the Annex 1 content index (page 164).

Å Energi discloses no measurable biodiversity targets for 2025. The E4 chapter places target-setting in the future: "in 2025 we have worked on mapping the current status as a basis for establishing the ambitions, targets and actions that will guarantee our ability to supply electricity far into the future" (page 100), and the policy section repeats that the need for a group-level governing document "will be reviewed in conjunction with establishing our ambitions, targets and actions" (page 101).

Consistent with the other limb of the minimum disclosure requirement on targets, the statement describes how effectiveness is tracked in the absence of quantified targets. Reporting is metric-led and explicitly qualitative where it cannot be quantified: "The metrics have been chosen to highlight the Group's material impacts, risks and dependencies related to biodiversity and ecosystems. Where complete quantification is not possible, the impacts have been discussed qualitatively. Further enhancements to the underlying data, methods and metrics will form part of the Group's ongoing work on nature and nature risk" (page 100). Progress is also tracked through the mitigation hierarchy applied in project models, the 2025 nature risk assessment following the TNFD LEAP methodology (page 71), and the testing of ecosystem accounting "in order to develop a better understanding of our impact and identify possible improvements" (page 151).

No target relating to land-use change, Red List species, protected areas or restoration is stated, and no base year or milestone is given.

Metrics related to biodiversity and ecosystems change

Reference: pages 104, 108 and 110, as listed in the Annex 1 content index (page 164).

Sites in or near Biodiversity Sensitive Areas (page 104). Hydroelectric Power: 27 sites covering 26,694.2 hectares, of which 4 power stations (0.21 ha) and 23 reservoirs or dams (26,694 ha). Network: 38 municipalities covering 557.61 hectares, comprising 262 km of overhead power lines (501.24 ha), 6.8 km of submarine lines (2.15 ha), 245.7 km of underground lines (50.25 ha), 3,424 poles (1.06 ha), 190 above-ground distribution substations (0.19 ha), 28 underground distribution substations (0.07 ha) and 7 above-ground transmission substations (2.66 ha).

Findings are reported for each business area (page 105). Hydroelectric Power: "We have no physical installations in or near UNESCO World Heritage Sites... We have one physical installation in or near a Key Biodiversity Area... We have four power stations, as well as 23 reservoirs/dams that are located in or closer than 100 metres to Norwegian protected areas." Network: no installations in UNESCO World Heritage Sites, installations "in three locations that are in or near a Key Biodiversity Area", and "36 locations (municipalities) where we have physical installations in a Norwegian protected area. In these municipalities, 116 different protected areas are affected."

Red List species (pages 104-106). A count of "Number of species on the Norwegian Red List for Species observed by power stations" broken down by category from Critically endangered (CR) downwards, based on the 2025 nature risk assessment and open databases including the Norwegian Biodiversity Information Centre and Naturbase. The metric is caveated: "the metric does not tell us anything about the actual impact on the species on the Red List, but it does give some idea of the inherent risk of negative impacts in the areas where we operate" (page 104).

Method and comparability are disclosed, including that double counting where installations overlap "has been eliminated", so "the total number of hectares reported will be lower for 2025 than the figure reported for 2024" (page 105). A full site-by-site listing runs to pages 112-123. Annex 2 points the SBM-3 paragraph 16(a)(i) and 16(c) SFDR datapoints here and marks paragraph 16(b) land degradation "Not material" (page 168).

Policies related to resource use and circular economy

Reference: page 125, as listed in the Annex 1 content index (page 164).

"The Group's 'Code of Conduct' and 'Code of Conduct for Suppliers and Business Partners' set environmental requirements, including for resource use and the circular economy. We shall aim for a circular economy outlook, which includes applying a life cycle perspective to assessments, promoting resource efficiency and reuse, and reducing impacts on nature, people and society" (page 125).

An external commitment is added: "Å Energi has signed up to the ten principles for green procurement established by Skift, with the aim of having a positive impact on the climate, environment and people in our value chain, as well as promoting green competitiveness. In 2025, the Group drew up new, explicit contractual requirements that promote circularity. We also ask suppliers to report key data about their recycling of materials in order to document their efforts to promote a circular economy and reduce environmental impacts" (page 125).

As for climate and biodiversity, no dedicated group policy exists: "Beyond the above guidelines and recommendations, as of 31 December 2025 Å Energi had not drawn up a separate governing document at the Group level specifically covering negative impacts on the environment caused by high resource use. The need for a document of this kind will be reviewed in conjunction with our work on setting ambitions, targets and associated actions for this area" (page 125).

Actions and resources related to resource use and circular economy

Reference: page 127, as listed in the Annex 1 content index (page 164).

Five named 2025 actions (page 127):

• Increasing lifespan and recovering metals. "One example is the renovation of Tjønnefoss and Iveland power stations in 2025, where in so far as possible we sent parts for refurbishment and reuse, as well as sending the metal from replaced components for recycling."
• Identification of data sources for materials used. "In 2025 Glitre Nett identified the existing systems and procedures used to record and report resource inflows and waste. Several procedures and systems were identified which can be developed and linked in order to get a better overview... work on this will continue in 2026."
• Better utilisation of the existing power grid. Glitre Nett increased the capacity of the Hallandsbru-Ålefjær-Timenes line "by approximately 15 percent", and "Making better use the existing grid, and avoiding the replacement of overhead power lines and poles, saved large quantities of materials such as metal and concrete".
• Reuse portal for grid operation. "In 2025, Norgesnett created a 'Reuse portal' in collaboration with selected contractors... It includes an app-based portal that can be used on mobile phones and a physical warehousing system. The test phase was completed with two contractors, and over the course of 2025 all other contractors were given access to the portal."
• Reuse of transformers and regeneration of SF6 gas. "Glitre Nett generally reuses transformers that still have technical value, rather than investing in new ones", and "Instead of disposing of used SF6 and acquiring new gas, Glitre Nett regenerates its own used gas."

Future work is described rather than resourced: "Going forwards, we will continue to catalogue resource use and quantities of waste, and use this knowledge to prioritise the most effective actions" (page 127). No CapEx or OpEx figures are attached.

Resource inflows

Reference: page 126. Note on basis: E5-4 is not listed in the Annex 1 content index (page 164), but the company identifies the disclosure by code itself in the GOV-5 section - "The figures for materials used reported under ESRS E5-4 are mainly estimates due to a lack of underlying data from suppliers, and the fact that historically this type of data has not been required in contracts with suppliers" (page 63) - and publishes a quantified inflows table, so the claim to have reported it is the company's own rather than an inference from narrative.

