Aker

The role of the administrative, management and supervisory bodies

Reference: page 18; pages 19-20.

The Board of Directors comprised seven members at year-end: the Chair, the Deputy Chair and five other members, none of whom hold executive positions in Aker ASA. Three members are elected by employees, two of the four shareholder-elected members are independent (50%), and four members are women, giving a gender ratio of 1.3 (57% women, 43% men).

The Board approves Aker ASA's sustainability policy and the Group's double materiality assessment (DMA) and sustainability statement, responsibilities reflected in its mandate. The Audit Committee, chaired by Frank O. Reite, prepares the Board's oversight of sustainability reporting and oversees risk management and internal control systems. Management, comprising the President & CEO (Oyvind Eriksen) and the CFO (Svein Oskar Stoknes), holds overall responsibility for implementing ownership strategies. The Board received training on sustainability topics, and new members complete an onboarding program covering the portfolio's governance and sustainability approach.

Information provided to and sustainability matters addressed by the administrative, management and supervisory bodies

Reference: page 19.

Management, the General Counsel and the Sustainability Manager provide quarterly updates to the Audit Committee on sustainability-related matters within the portfolio. In addition to the Group's DMA and CSRD reporting plan, the Audit Committee addressed climate-related risks and opportunities, and human rights and decent working conditions through the Company's due diligence process, during 2025, as well as material IROs related to the own workforce based on quarterly reporting from portfolio companies.

The Board has not adopted targets for material sustainability matters but receives an annual update on the results of the company's risk management process, informing its strategic discussions and decisions. Sustainability is integrated into Aker ASA's risk management process, and relevant group functions, including finance, treasury and legal, report regularly to management on matters of significance, including sustainability-related matters.

Integration of sustainability-related performance in incentive schemes

Reference: page 19.

"As of the reporting period, neither Aker ASA nor its subsidiaries have integrated specific sustainability targets into performance-based incentive schemes." Aker ASA's Sustainability Policy encourages the portfolio to include relevant sustainability-related targets in executive remuneration, where relevant, but this remains an expectation rather than a Group-level requirement.

This is consistent with the company's broader materiality-based approach to climate and sustainability governance (see E1-1), under which Aker ASA, as an investor rather than an operator, sets ambitions and expectations for the portfolio rather than binding Group-wide mechanisms such as remuneration links. No further detail on subsidiary-level incentive schemes incorporating sustainability performance is provided in the statement.

Statement on due diligence

Reference: page 20.

"Due diligence forms an integral part of the Group's approach to sustainability. Assessments of actual and potential adverse impacts and risks relating to people and the environment support the Group's alignment with national and international standards." The core elements of the due diligence process are reflected across the statement rather than in a single section.

Aker ASA maps its due diligence disclosures explicitly: integration into governance is described under GOV-2, SBM-1, SBM-3 and G1-1; stakeholder engagement under GOV-1, SBM-2, IRO-1, S1-1 and S2-1; identification and assessment of adverse impacts under IRO-1 and SBM-3; actions to address impacts under E1-3, S1-4, S2-4, G1-1 and G1-3; and outcomes and monitoring under E1-6, S1-9, S1-14, S1-16, E1-4, S1-5 and S2-5.

Risk management and internal controls over sustainability reporting

Reference: page 20.

In 2025, Aker ASA focused on establishing an Internal Control over Sustainability Reporting (ICSR) framework based on the principles of the COSO framework, applying to all portfolio companies covered by the report. Annual risk assessments identify the risk of material errors in reporting, with findings reported to the Audit Committee.

Two risks were identified with corresponding measures. First, completeness and accuracy in identifying and assessing relevant IROs, given the DMA's reliance on subsidiary input, mitigated through validation and ongoing dialogue. Second, completeness and accuracy of reported data from subsidiaries and other investments, mitigated through standardized reporting instructions, shared IT-based reporting tools, and analysis of reported data. "The sustainability statement is assured by the Group's independent auditor," with observations reviewed by management, the Board and the Audit Committee.

Strategy, business model and value chain

Reference: pages 21-23.

Aker ASA is "an industrial investment company with active ownership in a portfolio of independent companies across four key growth areas": Energy, Digitalization and artificial intelligence, Real estate, and Marine biotechnology. During 2025, material portfolio changes included the sale of Philly Shipyard (December 2024), the merger of Aker Horizons' operations, Aker Property Group's investments in SBB, Public Property Invest, Sveafastigheter and Veslefrikk, and investment in AI infrastructure through Nscale, including the Aker Nscale 50/50 joint venture, which signed a USD 6.2 billion customer contract with Microsoft for a data center at Kvandal.

Aker ASA's upstream activities involve securing capital (dividend income of more than NOK 6 billion annually, primarily from Aker BP and Aker Solutions, which together account for nearly 51% of gross asset value). Downstream activities include investments, realizations, dividend distribution and debt repayment. Table 1 sets out the material subsidiaries (Solstad Maritime, Mainstream, Aize, Cognite, Aker Property Group, Aker BioMarine) fully included in the Group's sustainability reporting, their products, markets and geographic areas.

