Aker BP

The role of the administrative, management and supervisory bodies

Reference: pages 41-42 (sections 1.3.1-1.3.4), table 2 (page 41).

Aker BP has a two-tier structure: a board of directors (BoD) as the supervisory body and an executive management team (EMT) as the administrative and management body. The BoD "oversees the company's overall management" and a key responsibility is "sanctioning the corporate strategy and overseeing Aker BP's ESG performance. This includes overseeing the company's material IROs and related policies, actions, metrics and targets" (page 41).

Three BoD subcommittees all carry sustainability functions (page 41):

• Audit and risk committee (ARC) - evaluates risk management and the effectiveness of internal controls
• Organisational development and compensation committee (ODCC) - ensures remuneration arrangements support the strategy
• Safety and environmental assurance committee (SEAC) - works with management on safety, cyber security and the environment

The CEO is responsible for day-to-day management and "oversees the management of the IROs and related policies, actions, metrics and targets"; monitoring and execution is delegated to business units led by EMT members (page 41).

Composition and diversity (table 2, page 41): BoD 13 members, 0 executive members, 5 employee-elected, 54 percent women, 50 percent independent. EMT 11 members, 27 percent women. ARC 4 members (75 percent women), ODCC 3 members (67 percent women), SEAC 5 members (0 employee-elected).

Competence is asserted rather than formally assessed: a BoD/ARC member "has extensive experience with climate impact through her role as CEO of Aker Carbon Capture", and "the sustainability-related competence is considered to be at an appropriate level" (page 42).

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

Reference: pages 42-43 (sections 1.3.4 and 1.4), page 44 (section 1.5.1).

Frequency and channels (page 42): "The full list of IROs is presented to the ARC and EMT twice a year, and to the BoD once a year. Additionally, selected key risks and opportunities are reported to the BoD, ARC and EMT." Performance against targets and KPIs is published quarterly, and "the IROs are an integral part of the annual strategy process and are considered in major business decisions".

Risk reviews (page 43): the enterprise risk management process "forms the basis for regular risk reviews of the company's prioritised risks by the EMT at least bi-monthly". Key risks from the EMT reviews are reported to the BoD. "Risk review sessions are held in the ARC three times per year, with overall accountability lying with the BoD, who receives updates from all ARC meetings."

Stakeholder views (page 44): "The ARC and EMT are informed about the views and interests of affected stakeholders through multiple channels, including the DMA approval process and presentation of cases reported through our integrity channel."

Specific matters covered in 2025: developments in applicable reporting frameworks including the Omnibus proposal (page 42); the full material IRO list, which "have been reviewed by the BoD, ARC and EMT" (page 47); quarterly compliance reporting on corruption and bribery risk to the EMT and ARC (page 121); and regular reporting of whistleblowing cases to the EMT and ARC (page 123).

Integration of sustainability-related performance in incentive schemes

Reference: page 40 (section 1.2.1.2).

Aker BP runs a single company-wide bonus programme rather than a separate executive scheme. "Delivery on the company initiatives and KPIs feeds into the Aker BP bonus programme and a monetary reward is calculated based on performance. The bonus scheme is defined as variable remuneration and utilises eight of nine equally weighted KPIs, along with initiative achievements and delivery on time, cost and quality through execution of key field development projects, as a basis" (page 40).

Quantified linkage: "Approximately 13 (22) percent of the bonus potential is dependent on sustainability-related initiatives and targets, of which 67 percent is climate-related. The reduction from last year is mainly due to changes in company initiatives used to measure variable payment" (page 40).

Coverage: "The bonus is paid to all permanent employees, including management, and is calculated with the same share of bonus potential for all employees" (page 40). The people and organisation KPI "is solely based on employee feedback and does not factor into the bonus potential to avoid biased feedback".

Governance: "The organisational development and compensation committee is responsible for ensuring remuneration arrangements support the strategy. The BoD is responsible for approving the incentive scheme" (page 40). Four of the nine 2025 corporate KPIs address sustainability directly: safety (serious incidents per million work hours), equity share scope 1 GHG intensity, CO2 equivalent emission reduction, and people and organisation (pages 39-40). Further detail is cross-referenced to the separate remuneration report (page 195).

Statement on due diligence

Reference: page 51 (section 1.6), table 4 (page 51), figure 9 (page 51).

Aker BP's due diligence process "is based on the OECD Due Diligence Guidance for Responsible Business. This risk-based process aims to avoid and address adverse impacts associated with our business, supply chain and other business relationships" (page 51).

Table 4 maps the five core elements of due diligence to sections and pages of the statement:

The company states it strives "to integrate the sustainability due diligence process into relevant business processes, such as risk assessments, environmental impact assessments, supplier pre-qualification and due diligence processes, M&A processes and health, safety, security, environment and quality (HSSEQ) assessments" (page 51). A separate human rights due diligence process is set out at page 113 (figure 39). Table 6 confirms the GOV-4 SFDR datapoint (paragraph 30) is material and located in section 1.6 (page 54).

Risk management and internal controls over sustainability reporting

Reference: pages 42-43 (section 1.3.5), page 37 (section 1.1).

Aker BP is unusually candid about the maturity gap. "Aker BP is exposed to risks related to inconsistent or incomplete reporting on sustainability topics, including the risk of greenwashing. Additionally, there are risks associated with the accuracy of data inputs and the high degree of manual processes involved in aggregating data from multiple systems into the sustainability statement" (page 42).

"Although the control environment in Aker BP is generally deemed to be at a sufficient level, risk assessment and related internal controls over sustainability reporting are generally not at the same maturity level as financial reporting" (page 43).

2025 remediation (page 43): "During 2025, we have initiated a project to mature internal control over sustainability reporting. We have performed a risk assessment for the disclosure requirements deemed to have the highest reporting risks, and designed internal controls to address and mitigate these risks. The mitigating actions include documented review controls, variance analysis between 2024 and 2025, as well as securing consistent use of terminology and calculation methodology across the different parts of the sustainability reporting."

Review chain (page 37): an internal review committee of senior managers, then the ARC, then review and approval by the BoD. A three lines of assurance model applies, with an internal audit and compliance department whose head reports to the BoD through the ARC and to the CEO (page 41).

Strategy, business model and value chain

Reference: pages 37-40 (sections 1.1, 1.2.1), figure 3 (page 38), figure 4 (page 39).

Business model. "Aker BP is a pure-play oil and gas company. Our operations relate to upstream activities, including exploration, development, production and decommissioning" (page 37). Production in 2025 was 420 mboepd, with Yggdrasil and Valhall PWP-Fenris advancing (page 37). The company operates the field centres Alvheim, Eiga, Skarv, Ula and Valhall and partners in Johan Sverdrup (page 3).

Fossil fuel sector declaration: "We only operate within one ESRS sector, which is the fossil fuel sector" (page 39).

Value chain (figure 3, page 38). Inputs: own workforce of more than 4,300 individuals; six field centres and five Norwegian office locations; 1,600 tier 1 suppliers worldwide; strategic alliances; materials including steel, concrete and chemicals. Outputs: energy and feedstock for petrochemicals; job creation ("our operated development projects are projected to contribute to approximately 150,000 full-time equivalents at Norwegian suppliers"); dividends and taxes. Midstream is transportation and sales; downstream is processing and use of sold products.

Strategy (figure 4, page 39). Six strategic priorities for 2022-2027, of which three are shaped by sustainability: operate safely and efficiently, decarbonise our business, and create the most attractive place to work. Decarbonisation goals: equity share scope 1 and 2 intensity below 4 kg CO2e/boe; 50 percent reduction in operational control scope 1 and 2 emissions by 2030; equity share scope 1 and 2 neutrality from 2030. Turnover was USD 10,699 million (table 26, page 96).

Interests and views of stakeholders

Reference: page 44 (section 1.5.1), figure 7 (page 44).

"Our stakeholders are those affected by or impacting Aker BP's activities and business relationships, whether in our role as an energy provider, employer, customer or as a business that helps stimulate local and national economies through jobs, investments and taxes paid" (page 44).

Figure 7 names the key stakeholder groups and the channel used for each: employees (internal communication channels, meetings with representatives, town hall events), investors (annual general meeting, negotiations, financial reporting, investor meetings), suppliers and contractors (negotiations and contracts, audits, supplier events, reporting), partners (industry working groups, conferences, formal meetings), local communities (public hearings, contact meetings), authorities (audits, monitoring, reporting) and NGOs (conferences, public hearings, monitoring).

Concrete mechanism: "every delivered plan for development and operation (PDO) includes an impact assessment, which ensures that more than 40 key stakeholders receive reports during public consultation processes. This allows stakeholders to share their views, raise relevant issues and provide input for necessary adjustments. To maintain transparency, we publish the impact assessments on our website" (page 44).

Feeding into strategy: "We include stakeholders' perspectives and priorities in our DMA... This process can potentially influence related policies, actions, metrics and targets, and ultimately our overall strategy and business model" (page 44). Note the counterpoint under E1: climate targets "have been set without direct involvement of external stakeholders" (page 66).

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

Reference: pages 47-50 (section 1.5.4), table 3 (pages 49-50).

Table 3 lists 36 material IROs across nine ESRS topics, each tagged by sub-topic, category (negative/positive, actual/potential impact; financial risk; financial opportunity), value chain position (upstream / own operations / downstream) and time horizon (short 0-3 years, medium 3-10, long 10-25).

Distribution by topic: E1 Climate change 8 (2 negative impacts, 1 positive impact, 3 risks, 2 opportunities); E2 Pollution 5; E3 Water 1; E4 Biodiversity 5; E5 Circular economy 3; S1 Own workforce 6; S2 Value chain workers 4; S3 Affected communities 1; G1 Business conduct 3.

Interaction with the business model (page 48): "The material impacts identified are inherent to the E&P value chain and are not unique to Aker BP's specific business model or strategy... Our ambition is to minimise negative environmental, social and governance impacts. However, many of the impacts presented in this report cannot feasibly be removed and will therefore to a certain degree always be present in oil and gas production."

Financial effects (page 48): three climate risks are "deemed to have current financial effect", but "it is challenging to measure the current and future financial effects of our material risks and opportunities on our financial position, performance and cash flows"; readers are referred to the sensitivity tests in note 3, page 154.

Resilience (page 48): "We have conducted resilience analyses on our material IROs related to climate change and biodiversity... However, we have not performed resilience analyses on IROs related to other topics." Climate-specific risk identification and scenario analysis is also presented under E1-2 and resilience under E1-3 (2025 ESRS numbering).

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

Reference: pages 43-47 (sections 1.4, 1.5.1-1.5.3), figure 8 (page 45).

Framework. "Risk management in Aker BP follows the principles in ISO 31000. IROs are identified, evaluated and mapped into our shared company risk matrix, including impact categories for personnel, environment (including climate), financial, reputation, project cost and schedule consequences" (page 43).

Four-step DMA (figure 8, page 45): (1) business context and stakeholder engagement; (2) identify IROs top-down and bottom-up, adding new ones to the long list; (3) assess and prioritise using "a rating system resulting in a severity x likelihood placement and a materiality assessment"; (4) validate with management and the BoD, report and monitor. The process iterates and validates at each step.

Scoring (page 45): "Negative impacts are evaluated based on severity, which is assessed through scale, scope and irremediability, and the likelihood of the impact occurring. Positive impacts are evaluated using scale, scope and likelihood. Risks and opportunities are evaluated based on the likelihood of occurrence and the magnitude of the potential financial effects."

2025 changes to the process (page 44): "This year's process included a comprehensive re-evaluation of all impacts, risks and opportunities, the introduction of peer benchmarking, and a move towards shorter, clearer impact names. We also consolidated overlapping impacts and applied financial materiality thresholds more consistently."

Topic-specific methods are given for E1 (pages 45-46, including climate scenario analysis), E2 (pages 46-47), E3 (page 47), E4 (page 47, guided by TNFD), E5 (page 47, NORSOK S-003 and Offshore Norge BAT guidelines) and G1 (page 47). 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: table 5 (pages 52-53), table 6 (pages 54-55), section 1.5.4.3 (page 48).

Aker BP prints a full ESRS content index. Table 5: Disclosure requirements in ESRS covered in the sustainability statement states: "The table below provides an overview of the disclosure requirements in ESRS which have been covered in this sustainability statement. Disclosure requirements not included in the table below have been deemed immaterial" (page 52).

Every entry maps a DR code to a section number rather than a page. Covered: BP-1, BP-2, GOV-1 to GOV-5, SBM-1 to SBM-3, IRO-1, IRO-2; E1-1 to E1-8; E2-1 to E2-4; E3-1 to E3-5; E4-1 to E4-5; E5-1 to E5-4; S1-1 to S1-11 and S1-14 to S1-17; S2-1 to S2-5; S3-1 to S3-5; G1-1 to G1-4.

Marked "NA": E1-9, E2-5, E2-6, E4-6, E5-5, E5-6. Marked "Not material": S1-12, S1-13, the whole of S4 Consumers and end-users, G1-5 and G1-6.