Resource inflows in renovations and new construction projects completed in 2025 (page 126):

Material selection is explained: "Our choice of material categories is based on the results of life cycle analysis (LCA) and environmental product declarations (EPDs), which show that concrete, asphalt, steel, aluminium and copper both represent the biggest volumes of materials in our projects and have the greatest environmental impacts" (page 126).

Method and limitations are disclosed in full: "The reporting of materials is mainly based on estimated quantities of materials, as we do not currently have complete and consistent data on materials used from suppliers for all projects. The estimates have been produced by the Hydroelectric Power and Network business areas using available project data, standardised assumptions and representative EPDs. Where direct data have not been available, conservative assumptions have been used in order to avoid under-reporting. Resource use is recorded under the year the projects are completed" (page 126).

The recycled and reused content datapoint is explicitly not available: "For the 2025 reporting year, sufficiently consistent and quality assured information about the percentage of recycled and reused materials at the Group level is not yet available. Å Energi is working to improve its underlying data and system support for material flows, with the aim of being able to report on this in future years" (page 126). No biological versus technical materials split and no total weight of products and materials used are given.

Policies related to own workforce

Reference: pages 134, 135 and 138, as listed in the Annex 1 content index (page 165).

"Å Energi's governing documents cover the whole workforce and are based on relevant legislation, conventions and guidelines established by international organisations such as the UN, ILO and OECD" (page 134). Four instruments are described:

• Code of Conduct - "which adheres to the UN's Guiding Principles on Business and Human Rights, shall ensure that Å Energi does not become party to human rights violations, and it states that we shall recognise that everyone is of equal value and appreciate diversity. The code also states that all managers shall ensure safe working conditions, equal treatment, workplace adjustments and a compliant working environment" (page 134).
• Policy for safeguarding human rights and decent working conditions - adhering to the UNGPs and the OECD Guidelines for Multinational Enterprises; "Boards of Directors shall at least once a year review the policy, and based on regular reports by the executive management ensure that the policy has been implemented and is being complied with" (page 134).
• Group HR guidelines and a standard employee handbook completed in January 2025, covering "terms of employment, working hours, outlays, travel and other HR-related topics, and it now also covers careers and professional development" (page 134).
• Group HSE guidelines, requiring subsidiaries to prioritise health and safety, assess risk, notify accidents and serious near misses quickly, and "perform a root cause analysis, implement corrective actions and share information about the incident so that lessons can be learned" (page 135).

Two gaps are disclosed. On work-life balance: "As at 31/12/2025, Å Energi had not drawn up a dedicated governing document for dealing with potential negative impacts from an inadequate work-life balance" (page 137). On vulnerable groups: "None of Å Energi's governing documents cover inclusiveness and positive actions specifically aimed at particularly vulnerable groups in our own workforce" (page 138). Annex 2 maps paragraphs 20, 21, 22 and 23 to these sections, marking the trafficking-prevention datapoint "Not applicable" (page 168).

Processes for engaging with own workforce and workers' representatives

Reference: pages 135-136, as listed in the Annex 1 content index (page 165).

"Å Energi collects employees' views and suggestions for improvements both directly and indirectly through employee representatives and the whistleblower channel. The HR Director has operational responsibility at the Group level for ensuring engagement with our own workforce and making sure that their suggestions are heard and taken into account in decision-making processes. The managing directors of the various subsidiaries are responsible for day-to-day engagement with employees" (page 135).

Structures and frequency are given: "In order to ensure the participation and influence of our employees, in 2023 we established a workplace democracy. Moreover, the Group works council is a forum where the senior management team, HR and an extended number of employee representatives meet on a quarterly basis to discuss issues affecting the whole Group. In addition, employee representatives attend monthly dialogue meetings with the CEO and HR" (page 135). Other channels are "annual employee satisfaction surveys, performance reviews, safety representatives, the working environment committee, and employee communication channels on our intranet", plus pulse surveys "conducted as and when there is a need" (page 135).

Effectiveness is tracked through what happens to results: "The results of employee satisfaction surveys are presented to the Group's Board of Directors and senior management team. Managers present the results for their areas to their employees, and implement corrective actions as needed" (page 135). For health and safety specifically, "Through the workplace democracy, it has also been agreed that the chief safety representatives for the Group shall attend the Group's employee engagement forums" (page 136). Four of the twelve Board members are elected at the proposal of the employees (page 26).

Processes to remediate negative impacts and channels to raise concerns

Reference: pages 135-136, as listed in the Annex 1 content index (page 165). Annex 2 maps the paragraph 32(c) grievance mechanisms datapoint here (page 168).

"Å Energi has established several whistleblowing channels for its own employees, as well as processes and procedures to remediate negative impacts on employees" (page 135). The whistleblowing system is described under business conduct: concerns "can be sent directly to the management, employee representatives, safety representatives, HR, the compliance function, the audit committee or the internal audit service", and "Both employees and third parties can submit reports through our whistleblowing portal, which also enables anonymous whistleblowing" (page 158). "Our internal audit service has ultimate responsibility for dealing with matters reported through the whistleblowing channel, and the Chief Audit Executive is the first person to receive reports", with a whistleblowing committee convened as appropriate and chaired by the Chief Audit Executive (page 158). Procedures state "that all whistleblowing reports shall be taken seriously, that whistleblowers shall be protected against retaliation and that all issues of concern shall be investigated" (page 158).

A second channel handles operational incidents: "Å Energi has designed and implemented a dedicated system for recording unwanted incidents and suggesting improvements which is available to all employees at the Group... available through several platforms, including a mobile phone app and an online reporting tool... When issues of concern are reported through this channel, they are escalated to the Chief Audit Executive or whistleblowing committee" (page 136).

Remediation process: "When high-risk incidents occur, a root cause analysis is performed with a view to limiting potential consequences, ensuring that the causes are uncovered, sharing learning points and implementing continuous improvement processes. All incidents that involve a breach of health and safety legislation or internal health and safety rules are considered nonconformities and are recorded in the Group's nonconformity management system" (page 136). Usage is quantified under S1-17 (page 139).