Interests and views of stakeholders

Reference: pages 23-24.

Table 2 sets out how Aker ASA and the Group engage key stakeholders. Employees and employee representatives are engaged through the Global Work Council, Work Environment Committees, performance reviews and board representation, aimed at "creating a safe, engaging and meaningful workplace." Portfolio companies are engaged through board representation, quarterly investment reviews, biannual clearing meetings and networks, to facilitate "responsible, profitable and sustainable business practices."

Business partners are engaged via supplier audits, assessments and meetings to "maintain strong collaboration" and uphold the Code of Conduct. Shareholders, lenders and analysts receive regular updates, investor meetings and quarterly/annual reporting. Authorities receive regulatory reporting, and unions are engaged through the Global Framework Agreement signed with IndustriALL Global Union, Fellesforbundet, Tekna and NITO to safeguard fundamental human and labor rights.

Material impacts, risks and opportunities and their interaction with strategy and business model

Reference: pages 27-28.

"The following ESRS standards are assessed as material for the Aker Group in 2025: E1 Climate Change, E2 Pollution, E5 Resource Use and Circular Economy, S1 Own Workforce, S2 Workers in the Value Chain, G1 Business Conduct." Table 3 categorizes 13 distinct material IROs across these six standards, spanning own operations, upstream and downstream value chain (see iro.json for the full breakdown).

Changes from 2024: positive impacts related to training and skills development were reassessed as non-material, as were two IROs (one on human rights, one on corruption and bribery), "although both topics remain material overall." New material IROs identified in 2025 include equal treatment, diversity and inclusion in other investments in the value chain, and impacts and dependencies related to corporate culture. Current financial effects relate to operational adjustments and compliance costs; "no material risk of significant adjustments to the carrying values of assets and liabilities is considered to exist" beyond what is already reflected in the financial statements. Climate-specific risk identification and scenario analysis is also presented under E1-2 (2025 ESRS numbering).

Description of the processes to identify and assess material impacts, risks and opportunities

Reference: pages 25-27.

The Group's DMA follows three steps. Step 1 (Understanding the Business) maps portfolio companies' products, services and value chains; in 2025 the included companies represented approximately 93% of GAV. Step 2 (Identifying IROs) draws on the ESRS 1 AR 16 topic list, with larger subsidiaries and other investments such as Aker BP and Aker Solutions preparing their own DMAs. Step 3 (Assessing and Prioritizing) applies a 1-to-5 scoring scale to severity, scope, likelihood and financial consequence; a topic is material within own operations when more than 50% of subsidiaries assess it as material, and similarly for the value chain.

For climate, Aker ASA performed a TCFD-aligned scenario analysis using three IEA World Energy Outlook 2025 scenarios (NZE, STEPS, CPS) supplemented with IPCC physical climate data, assessed over 2026/2030/2050 horizons as a percentage of GAV. For pollution, water/marine resources, biodiversity and business conduct, high-level screenings and portfolio dialogue were used instead of a full scenario analysis. Climate-specific risk identification and scenario analysis is also presented under E1-2 (2025 ESRS numbering).

Disclosure requirements in ESRS covered by the undertaking's sustainability statement

Reference: pages 56-57.

The report includes a "Disclosure Requirements in ESRS Covered by the Sustainability Statement" concordance table mapping each ESRS 2 general disclosure and each material topical standard's disclosure requirements to specific pages. ESRS 2 general disclosures (BP-1, BP-2, GOV-1 to GOV-5, SBM-1 to SBM-3, IRO-1, IRO-2) are all covered, at pages 18-28 and 56-57.

For the topical standards, coverage is: E1 (GOV-3 cross-reference, E1-1 to E1-6, pages 19, 29-37); E2 (E2-1 to E2-3, page 38); E5 (E5-1 to E5-3, page 39); S1 (S1-1 to S1-6, S1-9, S1-14, S1-16, S1-17, pages 43-48, 50, 54); S2 (S2-1 to S2-5, pages 49-52, 54); and G1 (G1-1, G1-3, G1-4, pages 53-55). A second table on the same pages lists datapoints deriving from other EU legislation (SFDR, Pillar 3, the Benchmark Regulation and the EU Climate Law), cross-referenced to page or marked "N/A" where not applicable.

Transition plan for climate change mitigation

Reference: page 29.

"Aker ASA has not yet established a transition plan in accordance with the requirements of ESRS E1-1, either for the Group or for the portfolio as a whole. Reporting emissions targets in absolute terms is not considered appropriate for Aker ASA." This reflects the company's role "as an investor rather than an operator," consistent with market practice for comparable investment companies. Pending revisions to the ESRS standards, Aker ASA states it cannot currently indicate when an ESRS E1-1-aligned transition plan will be in place.