Table 6: Other EU legislation (pages 54-55) lists the Appendix B datapoints derived from SFDR, Pillar 3, the Benchmarks Regulation and the EU Climate Law, each flagged material or not material with a location. Examples: board gender diversity (GOV-1 paragraph 21(d)) to table 2; involvement in fossil fuel activities (SBM-1 paragraph 40(d)(i)) to section 1.2.1 and figure 3; number of fatalities and work-related accidents (S1-14 paragraph 88(b),(c)) to table 30.

Section 1.5.4.3 explains the one topic excluded outright: consumers and end-users (page 48).

Transition plan for climate change mitigation

Reference: page 61 (section 2.2), pages 63-64 (section 2.3.1), pages 66-69 (section 2.4).

Aker BP has a decarbonisation plan published on its website, described as "part of our broader strategy to be the E&P company of the future" (page 61). It is built on the avoid - reduce - neutralise hierarchy (figure 11, page 66).

Explicit statement of non-compliance (page 61): "Aker BP is a pure-play E&P company with no refining or end-use sales, and we hence have limited ability to impact downstream scope 3 emissions. Our decarbonisation plan thus does not contain any targets to reduce these emissions and is therefore not in line with ESRS requirements. We do not have a timeline for if or when we will develop such a plan."

Targets in the plan (pages 67-69): 50 percent reduction in operational control scope 1 and 2 GHG emissions by 2030 against a 2017 baseline of 1.250 million t CO2e; 90 percent reduction by 2050 for both operational control and equity share; equity share scope 1 and 2 GHG emission neutrality from 2030 using carbon dioxide removal credits; equity share intensity below 4 kg CO2e/boe; operational control scope 1 methane intensity below 0.05 percent.

Levers and quantities (pages 63-64): retirement of Ula in 2028 (-171 kt CO2e), energy management to 2030 (-27 kt), retirement of Alvheim, Skarv and Eiga between 2030 and 2050 (-423 kt), energy management to 2050 (-26 kt). "Around 85 percent of Aker BP's equity share production is estimated to be electrified by 2030" and "100 percent of Aker BP's operated production is expected to be electrified with power from shore by the 2040s".

Costs (page 63): "Capex related to energy management initiatives between 2026 and 2050 is estimated to be USD 27 million"; retirement costs are "estimated to represent 48 percent of the abandonment liabilities presented in note 24, page 172".

Targets "are not science-based" (page 66).

Identification of climate-related risks and scenario analysis

Back-filled from ESRS 2 IRO-1 and the E1 scenario analysis section, where this content is disclosed in the FY2025 report (pages 45-46, 77-79). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against; Aker BP's own index maps IRO-1 to "section 1.5" and "section 2.6" (page 52).

Classification of risks. Table 7 (pages 59-60) identifies three climate financial risks, all transition in character: increased production costs and reduced growth prospects due to regulatory changes (EUA price, Norwegian CO2 tax, restricted acreage access, legal actions); lower oil and gas prices due to decreased demand and accelerated energy transition; and increased cost of capital from negative perceptions. Physical risk is expressly screened out: "Climate-related hazards were identified as part of our climate risk analysis but were deemed immaterial in relation to the impact these hazards are predicted to have on our assets" (page 46).

Methodology and horizons (page 45): short term up to three years, medium three to 10, long 10 to 25. "Except for the decommissioning of Ula and the addition of Yggdrasil and Valhall PWP-Fenris, the portfolio in 2030 is assumed to be similar to today"; by 2050 Eiga, Skarv and Alvheim are expected to be decommissioned (page 46).

Scenarios used (page 77). Three IEA World Energy Outlook 2025 scenarios "that cover three different emission pathways towards 2030 and 2050, resulting in three different temperature outcomes, including a 1.5-degree aligned scenario and an above 2-degree scenario": Current Policies (CPS), Stated Policies (STEPS) and Net Zero Emissions by 2050 (NZE). On NZE the report notes: "In the 2025 WEO, the NZE Scenario is no longer classified as a limited-overshoot scenario, as warming peaks above 1.6 °C and exceeds 1.5 °C for several decades before returning below 1.5 °C by 2100."

Scope and assumptions: the analysis covers producing assets and non-sanctioned projects (page 78); assumptions are internal equity share scope 1 CO2 emission forecasts to 2050, commodity prices, environmental fees and taxes, with FX and carbon prices held constant across scenarios (pages 77-78). No dedicated high-emission physical-risk scenario (for example RCP8.5) is named, consistent with physical hazards being assessed immaterial.

Resilience in relation to climate change

Back-filled from ESRS 2 SBM-3 and the E1 scenario analysis section, where this content is disclosed in the FY2025 report (pages 48, 78-79). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against; Aker BP's index maps SBM-3 to "section 1.5.4", "section 2.6" and "section 5" (page 52).

Results of the analysis (page 78). Portfolio net present value is tested against the three IEA scenarios: +21 percent under CPS, +6 percent under STEPS, and -41 percent under NZE, where oil falls to USD 51/bbl in 2030 and USD 26/bbl in 2050 and gas to USD 8.2 and USD 4.2 per MMBtu (real 2026 terms). "While transition risk is difficult to properly quantify in a long-term perspective, this analysis, showing a 41 percent NPV reduction under the extreme price scenario NZE, leads Aker BP to consider its strategy to be resilient to lower prices and reduced demand."

Carbon price sensitivity (page 79). "The NPV of the future carbon costs under the planning assumptions is limited to under two percent of the total portfolio NPV." Aker BP's internal carbon price assumptions "significantly exceed prices assumed under the IEA's scenarios" (figure 25).

Conclusion (page 79): "Aker BP considers its strategy, emission reduction pathway and portfolio to be resilient to the projected oil and gas prices, as well as carbon prices, under the various IEA scenarios. As we continue to reduce our emissions going forward, we will also reduce our exposure to risks of increased carbon prices."

Uncertainty is stated (page 78): "There are three major uncertainties related to the oil and gas demand: How high the peak in demand will be, how quickly demand falls and how the supply side adapts to demand."

Capacity to adapt (pages 48, 79): resilience testing covers "value creation, profitability, financial capacity and cash-flow generation", is run quarterly or semi-annually and ad hoc, and is "an integrated part of our annual strategy process"; business continuity planning uses preventive measures, redundancies and alternative delivery methods.

Policies related to climate change mitigation and adaptation

Reference: page 61 (section 2.1).

Aker BP has a standalone climate and energy policy, publicly available on its website, owned by the SVP people and safety, an EMT member, "who is the owner of this policy and is accountable for its implementation" (page 61).

The policy "addresses climate change mitigation and energy efficiency, and outlines our commitments to:

1. Reduce energy consumption and related emissions to air
2. Reduce GHG emissions
3. Manage climate-related risks and opportunities
4. Evaluate low-carbon innovation solutions to reduce emissions
5. Responsible management of our carbon dioxide removal portfolio" (page 61).

Scope and gaps, stated plainly (page 61): "This policy covers all climate-related impacts, risks and opportunities as described in table 7, page 59, except for GHG emissions from the downstream value chain, energy production and the opportunity related to financial benefits and improved reputation from investments in CCS." Downstream scope 3 emissions, which are 63,089 kt CO2e or roughly 92 percent of the total footprint, therefore sit outside the policy's coverage (page 74).

Context commitments (page 61): Aker BP "acknowledges the conclusions in the IPCC's latest assessment report, the Paris Agreement and associated goals, as well as Norwegian national climate commitments", and through its Konkraft collaboration contributes "to the Norwegian government's national commitment to reduce GHG emissions by a minimum of 55 percent by 2030".

Through the policy the company commits "to set short- and long-term targets for reducing scope 1 and 2 GHG emissions" and to "cooperate with suppliers and contractors to establish a GHG footprint and implement appropriate measures to reduce upstream scope 3 emissions". No climate change adaptation policy is presented, consistent with climate-related hazards being assessed as immaterial (page 46).

Actions and resources in relation to climate change policies

Reference: pages 63-65 (section 2.3), table 8 (page 63), tables 9 and 10 (page 64).

2025 delivery (page 63). "Scope 1 and 2 GHG emission reduction measures carried out in 2025 yielded an estimated total reduction of 40,500 t CO2e. For comparison, the reduction in 2024 was 56,800 t CO2e." Table 8 splits this into 40.4 kt from scope 1 and 0.1 kt from scope 2. Named initiatives: optimisation of WAG compressor operations on Ula; enabling the Edvard Grieg facility to supply the Noble Invincible rig with power from shore; optimisation of turbine load sharing and gas export conditions on Skarv; single-split operations on the Scarabeo 8 rig; and commissioning of the Carbon Optimiser project on Alvheim. Scope 2 reductions came from reduced gas recirculation through changed scrubber running conditions on Edvard Grieg.

Resources (page 63): "Costs related to energy management initiatives completed during 2025 were not significant." Forward capex for energy management 2026-2050 is estimated at USD 27 million; asset retirement costs are "estimated to represent 48 percent of the abandonment liabilities presented in note 24, page 172".

Planned actions (tables 9 and 10, page 64): decommissioning of Ula in 2028 (-171 kt CO2e); energy management to 2030 (-27 kt); retirement of Skarv, Alvheim and the Eiga area 2030-2050 (-423 kt); energy management to 2050 (-26 kt). Energy management assumes "one percent cumulative emission reductions with lasting effect per year".

Methane (page 64): member of OGMP 2.0, "committed to reporting in accordance with the OGMP 2.0 standard from 2025 onwards", developing site-specific monitoring survey plans and improved leak detection and repair (LDAR) techniques.

Upstream scope 3 (page 65): "As of 2025, Aker BP does not have any targets related to upstream scope 3 emissions"; during 2025 the company "strengthened our partnerships with selected suppliers with a goal of identifying product-specific emission factors".

CCS and R&D (page 65): three CO2 storage licences (Poseidon EXL005, Atlas EXL011, Forsete EXL013) and a partnership with Höegh Evi; R&D spend USD 38.6 million of which USD 4.0 million on climate and external environment.

Targets related to climate change mitigation and adaptation

Reference: pages 66-69 (section 2.4), figures 11-15.

Target 1 (page 67): "We aim to reduce our operational control scope 1 and 2 GHG emissions by 50 percent by 2030 compared with our 2017 baseline. By 2050, we aim to achieve a 90 percent reduction in operational control and equity share scope 1 and 2 GHG emissions." The 2017 baseline is 1.250 million t CO2e (1.245 Mt scope 1, 5,000 t scope 2), chosen because "this is the first year all producing assets under Aker BP's operational control were in full stable production". 2025 outturn: 892,000 (850,000) t CO2e, a 29 percent reduction.

Target 2 (page 68): equity share scope 1 and 2 GHG emission neutrality from 2030 using high quality carbon dioxide removal credits. 2025 equity share emissions were 429,000 (418,000) t CO2e, 36 percent below the 2017 baseline.

Target 3 (page 69): equity share scope 1 and 2 intensity below 4 kg CO2e/boe; 2025 outturn 2.8 (2.6) kg CO2e/boe, against an IOGP global average of 17.8 kg CO2e/boe in 2024. Continuous target, no baseline or applicability period.

Target 4 (page 69): operational control scope 1 methane intensity below 0.05 percent of saleable gas; 2025 outturn 0.017 (0.018) percent, against 0.12 percent reported by OGCI.

Stated limitations (page 66): "Our climate-related targets are not science-based, but are in line with Norwegian Oil and Gas joint climate strategy and decarbonisation targets, as well as Norway's Nationally Determined Contributions under the Paris Agreement." "Our targets are not externally assured." "Aker BP's climate-related targets have been set without direct involvement of external stakeholders." Targets cover CO2, CH4 and N2O, use a location-based method for scope 2, and rely on Aker BP's own emission forecasts. No scope 3 target of any kind exists (pages 62, 65). "No changes have been made to any of our climate-related targets or underlying metrics during 2025." There is no overarching energy reduction target; asset-specific energy targets are used instead (page 63).

Energy consumption and mix

Reference: page 73 (sections 2.5.5 and 2.5.6), table 12 (page 73), figure 21 (page 73).

Aker BP reports equity share energy consumption. Total fossil energy consumption in 2025 was 2,405,338 MWh (2,353,897 MWh in 2024), 90 percent of total energy consumption (89 percent in 2024).

Table 12 (page 73), all figures MWh, 2025 (2024):

• Fuel consumption from coal and coal products: nil
• Fuel from crude oil and petroleum products: 339,737 (358,626)
• Fuel from natural gas: 1,350,193 (1,229,369)
• Fuel from other fossil sources: nil
• Purchased electricity, heat, steam and cooling from fossil sources: 715,408 (765,901)
• Consumption from nuclear sources: 179,146 (191,790), 7 percent share in both years
• Fuel from renewable sources including biomass: nil
• Purchased electricity, heat, steam and cooling from renewable sources: 91,926 (92,639)
• Self-generated non-fuel renewable energy: nil
• Total renewable energy consumption: 91,926 (92,639), 3 percent share (4 percent in 2024)

A footnote is important for comparability: "These numbers are consolidated using a market-based energy consumption mix, in line with ESRS requirements. If we had applied a location-based energy consumption mix, the share of renewable sources in total energy consumption would be 38 percent for 2025" (page 73). The 2024 values are restated because the market-based mix for 2024 was unavailable when the 2024 report was published.