Taking action on material impacts on own workforce

Reference: pages 136, 137 and 138, as listed in the Annex 1 content index (page 165).

Health and safety (page 136). "We collect data from all of our subsidiaries through their unwanted incident reports, and we continuously seek to implement measures to prevent repeat incidents." Specific actions: employees "are offered a range of courses related to health and safety, including first aid and winter driving courses, and all new hires are offered, and encouraged to complete, general health and safety training. In order to reduce sickness absence, all employees are offered voluntary health checks, as well as appropriate vaccinations. We also pay for health insurance for all of our employees." Risk assessments use the safe job analysis (SJA) approach, and "Å Energi has insurance policies to cover all major types of operational incident" (page 136).

Work-life balance (page 137). "Å Energi continuously strives to ensure a good work-life balance for our employees at all stages of their lives. For example, we seek to optimise shift patterns and to give employees flexibility by offering flexitime and hybrid working arrangements with the option of working from home. Å Energi also has good arrangements for parental leave and family care leave, with employees receiving full pay and full holiday pay entitlements during parental leave, and full pay during family care leave in conjunction with childbirth. All employees at Å Energi are entitled to take family-related leave. In addition, all employees over the age of 65 receive a flexitime balance of 37.5 hours." A new scheme was introduced: "In 2025, Å Fleks was established as part of the integration process after the merger... Employees are offered 40 hours which they can take off subject to agreement with their immediate line manager."

Equal treatment (page 138). "Å Energi is heavily involved in Kraftkvinnene, a network aimed at all women in the renewable energy sector... The Group is working actively to provide good working environments and exciting tasks for women, particularly in traditionally male-dominated roles." For age diversity, "in 2024 Å Energi launched the professional and social network Ung i Å ('Young people at Å') for all employees up to the age of 35" (page 138).

Targets related to own workforce

Reference: pages 136, 137 and 138, as listed in the Annex 1 content index (page 164).

Å Energi has one quantified workforce target and declares the absence of the others.

Health and safety (page 136). "Å Energi's overarching goal is to continue addressing health and safety in such a way that it fulfils its zero accident vision for its own employees, contract staff and third parties, while maintaining a low sickness absence rate (<3%). In order to achieve this, actions shall be taken to prevent occupational sickness absence and to promote wellbeing and good health at the workplace." Against the <3% target, sickness absence was 3.2% in both 2025 and 2024 (page 137).

Worker involvement in target-setting is disclosed as limited: "Employees at Å Energi have not been directly involved in the process of determining the above targets, nor have they been directly involved in the processes of assessing Å Energi's performance against its targets. However, employees can make suggestions for improvements related to health and safety through our system for reporting unwanted incidents" (page 136).

Work-life balance (page 137). "As at 31/12/2025, Å Energi had not set any time-bound, quantifiable targets related to its employees' work-life balance."

Diversity and equal opportunity (page 138). "As at 31/12/2025, Å Energi had not set a gender balance target for the Group", and "Beyond this, at 31/12/2025 the Å Energi Group had not set any time-bound, quantifiable targets related to diversity and equal opportunity." Direction without a target is given for age structure: "we want a good balance of experienced professionals and of young, recent graduates... In order to do that, we must focus on diversity in all of our recruitment processes."

Effectiveness is tracked through the monitoring described alongside: "By closely monitoring sickness absence and injuries, and comparing our progress with our targets, we can identify which areas require further action" (page 136).

Characteristics of the undertaking's employees

Reference: page 133, as listed in the Annex 1 content index (page 165), with reporting principles at page 140.

Headcount at 31 December 2025 was 2,020 employees (2024: 2,025), of whom 452 female, 1,568 male, 0 other and 0 not reported (page 133).

By contract type (page 133):

Turnover: 242 employees left during 2025 (2024: 169), a turnover rate of 11.98% against 8.33% in 2024 (page 133).

No country breakdown is given, and the reason is stated: "Å Energi has employees in Norway, Sweden, Denmark, Finland, Belgium, Switzerland and Germany. However, Å Energi does not have significant employment outside Norway, where 'significant employment' is defined as at least 50 employees representing at least 10% of the undertaking's total number of employees. Å Energi has therefore chosen to disclose information about its employees collectively, rather than broken down by the countries where it has employees" (page 140).

Scope: "The information covers all companies consolidated in the financial statements, as well as joint ventures with employees in which Å Energi holds an ownership interest of over 50% (Otra Kraft and Arendals Vasdrags Brugseierforening). For the joint ventures, employees and employee data are included in full" (page 140). Use of temporary contracts is explained at page 134. Headcount is reported in number of people, not FTE.

Characteristics of non-employees in the undertaking's own workforce

Reference: page 133, as listed in the Annex 1 content index (page 165).

The statement reports 100 non-employee workers in the own workforce at 31 December 2025, against 110 in 2024 (page 133, table "Non-employee workers in Å Energi's own workforce").

The definition is given in the reporting principles: "Å Energi's own workforce comprises its own employees and non-employees. Our own employees are defined as employees with a direct contractual relationship with Å Energi. Non-employees are defined as independent contract staff and workers hired through employment agencies" (page 140). The chapter introduction repeats it: "Å Energi's own workforce consists of employees with a direct employment contract with Å Energi, as well as independent contract staff and workers hired through employment agencies" (page 130).

The figure is a single total. It is not broken down between self-employed people and workers provided by undertakings primarily engaged in employment activities, and no gender or contract-type split is given for this group. The health and safety metrics are explicitly narrower: the H2 injury frequency "includes our own employees, and not contract staff" (page 140), and the sickness absence rate "only relates to permanent and temporary employees" (page 140). Health and safety impacts on contract staff at Å Energi's own sites are reported under S2 instead, where the first material IRO is the "Potential negative impact on the health and safety of contract staff and other third parties as a result of challenging working conditions at Å Energi's sites" (page 142).

Collective bargaining coverage and social dialogue

Reference: page 137, as listed in the Annex 1 content index (page 165).

"At Å Energi, 77.22% of all employees are covered by collective bargaining agreements. In addition to pay, the collective bargaining agreements cover the process for consulting with employee representatives, training and development, protection against discrimination and health and safety. At Å Energi, 35% of employees are covered by an employee representative" (page 137).

The agreements are also the basis of employment terms generally: "Å Energi's employment contracts are all based on collective bargaining agreements, which give employees additional rights over and above their statutory ones. Amongst other things, this includes rights related to time off in lieu and compensation" (page 137).