In the meantime, the company applies a materiality-based approach under which it: monitors the portfolio's climate impacts and risks and supports credible, company-specific climate strategies; promotes alignment with net zero ambitions and stakeholder expectations; and integrates climate considerations into investment decisions and board-level oversight. Portfolio companies themselves retain responsibility for their own transition plans; Aker BP's is referenced as embedded in its business model (page 29).

Identification of climate-related risks and scenario analysis

Back-filled from ESRS 2 IRO-1, where this content is disclosed in the FY2025 report (pages 25-26, 29-30). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Aker ASA "has performed a scenario analysis in accordance with the recommendation of the Task Force on Climate-related Financial Disclosures (TCFD)," first conducted in 2022 and updated annually. It draws on three IEA World Energy Outlook 2025 scenarios covering 2025-2050: NZE ("high transition risk; low physical risk"; no longer a "limited overshoot" scenario in WEO 2025, as warming now peaks at 1.6C before returning below 1.5C by 2100); STEPS ("moderate transition risk; significant physical risk"); and CPS ("low transition risk; high physical risk"), supplemented with IPCC Sixth Assessment Report data. Risks and opportunities are assessed over short (2026), medium (2030) and long term (2050) as a percentage of GAV; "no material parts of the value chain are excluded." The analysis involved Aker ASA's Investment Director, General Counsel and CFO, cross-checked against critical assumptions (asset lifetimes, cash flow, impairments); "the assessment has not identified any need to change accounting estimates."

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 (page 27, section 1.5.3; pages 29-30, section 2.1.1). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

"Aker ASA's strategy is designed to address material IROs. Periodic scenario analyses across the portfolio and internal risk assessments contribute to evaluating adaptability over short, medium and long-term time horizons." Business models "are continuously assessed against the company's financial plan," reviewed quarterly by the Finance Committee, and "Aker ASA considers its strategy and diversified portfolio to be resilient against material IROs." At the E1 level, "portfolio resilience analyses form the basis of Aker ASA's financial plan," and Aker BP "conducts regular resilience analyses based on the IEA scenarios," testing commodity price, levy and tax assumptions in its valuation models. With "few assets directly exposed to an increased frequency of extreme weather," and most assets having "long remaining useful lives or being capable of retrofit or repurposed if required," long-term physical risks "are not expected to have a material impact on asset lifetimes, strategic planning or capital allocation."

Policies related to climate change mitigation and adaptation

Reference: pages 30-31.

Three Board-approved policies apply across the entire portfolio. The Investment Policy describes how Aker ASA exercises active ownership, including monitoring climate-related IROs as part of ownership agendas; the Investment Director updates it and the CEO implements it. The Risk Policy covers how the company prioritizes and manages climate-related risks and opportunities, with portfolio companies expected to establish their own risk management processes. The Sustainability Policy sets out commitments across climate, social and governance matters, and expects portfolio companies to establish proportionate climate targets and action plans, manage emissions in line with national/international expectations, and identify and manage physical and transition risks using frameworks such as TCFD.

Table 4 shows which of Aize, Aker BioMarine, Aker Property Group, Cognite, Mainstream, Renewable Power and Solstad Maritime have adopted climate change mitigation, adaptation, energy efficiency and renewable energy policies; Aize and Aker Property Group currently address sustainability through their Codes of Conduct rather than dedicated climate policies.

Actions and resources in relation to climate change policies

Reference: pages 31-34.

Aker ASA identifies and implements actions through board representation, regular reporting and direct dialogue with portfolio companies; quarterly and annual reporting on selected indicators is overseen by the General Counsel, who reports to the Audit Committee. Table 6 sets out key climate actions across the portfolio: Aker BP is decommissioning fields (Ula field, Skarv/Alvheim/Eiga) expected to cut Scope 1 and 2 emissions by up to 423,000 tCO2e by 2030-2050, alongside energy management actions; Aker Solutions is pursuing renewable energy and energy efficiency at its Yard (a 50% Scope 1/2 reduction target by 2030 versus 2023) and low-emission procurement; Aker Qrill Company achieved over 30% higher catch rates and approximately 15% lower CO2 intensity in 2025 through improved harvesting.

Solstad Maritime/Offshore report shore power and battery-hybrid retrofits (1-12% annual fuel/emissions reductions per vessel) and a biofuel trial on the AHTS Normand Ferking. Aker BioMarine is purchasing green electricity for its Houston facility, expected to eliminate Scope 2 emissions there from 2026, and has already transitioned to LED lighting.

Targets related to climate change mitigation and adaptation

Reference: pages 32-33.