Energy intensity in high climate impact sectors (figure 21, page 73): 250 MWh per million USD of net revenue in 2025, up from 216 in 2024. Net revenue from high climate impact sectors is total petroleum revenue, extractable from note 5, page 155.

Aker BP states it operates in a single ESRS sector, the fossil fuel sector (page 39). Assets connected to power from shore consume electricity; non-electrified assets generate power using gas turbines (page 73).

Gross Scopes 1, 2, 3 and Total GHG emissions

Reference: pages 70-74 (sections 2.5.1-2.5.3, 2.5.6), table 13 (page 74), table 11 (page 70).

Aker BP reports two consolidations throughout: operational control and equity share. Table 13 (page 74), 1,000 t CO2e, 2025 (2024):

Scope 3 by category, equity share (figure 19, page 72; table 13): purchased goods and services 89; capital goods 242; fuel- and energy-related activities 19; upstream transportation and distribution 185; waste generated in operations 1; business travel 12; downstream transportation and distribution 193; processing of sold products 4,677; use of sold products 63,089. Categories 7, 8, 12, 13, 14 and 15 are declared not material with reasons (page 72).

Intensities (figure 20, page 73): operational control scope 1 and 2 intensity 6.8 (6.0) kg CO2e/boe; equity share 2.8 (2.6); scope 1 methane intensity 0.017 percent (0.018); GHG per net revenue 6.4 (5.9) kg CO2e/USD location-based and 6.5 (5.9) market-based.

Emission sources (table 11, page 70): fuel combustion 817, flaring and well testing 40, venting and fugitive 15, loading of hydrocarbons 10 (operational control). Flared volume 13 (18) million sm3. "Aker BP has zero scope 1, 2 or 3 emissions from biogenic sources"; GWP factors are IPCC AR6. Scope 2 2024 values are restated because NVE emission factors were unavailable at the time; 2024 factors are used for 2025 (page 71). Table 14 (page 75) adds a third consolidation of 481 (464) kt CO2e for investees where Aker BP has operational control, which the company says "leads to confusion and double-counting of emissions".

GHG removals and GHG mitigation projects financed through carbon credits

Reference: page 76 (section 2.5.8), figures 22 and 23 (page 76), page 68 (section 2.4.2).

Aker BP's index maps E1-7 to section 2.5.8 (page 52), and table 6 flags the E1-7 EU Climate Law datapoint (paragraph 56) as material (page 54).

Nil return for the reporting year (page 76): "While no credits were retired in 2025, we intend to neutralise around 4 million t CO2e between 2030 and 2050, based on a projection of our equity share scope 1 and 2 GHG emissions in the same period. The exact amount required will depend on our future emissions."

Portfolio (page 76): "Aker BP has invested in three CDR projects on three continents, all based on reforestation and developed under Verra registry's Verified Carbon Standard (VCS). The projects are designed to capture carbon through natural processes, in addition to having positive effects on biodiversity and for local communities."

Quality criteria (page 76): the company aims "to only invest in carbon removal projects that are certified under internationally recognised standards, have strong additionality and robust measures in place to minimise reversal risks and leakage, are validated and verified by independent and reliable auditors, and identify and mitigate risks of social and environmental harm".

Relationship to targets (pages 68, 76): removals sit outside the reduction targets. "Our first and foremost priority within our approach to decarbonisation is to avoid and reduce scope 1 and 2 GHG emissions from our own operations." The commitment "is voluntary and costs related to the purchase of CDR credits come in addition to mandatory acquisition of EU ETS quotas and payment of Norwegian CO2 taxes", which "has a positive impact on the business cases for emission reduction initiatives".

Figure 23 charts annual credit needs to 2050 in Verified Carbon Units, splitting removals required, removals in the current portfolio, and removals still to purchase. No breakdown of removals by removal type, vintage, or amount of credits cancelled in the reporting year beyond the nil figure is given.

Internal carbon pricing

Reference: pages 75-76 (section 2.5.7), figure 25 (page 79).

"To assess and manage climate-related risks, we use scenario analysis, sensitivity testing and an internal carbon price" (page 46). The index maps E1-8 to section 2.5.7 (page 52).

Type and scheme. Aker BP applies a shadow price: "All our operated assets and business units use a uniform set of the internal carbon price (shadow price) assumptions, aligned with the financial statements" (page 75). Three cases are maintained: "We operate with low, base and high case scenarios for carbon prices. We use the high case scenario for resilience testing, while our base case is used for business planning. Our base case carbon price assumption is used for assessing commercial feasibility of decarbonisation initiatives and is used uniformly across all our assets."

Governance and revision: carbon price assumptions are "part of Aker BP's internal set of corporate assumptions. These are updated on a quarterly basis and approved by the CFO" (page 75).

Basis of the base case (page 75): it tracks Norway's climate action plan target "to gradually increase the total cost per tonne of CO2 to 2,000 NOK (real 2020 terms) by 2030", assumes continued EU ETS reform, inclusion of new segments and phase-out of free allocation, and a continued increase towards 2050. The low case assumes faster renewable growth and lower EUA demand; the high case the opposite.

Scope of application (page 76): "The carbon price is used for assessing the feasibility of reduction initiatives for operational control scope 1 CO2 emissions only, which in 2025 comprised around 850,000 (806,000) t CO2, or approximately 95 percent of our total scope 1 and 2 GHG emissions."

Level relative to external benchmarks (page 79): "Aker BP's internal carbon price assumptions significantly exceed prices assumed under the IEA's scenarios", including NZE, in both 2035 and 2050. The specific NOK or USD per tonne values for each case are not printed.

Policies related to pollution

Reference: page 81 (section 3.1), page 57.

Three policies cover pollution: the external environment policy, the emergency preparedness and response policy and the risk and barrier policy (page 80). The SVP people and safety, an EMT member, "is accountable for the external environment policy. The other mentioned policies are owned by relevant managers in the people and safety department" (page 81). The external environment policy and emergency preparedness and response policy are publicly available.

External environment policy commitments (page 81):

• Continuously manage and reduce our environmental footprint
• Increase knowledge and contribute to R&D activities to better understand environmental impacts and ecosystems
• Transparent reporting of environmental performance regularly
• Mitigate negative impacts related to pollution of discharges to sea and emissions to air

"These commitments relate to our material impacts and risks as they cover both pollution to air and pollution of water from our own operations. The first and fourth commitments specifically detail our responsibility to prevent, reduce and remediate pollution resulting from assets under our operational control" (page 81). The company commits to keeping impact "as low as reasonably practicable using best available techniques (BAT) and following NORSOK standard S-003 environmental care".

Emergency preparedness and response policy (page 81) sets three core principles: asset-specific oil spill preparedness plans using BAT; active participation in the Norwegian Clean Seas Association for Operating Companies (NOFO) "ensuring 24/7 oil spill preparedness and oil spill recovery at sea"; and assessment of operational mitigation measures such as mechanical collection or chemical dispersion.

Stated gap (page 81): "Aker BP does not have any policies, actions, metrics or targets related to impact of pollution to air from downstream activities or impact of microplastics downstream." The environmental management system follows ISO 14001 and is regularly audited (page 57).

Actions and resources related to pollution

Reference: pages 81-82 (section 3.2), table 16 (page 82).

Actions "follow the mitigation hierarchy of prevention, reduction, remediation and, where possible, restoration. All own operations, both operated and non-operated fields and wells, are regulated by the same laws and regulations" (page 81).

2025 actions and results (table 16, page 82). The same five initiatives that cut GHG emissions delivered reductions of NOX 109 tonnes, SOX 2 tonnes and nmVOC 13 tonnes: optimisation of WAG compressor operations on Ula; enabling the Edvard Grieg facility to supply the Noble Invincible rig with power from shore; optimisation of turbine load sharing and gas export conditions on Skarv; single-split operations on the Scarabeo 8 rig; and commissioning of the Carbon Optimiser project on Alvheim. "This list is not intended to be exhaustive and does not include all measures reported to the Norwegian Environment Agency."

Water treatment (page 82): "treatment of produced water to lower the hydrocarbon content in discharged produced water, whilst selecting chemicals with lowest risk of environmental harm, and reinjection produced water to avoid and reduce discharge to sea."

Planned measures (page 82): "installation of a new produced water treatment facility at Valhall PWP as well as measures to ensure compliance with revised discharge requirements (15 ppm OiW) also for other assets. For example, at the Edvard Grieg facility, we plan to install a weir plate in the primary inlet separator in 2026 to improve separation of oil in water."

Structural lever (page 82): "Retirement of our fuel-driven asset Ula in 2028 will represent an important milestone for reduction of pollution to air and sea. Ula accounts for approximately 70 percent of Aker BP's total OiW (oil in water) discharges to sea (2025 numbers, operational control) and also contributes around 20 percent of our total NOX emissions."

NOX Fund (page 82): Aker BP contributes through the NOX fee; "over time NOX-reducing measures have been installed on three of the drilling vessels operating under Aker BP's operational control". No monetary amounts are attached to pollution actions.

Targets related to pollution

Reference: page 82 (sections 3.3 and 3.4).

Aker BP reports a nil return at company level: "Aker BP has, as per 2025, not set a reduction target for pollution to air or sea on a company level. However, our ambition is to avoid acute discharges and spills to sea" (page 82).

What is used instead (page 82): "Aker BP has asset-specific performance indicators for emissions to air, produced water reinjection rate, oil-in water content and other pollutants in discharged produced water. The performance indicators are related to our discharge permits and are monitored and tracked on a monthly basis to evaluate our initiatives and the effectiveness of our environmental policy."

Regulatory ceiling as the operative constraint (pages 82-84): "Discharges to sea and emissions to air from both production activities and exploration drilling, are governed by our discharge permits issued by the Norwegian Environment Agency. The discharge permits are asset-specific and include limits for emissions to air and sea. Emissions of NOX, SOX, nmVOC, discharge of chemicals in produced water and drilling chemicals are all regulated in our permits." The company adds that "our process for setting annual asset-specific key performance indicators allows us to set stricter targets than the authority permits. KPIs are followed up in digital dashboards available to both management and personnel engaged in operation of the assets."

Risk-based threshold (page 84): produced water discharge "is risk-rated by calculation of the environmental impact factor (EIF) and aims to be less than 10 for lower environmental risk. We evaluate necessary actions to reduce discharge if the EIF is between 11-100." The absolute regulatory maximum is 30 mg dispersed oil per litre of produced water per month, weighted average, with a revised 15 ppm OiW requirement being worked towards (pages 82, 84).

No baseline year, target year, or quantified reduction level is set for any pollutant.

Pollution of air, water and soil

Reference: pages 83-84 (sections 3.4.1 and 3.4.2), table 17 (page 83), table 18 (page 84), figure 29 (page 84).

Aker BP reports E-PRTR Annex II pollutants for both air and water. Table 6 confirms the E2-4 datapoint (paragraph 28) is material (page 54).

Air (table 17, page 83), tonnes, 2025 (2024):

"SOX emissions remained below threshold in 2025, with 49 tonnes in total for Aker BP compared to the limit of 150 tonnes per year per facility" (page 84). Figures cover only facilities exceeding the Annex II threshold; comparatives were adjusted accordingly.

Water (table 18, page 84), kg, operational control 2025 (2024): phenols 41,807 (42,304); BTEX sum 89,041 (88,870), of which benzene 45,364, toluene 30,655, xylenes 11,721, ethylbenzene 1,038; arsenic 22 (23); cadmium 5 (6); lead 79 (63); zinc 2,759 (4,294); PAH 3,574 (3,083) of which naphthalene 3,192 (2,738). Equity share figures are given alongside.

Produced water balance (figure 29, page 84): 19.9 (19.3) million m3 of produced water, of which 73 percent (67 percent) reinjected, 26 percent (31 percent) discharged and under 1 percent to oil export.

Measurement (pages 83-84): NOX and nmVOC are calculated from fiscally measured fuel gas and flare volumes using equipment-specific factors under Offshore Norge guideline 044; fugitive emissions "are not measured" due to "complexity and unavailability of sufficient measurement equipment". Oil in water is "either measured daily or monitored through continuous online measurements. Analysis of remaining pollutants in the discharged produced water stream is conducted twice a year." "Pollution-related metrics are not validated by third parties" (page 83). No soil pollution is reported; all own operations are offshore or at two onshore power stations.

Policies related to water and marine resources

Reference: page 85 (section 4), table 19 (page 85), page 47 (section 1.5.3.3).

Water and marine resources is material to Aker BP only through a single upstream value chain impact. The ESRS content index maps E3-1 to E3-5 all to "section 4" (table 5, page 52), and section 4 occupies a single page.

The company's full E3 disclosure (page 85): "Water and marine resources is not a material topic for Aker BP's own operations. We have identified one material impact within this topic, as we believe that water consumption in our upstream value chain could potentially prove to be material. We are in the process of conducting necessary mappings and assessments on the level of materiality for water and marine resources in our value chain. As we have not yet been able to obtain the necessary data and insight into our value chain related to water and marine resources, we do not have any related policies, actions, targets or metrics to report." The "Relevant policies" box for the chapter reads "None".

The single material IRO (table 19, page 85): "Freshwater withdrawal - In the value chain, large amounts of water are withdrawn during the production of oil and gas-related infrastructure. The extent of the negative impact depends on the level of water scarcity in the area." It is classified a negative actual impact, upstream only, over the medium and long term.