Social dialogue structures are described under S1-2: the workplace democracy established in 2023, the Group works council meeting quarterly with the senior management team, HR and employee representatives, monthly dialogue meetings between employee representatives and the CEO and HR, the working environment committee and the safety representatives (pages 135-136). Four of the twelve Board members are elected at the proposal of the employees (page 26).

No breakdown of coverage by EEA country or by region is presented, and the 77.22% and 35% figures are given for the Group as a whole, consistent with the statement's position that it "does not have significant employment outside Norway" (page 140).

Diversity metrics

Reference: page 139, as listed in the Annex 1 content index (page 165).

Gender distribution at top management level (page 139):

Distribution of employees by age group (page 139):

Top management is defined in the reporting principles: "Å Energi's top management is defined as managers in the first two levels below the Board of Directors, audit committee and CEO. The senior management team constitutes Level 1, while section managers at the Group level and the managing directors of subsidiaries constitute Level 2" (page 140).

Movement is commented on: "In general, the evolution of the metrics from 2024 to 2025 shows a stable situation. Changes in the distribution of employees by age group are largely due to the natural ageing of the organisation... There was only a slight change in the gender balance at the top management level, including section managers, from 2024 to 2025" (page 139). Board gender diversity is incorporated by reference to the Corporate Governance statement per Annex 2 (page 167).

Adequate wages

Reference: page 137, as listed in the Annex 1 content index (page 165).

This is a short, complete nil-exception return: "All employees at Å Energi are paid an adequate wage. Find out more about Å Energi's remuneration policy in the Diversity Report, which is available on our website aenergi.no" (page 137).

No employees are therefore reported as paid below an adequate wage benchmark, and no percentage or country breakdown of non-compliance is given because none is claimed. The statement does not name the benchmark used to reach that conclusion, and the supporting detail sits outside the sustainability statement in a separate Diversity Report on the company's website, which is not incorporated by reference in the Annex 1 content index (pages 163-166).

Adjacent evidence in the statement is consistent with the claim: 77.22% of employees are covered by collective bargaining agreements, which "In addition to pay" cover consultation, training and development, protection against discrimination and health and safety (page 137), and "Å Energi's employment contracts are all based on collective bargaining agreements, which give employees additional rights over and above their statutory ones" (page 137). Wage adequacy in the value chain is treated separately under S2, where inadequate wages are identified as part of the raw-materials extraction risk (page 142).

Social protection

Reference: page 137, as listed in the Annex 1 content index (page 165).

"All of Å Energi's employees in Norway are entitled to social protection through the Norwegian national insurance scheme in the event of loss of income due to illness, unemployment, occupational injury or acquired disability, parental leave and retirement" (page 137).

The disclosure covers the full set of major life events ESRS S1-11 asks about - sickness, unemployment from the point at which the employee works for the undertaking, employment injury and acquired disability, parental leave, and retirement - by reference to statutory cover rather than company schemes.

One scope limitation follows from the wording: the statement addresses employees in Norway. Å Energi "has employees in Norway, Sweden, Denmark, Finland, Belgium, Switzerland and Germany", though it "does not have significant employment outside Norway", defined as "at least 50 employees representing at least 10% of the undertaking's total number of employees" (page 140). Employees outside Norway are not separately addressed, and no count or percentage of employees not covered is given.

Company-funded provision is described elsewhere in the chapter rather than under this heading: "In order to reduce sickness absence, all employees are offered voluntary health checks, as well as appropriate vaccinations. We also pay for health insurance for all of our employees" (page 136), and parental and family care leave arrangements with full pay are set out at page 137.

Health and safety metrics

Reference: page 137, as listed in the Annex 1 content index (page 164). Annex 2 maps paragraphs 88(b), 88(c) and 88(e) here (page 168).

Health and safety metrics (own workforce) (page 137):

The doubling of injuries is explained rather than left bare: "The great majority of the increase in personal injuries is due to the acquisition of Nettpartner and incidents at Glitre Nett, which increase the exposure of our own employees within the contracting business" (page 137). Sickness absence of 3.2% sits above the Group's stated target of below 3% (page 136).

Definitions are given at page 140: the coverage percentage divides employees covered by the central health and safety management system by total employees; H2 is a "12-month rolling average number of injuries resulting in lost time or requiring medical care per million hours worked", and "This metric includes our own employees, and not contract staff"; sickness absence "only relates to permanent and temporary employees". No injury figures for non-employee workers in the own workforce are given.

Remuneration metrics (pay gap and total remuneration)

Reference: page 139, as listed in the Annex 1 content index (page 165). Annex 2 maps paragraph 97(a) and 97(b) here (page 168).

Remuneration metrics (page 139):

Both metrics moved against the company year on year: the gender pay gap widened from 6.28% to 7.1%, and the ratio of highest-paid to median pay rose from 6.55 to 6.79. Neither movement is commented on in the text.

Definitions are given in the reporting principles: "The gender pay gap is defined as the difference in the average gross hourly pay level of male and female employees, expressed as a percentage of the average gross hourly pay level of male employees. Data on pay have been collected per company and consolidated for the Group" (page 140). And: "The annual total remuneration ratio is defined as the annual total remuneration for the undertaking's highest paid individual divided by the median employee annual total remuneration (excluding the highest-paid individual)" (page 140).

Context from elsewhere in the report: there is no variable pay at executive level, since "No members of the senior management team had bonus agreements in 2025" (page 230). Further remuneration policy detail is placed outside the statement - "Find out more about Å Energi's remuneration policy in the Diversity Report, which is available on our website aenergi.no" (page 137).

Incidents, complaints and severe human rights impacts

Reference: page 139, as listed in the Annex 1 content index (page 165). Annex 2 maps paragraph 103(a) here and records paragraph 104(a), non-respect of the UNGPs and OECD guidelines, as "Not applicable" (page 168).

Number of incidents and complaints reported (page 139):

The narrative adds how cases are handled: "During the reporting period, a total of two cases of discrimination, including harassment, were reported at the Group. Å Energi has a zero tolerance policy with respect to offensive conduct. We prefer cases of offensive conduct to be addressed and resolved locally, but they can be escalated if necessary" (page 139).