No Group-level, outcome-oriented, time-bound climate target is set, as this "is not considered appropriate to set... in accordance with the minimum disclosure requirements (ESRS 2 MDR-T) at the Group level" given the indirect, portfolio-dependent nature of the Group's climate impact. Instead, Table 5 sets out targets at four portfolio companies: Aker BP (50% Scope 1/2 reduction by 2030 and 90% by 2050 against a 2017 baseline of 1,250,000 tCO2e, 29% achieved; carbon-removal-credit neutrality by 2030); Aker Solutions (50% Scope 1/2 reduction by 2030 against a 2023 baseline, 36.2% achieved; net zero Scope 1-3 by 2050, though Scope 3 rose 7%); Aker Qrill Company (50% emission-intensity reduction per kg of krill meal by 2035, 2.43 to 1.73 kg CO2e/kg achieved); and Aker BioMarine (50% emission-intensity reduction per net revenue by 2030, 0.154 to 0.128 CO2e/kUSD achieved).

Solstad Maritime and Solstad Offshore have communicated net zero ambitions aligned with the 1.5C pathway rather than quantified targets; Aker BP's and Aker Qrill's targets are not science-based, while Aker Solutions followed the SBTi Absolute Contraction Approach.

Energy consumption and mix

Reference: page 35.

Table 7 reports energy consumption and mix for the Group's own operations (the same boundary as Scope 1 and 2 GHG reporting), so energy consumption from other investments in the value chain is excluded. Solstad Maritime accounts for 93% of the Group's own-operations energy consumption, predominantly marine gas oil combustion on vessels. Total energy consumption was 1,408,974 MWh in 2025, of which 99.8% (1,406,246 MWh) came from fossil sources, 0.1% (888 MWh) from nuclear, and 0.2% (2,728 MWh) from renewable sources.

Purchased electricity that lacks guarantees of origin is conservatively classified as fossil under ESRS, even though most of this consumption occurs in Norway "where power generation is predominantly renewable." Energy intensity from subsidiaries in high climate impact sectors (Aker Property Group, Aker BioMarine, Mainstream, Solstad Maritime) was 112 MWh per million NOK of net revenue (Table 8). "Energy consumption is reported in accordance with ESRS for the first time in 2025, and comparative figures are therefore not included."

Gross Scopes 1, 2, 3 and Total GHG emissions

Reference: pages 35-37.

Table 9 reports gross Scope 1 emissions of 368,209 tCO2e in 2025, down 16% from a 2024 base year of 440,465 tCO2e, driven mainly by the sale of Aker BioMarine's Feed Ingredients segment. Scope 2 emissions were 7,508 tCO2e location-based (down 54%) and 9,525 tCO2e market-based (down 64%). Scope 3 emissions totalled 15,216,015 tCO2e (down 4%), entirely attributed to Category 15 Investments, "the only significant Scope 3 category for the Aker Group," which accounts for 98.5% of total Scope 3 emissions and originates primarily from Aker BP's Category 10 (processing of sold products) and Category 11 (use of sold products) emissions.

Total GHG emissions (location-based) were 15,591,731 tCO2e, down 4% year on year; Aker BP accounts for 94% of total GHG emissions. GHG intensity per net revenue fell from 1,262 to 849 tCO2e/NOK million (Scope 1-3) and from 35 to 20 tCO2e/NOK million (Scope 1-2), per Table 10. Biogenic emissions were 891 tCO2e (Scope 1) and 280 tCO2e (Scope 3 Category 3).

Policies related to pollution

Reference: page 38.

Aker ASA has not established a dedicated pollution policy at Group level; its Investment Policy and Risk Policy (described under E1-2/chapter 2.1) are the relevant governing documents, and pollution is addressed through active ownership in Aker BP and Aker Solutions rather than Group-wide policy. "Both Aker BP and Aker Solutions have established policies and procedures to identify, manage, and reduce their material impacts related to water pollution," and both are "committed to integrating environmental considerations into their core operations and collaborate with partners and suppliers toward this end."

Pollution "has been assessed as material in Aker ASA's downstream value chain, primarily due to investments in oil and gas-related activities through Aker BP and Aker Solutions," but "has not been assessed as material to the Group's own operations," so this chapter is narrower in scope than the other topic chapters. Aker ASA expects portfolio companies to identify pollution-related IROs and implement appropriate policies where material matters are found.

Actions and resources related to pollution

Reference: page 38.

"Although Aker ASA has not established pollution-related targets or key actions in line with ESRS 2, pollution is an important area in its active ownership in Aker BP and Aker Solutions." Actions are channelled through the same monitoring approach as climate matters (section 2.1.4).

Aker BP "takes a structured approach to pollution management, based on the principles of prevention, reduction, remediation, and restoration," with environmental risks assessed ahead of new projects and "clear incident response procedures" for discharges. Aker Solutions "aims to prevent pollution and maintain control in the event of unforeseen incidents," using Best Available Technologies, substitution of hazardous chemicals, and optimization of material choices; "all locations update their environmental aspects and risk assessments annually," with discharges managed within regulatory permits and subject to periodic monitoring.

Targets related to pollution

Reference: page 38.