DMA basis (page 47): "Aker BP's own operations are located on the NCS. We do not withdraw water from water-stressed regions, and none of our own operations are situated in such environments... Based on this assessment, water is not considered a material topic for Aker BP's own operations. We have therefore not deemed it necessary to conduct consultations with local communities. However, activities within our upstream value chain could potentially be located in water-stressed areas."

Aker BP has applied the ESRS 1 transitional provision for value chain metrics and states it "reported metrics related to the value chain for E1, as well as for resource inflows under E5. For all other topics, value chain metrics were not available at the time of submitting this report due to an incomplete understanding of value chain-related impacts, risks and opportunities (IROs) and insufficient data maturity of suppliers" (page 37).

On E3-1 specifically: no water policy exists. Table 6 marks the SFDR datapoints "ESRS E3-1 Dedicated policy paragraph 13" and "ESRS E3-1 Sustainable oceans and seas paragraph 14" as not material (page 54).

Actions and resources related to water and marine resources

Reference: page 85 (section 4), table 19 (page 85), page 47 (section 1.5.3.3).

Water and marine resources is material to Aker BP only through a single upstream value chain impact. The ESRS content index maps E3-1 to E3-5 all to "section 4" (table 5, page 52), and section 4 occupies a single page.

The company's full E3 disclosure (page 85): "Water and marine resources is not a material topic for Aker BP's own operations. We have identified one material impact within this topic, as we believe that water consumption in our upstream value chain could potentially prove to be material. We are in the process of conducting necessary mappings and assessments on the level of materiality for water and marine resources in our value chain. As we have not yet been able to obtain the necessary data and insight into our value chain related to water and marine resources, we do not have any related policies, actions, targets or metrics to report." The "Relevant policies" box for the chapter reads "None".

The single material IRO (table 19, page 85): "Freshwater withdrawal - In the value chain, large amounts of water are withdrawn during the production of oil and gas-related infrastructure. The extent of the negative impact depends on the level of water scarcity in the area." It is classified a negative actual impact, upstream only, over the medium and long term.

DMA basis (page 47): "Aker BP's own operations are located on the NCS. We do not withdraw water from water-stressed regions, and none of our own operations are situated in such environments... Based on this assessment, water is not considered a material topic for Aker BP's own operations. We have therefore not deemed it necessary to conduct consultations with local communities. However, activities within our upstream value chain could potentially be located in water-stressed areas."

Aker BP has applied the ESRS 1 transitional provision for value chain metrics and states it "reported metrics related to the value chain for E1, as well as for resource inflows under E5. For all other topics, value chain metrics were not available at the time of submitting this report due to an incomplete understanding of value chain-related impacts, risks and opportunities (IROs) and insufficient data maturity of suppliers" (page 37).

On E3-2 specifically: no actions or resources are reported. The forward statement is that the company is "in the process of conducting necessary mappings and assessments on the level of materiality for water and marine resources in our value chain" (page 85), with no timeline or budget attached.

Targets related to water and marine resources

Reference: page 85 (section 4), table 19 (page 85), page 47 (section 1.5.3.3).

Water and marine resources is material to Aker BP only through a single upstream value chain impact. The ESRS content index maps E3-1 to E3-5 all to "section 4" (table 5, page 52), and section 4 occupies a single page.

The company's full E3 disclosure (page 85): "Water and marine resources is not a material topic for Aker BP's own operations. We have identified one material impact within this topic, as we believe that water consumption in our upstream value chain could potentially prove to be material. We are in the process of conducting necessary mappings and assessments on the level of materiality for water and marine resources in our value chain. As we have not yet been able to obtain the necessary data and insight into our value chain related to water and marine resources, we do not have any related policies, actions, targets or metrics to report." The "Relevant policies" box for the chapter reads "None".

The single material IRO (table 19, page 85): "Freshwater withdrawal - In the value chain, large amounts of water are withdrawn during the production of oil and gas-related infrastructure. The extent of the negative impact depends on the level of water scarcity in the area." It is classified a negative actual impact, upstream only, over the medium and long term.

DMA basis (page 47): "Aker BP's own operations are located on the NCS. We do not withdraw water from water-stressed regions, and none of our own operations are situated in such environments... Based on this assessment, water is not considered a material topic for Aker BP's own operations. We have therefore not deemed it necessary to conduct consultations with local communities. However, activities within our upstream value chain could potentially be located in water-stressed areas."

Aker BP has applied the ESRS 1 transitional provision for value chain metrics and states it "reported metrics related to the value chain for E1, as well as for resource inflows under E5. For all other topics, value chain metrics were not available at the time of submitting this report due to an incomplete understanding of value chain-related impacts, risks and opportunities (IROs) and insufficient data maturity of suppliers" (page 37).

On E3-3 specifically: no water-related targets are set, and none are announced. This is a nil return rather than a phase-in omission: the company states plainly that it has no policies, actions, targets or metrics to report for this topic (page 85).

Water consumption

Reference: page 85 (section 4), table 19 (page 85), page 47 (section 1.5.3.3).

Water and marine resources is material to Aker BP only through a single upstream value chain impact. The ESRS content index maps E3-1 to E3-5 all to "section 4" (table 5, page 52), and section 4 occupies a single page.

The company's full E3 disclosure (page 85): "Water and marine resources is not a material topic for Aker BP's own operations. We have identified one material impact within this topic, as we believe that water consumption in our upstream value chain could potentially prove to be material. We are in the process of conducting necessary mappings and assessments on the level of materiality for water and marine resources in our value chain. As we have not yet been able to obtain the necessary data and insight into our value chain related to water and marine resources, we do not have any related policies, actions, targets or metrics to report." The "Relevant policies" box for the chapter reads "None".

The single material IRO (table 19, page 85): "Freshwater withdrawal - In the value chain, large amounts of water are withdrawn during the production of oil and gas-related infrastructure. The extent of the negative impact depends on the level of water scarcity in the area." It is classified a negative actual impact, upstream only, over the medium and long term.

DMA basis (page 47): "Aker BP's own operations are located on the NCS. We do not withdraw water from water-stressed regions, and none of our own operations are situated in such environments... Based on this assessment, water is not considered a material topic for Aker BP's own operations. We have therefore not deemed it necessary to conduct consultations with local communities. However, activities within our upstream value chain could potentially be located in water-stressed areas."

Aker BP has applied the ESRS 1 transitional provision for value chain metrics and states it "reported metrics related to the value chain for E1, as well as for resource inflows under E5. For all other topics, value chain metrics were not available at the time of submitting this report due to an incomplete understanding of value chain-related impacts, risks and opportunities (IROs) and insufficient data maturity of suppliers" (page 37).

On E3-4 specifically: no water consumption, withdrawal, discharge or storage figures are given for own operations or the value chain. Table 6 marks the SFDR datapoints "ESRS E3-4 Total water recycled and reused paragraph 28(c)" and "ESRS E3-4 Total water consumption in m3 per net revenue on own operations paragraph 29" as not material (page 54). Produced water volumes are reported instead under E2-4 (19.9 million m3, 73 percent reinjected, figure 29, page 84).

Anticipated financial effects from water and marine resources-related impacts, risks and opportunities

Reference: page 85 (section 4), table 19 (page 85), page 47 (section 1.5.3.3).

Water and marine resources is material to Aker BP only through a single upstream value chain impact. The ESRS content index maps E3-1 to E3-5 all to "section 4" (table 5, page 52), and section 4 occupies a single page.

The company's full E3 disclosure (page 85): "Water and marine resources is not a material topic for Aker BP's own operations. We have identified one material impact within this topic, as we believe that water consumption in our upstream value chain could potentially prove to be material. We are in the process of conducting necessary mappings and assessments on the level of materiality for water and marine resources in our value chain. As we have not yet been able to obtain the necessary data and insight into our value chain related to water and marine resources, we do not have any related policies, actions, targets or metrics to report." The "Relevant policies" box for the chapter reads "None".

The single material IRO (table 19, page 85): "Freshwater withdrawal - In the value chain, large amounts of water are withdrawn during the production of oil and gas-related infrastructure. The extent of the negative impact depends on the level of water scarcity in the area." It is classified a negative actual impact, upstream only, over the medium and long term.

DMA basis (page 47): "Aker BP's own operations are located on the NCS. We do not withdraw water from water-stressed regions, and none of our own operations are situated in such environments... Based on this assessment, water is not considered a material topic for Aker BP's own operations. We have therefore not deemed it necessary to conduct consultations with local communities. However, activities within our upstream value chain could potentially be located in water-stressed areas."

Aker BP has applied the ESRS 1 transitional provision for value chain metrics and states it "reported metrics related to the value chain for E1, as well as for resource inflows under E5. For all other topics, value chain metrics were not available at the time of submitting this report due to an incomplete understanding of value chain-related impacts, risks and opportunities (IROs) and insufficient data maturity of suppliers" (page 37).

On E3-5 specifically: the single material IRO is classified as a negative actual impact, not a financial risk or opportunity, so no financial effects are identified to quantify. Table 3 (page 49) attributes current financial effect only to three climate risks. Table 6 marks "ESRS E3-1 Water and marine resources paragraph 9" material with location section 4 (page 54).

Transition plan on biodiversity and ecosystems

Reference: pages 86-88 (section 5), table 21 (page 87).

Aker BP does not present a biodiversity transition plan as such; instead the index maps E4-1 to "section 5" (page 52) and the chapter opens with the company's alignment statement and a resilience analysis.

Framing (page 86): "Aker BP acknowledges the objectives of the Convention on Biological Diversity and welcomes the goals of the Kunming-Montreal Global Biodiversity Framework to halt and reverse biodiversity loss. We recognise that climate change and biodiversity loss are complex and deeply interconnected challenges, and we strive to address both in our business practices."

Resilience of the strategy and business model (page 87): "The resilience of Aker BP's strategy and business model in relation to biodiversity and ecosystem services is qualitatively assessed with involvement of internal stakeholders, taking into consideration our biodiversity-related physical, transition and systemic risks... The scope of this resilience analysis currently encompasses our own operations. We aim to expand the scope to include our value chain as our understanding of location-specific material impacts, risks and opportunities within the value chain continues to evolve. The approach to the assessment is guided by the Taskforce on Nature-related Financial Disclosures' recommendations."

Key assumptions (page 87): "low probability of unexpected regulatory changes since Aker BP's own operations are located in Norway, which has a transparent and predictable regulatory regime"; and that the business model "does not directly depend on the supply of biological resources (e.g., fisheries and forest products)".

Conclusion (page 88): "This resilience analysis of Aker BP's biodiversity-related risks concludes that Aker BP's strategy and business model are resilient to the identified biodiversity and ecosystems-related physical, transition and systemic risks. These risks are not likely to have major implications for our business over short-, medium- and long-term horizons."

Table 21 (page 87) sets out risk drivers and mitigations across policy, liability, market, reputation, technology, acute and chronic physical, and systemic categories. No time-bound biodiversity transition plan, no alignment with the Global Biodiversity Framework targets and no biodiversity offsets are presented; "biodiversity offsets have not been used in the action plans for the assets in our own operations" (page 89).

Policies related to biodiversity and ecosystems

Reference: page 88 (section 5.1).

Aker BP has a standalone biodiversity policy, available on its website, owned and accountable to the SVP people and safety, an EMT member. "The policy covers our operated assets only" (page 88).

Commitments (page 88): the policy commits Aker BP "to respecting internationally recognised areas of high natural and cultural importance as defined by the IUCN, UNESCO and Ramsar Convention", and addresses material matters "through commitments to identifying, monitoring and accounting for biodiversity-related dependencies, risks, impacts and opportunities, integrating material issues into decision-making and risk management, applying a mitigation hierarchy..., engaging with relevant stakeholders and value chain, and supporting R&D activities".

Mitigation hierarchy and avoidance (page 88, figure 30 page 90): avoid, reduce, restore, compensate. "The policy emphasises the prioritisation of avoidance first by commitment not to engage in exploration and production activities in legally protected areas or internationally recognised areas. When operating close to or within nationally established SVOs, Aker BP shall exercise due care to avoid negative impacts on the biodiversity values for which the SVO areas were designated."

Oceans and seas (page 88): "Aker BP does not have a standalone policy on sustainable oceans or seas practices. However, we are guided by the UN Sustainable Development Goal 14 (life below water) and integrate ocean sustainability, such as risk-based oil spill preparedness and response, into our policies." Table 6 marks the SFDR datapoints "ESRS E4-2 Sustainable land / agriculture practices or policies paragraph 24(b)" and "Sustainable oceans / seas practices or policies paragraph 24(c)" as material and "Policies to address deforestation paragraph 24(d)" as material with no location (pages 54-55).

Stated exclusions (page 88): climate-driven biodiversity impacts are handled through the climate and energy policy, and accidental discharge risk through the external environment policy. "Aker BP has not identified any material negative impacts related to land degradation, desertification or soil sealing." Value chain engagement is a commitment rather than a current practice: the company commits "to stepping up engagement with our suppliers and encouraging traceability in the supply chain".

Actions and resources related to biodiversity and ecosystems

Reference: page 89 (section 5.2), table 22 (page 90).