Definitions are given at page 140: the discrimination figure "Includes incidents reported through the whistleblowing channel"; the complaints figure is the "total number of cases via whistleblowing channel, excluding discrimination cases reported under 103 a"; and fines, penalties and compensation information "is taken from the Group's central HR department".

No severe human rights incidents are reported for the own workforce, and the corresponding value chain figure is also nil: "In 2025, no serious incidents involving human rights violations were reported in the Group's upstream and downstream value chains" (page 145). No work-related fatalities occurred (page 137).

Policies related to value chain workers

Reference: page 144, as listed in the Annex 1 content index (page 165). Annex 2 maps paragraphs 17, 18 and 19 here, including the UNGP and ILO fundamental conventions datapoints (page 168).

"The risk of violations of human rights and of unethical practices is often greatest in the supply chain. Supply chain responsibility is therefore a priority for us" (page 144). Three instruments govern it: the Code of Conduct, the "Policy for safeguarding human rights and decent working conditions", and the "Code of Conduct for Suppliers and Business Partners" (page 144).

The supplier code's scope and content: it "applies to all of the supplier's employees, board members, contract staff, consultants and other people acting on behalf of the supplier. The code states that suppliers shall support and respect internationally recognised human rights and ensure that they do not become party to human rights violations. This means that the suppliers themselves must perform human rights due diligence in accordance with the UN's Guiding Principles on Business and Human Rights. Suppliers shall also comply with the fundamental conventions of the ILO on the right to organise, the right to collective bargaining and the elimination of forced labour, child labour and discrimination at the workplace" (page 144).

Enforcement is contractual and consequences are spelled out: "Through a standard clause in Å Energi's contracts, suppliers undertake to comply with the Group's 'Code of Conduct for Suppliers and Business Partners'. If a supplier fails to adhere to it, it will be considered a breach of its contract with Å Energi. This may lead to contract termination, a commensurate compensation claim being made, disqualification as a supplier and/or being reported to the relevant authorities" (page 144). Å Energi's UN Global Compact membership carries "a responsibility to ensure compliance with the standards throughout its value chain" (page 144).

Processes for engaging with value chain workers about impacts

Reference: page 145, as listed in the Annex 1 content index (page 165).

Engagement is with suppliers and knowledgeable third parties rather than with workers directly, and the statement is explicit about that: "In order to mitigate the risk of human rights violations and inadequate working conditions, it is essential to have information about the working conditions of workers in the value chain. The Group takes various approaches to obtaining this information, including engagement with suppliers and relevant stakeholder groups with knowledge about the situation of the workers" (page 145).

The mechanisms: "In tender processes and during pre-qualification, our expectations and requirements of suppliers are clearly set out in accordance with our governing documents. In addition, risk assessments of the Group's suppliers and transactions are conducted using a supplier management system. The system performs an initial assessment based on geographic, social and industrial risk, which provides an insight into high-risk suppliers in our portfolio. The risk assessments are a way of gaining insight about the situation of workers in the value chain, and that insight provides a basis for taking action. In addition, for many years the Group has used the Achilles UNCE database to pre-qualify its biggest and most critical suppliers" (page 145).

Direct dialogue and accountability: "In order to ensure an open dialogue and influence in our supplier chain, we hold regular meetings with the biggest suppliers to Å Energi, covering topics like risk assessments, production and social sustainability. The Group's purchasing department has operational responsibility for ensuring that this engagement takes place and that input is taken into account" (page 145).

A limitation is disclosed: "As at 31/12/2025, we had not signed any global framework agreement or any other agreement with a global trade union regarding the need to respect the human rights of value chain workers" (page 145).

Processes to remediate negative impacts and channels for value chain workers

Reference: page 145, as listed in the Annex 1 content index (page 165).

"Å Energi has established internal and external whistleblowing channels with associated procedures for dealing with whistleblower cases and mechanisms for protecting whistleblowers from retaliation. The external whistleblowing channel is available to all employees, contract staff and external third parties through the Group's website" (page 145).

The statement then discloses the limitation that matters most for this DR: "However, the Group does not have a dedicated process for raising awareness of, and inspiring trust in, the whistleblowing channel amongst value chain workers" (page 145). No assessment of whether value chain workers know of or trust the channel is reported, and no figures are given for reports received from them.

The channel itself is described under business conduct: reports may be submitted through the whistleblowing portal, which "also enables anonymous whistleblowing of issues of concern affecting our business. The whistleblowing portal is available both on our intranet and the website aenergi.no" (page 158). The Chief Audit Executive is the first recipient and chairs a whistleblowing committee where one is convened, and procedures require that "all whistleblowing reports shall be taken seriously, that whistleblowers shall be protected against retaliation and that all issues of concern shall be investigated" (page 158).

Contractual remediation routes are set out under S2-1: breach of the supplier code "may lead to contract termination, a commensurate compensation claim being made, disqualification as a supplier and/or being reported to the relevant authorities" (page 144). Outcome for the year: "In 2025, no serious incidents involving human rights violations were reported in the Group's upstream and downstream value chains" (page 145).

Taking action on material impacts on value chain workers

Reference: page 145, as listed in the Annex 1 content index (page 165). Annex 2 maps paragraph 36, human rights issues and incidents in the upstream and downstream value chain, to this section (page 170).

The disclosure is largely a declared absence of action, and the statement is blunt about it: "Å Energi is continuously striving to put the spotlight on social sustainability and ensure that it chooses suppliers with responsible value chains. During 2025, Å Energi made it a priority to raise skills in this area, including through lectures, nano-courses and internal information sharing. As at 31/12/2025, no specific actions had been taken to manage the potential negative impacts and risks associated with workers in the value chain. Nor have any quantifiable targets been set for mitigating the risk of violations of human rights and labour rights. In 2025, no serious incidents involving human rights violations were reported in the Group's upstream and downstream value chains" (page 145).

What is in place operates through procurement rather than as topic-specific action: supplier risk assessment in the supplier management system on geographic, social and industrial risk; pre-qualification of the biggest and most critical suppliers through the Achilles UNCE database; contractual commitment to the supplier code with termination and disqualification as sanctions; and regular meetings with the largest suppliers covering risk assessments, production and social sustainability (pages 144-145). Due diligence under the Norwegian Transparency Act is reported separately: "Å Energi produces an annual report on the due diligence carried out by the Group in accordance with the Transparency Act. This is available on our website aenergi.no" (page 145).