"Aker BP has not set short- or long-term reduction targets for water pollution, as total discharges depend on activity levels in operations and drilling." Instead, "annual indicators for reinjection of produced water, as well as oil and other contaminants in discharge water, are monitored and followed up monthly to evaluate commitments and actions." These indicators are installation-specific, and "associated targets are set annually in accordance with Aker BP's discharge permits" rather than as fixed multi-year reduction goals.

No pollution targets are disclosed for Aker Solutions or at Group level in this chapter; the statement instead cross-references section 2.1.4 (climate-related monitoring, actions and targets) as also relevant to pollution. No Group-level pollution target under ESRS 2 MDR-T has been established.

Policies related to resource use and circular economy

Reference: page 39.

Aker ASA's Sustainability Policy communicates "a long-term ambition of zero waste" and encourages the portfolio "to pursue scalable solutions that address waste challenges." Its Investment Policy and Risk Policy (chapter 2.1) are also relevant. Aker BP's circular economy policy, owned by the SVP People and Safety, "expresses its ambition to optimize material use and reduce waste across its own operations and upstream value chain," committing to a waste hierarchy of reduction at source, reuse and repair, then recycling and energy recovery, applied "throughout the project lifecycle, from field development through drilling and production to decommissioning."

Aker Solutions has four governance documents: a sustainability policy (EVP Strategy and Technology), an HSSE policy (EVP New Build), a waste management procedure (Head of Environment), and a work instruction for handling and disposal of surplus and residual materials (Supply Chain Excellence), together covering resource flows, waste reduction and circular economy.

Actions and resources related to resource use and circular economy

Reference: page 39.

"Although Aker ASA has not established targets and actions in line with ESRS 2, resource use and circular economy are important areas in its active ownership in Aker BP and Aker Solutions," monitored through the same section 2.1.4 mechanism used for climate.

Aker BP's key actions relate to reducing drilling waste, reusing drilling fluids, recycling materials from decommissioning, and supplier engagement; performance in decommissioning is tracked via "the share of materials from decommissioned installations that are recycled." Aker Solutions' actions include the use of robotics at its Verdal technology center to reduce material waste, piloting 3D printing to recover waste materials, deploying drone technology for maintenance, and increasing material reuse between projects, with "approximately 10,700 tons reused in 2025." Project managers will evaluate the effectiveness of these actions "over the next two years."

Targets related to resource use and circular economy

Reference: page 39.

No quantified Group-level or portfolio-company targets for resource use and circular economy are disclosed. "No specific targets have yet been set" for Aker BP, "as Aker BP is still evaluating which approaches are best suited to its operations," beyond monitoring resource inflows/outflows and decommissioning-recycling shares. Aker Solutions similarly reports actions (robotics, 3D printing, material reuse) without a stated numerical target, instead evaluating "the effectiveness and feasibility of the actions over the next two years."

At Group level, Aker ASA's sustainability policy sets only a qualitative "long-term ambition of zero waste," not a time-bound, outcome-oriented target meeting ESRS 2 MDR-T requirements. As with pollution, the statement cross-references section 2.1.4 (climate-related monitoring, actions and targets) as the relevant monitoring mechanism for this topic.

Policies related to own workforce

Reference: pages 43-44; page 50.

Aker ASA's policies on human rights and working conditions apply to employees, non-employees and others acting on the company's behalf, implemented across the Group with subsidiaries either adopting Aker ASA's policies or developing aligned ones. Key policies: Aker ASA's Code of Conduct, covering commitments to fundamental human and labor rights and equal treatment; the Sustainability Policy; the Global Framework Agreement (GFA), signed with IndustriALL Global Union, Fellesforbundet, NITO and Tekna, setting minimum social safeguards under the UN Guiding Principles, the ILO Declaration and the OECD Guidelines; and Guidelines for Equality, Diversity, and Inclusion governing Board, management and supervisory body composition.

"Aker ASA's Code of Conduct clearly states that harassment or degrading treatment will not be tolerated in any form," backed by whistleblowing procedures and remedial measures, including disciplinary sanctions where necessary. The GFA "further sets expectations for the Group to actively work toward eliminating gender pay gaps."

Processes for engaging with own workforce and workers' representatives about impacts

Reference: pages 44-45.

The Aker Model is described as "a living form of collaboration that has evolved over generations across the Aker portfolio," rooted in trust-based cooperation among owners, management and employee representatives, going "beyond legal and contractual requirements." Three of Aker ASA's seven Board members are employee-elected, and a Global Works Council (GWC), established in 2018 and chaired by an employee-elected board member, promotes cooperation between employee representatives across the portfolio.

Table 11 sets out subsidiary-level dialogue mechanisms: Aize runs semi-annual employee engagement surveys and an annual "Aizembly"; Aker BioMarine runs semi-annual eNPS surveys, monthly town halls and quarterly trade union meetings; Cognite holds an annual conference and monthly KPI reviews; Solstad Maritime holds annual crew conferences. Each subsidiary with more than 30 employees holds at least one annual Working Environment Committee meeting. The CXO leadership development program, established in 2022, develops talent across the portfolio.