Standing programme (page 89): baseline surveys or assessments of the seabed and benthic fauna prior to drilling and new developments; environmental monitoring of sediments, benthic fauna and the water column around production facilities; monitoring of operational emissions and discharges; post-decommissioning seabed surveys; and use of the collected data in environmental risk analyses for planning new wells.

2025 drilling in or near SVOs (pages 89-90). Five operations are described with named mitigations, and the stated outcome is that "all drilling and commissioning activities were completed with no measurable negative impact on biodiversity":

• Page well (PL1086, North Sea, within SVO Tobisfeltet, sand eel habitat): timing planned under the Norwegian marine management plan to avoid spawning and early life stages; "the drill cuttings generated during drilling were collected and sent ashore for further treatment to prevent physical disruption of sand eels' bottom habitats from discharges"
• Elgol well (PL1131, Barents Sea, within SVO Kystsonen Finnmark): drilling scheduled "to avoid oil-bearing formations during spring and summer"
• Rondeslottet (PL1005, Norwegian Sea, 5 km from SVO Eggakanten Sør): dynamic positioning used, "eliminating any physical seabed impact from anchors or chains"; modelling of cuttings dispersion and blowout simulations "consistently indicated low environmental risk"
• Bounty Updip (PL886, 4 km from SVO Kystsonen Norskehavet Sør): operations scheduled to avoid breeding and spawning periods
• Yggdrasil area development, Munin (5 km from SVO Vikingbanken, 2025-2027): site surveys "confirming that no significant benthic communities were present"; cuttings dispersion "limited to within 150 metres of the well location"

Value chain (page 89): "In 2023, Aker BP integrated biodiversity requirements into new contracts and invitations to tender and has been updating existing contracts throughout 2024 and 2025."

Limits (page 89): "Biodiversity offsets have not been used in the action plans for the assets in our own operations." No monetary resources are attached to biodiversity actions. Onshore, "no measurable negative impacts have been identified on these sensitive areas from the operational activities at Aker BP's sites. For this reason, Aker BP has not implemented any local impact mitigation measures" (page 90).

Targets related to biodiversity and ecosystems

Reference: page 89 (section 5.3).

A nil return with an explanation. "Aker BP has not set measurable biodiversity-related targets as of 31 December 2025, as we are currently exploring options suited for our business" (page 89).

What is tracked instead (page 89): "However, Aker BP tracks the effectiveness of our policies' objectives and actions in relation to the material biodiversity impacts through careful planning of new drilling projects. This planning considers the proximity to biodiversity-sensitive areas and the seasonality of valuable biological resources. As further described in section 5.4, we use quantitative indicators - such as the distance to biodiversity-sensitive areas - which enable us to implement precautionary measures where necessary early in the planning phase for new wells."

That indicator is operationalised in table 22 (page 90), which records distance to SVO for each 2025 well: Page and Elgol within an SVO, Bounty Updip 4 km, Rondeslottet 5 km and Yggdrasil Munin 5 km. A second effectiveness measure is the qualitative outcome statement that "all drilling and commissioning activities were completed with no measurable negative impact on biodiversity" (page 89).

Related supplier metric (page 124): under business conduct, Aker BP reports "an ambition of achieving at least an 80 percent response rate for environmental performance data requests from our 26 most relevant suppliers regarding environmental impact. These requests, issued through the CDP Supply Chain module, address questions regarding climate change and biodiversity. In 2025, we received 23 responses, corresponding to a response rate of 88 percent."

No target is set against the Kunming-Montreal Global Biodiversity Framework, no biodiversity net gain commitment is made, and no ecological-threshold or species-level target is disclosed. The forward statement is that the company "plans to step up engagement on biodiversity with our supply chain and continue mapping of the biodiversity impacts and risks in our value chain" (page 89), without a date.

Impact metrics related to biodiversity and ecosystems change

Reference: page 90 (section 5.4), table 22 (page 90).

Aker BP reports site-location metrics rather than condition or species metrics. "Measurements of the biodiversity metrics are not validated by an external body" (page 90).

Offshore sites in and near biodiversity-sensitive areas (table 22, page 90). Five 2025 wells are listed with licence, marine area, operator, Aker BP equity share, drilling period, SVO name, distance to SVO and biodiversity values:

Reporting is "guided by the internal mapping tool, MapInsight, which contains information about these areas and allows for precise pinpointing of operational sites relative to them" (page 90).

Onshore sites (page 90). "Johan Sverdrup's onshore power station at Haugsneset lies within one km of the Gåsholmen and Årvikholmen nature reserve (IUCN IA)". "Valhall's onshore power converter station is located within one km of the Røyrtjønn nature reserve (IUCN IA), part of the Ramsar-listed wetlands", with Listastrendene (IUCN V), Einarsneset, Lundevågen, Hanangervann and Kråkenesvann (all IUCN IV) nearby.

Stated position on impact (page 90): "At the time of submitting this sustainability statement, no measurable negative impacts have been identified on these sensitive areas from the operational activities at Aker BP's sites."

Production assets in own operations "are located outside biodiversity-sensitive areas" (page 47). No land-use change area, no ecosystem extent or condition metric, and no threatened-species metric is reported.

Policies related to resource use and circular economy

Reference: page 92 (section 6.1), figure 31 (page 92).

Aker BP has a circular economy policy, available on its website, approved and owned by the SVP people and safety, an EMT member, who "is accountable for the implementation of the policy" (page 92).

Scope and commitments (page 92): the policy "outlines our ambition to optimise material use and reduce waste at the assets under our operational control and in our upstream value chain where relevant. The policy states our commitment to sustainable sourcing and working proactively with our suppliers to introduce circular economy in the supply chain, including incorporating renewable and recycled content in products to reduce use of virgin raw materials. The policy also expresses our commitment to incorporate circular economy into our strategies and performance management."

Stated exclusion (page 92): "Transitioning away from use of virgin resources is not covered by this policy, due to the nature of our business model as a pure-play oil and gas company."

Circular economy hierarchy (figure 31, page 92): (1) reduce resource use and waste through operational efficiency and sustainable design; (2) reuse, repurpose and repair equipment to extend material lifecycle; (3) recycle materials to replace virgin material use; (4) recover energy from waste. "By adopting this hierarchy, we aim to reduce waste at the source through operational efficiencies and sustainable design, reusing and repairing existing equipment and materials, recycling and energy recovery. This aims to ensure that equipment and materials are kept in the form with the highest possible value to the economy for the longest period of time. We are committed to implement this hierarchy throughout the entire project life cycle, from field development to drilling and production through to decommissioning" (page 92).

The DMA methodology for E5 is guided by "industry standards and best practices, such as NORSOK S-003:2017 Environmental care and Offshore Norge's guidelines for best available techniques assessments", with value chain considerations "based on a preliminary screening of our value chain activities" (page 47).

Actions and resources related to resource use and circular economy

Reference: pages 92-93 (section 6.2).

Reduction of drilling waste (page 92): "Aker BP has installed a thermal cuttings treatment unit on the Noble Invincible rig, used for drilling new wells in several areas over the last two to three years. In 2026 this unit will continue to process oil-based cuttings at high temperatures, separating them into dry cuttings with residual oil content meeting regulatory thresholds that allow discharge to sea... while the recovered base oil will be reused to make new drilling fluids."

Reuse of drilling fluids (page 93): "Most of the oil-based drilling fluids Aker BP uses are reused when drilling between sections or returned to the drilling fluids supplier, who reconditions the drilling fluids for reuse. The reuse rate in 2025 was approximately 79 (79) percent for oil-based drilling fluids."

Reuse of surplus inventory (page 93): dashboards "that provide visibility and control over reuse and redistribution of materials", and within drilling and wells "a dedicated tracking system has been established, supported by assigned personnel and routines that ensure that surplus inventory is selected prior to ordering new resources".

Recycling from decommissioning (page 93): the 2025 physical scope covered "Phase 3 P&A (conductor pulling) of the eight wells of Hod A", the "Hod A topside and jacket" and the "PCP jacket". "The outcome of the disposal works in 2025 is documented in the final disposal close-out report and is a recycle rate of approximately 91 percent." Abandonment spend during 2025 was USD 85 (227) million, with future decommissioning costs in the abandonment liabilities at note 24, page 172.

Supply chain engagement (page 93): circular economy requirements were integrated into new contracts and invitations to tender in 2023 and are included when existing contracts are updated. Contractors are required to contribute to "improving product durability, reusability, upgradability and reparability", "addressing hazardous chemicals in products", "increasing recycled content in products", "incentivising product-as-a-service or other sharing models" and "leveraging digital platforms to reduce and document the environmental footprint of products and services".

Targets related to resource use and circular economy

Reference: page 93 (section 6.3).

A nil return with a stated reason and a described alternative. "As of 31 December 2025, Aker BP has not adopted targets related to circular economy, as we are currently investigating different options suited for our activities" (page 93).

Effectiveness tracking in place of targets (page 93): "Aker BP monitors the effectiveness of its circular economy policies and actions by tracking major resource inflows and waste. For example, we measure performance against decommissioning project objectives using quantitative indicators, such as the percent recycled materials from decommissioned installations. We do not measure progress from a base period, but rather on a project basis."

The operative indicator is the decommissioning recycling factor: "the recycling factor is a key metric in contracts for removal of offshore structures and has historically been around 95 percent. The recycling factor is calculated by dividing the sum of the recycled fractions by the total weight of the disposed material" (page 94). The 2025 outturn was approximately 91 percent (pages 93-94).

Aker BP also tracks the oil-based drilling fluid reuse rate, 79 (79) percent in 2025 (page 93), and the total resource inflow of steel, 103,202 (21,689) tonnes (page 93), without setting a target for either.

No target is set for the share of secondary or recycled inputs, for waste reduction, for waste diversion, or for the use of virgin materials. The company's stated position is that "transitioning away from use of virgin resources is not covered by this policy, due to the nature of our business model as a pure-play oil and gas company" (page 92).

Resource inflows

Reference: page 93 (sections 6.4 and 6.4.1).

Aker BP reports a single material inflow. "Steel for construction of wells and offshore installations, such as pipelines, topside and subsea templates, is deemed to be a material resource inflow for Aker BPs operations. The total resource inflow of steel during 2025 was 103,202 (21,689) tonnes. The increase is primarily due to increased drilling and commissioning activities, which require large amounts of steel. We aim to optimise material use to reduce environmental impact and support a more circular approach to resource management" (page 93).

The near five-fold year-on-year increase is consistent with the capital goods scope 3 category, which rose from 57 to 242 kt CO2e on an equity share basis (table 13, page 74), and with the statement that "scope 3 emissions under category 2 increased significantly during 2025 due to increased drilling and commissioning activities, which require large amounts of steel. Beyond 2027, we expect the emission levels within this category to fall back to levels consistent with previous years" (page 72).

Method and boundary (page 93): "The data for resource inflows metrics is based on the same data sources, methodologies and boundaries used for scope 3 emissions reporting, as outlined in section 2.5.3." Table 27 (page 97) confirms that for capital goods "the amount of steel (or other materials) used/installed is gathered annually from suppliers and alliance partners" with "100% of data obtained from suppliers or value chain partners", and that where product-specific factors are unavailable the World Steel Association factor of 1.92 t CO2e per tonne of steel is applied. "Measurements of circular economy metrics are not validated by an external body" (page 93).

Aker BP is one of the few topics for which the company reports value chain metrics: it states it "has reported metrics related to the value chain for E1, as well as for resource inflows under E5" (page 37). No breakdown between biological and technical materials, and no share of secondary or reused components, is given.

Waste

Reference: pages 94-95 (section 6.4.2), table 24 (page 95), table 25 (page 95), figure 32 (page 94).

Waste is a material sub-topic (two of the three material E5 IROs are waste, table 23, page 91), and table 6 marks the SFDR datapoints "ESRS E5-5 Non-recycled waste paragraph 37(d)" and "ESRS E5-5 Hazardous waste and radioactive waste paragraph 39" as material, located in section 6.4 (page 55).

Generation and handling (table 24, page 95), tonnes, 2025 (2024):

Diverted versus directed to disposal (table 25, page 95): total diverted from disposal 3,987 (3,130) tonnes; total directed to disposal 38,974 (35,761) tonnes.

Composition and drivers (page 94): "the largest fraction of waste consists of drilling fluids and drill cuttings... In 2025, the total amount of waste from drilling fluids and cuttings was 39,322 (31,544) tonnes. Drilling waste increased in 2025 due to increased drilling activities." NORM arises from formation water and rock formations.

Decommissioning waste (page 94): "approximately 90 percent of the waste fractions consist of metals"; the 2025 disposal recycle rate was approximately 91 percent against a historical contractual factor "around 95 percent".

Measurement (page 93): "metrics reported for waste are based on the actual weighing of waste and materials at the contractors' onshore receiving facilities. The measurement uncertainty is assumed to be less than five percent." Not validated by an external body.

Policies related to own workforce

Reference: page 99 (Commitment to respecting human rights of individuals), page 103 (section 7.1.1), page 106 (section 7.2.1), page 108 (section 7.3.1).