Risk identification is quantified even though action is not: "In 2025, Å Energi identified 87 suppliers that operate in 13 countries with a medium to high risk of breaches of workers' human rights" (page 142). No remediation case figures or severe human rights incidents are reported.

Targets related to value chain workers

Reference: page 145, as listed in the Annex 1 content index (page 165).

Å Energi discloses that it has set no targets: "As at 31/12/2025, no specific actions had been taken to manage the potential negative impacts and risks associated with workers in the value chain. Nor have any quantifiable targets been set for mitigating the risk of violations of human rights and labour rights" (page 145).

Nor are there metrics: "The scope of our reporting under ESRS S2 - Workers in the value chain is based on financial consolidation. As at 31/12/2025, no metrics have been established for this area, but our reporting will follow the same consolidation principles when they have been determined. Nevertheless, the text below includes some figures to give a general overview of the scope of the value chain" (page 146).

The one figure offered in place of a target is a risk-exposure count: "In 2025, Å Energi identified 87 suppliers that operate in 13 countries with a medium to high risk of breaches of workers' human rights" (page 142), sourced from "Å Energi's centralised purchasing system. The system's classification is based on its own risk assessment module and external sources of data on risk that have been incorporated into supplier assessments. The figure reflects the Group's supplier portfolio at the end of the reporting year" (page 146).

Effectiveness in the absence of targets is tracked through supplier risk assessment and pre-qualification, the Achilles UNCE database, annual Transparency Act due diligence reporting, and the nil incident return for 2025 (pages 145-146).

Policies related to affected communities

Reference: page 149, as listed in the Annex 1 content index (page 165). Annex 2 maps paragraph 16 human rights policy commitments here and paragraph 17 to the S3 "Results" section (page 170).

"Å Energi is a member of the UN Global Compact (UNGC) which commits it to following that organisation's ten universal principles on responsible business conduct... Our membership also commits us to seeking out sustainable solutions that create value for people, nature and society. Our membership covers the whole Group and its subsidiaries, and our CEO has overall responsible for overseeing it. Each year, Å Energi reports to the UNGC through a 'Communication on Progress' that documents our progress in the various areas" (page 149).

The policy set is the Code of Conduct, the "Policy for safeguarding human rights and decent working conditions" and the supplier code, which "specifies that suppliers shall respect the rights and social, cultural, environmental and financial interests of affected communities - particularly those of indigenous peoples, tribal peoples and other vulnerable groups" (page 149). "All of our governing documents build on international standards and guidelines established by the United Nations (UN), International Labour Organization (ILO) and Organisation for Economic Co-operation and Development (OECD)" (page 149).

A clear absence is declared: "As at 31/12/2025, Å Energi had not drawn up any separate governing documents, targets or metrics for land use change in local communities, as this has been a continuous process that is dealt with as required" (page 149).

Affected communities are defined: "residents and users of our services in areas where we supply electricity, shareholder municipalities and municipalities that host infrastructure, as well as users of the countryside where our physical installations are located. Beyond this, we have not identified specific groups who are more exposed to negative impacts than others" (page 149).

Processes for engaging with affected communities about impacts

Reference: page 150, as listed in the Annex 1 content index (page 165).

"Å Energi has a wide range of stakeholders in affected communities, and we give high priority to good communication, establishing a common understanding and constructive engagement on topics that are important to them. We carry out dialogue meetings, AGMs and shareholder meetings covering topics including our ownership model, new construction projects, reliability of supply, biodiversity, coordination with countryside users, licence terms and opportunities for collaboration. The frequency of the dialogue meetings depends on the topics, project and need, with responsibility lying with executive managers or project managers at subsidiaries. Shareholder meetings and AGMs are normally held in accordance with a regular annual cycle" (page 150).

Open access is described: "All affected stakeholders can also contact Å Energi directly through its subsidiaries' established communication channels. These channels allow them to provide feedback, suggest improvements and express concerns or needs. We consider our engagement with local communities to be effective" (page 150). The effectiveness claim is asserted rather than evidenced by a measure.

Much of the engagement is regulated rather than voluntary: "Much of our engagement is regulated through licensing processes, through which the Norwegian Water Resources and Energy Directorate (NVE) sets clear requirements to involve local communities and stakeholders. For major development projects, NVE requires us to notify it of our proposed impact assessment plan prior to submitting an application... NVE also holds public consultations" (page 151). For smaller projects "where NVE does not require prior notification, we assess the need for engagement on a case-by-case basis" (page 151). During operation, engagement continues "particularly in areas with strong environmental interests, such as river systems with salmon populations" (page 151).

Processes to remediate negative impacts and channels for affected communities

Reference: page 150, as listed in the Annex 1 content index (page 165).

"Members of affected communities and in the surrounding area can report nonconformities or issues of concern through the Group's whistleblowing channel. It is available to everyone through our website aenergi.no, and it can be used to send anonymous or direct reports. We have good procedures for ensuring that whistleblowers do not suffer retaliation" (page 150).

The limitation on awareness and trust is disclosed rather than glossed: "The Group has not conducted a formal assessment of the extent to which stakeholders in affected communities are familiar with and trust our whistleblowing channels" (page 150).

Remediation in practice runs through the licensing system and compensation: "Feedback from affected parties and licensing requirements form the basis for our actions during both construction and operation", and "Affected landowners are compensated in accordance with the applicable standard rates, and agreements are reached with municipalities where necessary. Other actions are considered on a case-by-case basis in close consultation with affected communities" (page 151). Licence conditions can also compel further action: "Many licences also come with conditions regarding authorisations. This allows the Norwegian Water Resources and Energy Directorate (NVE) or The Norwegian Environment Agency, for instance, to impose additional measures" (page 102).

The year's outcome is a nil return: "In 2025, no violations of human rights were reported in relation to affected communities" (page 151). No number of community grievances received or resolved is given.

Taking action on material impacts on affected communities

Reference: page 151, as listed in the Annex 1 content index (page 166). Annex 2 maps paragraph 36, human rights issues and incidents, to the S3 "Results" section (page 170).

The impact being managed is described first: "Building and operating electrical installations and infrastructure has a negative impact on land and recreational areas in affected communities. This impact includes both visual alterations to the landscape and land directly occupied by projects. Building and transporting renewable energy requires the use of areas that can affect and create challenges for local industries including forestry, reindeer husbandry and tourism. In addition, development projects affect recreational areas and have a negative impact on the quality of outdoor recreational experiences in affected communities" (page 151).