Processes to remediate negative impacts and channels for own workforce to raise concerns

Reference: page 44; page 54.

The Group's whistleblowing channels, "operated by independent third parties, allow employees and non-employees to anonymously report concerns, incidents, breaches, or suspected breaches of the Code of Conduct and internal rules." At Aker ASA, reports may be submitted through three channels: the reporting line, the independent whistleblowing channel, or directly to the Chair of the Audit Committee, the last of which "supports direct reporting to the Board where other points of contact are considered inappropriate."

Reports received are "first assessed by the independent third party before being forwarded to the person responsible at the relevant company" (the General Counsel at Aker ASA); where escalation criteria are met, matters are referred to the Chair of the Audit Committee. Whistleblowers "may remain anonymous throughout the process, and personal data is handled in accordance with applicable GDPR regulations." Subsidiaries maintain their own equivalent channels administered by independent third parties.

Taking action on material impacts on own workforce

Reference: pages 45-47.

"No outcome-oriented and time-bound targets in line with ESRS 2 MDR-T have been set at the Group level, as subsidiaries operate as independent entities under different market and regulatory conditions." Instead, quarterly reporting on health-and-safety and equal-treatment indicators is overseen by the General Counsel, who reports to the Audit Committee.

Table 12 sets subsidiary targets: Aize targets a 4.0 engagement score (achieved 4.11); Aker BioMarine targets zero work-related injuries in Houston (achieved 2) and 50/50 gender balance in recruitment (achieved 22 men/27 women); Aker Property Group targets zero injuries and near misses (achieved 1 and 4); Cognite targets 100% anti-harassment training participation (achieved); Mainstream targets a serious incident potential below 1.74 and LTIF below 3.00 (achieved 2.62 and 3.14); Solstad Maritime targets a 1.00 total recordable case frequency (achieved 1.20) and 10% female maritime personnel by 2030 (at 9%). Table 13 lists corresponding subsidiary key actions, such as equal pay analyses, harassment/discrimination surveys and safety training, none of which "give rise to material operating or capital expenditure."

Targets related to own workforce

Reference: page 46.

No Group-level, outcome-oriented, time-bound target for own-workforce matters is set under ESRS 2 MDR-T, "as subsidiaries operate as independent entities under different market and regulatory conditions." Aker ASA instead defines overall ambitions and expectations for the Group, with subsidiaries expected to set their own company-specific targets, "giving them ownership of the process and accountability for delivery."

Table 12 (see S1-4) sets out the subsidiary-level targets actually in place: injury-reduction and engagement-score targets at Aize, Aker BioMarine, Aker Property Group, Mainstream and Solstad Maritime, and gender-balance/pay-equality and female-representation targets at Aker BioMarine and Solstad Maritime respectively. "No baseline year has been defined for any of the targets, as the reporting parameters are not considered appropriate for this purpose."

Characteristics of the undertaking's employees

Reference: pages 47-48.

Total headcount was 2,891 at year-end 2025, down from 3,102 in 2024 (Table 14). By country, Norway had 1,367 employees (1,545 in 2024), the Philippines 559 (580), the United States 356 (295), Australia 176 (200), South Africa 84 (83), the United Kingdom 99 (102), Chile 61 (81) and India 62 (1). By gender (Table 16): male 2,166, female 716, other 9 (2024: 2,309/792/<5).

By contract type (Table 17): 2,799 permanent employees (674 female, 2,116 male, 9 other), 64 temporary, and 28 non-guaranteed-hours employees. Employee turnover was 16.9% in 2025 versus 16.0% in 2024, with 487 employees leaving during the year (Table 15). Employee counts correspond to Note 12 of the consolidated financial statements; subsidiaries with limited operations are included only in the gender and country breakdowns.

Diversity metrics

Reference: page 48.

Table 18 reports gender distribution in top management (executive management at Aker ASA and at subsidiaries): 76.3% male (29 individuals) and 23.7% female (9 individuals) in 2025, versus 72.5%/27.5% in 2024, a slight decline in female representation at the top-management level.

Table 19 reports employees by age group: 396 under 30 (2024: 471), 1,728 aged 30-50 (1,868-73), and 758 over 50 (696). Diversity governance is set out under the Guidelines for Equality, Diversity, and Inclusion (see S1-1), which govern Board, management and supervisory body composition, and the GFA's commitment to "actively work toward eliminating gender pay gaps." Board-level gender balance is reported separately under GOV-1 (57% women, 43% men).

Health and safety metrics

Reference: page 48.

Table 20 reports 97% of own workforce covered by a health and safety management system based on legal requirements and/or recognized standards (up from 90% in 2024); 11 recordable work-related accidents (up from 9 in 2024), a rate of 1.24 per million hours worked (2024: 1.08); and zero fatalities in both years. "No group-level occupational health and safety management system is in place," with relevant subsidiaries responsible for implementing their own systems.