Aker BP's index maps S1-1 to the human rights commitment on page 99 plus sections 7.1.1, 7.2.1 and 7.3.1 (page 53). Seven policies apply to own workforce: code of conduct, human rights policy, diversity, equity and inclusion policy, safe operations policy, emergency preparedness and response policy, health and working environment policy, and the employee handbook (page 100).

Human rights policy (page 99). Owned by and accountable to the CEO, aligned with the UN Guiding Principles and the OECD Guidelines, and applicable "to all Aker BP employees and non-employees, as well as suppliers, contractors and business partners". Commitments include to "treat everyone who works for Aker BP with fairness, respect and dignity"; "provide fair working conditions for our own workforce"; "eliminate all forms of discrimination and harassment"; "respect the freedom of association and right to collective bargaining"; "oppose any form of forced or compulsory labour, child labour or human trafficking"; and to "have systems in place for raising concerns and provide appropriate remediation".

Employee handbook (page 103). Owned by the SVP people and safety, based on the Norwegian Working Environment Act, covering social dialogue, social protection, work-life balance and working time.

Diversity, equity and inclusion policy (page 106). Owned by the SVP people and safety; "promotes an inclusive workplace free from discrimination and harassment regardless of factors such as gender, linguistic ability, race, ethnic origin, physical or mental ability, age, nationality, sexual orientation, religion or belief, marital status or socio-economic status". Stated gap: "The policy does not specifically address commitments related to inclusion and positive actions for employees that are at particular risk or vulnerable."

Health and safety policies (page 108). Safe operations policy, health and working environment policy and emergency preparedness and response policy, guided by "OHSAS 18001 and ISO 45001".

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

Reference: page 103 (section 7.1.1.1).

"Engagement with our own workforce is essential to identify, prevent, mitigate and account for actual and potential impacts. The SVP people and safety has the overall responsibility for all employee involvement" (page 103).

Surveys (page 103): "Aker BP conducts pulse surveys to monitor employee satisfaction and identify organisational concerns related to our impacts... Employee experience is assessed through factors such as engagement, experience versus expectations, inclusion and well-being. Both employees and non-employees are included in these surveys. ... In 2025, we conducted three pulse surveys as part of our transition from quarterly to biannual measurements, following the introduction of the more comprehensive Organisational and Psychosocial Work Environment (OPA) survey, first conducted in 2024 and now carried out every second year."

Representative structures (page 103): "Engagement is also maintained through employee representatives in groups such as the board of directors, the work council and the working environment committee. Both the work council and the working environment committee meet regularly, at least quarterly, with the primary responsibility of the employee representatives being to safeguard Aker BP employees' interests and mitigate negative impacts." Five of the 13 board members are employee-elected (table 2, page 41).

Trade unions (page 103): "Aker BP supports employees' rights to form and join trade unions, and equally their right to remain non-unionised... the company communicates with the trade unions during the annual salary negotiations and on an ad hoc basis regarding organisational restructuring. These interactions collectively have a direct impact on working conditions."

Non-employees (page 103): "For non-employees, working conditions and terms of employment are influenced by our collective bargaining agreements, and this is represented in our contracts with the companies through which they are hired." Survey results are used to drive action: "after a pulse survey is conducted, all teams review their results and implement actions if necessary" (page 104).

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

Reference: page 103 (section 7.1.1.1), page 99, pages 122-123 (section 10.2).

Aker BP's index maps S1-3 to section 7.1.1.1 and the human rights commitment on page 99 (page 53). Table 6 marks the SFDR datapoint "ESRS S1-3 Grievance/complaints handling mechanisms paragraph 32(c)" as material, located in section 7.1.1 (page 55).

Channels (pages 103, 123): "Both employees and non-employees can raise concerns and report suspected violations of applicable laws and regulations through several channels, including our integrity channel." The speaking up policy lists the routes: "Our own workforce can report to their line manager, a representative of senior management, their trade union representative, safety delegates, offshore installation managers, the compliance or legal departments, other functional units, or report anonymously via the company's integrity channel."

Independence (page 123): "The integrity channel is managed by an independent third party (KPMG), ensuring confidentiality and proper handling of reports in accordance with the applicable standards and the internal procedure for handling whistleblowing reports."

Non-retaliation (pages 123): the speaking up policy "builds on a strict non-retaliation principle, ensuring that no retaliatory actions are taken against whistleblowers". In 2025 "a whistleblower non-retaliation programme was introduced. Whistleblowers are asked if they wish to be contacted after their case is closed and whether they have experienced any retaliatory actions."

Remediation (page 103): "As stated in our human rights policy, we shall have measures in place to reduce or mitigate any adverse impact on our own workforce and will, where relevant, provide or cooperate in effective grievance mechanisms. Follow-ups with the affected parties aim to ensure the effectiveness of the remedy."

Effectiveness tracking (page 123): the compliance department reviews all integrity reports and reports to the EMT and ARC; in 2025 "a dashboard was established to provide an overview of cases and internal KPIs, including handling time and follow-up of whistleblowing cases". Volume: 13 (21) whistleblowing cases in 2025, of which employee relations 9 (12), safety and security 2 (1), inquiries and other 2 (1), business integrity 0 (5), supply chain and business partners 0 (2) (figure 44, page 123).

Taking action on material impacts on own workforce

Reference: pages 104-105 (section 7.1.2), page 106 (section 7.2.2), pages 108-109 (section 7.3.2).

Working conditions (pages 104-105). "We use our pulse survey to identify which key actions to implement for our impacts related to working conditions within our own workforce... After a pulse survey is conducted, all teams review their results and implement actions if necessary to prevent and mitigate adverse material impacts. If a negative trend is observed across the company, cross-company actions are undertaken to address it." Outcome for the year: "For 2025, no pulse surveys indicated the need for additional cross-company actions." On offshore working time, "extended offshore stays, overtime and total workload offshore are monitored, and dashboards enable proactive follow-up at both individual and installation level. For 2026, we will further develop and improve the dashboards."

Equal treatment (page 106). "We work in a systematic manner to promote equality and prevent discrimination, as required by the Norwegian Equality and Anti-Discrimination Act." Measures: "dashboards for each business unit to track gender ratio development, which are accessible to all employees"; diversity and inclusion embedded "in e-learning available to all employees, in leadership training programmes and across all our people processes"; enhanced employer branding "to attract a broader and more diverse talent pool"; and support for "initiatives that promote education and careers for girls".

Health and safety (pages 108-109). Two named 2025 initiatives. The resilience project, "a preventive initiative aimed at strengthening the robustness of our own workforce and enhancing our collective capacity to manage pressure and change... The project was a cross-functional collaboration between the health and working environment department and the people and organisation department and was completed in 2025." And a safety culture working group established for the 2026 high-activity phase, which "focused on identifying competence gaps, improving onboarding and communication, and developing targeted measures for new workers", plus "enhancing training and support for leaders" and "assessing contractual requirements to secure competence and collaboration with suppliers".

No monetary resources are attached to own-workforce actions.

Targets related to own workforce

Reference: page 105 (section 7.1.3), page 106 (section 7.2.3), page 109 (section 7.3.3), figure 37 (page 109).

Aker BP sets targets for two of its three S1 areas and states a nil return for the third.

Working conditions - no targets (page 105): "We have not yet set any time-bound, outcome-oriented targets related to working conditions, as we have not identified any targets that are likely to result in changes for our workforce. We have also not set any time-bound, outcome-oriented targets specifically related to working time offshore." Effectiveness is tracked instead through pulse survey metrics: engagement 87 percent (86 percent) and work-life balance 81 percent (79 percent) favourable responses (figure 34, page 105).

Gender - one target (page 106): "Aker BP monitors the effectiveness of its policies, procedures and actions related to gender equality through a target of achieving 30 percent female employees by 2030. This target supports our efforts to address potential challenges related to underrepresentation, and has been approved by the BoD, where employee representatives are included. The baseline year is 2022, with a baseline value of 23.4 percent. No stakeholders have been involved in determining or setting the target. By the end of 2025, we had 25.5 (24.7) percent female employees, which is in line with our initial plan." The company adds: "We do not have other targets regarding equal treatment and opportunities for all."

Health and safety - four annual KPI targets (figure 37, page 109), all met in 2025:

These "have been approved by the BoD where employee representatives are included" and "include value chain workers on Aker BP operated offshore facilities (including mobile drilling units)". "We do not have targets for work-related illness. However, performance is monitored using metrics." "None of our stakeholders have been involved in setting the targets" (page 109).

Characteristics of the undertaking's employees

Reference: figure 33 (page 102), tables 33-35 (page 118), page 100 (section 7).

Head count at year end, 2025 (2024):

• Total employees: 3,108 (2,962); male 2,317 (2,231), female 791 (731); none reported as other or not reported (table 33, page 118)
• All employees are in Norway: 3,108 (2,962) (table 34, page 118); "Employed in Norway: 100% (100%)" (figure 33)
• Permanent employees 3,056 (2,911); temporary 52 (51); non-guaranteed hours 0 (0); full-time 3,013 (2,875); part-time 43 (36) (table 35, page 118)
• Temporary split male 31 (31), female 21 (20); part-time male 17 (12), female 26 (24) (table 35)
• Nationalities 51 (44); average age 45 (45), with the prior year "recalculated using an updated and consistently applied methodology"
• Age distribution: 18-29 279 (236); 30-49 1,637 (1,564); 50+ 1,192 (1,162)
• Total new hires 214 (299), 7.3 percent (10.9 percent) of employees; female 77 (90), male 137 (209)
• Total turnover 67 (76), 2.2 percent (2.6 percent) of employees; female 17 (21), male 50 (55). "Total turnover is calculated by dividing the number of employees who left the company during the year by the total number of employees on 31 December 2025" (figure 33, page 102)
• Board of directors 13 (13): female 7 (6), male 6 (7)

Contract practice (page 100): "Full-time employment is offered to all of Aker BP's permanent employees. Temporary contracts are provided to either summer students or temporary substitutes for permanent employees. Our part-time employees are employees who have applied for and been granted reduced working hours. We do not hire employees on zero-hour contracts."

The S1 boundary is stated at page 37: "The S1 (own workforce) standard limits reporting to personnel employed or contracted by Aker BP."

Parental leave (figure 35, page 105): 100 percent of employees are entitled to parental leave; 241 (213) entitled employees took parental leave, 7.8 percent (7.2 percent) of employees, of whom female 65 (56) and male 176 (157).

Characteristics of non-employee workers

Reference: figure 33 (page 102), page 100 (section 7), page 99.

Aker BP's index maps S1-7 to figure 33 (page 53), and non-employees are reported alongside employees throughout.

Head count, 2025 (2024): "Aker BP's own workforce consists of 3,108 (2,962) employees and 1,215 (1,105) non-employees (see note 8, page 156)" (page 100). Total own workforce is therefore 4,323 (4,067), all employed in Norway (page 99).

Definition applied (page 100). "Non-employees: People under an agency-type arrangement that meets the following criteria:

• The position requires that the person acts in an Aker BP role or capacity
• The work will mainly be carried out at Aker BP's offices or installations, and by use of Aker BP's equipment
• The duration of the engagement is at least three months"

Coverage by policies and processes. Non-employees are within the human rights policy scope (page 99); included in pulse surveys (page 103); covered by the National Insurance Scheme and, for terms of employment, "influenced by our collective bargaining agreements, and this is represented in our contracts with the companies through which they are hired" (page 103); able to use all reporting channels including the integrity channel (page 103); and required to complete mandatory ethics and compliance onboarding training (page 122).

Safety data are reported separately for non-employees (table 30, page 110): fatalities 0 (0); total recordable injuries 0 (3); total recordable injury frequency 0.0 (1.8) per million work hours; work hours 2.1 (1.7) million. Own workforce combined: TRIF 0.4 (0.9), work hours 7.0 (6.3) million.

No breakdown of non-employees by gender, age or contract type is given, and the head count is a single figure rather than the ESRS split between self-employed people and people provided by undertakings primarily engaged in employment activities.

Collective bargaining coverage and social dialogue

Reference: table 29 (page 105), page 103 (section 7.1.1.1).

Table 29: Collective bargaining and social dialogue (page 105) reports, for the EEA, two rows against banded coverage rates (0-19, 20-39, 40-59, 60-79 and 80-100 percent): collective bargaining coverage for employees in Norway, and social dialogue measured as workplace representation in Norway. Coverage is presented as a band rather than a single percentage.

Change in basis, disclosed in the footnote (page 105): "From 2025, Aker BP reports the share of employees who are union members instead of showing full coverage. Non-unionised employees are still covered by collective bargaining agreements, and these agreements determine their working conditions and terms of employment." This is a break in comparability that a reader should note, because it shifts the metric from coverage to union density.

Supporting narrative (page 103). "Employees' interests are also secured through trade unions, which are associations of workers in the same industry or profession advocating for favourable working conditions for their members. As described in our code of conduct, Aker BP supports employees' rights to form and join trade unions, and equally their right to remain non-unionised... Non-unionised employees are still covered by collective bargaining agreements". The company communicates with trade unions "during the annual salary negotiations and on an ad hoc basis regarding organisational restructuring".

Workplace representation structures (pages 41, 103): five of 13 board members are employee-elected; a work council and a working environment committee each meet at least quarterly, the first to ensure "employee influence on company management and operations" and the second "to ensure a sound working environment".