Actions (page 151): "We consider it very important to engage constructively during the licensing process in order to identify and reduce negative impacts on affected communities... Licence applications and concept selection studies include assessments of social benefits, economics and environmental impacts, and they inform the licence terms and mitigation measures. In relation to this, we are testing ecosystem accounting in order to develop a better understanding of our impact and identify possible improvements."

Specific mitigations are named: "In conjunction with grid-related projects, actions such as low-impact forest clearing and revegetation of site roads reduce the impact on the natural environment. In the case of hydroelectric power stations, actions are required in relation to rivers being dammed and water levels in being regulated. For example, it may be necessary to remove trees before areas are flooded in order to ensure opportunities for outdoor recreation and fishing. Affected landowners are compensated in accordance with the applicable standard rates" (page 151).

Accountability: "Our Regulatory Affairs Department and staff at the parent company, working with dedicated teams at our subsidiaries, are responsible for managing our impacts on affected communities" (page 151). Result for the year: "In 2025, no violations of human rights were reported in relation to affected communities" (page 151). No CapEx or OpEx amounts are attached.

Targets related to affected communities

Reference: page 149, as listed in the Annex 1 content index (page 166).

Å Energi discloses no targets for this topic and states the position and the reason: "As at 31/12/2025, Å Energi had not drawn up any separate governing documents, targets or metrics for land use change in local communities, as this has been a continuous process that is dealt with as required" (page 149).

In place of targets, the statement describes how effectiveness is tracked. Engagement quality is asserted and the basis for it described: "We consider our engagement with local communities to be effective" (page 150), resting on dialogue meetings, AGMs and shareholder meetings, open access through subsidiaries' communication channels, and the statutory consultation steps NVE requires for major development projects (pages 150-151). Impact understanding is being built through a new method: "we are testing ecosystem accounting in order to develop a better understanding of our impact and identify possible improvements" (page 151).

Two measurable outcomes are reported for the year, both nil returns: "In 2025, no violations of human rights were reported in relation to affected communities" (page 151), and no community-related fines or compensation figures are presented. One acknowledged gap in the tracking: "The Group has not conducted a formal assessment of the extent to which stakeholders in affected communities are familiar with and trust our whistleblowing channels" (page 150).

No target relating to land take, compensation, consultation coverage or grievance resolution is stated, and no base year or timeframe for setting one is given.

Business conduct policies and corporate culture

Reference: pages 157 and 158, as listed in the Annex 1 content index (page 166). Annex 2 maps paragraph 10(b), the UN Convention against Corruption, and paragraph 10(d), protection of whistleblowers, here (page 170).

"Together, our code of conduct and values constitute an important foundation for our corporate culture. Our values are: We lead the way, We take responsibility, and We play as a team. Our code of conduct guides our business activities and sets out our fundamental duty to conduct ourselves in a way that is sustainable, ethical and socially responsible. Å Energi's code of conduct applies to all companies in the Group and everyone who works for Å Energi. This includes employees at all levels, Board members, contract staff, consultants and other people acting on behalf of, or representing, Å Energi" (page 157).

Ownership and dissemination: "The code of conduct and values have been adopted by the Board of Directors, and the HR Director has ownership of them. Managers at the group are responsible for promoting the code of conduct and values." Training is described: "Employees shall be given training as part of their onboarding process, as well as regular refreshers. In 2025, there was a focus on improving training programmes and adapting them. The need for dilemma training, guidance and tailored training for all levels of the organisation are continuously reviewed" (page 157).

The culture work is dated: "Since the merger, we have systematically addressed our business conduct and corporate culture, including a culture assessment in 2022, establishing new joint values and a code of conduct for the Group in 2023 and creating and conducting various types of training and awareness-raising in 2024 and in 2025. Work on improving our business conduct and corporate culture will continue in 2026" (page 157).

Whistleblower protection is set out at page 158, including channels to management, employee representatives, safety representatives, HR, compliance, the audit committee or internal audit, anonymous reporting through the portal, and procedures requiring protection against retaliation. Fair competition and tax are also covered (page 92).

Management of relationships with suppliers

Reference: page 158, as listed in the Annex 1 content index (page 166).

"As a major player with real influence, Å Energi has a responsibility to ensure that suppliers conduct themselves in a way that is responsible and sustainable. Good supplier management is therefore a key prerequisite for ensuring that the Group operates in an ethical manner" (page 158).

Qualification and contracting: "Å Energi's ambition is to put all critical suppliers through a qualification process before they can supply goods and services to the Group. For the biggest and most critical suppliers, Å Energi uses the supplier database Achilles UNCE as part of this process. When they sign a contract, all suppliers with a direct contractual relationship with Å Energi undertake to adhere to the Group's 'Code of Conduct for Suppliers and Business Partners'. Business-specific requirements covering social and environmental matters are also specified when this is deemed relevant" (page 158).

Work in progress is disclosed as such: "The Group has begun work on establishing standardised procedures for risk-based integrity due diligence across the Group. The aim is to ensure that the reputations, backgrounds and capabilities of suppliers meet the Group's requirements and expectations. In addition, the need for additional system support for regular oversight and monitoring of suppliers and other business partners is being reviewed, to ensure that risk assessments remain up-to-date at all times" (page 158).

Environmental requirements were tightened during the year: "In 2025, work began on setting additional requirements for suppliers in order to promote more climate and environmentally friendly procurement. This involves drawing up guidelines, consulting with suppliers and incorporating the requirements into the Group's purchasing procedures. The goal is to reduce GHG emissions, minimise negative impacts on nature and promote a more circular economy through our work with suppliers" (page 158).

The section closes with a declared absence: "Beyond the above, as at 31/12/2025 Å Energi had not set any specific targets for supplier management" (page 158). No payment-practice information is given here.

Prevention and detection of corruption and bribery

Reference: pages 157 and 158, as listed in the Annex 1 content index (page 166). Annex 2 maps paragraph 24(b), standards of anti-corruption and anti-bribery, here (page 170).

"Å Energi considers all forms of corruption unacceptable, and it sets high standards of its own business activities, suppliers and business partners. The Group's goal is that no form of active or passive corruption shall take place within the Group's business activities" (page 157).