The narrative states that "the Group recorded ten work-related accidents" in 2025: seven onboard five of Solstad Maritime's offshore vessels, two reported by Aker Property Group in property management operations, and two at Aker BioMarine's Houston production facility, a breakdown that itself sums to eleven, matching Table 20's recordable-accidents count of 11 rather than the "ten" stated in the surrounding text.

Compensation metrics (pay gap and total compensation)

Reference: page 48.

Table 21 reports a gender pay gap of 5.6% in 2025, down from a restated 9.3% in 2024 (originally reported as 10%). The total annual remuneration ratio of the highest-paid individual (the President & CEO) to the median remuneration of all employees was 36.8 in 2025, versus a restated 36.6 in 2024 (originally 39.3).

Two methodological changes were made in 2025: the gender pay gap is now calculated on average gross hourly pay rather than annual average pay, with 2024 figures restated using 1,950 hours as the standard full-time-equivalent; and for both indicators, "the CEO's compensation is limited to base salary and actual bonus paid," excluding other benefits previously included, "to align the methodology with subsidiaries reporting." Both indicators include fixed and variable pay.

Incidents, complaints and severe human rights impacts

Reference: page 48.

"In 2025, three cases related to discrimination or harassment were recorded and addressed across two subsidiaries, all of which were reported through the subsidiaries' whistleblowing channels. No fines or sanctions were imposed on the relevant subsidiaries." Discrimination and harassment indicators "are reported in accordance with ESRS for the first time in 2025, and comparative figures are therefore not included."

This is the own-workforce complement to the corruption/bribery incident disclosure under G1-4 and draws on the same whistleblowing infrastructure described under S1-3 (independent third-party channels, escalation to the Chair of the Audit Committee where criteria are met, GDPR-compliant anonymity). No severe human rights impacts affecting the Group's own workforce are reported as having occurred in 2025.

Policies related to value chain workers

Reference: pages 49-50.

Aker ASA's policies on human rights and working conditions in the value chain are anchored in three documents. Aker ASA's Code of Conduct describes commitments to fundamental human rights and decent working conditions in the value chain, stating the company "shall strive to ensure that its operations do not cause or contribute, directly or indirectly, to adverse impacts." The Sustainability Policy describes how Aker ASA works with the portfolio to avoid causing or contributing to adverse human rights impacts. Aker ASA's Code of Conduct for Business Partners governs cooperation with suppliers, customers and other third parties, requiring a safe working environment and risk-based due diligence.

Together the policies commit to zero tolerance for child labor, forced labor, modern slavery and human trafficking, aligned with the UN Guiding Principles, the ILO Declaration and the OECD Guidelines. Table 22 lists subsidiary-level supplier policies, such as Aize's Supplier Code of Conduct and Solstad Maritime's Procurement Policy (all procurement above USD 50,000).

Processes for engaging with value chain workers about impacts

Reference: pages 50-51.

Aker ASA and its subsidiaries "apply a risk-based approach to assessing potential adverse impacts on value chain workers," using criteria such as country of operation and activity type, in line with the Norwegian Transparency Act, the OECD Guidelines and the UN Guiding Principles. "At Group level, direct engagement with business partners' workforce is limited to whistleblowing channels," while several subsidiaries maintain their own procedures for direct and indirect dialogue with suppliers.

Table 23 lists subsidiary supplier-dialogue mechanisms: Aize sends annual questionnaires to selected suppliers; Aker BioMarine conducts annual supplier reviews and questionnaires; Aker Property Group conducts annual supplier audits and ongoing dialogue; Solstad Maritime runs value chain surveys and supplier self-assessments at onboarding. "Most subsidiaries engage through credible intermediaries rather than directly with individual workers," and effectiveness is assessed via supplier responsiveness and resolution of identified deviations.

Processes to remediate negative impacts and channels for value chain workers to raise concerns

Reference: pages 50-51; page 54.

"All value chain workers can report concerns, incidents, or suspected breaches of Aker ASA's or subsidiaries' Code of Conduct directly through the Group's whistleblowing channels," the same third-party-operated, anonymous system described under S1-3. Business partner audits are conducted "as needed, following a risk-based approach to identify potential or actual breaches of human rights or decent working conditions," with business partners responsible for promptly addressing breaches of the Code of Conduct for Business Partners, and Aker ASA reserving "the right to terminate agreements in the event of material breaches."

Quarterly reporting to the Audit Committee also covers "the number of information requests under the Norwegian Transparency Act and the number of complaints related to possible breaches of the UN Guiding Principles and OECD Guidelines." Under Aker ASA's M&A Integrity Procedure, human rights risk is also assessed in mergers and acquisitions due diligence.

Taking action on material impacts on value chain workers

Reference: pages 51-52.

"No outcome-oriented and time-bound targets in line with ESRS 2 MDR-T have been set at the Group level," applying equally to other investments in the value chain; "subsidiaries prioritize a risk-based approach over setting time-bound targets," monitoring instead via indicators such as risk assessments conducted, training scope, high-risk suppliers identified, and deviations closed. "In 2025, no breaches of the UN Guiding Principles, the ILO Declaration, or the OECD Guidelines were reported or identified in relation to workers in the Group's value chains."