All employees are in Norway (table 34, page 118), so no non-EEA disclosure arises. Human rights policy commitments include respect for "the freedom of association and right to collective bargaining" (page 99).

Diversity metrics

Reference: page 106 (section 7.2.3), figure 33 (page 102), table 36 (page 118), table 2 (page 41).

Gender distribution across employees (figure 33, page 102; table 33, page 118): 791 (731) female and 2,317 (2,231) male of 3,108 (2,962) employees, giving 25.5 percent (24.7 percent) female employees (page 106).

Gender at top management (table 36, page 118). The female population share is reported for each employee category, 2025 (2024):

Category-level shares are also given for subsurface and drilling, technical, business support and offshore populations, ranging from 9.6 percent for offshore management to 64.7 percent for business support professionals (table 36, page 118; figure 36, page 107).

Governance bodies (table 2, page 41): board of directors 54 percent (46 percent) women across 13 members; audit and risk committee 75 percent; organisational development and compensation committee 67 percent; executive management team 27 percent across 11 members. Board independence is 50 percent.

Age distribution (figure 33, page 102): 279 (236) employees aged 18-29; 1,637 (1,564) aged 30-49; 1,192 (1,162) aged 50+. Average age 45 (45), across 51 (44) nationalities.

The company's stated position is that "at Aker BP we promote an inclusive culture where all employees have equal opportunities" and that underrepresentation "can lead to issues such as discrimination, inequality and harassment in the workplace" (pages 101, 106). "None of our metrics are validated by an external body" (page 106).

Adequate wages

Reference: page 103 (section 7.1.1.1), page 106 (section 7.2.3).

Aker BP's index maps S1-10 to section 7.1.1.1 (page 53). The company does not present an adequate-wage benchmark test; instead it relies on collective bargaining coverage and a stated pay-neutrality ambition, all employees being in Norway.

Collective agreements as the wage floor (page 103): "Non-unionised employees are still covered by collective bargaining agreements, and these agreements will determine their working conditions and terms of employment. For non-employees, working conditions and terms of employment are influenced by our collective bargaining agreements, and this is represented in our contracts with the companies through which they are hired." Trade unions are engaged "during the annual salary negotiations".

Pay system ambition (page 106): "Aker BP has an ambition to maintain a neutral pay system as a part of our effort to foster diversity and inclusion. This aims to ensure that individuals in identical positions, with equivalent experience and the same formal competence, receive equal compensation for comparable results, irrespective of gender or other diversity factors. The gender base pay ratio for tariff workers is 100 percent when adjusted for equal positions and seniority. Onshore employees and offshore supervisors are individually evaluated based on job complexity and accountability, as well as formal competence and experience level."

Policy commitment (page 99): the human rights policy commits Aker BP to "provide fair working conditions for our own workforce, in accordance with all applicable legislation".

No percentage of employees paid below an applicable adequate wage benchmark is reported, and no benchmark is named. The company reports no employee outside Norway (table 34, page 118), and the material S1 IROs identified in the DMA do not include remuneration in own operations; inadequate remuneration is identified only as a value chain worker impact (tables 28 and 31, pages 101 and 111).

Social protection

Reference: page 103 (section 7.1.1.2).

Aker BP's index maps S1-11 to section 7.1.1.2, a dedicated "Social protection" subsection (page 53).

Statutory baseline (page 103): "The Norwegian National Insurance Scheme provides social protection for all Norwegian citizens. This provides coverage for all Aker BP employees and non-employees against loss of income up to a specified level set by national insurance due to sickness, unemployment, work-related injuries, disability, parental leave and retirement through public programmes."

That list covers all five ESRS major life events plus unemployment and disability, and applies to the whole own workforce of 4,323 people, all of whom are employed in Norway (pages 99, 118).

Company top-up for employees (page 103): "Aker BP provides additional coverage for employees to ensure that significant life events do not cause substantial income reduction. This includes, but is not limited to:

• Aker BP employees are eligible for the company's defined contribution pension plan, with Aker BP's pension contribution set at the maximum level permitted by Norwegian pension legislation
• In cases of sickness and work-related injuries, Aker BP covers the gap between the salary provided by the National Insurance Scheme and the employee's regular salary for up to one year
• In cases of parental leave, Aker BP covers the gap between the salary provided by the National Insurance Scheme and the employee's regular salary for 49 weeks. As an alternative, the employees may choose to take 80 percent salary for 59 weeks"

Related benefits are described under health and safety: "Aker BP provides health services to prevent, identify and monitor work-related health risks, and provides employee benefits such as regular health checks and health care insurance" (page 108). Uptake of parental leave is reported at figure 35 (page 105): 241 (213) employees, 7.8 percent (7.2 percent), of whom 176 (157) male.

No percentage of employees not covered is given, because the disclosure is that coverage is universal through the national scheme.

Health and safety metrics

Reference: page 109 (section 7.3.3), table 30 (page 110), figure 37 (page 109).

Table 6 marks the S1-14 SFDR and Benchmarks Regulation datapoints - number of fatalities and rate of work-related accidents (paragraph 88(b),(c)) and days lost (paragraph 88(e)) - as material, located in table 30 (page 55).

Table 30: Safety performance last two years (page 110), 2025 (2024):

Coverage (page 109): "our KPIs do not only cover our own workforce. They include HSE performance in areas where Aker BP has operator responsibility. This includes contractors injured on our installations and personnel injured on drilling rigs we lease."

Narrative on the year (page 109): "All three SIF events in 2025 resulted in actual personal injuries of varying severity and were classified as serious due to their potential for more severe outcomes under slightly different circumstances." "11 of the 24 work-related injuries resulted in days away from work. Three of these injuries involved an Aker BP employee, and they resulted in a total of 187 lost workdays." One work-related illness was registered for employees.

"None of our metrics are validated by an external body" (page 109). No percentage of own workforce covered by a health and safety management system is given, though the system is stated to apply to the own workforce (page 108).

Work-life balance metrics

Reference: pages 103-105 (sections 7.1.1.2, 7.1.1.3, 7.1.1.4, 7.1.3), figure 35 (page 105).

Aker BP's index maps S1-15 to sections 7.1.1.2, 7.1.1.3, 7.1.1.4 and 7.1.3 (page 53).

Entitlement and take-up (figure 35, page 105): "100 percent of employees are entitled to take parental leave", and 241 (213) entitled employees took parental leave in 2025, being 7.8 percent (7.2 percent) of employees. The split is female 65 (56) and male 176 (157).

Work-life balance arrangements (page 104): "Aker BP facilitates a healthy work-life balance in accordance with Norwegian legislation. Onshore employees have flexible working hours and a flexible hybrid working policy that allows for remote work, whereas offshore personnel follow fixed rotational schedules... All employees are entitled to parental and family-related leave per Norwegian law. During paid family-related leave, employees remain covered by Aker BP's insurance plans and continue to take part in the company's compensation and benefits processes to ensure that periods of leave do not negatively affect salary development."

Working time (page 104): "Working time at Aker BP is regulated in accordance with the Norwegian Working Environment Act. Offshore personnel work in fixed 2-4 rotational schedules (two weeks on, four weeks off). Extended offshore stays are managed through a documented case-by-case process, which includes consultation with employee representatives and clear responsibility for offshore leaders." Monitoring uses dashboards "at both individual and installation level" (page 105).

Financial support during leave (page 103): for parental leave Aker BP "covers the gap between the salary provided by the National Insurance Scheme and the employee's regular salary for 49 weeks. As an alternative, the employees may choose to take 80 percent salary for 59 weeks."

Effectiveness measure (figure 34, page 105): the pulse survey work-life balance score was 81 percent (79 percent) favourable, "defined as a rating of four or five" on a five-point scale. The company notes "our pulse survey results indicate that our employees are highly motivated and that they are able to maintain a healthy work-life balance" (page 105).

Compensation metrics (pay gap and total compensation)

Reference: page 106 (section 7.2.3), figure 36 (page 107), table 36 (page 118).

Table 6 marks the S1-16 datapoints "unadjusted gender pay gap paragraph 97(a)" and "excessive CEO pay ratio paragraph 97(b)" as material, located in section 7.2.3 and figure 36 (page 55).

CEO pay ratio (page 106): "In 2025, the annual total remuneration ratio of the highest paid individual to the median annual total remuneration for all employees was 9.0 (8.6). The numerator and the denominator include base salary, variable salary and other benefits, and is calculated as a median annual total remuneration."

Gender pay ratios (table 36, page 118). Aker BP reports the ratio of women's to men's pay by category rather than a single unadjusted gap. Total, 2025 (2024): base pay ratio 97.9 percent (95.8 percent) and total pay ratio 92.1 percent (91.2 percent). Category detail for 2025 includes:

Values for subsurface and drilling, technical and business support populations, split between managers and senior professionals and professionals, run from 89.0 to 97.7 percent on base pay. "Employees who joined or left the company during the year are not included in these numbers."

Method and caveat (page 106): "The gender base pay ratio for tariff workers is 100 percent when adjusted for equal positions and seniority. Onshore employees and offshore supervisors are individually evaluated based on job complexity and accountability, as well as formal competence and experience level. For pay analysis purposes, employees are further grouped into three categories: subsurface and drilling, technical and business support."

"None of our metrics are validated by an external body" (page 106). Executive remuneration detail is cross-referenced to the separate remuneration report (page 195).

Incidents, complaints and severe human rights impacts

Reference: page 106 (section 7.2.3), page 123 (section 10.2.3), figure 44 (page 123).

Nil returns for the reporting period (page 106): "There have been zero confirmed cases of discrimination and harassment in the reporting period, and we have not encountered any severe human rights incidents involving our employees. As a result, no associated fines have been paid. For the total number of complaints filed through the integrity channel, see section 10.2."

Complaints volume (page 123, figure 44): 13 (21) whistleblowing cases were received in 2025 "via the integrity channel and via reports directly to the compliance department". The subjects were employee relations 9 (12), safety and security 2 (1), inquiries and other 2 (1), business integrity 0 (5), and supply chain and business partners 0 (2). The company does not state how many of these were substantiated or how many related to own workforce discrimination or harassment specifically, beyond the zero confirmed cases above.

Mechanism (pages 103, 123): the integrity channel is "managed by an independent third party (KPMG)" and available anonymously; a strict non-retaliation principle applies, and in 2025 "a whistleblower non-retaliation programme was introduced". A dashboard tracks "handling time and follow-up of whistleblowing cases".

Table 6 treatment (page 55): the SFDR datapoint "ESRS S1-17 Incidents of discrimination paragraph 103(a)" is marked material with no location given, and "ESRS S1-17 Non-respect of UNGPs on Business and Human Rights and OECD Guidelines paragraph 104(a)" is marked material, located in section 7.2.3.

No fines, penalties or compensation for damages related to own-workforce incidents are reported, consistent with the zero confirmed cases. Value chain human rights findings are reported separately under S2-4 (67 audit findings, page 114).

Policies related to value chain workers

Reference: page 99, page 112 (section 8.1).

Aker BP's index maps S2-1 to the human rights commitment on page 99 and section 8.1 (page 53). Table 6 marks the S2-1 datapoints on human rights policy commitments (paragraph 17), policies related to value chain workers (paragraph 18), non-respect of UNGPs and OECD guidelines (paragraph 19) and ILO due diligence policies (paragraph 19) as material (page 55).

Policies (page 112): "Our code of conduct and human rights policy address material topics such as working conditions, human rights (including forced labour and inadequate framework for young workers), harassment, and health and safety. These policies apply to both our own operations and our upstream value chain." The human rights policy is owned by the CEO and "applies to all Aker BP employees and non-employees, as well as suppliers, contractors and business partners" (page 99). It is "aligned with the United Nations (UN) Guiding Principles on Business and Human Rights and the Organisation for Economic Co-operation and Development (OECD) Guidelines for Multinational Enterprises" and acknowledges "the International Bill of Human Rights and the International Labour Organisation's Declaration on Fundamental Principles and Rights at Work".

Operating principles for business relationships (page 112):

• "Assess business relationships using Aker BP's business partner integrity procedure to evaluate legal and ethical risks and, where applicable, include contractual obligations on ethics and compliance. This procedure pays special attention to material topics for value chain workers."
• "Clearly communicate our requirements to business partners and monitor compliance where necessary. These requirements are specified in contracts and in Aker BP's supplier declaration, which all new suppliers must sign before becoming an Aker BP supplier."
• "Take appropriate measures if business partners fail to meet our requirements and report any misconduct."

Stated gap (page 112): "While Aker BP does not have a separate supplier code of conduct, the principles above, together with the supplier declaration and contractual clauses, aim to ensure that our business partners actively establish processes to mitigate any adverse impacts on their employees and workers within their value chain."

Context: approximately 1,600 (1,600) tier 1 suppliers, some "operating in industries and countries associated with a high risk of poor working conditions, health and safety incidents, forced labour, inadequate frameworks for young workers and harassment" (page 111).

Processes for engaging with value chain workers about impacts

Reference: page 113 (section 8.1.1), figure 39 (page 113).