The framework: "An anti-corruption handbook for the Group has been produced to complement the code of conduct. The Chief Legal and Compliance Officer has ownership of the handbook, which aims to prevent corruption within the Group's own business activities, as well as at our suppliers and business partners. The anti-corruption handbook is available to all of our employees through the intranet, in both Norwegian and English" (page 157).

Training and risk mapping: "Å Energi has an anti-corruption programme, which consists of training in our code of conduct, anti-corruption handbook and whistleblowing procedures. In addition, work has begun on establishing comprehensive procedures for running background checks on suppliers and business partners. There was a particularly strong focus on this in 2025, which will continue in 2026... Work on cataloguing and identifying parts of the Group exposed to corruption risk was a priority in 2025. As part of this process, areas that may be vulnerable were identified. Training has been given to our managers and certain entity-specific guidelines are being drawn up. This work will continue in 2026" (page 157).

Responsibility is allocated: "Å Energi's Board of Directors and senior management team are responsible for the anti-corruption programme, and the managing directors at subsidiaries are responsible for identifying, monitoring and reporting any risks" (page 157).

Detection runs through the whistleblowing system: "Breaches and suspected breaches of the code of conduct, including corruption and bribery, are managed through the whistleblower system" (page 157), with the Chief Audit Executive as first recipient and independent of the people involved (page 158). No percentage of employees trained or of functions covered by risk assessment is quantified.

Targets related to business conduct

Back-filled from the business conduct chapter, where targets are addressed as part of the MDR-T minimum disclosure requirements rather than as a numbered disclosure requirement. G1-3 became a standalone targets DR only in the 2025/2026 ESRS.

Å Energi discloses no business conduct targets, and says so separately for each sub-topic. On corporate culture: "As at 31/12/2025, the Group did not have any specific targets related to its corporate culture" (page 157). On corruption: "Beyond the above, as at 31/12/2025 we had not set any specific targets for our anti-corruption and anti-bribery activities" (page 157). On whistleblowing: "As at 31/12/2025, the Group did not have any specific targets related to whistleblowing" (page 158). On suppliers: "Beyond the above, as at 31/12/2025 Å Energi had not set any specific targets for supplier management" (page 158). On political activities: "Beyond the above, as at 31/12/2025 we had not set any specific targets in relation to political activities" (page 159).

Consistent with MDR-T's other limb, the statement describes how effectiveness is tracked in the absence of targets:

• An overall aim that functions as a zero-tolerance benchmark: "The Group's goal is that no form of active or passive corruption shall take place within the Group's business activities" (page 157).
• Monitoring through the whistleblowing system, where "Our internal audit service has ultimate responsibility for dealing with matters reported through the whistleblowing channel", with the Chief Audit Executive "responsible for reporting to the senior management team and Board of Directors" (page 158).
• Risk-mapping as a tracked programme: corruption-risk cataloguing was "a priority in 2025", vulnerable areas were identified, manager training was delivered and entity-specific guidelines are being drawn up, with the work continuing in 2026 (page 157).
• Supplier qualification through the Achilles UNCE database and contractual commitment to the supplier code, with standardised risk-based integrity due diligence under development (page 158).
• Outcome metrics reported annually: zero convictions and NOK 0 of fines for anti-corruption and anti-bribery violations in both 2025 and 2024 (page 158).

Incidents of corruption or bribery

Reference: page 157, as listed in the Annex 1 content index (page 166). Annex 2 maps paragraph 24(a), fines for violation of anti-corruption and anti-bribery laws, and paragraph 24(b), standards of anti-corruption and anti-bribery, here (page 170).

Corruption and bribery in 2025 (page 158):

The narrative confirms the nil return: "In 2025 the Group received no convictions or fines for violation of anti-corruption and anti-bribery laws" (page 157).

The reporting basis is stated, including its limits: "Data on convictions for violations of anti-corruption and anti-bribery laws have been obtained from the Group's centralised legal and compliance function. Å Energi only reports confirmed cases, and the metric reflects the position at the end of the reporting year" (page 159). And for fines: "Information about any fines or penalties for violations of anti-corruption and anti-bribery laws and regulations have been obtained from the Group's legal and compliance function. Amounts should be given in Norwegian kroner (NOK)" (page 159). Scope is "based on financial consolidation. This principle applies both to qualitative and quantitative information" (page 159).

Because only confirmed cases are reported, no figures are given for incidents under investigation, confirmed incidents involving own workers or business partners, or dismissals and contract terminations arising from corruption. Suspected breaches are handled through the whistleblower system (page 157), and the own-workforce whistleblowing volumes appear under S1-17 (page 139).

Political influence and lobbying activities

Reference: page 159, as listed in the Annex 1 content index (page 166).

Political engagement is one of Å Energi's material IROs, recorded as a "Potential positive impact on society from political influence and lobbying activities" (pages 67, 155).

"Å Energi works proactively and systematically to understand changes in the regulatory environment by monitoring and analysing conditions in relevant markets, so it can have a positive impact on discussions that affect the electric power industry... Å Energi contributes specialist expertise through expert committees and industry associations" (page 159). Responsibility is named: "Our CSR function is responsible for Å Energi's engagement with political stakeholders", and the CSR function "works closely with the EU in Brussels, and it also engages strongly with Norwegian politicians and the trade association Renewables Norway" (pages 82, 159).

The main topics are listed: development of electrical installations to meet climate goals and reliability-of-supply requirements "through sustainable use of land and nature"; predictability for investment in renewable energy and power; "We need more electricity and more grid capacity, faster - that means reducing lead times and making licensing processes more efficient"; and "A properly functioning market that ensures the optimal use of energy resources" (page 159). The year's focus is given: "The Norwegian parliamentary election in 2025 was a particular area of focus for Å Energi. The government and parliament's planned policies on energy and climate will be monitored by the Group in 2026" (page 159).

The revolving-door datapoint is a nil return: "No member of the Group's Board of Directors or senior management team occupies an equivalent position in a government entity or supervisory authority, nor have they done so in the past two years" (page 159).

Two absences are disclosed: "Our work in relation to the regulatory environment is based on action plans and decisions approved by the senior management team, and on account of the scope and nature of the work, we have not considered it necessary to have further governing documents in this area", and "as at 31/12/2025 we had not set any specific targets in relation to political activities" (page 159). No financial or in-kind political contributions are reported, and no transparency-register entry is given.