Table 24 lists subsidiary key actions: Aize maps consultancy vendor relationships to assess social-dumping risk and conducts risk-based supplier mapping under the Transparency Act; Aker BioMarine runs Transparency Act audits and a new business-partner follow-up system; Aker Property Group conducts risk-based supplier mapping and human rights training; Solstad Maritime runs a qualification procedure with pre-meetings and spot checks/audits of selected shipyards. None of these give rise to material costs beyond normal business operations.

Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities (value chain workers)

Reference: pages 51-52.

Consistent with S2-4, no Group-level, outcome-oriented, time-bound target for value chain workers is set under ESRS 2 MDR-T; Aker ASA instead defines shared ambitions and expectations, expecting portfolio companies "to comply with the UN Guiding Principles, and to maintain updated policies and procedures to identify and mitigate adverse impacts on workers in their own operations and value chain."

Subsidiaries "prioritize a risk-based approach over setting time-bound targets, and instead monitor whether actions deliver intended results using relevant indicators such as the number of risk assessments conducted, scope of training, identified high-risk suppliers, deviations identified, and deviations closed." No baseline year is defined for any value-chain-worker indicator, as the reporting parameters are "not considered suitable for this purpose."

Business conduct policies and corporate culture

Reference: page 53.

Aker ASA identifies "impacts and dependencies related to corporate culture across the portfolio" as a material IRO, and "corruption and bribery" as a second. Governing documents include the Board-approved Code of Conduct, covering anti-corruption, gifts and hospitality, conflicts of interest, sensitive information and due diligence, aligned with the UN Convention against Corruption, applying to all employees and non-employees; the Code of Conduct for Business Partners; and the Board-approved Anti-Corruption Policy, underlining "Aker ASA's zero tolerance for corruption and bribery."

"Aker ASA's ability to maintain a responsible and ethical corporate culture across its portfolio is critical to long-term value creation and stakeholder trust," requiring "transparency and accountability, particularly through effective whistleblower protection." Activities in high-risk countries (Central America, South America, Asia, Africa) are reported quarterly to Aker ASA, with a list of high-risk countries reviewed annually against corruption, social and environmental risk factors.

Prevention and detection of corruption and bribery

Reference: page 54.

"The Group maintains a zero tolerance policy for corruption and bribery in their own operations and value chains," supported by guidelines on gifts, hospitality, donations and sponsorships, and due diligence procedures for business partners and suppliers. Aker ASA's authorization matrix "defin[es] the boundaries between what the Board and the CEO may decide," and payment approvals require at least two individuals, "with different thresholds determining what requires additional approval."

Whistleblowing routines allow reports of suspected corruption via the reporting line, the independent whistleblowing channel, or directly to the Chair of the Audit Committee. Portfolio companies report quarterly to the General Counsel on compliance indicators, including Code of Conduct breaches and corruption/bribery suspicions, who reports to the Audit Committee. Table 26 shows mandatory annual Code of Conduct and anti-corruption training programs at Aize, Aker BioMarine, Aker Property Group, Cognite, Mainstream and Solstad Maritime.

Targets related to business conduct (part of MDR-T/GDR-T disclosures)

Reference: page 54.

The statement was prepared under the 2023 ESRS, which had no standalone business-conduct targets DR; the relevant content sits under the ESRS 2 MDR-T minimum disclosure requirement. "No outcome-oriented and time-bound targets for business conduct in line with ESRS 2 MDR-T have been set at the Group level. Aker ASA will assess on an ongoing basis whether such targets are appropriate and how they might be defined."

In the absence of a stated target, effectiveness is tracked instead: "Corporate culture is monitored in the Group through, among other things, regular employee surveys, with results followed-up in each subsidiary through performance reviews and dialogue with direct managers. Actions are implemented as needed." Anti-corruption policy effectiveness is separately monitored via quarterly compliance reporting from portfolio companies to the General Counsel and the Audit Committee (see G1-3).

Incidents of corruption or bribery

Reference: page 55.

"Aker ASA and the Aker Group were not convicted of any breaches of anti-corruption or anti-bribery laws in 2025, and accordingly received no fines. No breaches of the anti-corruption policy were identified either." No prior instances of corruption or bribery are known within the Group; should any be identified, the report states "the matter will be investigated by individuals with no involvement in the case, and any breach will result in disciplinary action, as well as potential criminal prosecution."

On training, Aize, Aker BioMarine, Aker Property Group and Mainstream have identified functions considered more exposed to corruption and bribery risk (e.g. sales at Aize; management, finance, sales and Houston operations at Aker BioMarine). "In 2025, 53% of at-risk functions across Aize, Aker BioMarine, Aker Property Group, and Mainstream received training," with remaining functions scheduled to complete training by March or during 2026.