"In line with the principles of the Norwegian Transparency Act and the OECD Guidelines for Multinational Enterprises, as well as the UN Guiding Principle on Business and Human Rights, we apply a risk-based approach when evaluating potential adverse impacts on value chain workers. This includes evaluation of several factors, such as country risk rating, industry classification and type of activities" (page 113).

Direct engagement channels (page 113):

• "Safety representatives onshore and offshore, led by the coordinating safety officer, as well as site managers at project construction sites worldwide, shall regularly and continuously communicate with value chain workers directly, fostering trust and encouraging the reporting of any concerns. Their observations help identify and prevent actual and potential adverse impacts on value chain workers."
• "Oversight of contractors occurs through formalised processes, with the frequency of engagement depending on the type of contractual relationship. All contracts have a designated person from Aker BP who is responsible for managing the contract and ensuring engagement according to the plan. Key suppliers and alliance partners are frequently engaged through performance review meetings, addressing working conditions and other relevant issues."
• "We believe that our alliance model, as further described in section 10.3, enables us to optimise our influence to positively impact workers in the value chain."

Engagement through audits (page 113): "Stakeholder engagement is also an essential part of our audits... Worker interviews play a key role in our on-site audits, giving us a unique insight into their views and perspectives. We apply a risk-based approach when setting the audit programme and frequency for the following year, taking into account the rights and needs of vulnerable individuals and groups. The supply chain department is responsible for this programme." In 2025 the three audits involved "document reviews and interviews with management, value chain workers and union representatives, covering 160 workers" (page 114).

Accountability (page 113): the supply chain department owns the audit programme; a designated Aker BP person owns each contract. No named EMT-level owner is given for value chain worker engagement specifically, unlike own workforce, where the SVP people and safety holds overall responsibility (page 103).

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

Reference: page 113 (section 8.1.1), pages 114-115 (section 8.2.1), page 123.

Aker BP's own channel (page 113): "Value chain workers can also raise concerns and report suspected violations of applicable laws and regulations through the Aker BP integrity channel." The channel "is accessible via our website and is available to all external parties, including value chain workers and affected communities", is managed by an independent third party (KPMG), permits anonymous reporting and operates on a strict non-retaliation principle (page 123).

Requiring suppliers to have their own channels (page 113): "as part of our supplier declaration and contractual clauses, we aim to ensure that our suppliers meet our expectations by establishing channels for value chain workers to raise concerns. Further, as part of our human rights audits of our suppliers, we assess whether these channels are available and communicated to the value chain workers." The categorisation of 2025 audit findings shows "disciplinary and grievance mechanisms" as a distinct category with 6 (20) findings (figure 41, page 114).

Remediation (pages 99, 115): the human rights policy commits Aker BP to "have systems in place for raising concerns and provide appropriate remediation where we have caused or contributed to adverse impacts on human rights", and "we shall have measures in place to reduce or mitigate adverse impacts and will, where relevant, provide or cooperate in effective grievance mechanisms. Follow-ups with the affected parties aim to ensure the effectiveness of the remedy."

Outcome for the year (page 115): "All audits have resulted in reports with findings and recommendations. Additionally, Aker BP and the audited companies have created corrective action plans to address the findings. None of the findings required any further action to provide or enable remedy. Aker BP expects the suppliers to address the findings, and we monitor their progress through follow-up meetings. Responsibility for audit follow-up lies with the designated roles within the audit team or supply chain department." Closure is confirmed for the prior year: "All findings identified in 2024 have been mitigated and closed through close follow-up with suppliers" (page 115).

Aker BP does not report how many concerns were raised by value chain workers through its own integrity channel; the 13 cases reported in figure 44 (page 123) are not split by reporter category, though supply chain and business partners accounted for 0 (2).

Taking action on material impacts on value chain workers

Reference: pages 114-115 (section 8.2), figures 40 and 41 (page 114).

Audit programme, 2025 (page 114). "In 2025, we carried out three on-site audits: one at a construction site and two with vessel suppliers. This reduction from seven audits in 2024 is due to a smaller global supplier portfolio, as construction and assembly activities have increasingly transitioned back to Norway." Audits covered two countries in 2025 against seven in 2024 (figure 40, page 114). "The audited suppliers were selected based on risk and criticality assessments. Each audit involved document reviews and interviews with management, value chain workers and union representatives, covering 160 workers. All audits were conducted by independent auditors on behalf of Aker BP."

Audit focus (page 114): human rights (forced labour and inadequate framework for young workers); working conditions (insecure employment, inadequate remuneration, limited social dialogue, work-life imbalance and long working hours); health and safety; and harassment.

Findings (figure 41, page 114): 67 total findings in 2025 (144 in 2024), categorised as remuneration 14 (26); management systems 11 (12); discrimination 11 (9); health and safety 9 (21); disciplinary and grievance mechanisms 6 (20); employment, recruitment and subcontractor management 5 (21); freedom of association 4 (8); child labour and young workers 4 (4); freely chosen employment 3 (15); working hours 0 (8).

Follow-up (page 115): corrective action plans were created with each audited company; "none of the findings required any further action to provide or enable remedy"; and "all findings identified in 2024 have been mitigated and closed through close follow-up with suppliers".

Position outside the audit programme (page 114): "As of 2025, outside the audit programme, we have not received any reports or identified instances of non-compliance with the UN Guiding Principles on Business and Human Rights, ILO Declaration on Fundamental Principles and Rights at Work or OECD Guidelines for Multinational Enterprises involving value chain workers."

2026 plans (page 115): continued follow-up of 2025 findings, and "a structured, risk-based evaluation process will be applied to review and prioritise human rights audit nominations submitted internally by our organisation". No monetary resources are attached.

Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities

Reference: page 115 (section 8.3).

A nil return with a stated reason and a described alternative. "While we are focusing on improving our efforts towards workers in the value chain, we have not defined any measurable targets as we have not identified any targets that are likely to result in positive changes for workers in the value chain" (page 115).

What is tracked instead (page 115): "However, several metrics are derived from the on-site audits conducted. Figure 41 provides an overview of how the findings from 2025 are distributed across various categories. The categories were created by internal experts within this topic. We track the effectiveness of our policies and actions through our implementation of on-site audits. The metrics below provide insight into the measures we use in evaluating our progress. None of our metrics are validated by an external body."

The operative indicators are therefore: number of supplier on-site human rights audits conducted, 3 in 2025 against 7 in 2024; number of countries in which audits were undertaken, 2 against 7; number of workers covered by audit interviews, 160; and the count and categorisation of findings, 67 against 144 (figures 40 and 41, page 114; page 111).

Closure of findings functions as a second effectiveness measure: "all findings identified in 2024 have been mitigated and closed through close follow-up with suppliers" (page 115).

A related target does exist under business conduct rather than S2 (page 124): "we have set an ambition of achieving at least an 80 percent response rate for environmental performance data requests from our 26 most relevant suppliers regarding environmental impact... In 2025, we received 23 responses, corresponding to a response rate of 88 percent." That request covers climate change and biodiversity, not labour conditions.

No target is set for audit coverage, finding closure rate, or share of spend covered by the supplier declaration.

Policies related to affected communities

Reference: page 99, pages 116-117 (section 9.1).

Aker BP's index maps S3-1 to the human rights commitment on page 99 and section 9.1 (page 53). Table 6 marks the S3-1 datapoints on human rights policy commitments (paragraph 16) and non-respect of UNGPs, ILO principles or OECD guidelines (paragraph 17) as material (page 55).

Policies (pages 116-117). Five policies are listed for the topic: code of conduct, human rights policy, anti-corruption procedure, supply chain management policy and sponsorship policy (page 116). "Aker BP strives to ensure that our activities, as well as those within our value chain, do not cause any harm to affected communities. Our code of conduct and human rights policy thoroughly address this concern" (page 116). The human rights policy is owned by the CEO and commits the company to "respect the human rights of all individuals and groups that may potentially be affected by our operations" (page 99).

Supply chain reach (page 117): "our supply chain management policy outlines our approach to ethical, transparent and risk-aware supply chain practices, including integrity due diligence (IDD) and supplier risk management... We expect all our suppliers to maintain transparency in their interactions with affected communities and to take appropriate steps to identify and mitigate potential negative impacts. These expectations are formalised in our IDD process and supplier declaration."

Definitions used (page 116). "Local communities: Refers to communities affected by our operations, such as fisheries in the sense that we share the use of the ocean and the same areas where these communities are dependent on fisheries." "Affected communities: Refers to both Aker BP's local communities and the communities affected by our supply chain, such as communities in Norway and abroad where we have fabrication and commissioning work related to ongoing development projects."

Risk framing (page 117): "During periods of increased operational activity, such as those linked to the development and execution of major projects, we recognise that the risk of disturbance to local communities may be heightened. We apply our established formal consultation processes and maintain ongoing dialogue with stakeholders." No indigenous peoples policy is presented; the single material IRO concerns communities' economic, social and cultural rights (table 32, page 116).

Processes for engaging with affected communities about impacts

Reference: page 117 (section 9.1.1), page 44.

"Engaging with affected communities, through formal consultation and day-to-day dialogue, is essential to identify any actual and potential impacts, risks or opportunities concerning those communities, as well as to monitor compliance with the UN Guiding Principles in Business and Human Rights, the ILO Declaration on Fundamental Principles and Rights at Work, and the OECD Guidelines for Multinational Enterprises. It also provides insight into how different groups may be at greater risk of harm" (page 117).

Formal consultation (page 117): "Aker BP has a systematic process for engaging with affected communities, which is directly linked to and regulated by Norwegian legislation and government expectations. This process forms part of Aker BP's governance and business model and is continuously ongoing. During this process, we carefully adhere to the public consultation procedures to identify and consider impacts of significant activities. For instance, we are obliged to conduct public consultations of the environmental and societal impact assessments for any projects to be sanctioned. This approach provides affected communities, and others, an opportunity to discuss and address both positive and negative aspects of the company's plans... A senior role within the project to be under development is responsible for this process."

Scale is given at page 44: "every delivered plan for development and operation (PDO) includes an impact assessment, which ensures that more than 40 key stakeholders receive reports during public consultation processes... To maintain transparency, we publish the impact assessments on our website."

Day-to-day dialogue (page 117): "We use informal communication with affected communities daily to foster open dialogue and collaboration, addressing concerns and ensuring well-being. These efforts also help anticipate potential grievances. For example, we meet with local municipalities, politicians and other stakeholders in areas affected by high activity levels and ripple effects from our investments, focusing on Aker BP's project portfolio. The frequency of this type of engagement depends on the activities. The feedback we receive through continuous dialogue and follow-ups is used to achieve effective processes. A designated role within the company is responsible for ensuring that this engagement occurs."

Underlying context (page 117): "The oil and gas resources on the Norwegian continental shelf, where Aker BP operates, belong to the Norwegian society at large. Aker BP's role is to create value based on these resources." Suppliers are required "to maintain transparency in their interactions" with communities.

Processes to remediate negative impacts and channels for affected communities to raise concerns

Reference: page 117 (section 9.1.1.2), page 123 (section 10.2), page 47.

Aker BP's index maps S3-3 to section 9.1.1.2 (page 53).

Channel (page 117): "Moreover, Aker BP's integrity channel, which is available to all on our external website, serves as a platform for affected communities and individuals to raise their concerns. Through our website, code of conduct and sustainability statement, we provide information needed to ensure trust in the processes for raising concerns. For further details on the integrity channel, refer to section 10.2. To facilitate that our suppliers engage with affected communities, we require them to maintain transparency in their interactions, as outlined in our IDD process and supplier declaration."

How the channel works (page 123): it is "managed by an independent third party (KPMG), ensuring confidentiality and proper handling of reports in accordance with the applicable standards and the internal procedure for handling whistleblowing reports, which addresses topics such as confidentiality and data privacy". Reports may be made anonymously; the compliance department reviews all integrity reports and reports regularly to the EMT and ARC. A strict non-retaliation principle applies.

Statutory route alongside the company channel (pages 44, 47): "All petroleum-related activities on the NCS are subject to authority approval through an environmental permit consultation process. Stakeholders, local communities and interested parties are entitled to address environmental issues and provide recommendations to the authorities on our planned activities at a public hearing. This consultation process is of value for ensuring co-existence between industrial activities in the area."

Remediation commitment (page 99): the human rights policy commits the company to "have systems in place for raising concerns and provide appropriate remediation where we have caused or contributed to adverse impacts on human rights", with follow-ups aimed at ensuring the effectiveness of the remedy.

Outcome (page 117): "In 2025, as in 2024, we did not receive any reports of human rights issues or incidents affecting communities through our integrity channel." Aker BP does not report separately whether affected communities are aware of and trust the channel beyond the statement that information is provided through the website, code of conduct and this statement.

Taking action on material impacts on affected communities

Reference: page 117 (section 9.2), page 47.

Table 6 marks the SFDR datapoint "ESRS S3-4 Human rights issues and incidents paragraph 36" as material, located in section 9.3 (page 55).

2025 action (page 117): "In 2025, we continued to implement and follow up on the improvements made to our IDD process in 2024, with the ambition of better mitigating the risk of adverse impacts and poor stakeholder engagement by our tier 1 suppliers. As part of the IDD process, potential suppliers within certain thresholds are required to confirm that they have policies and procedures in place to avoid and manage adverse impacts on communities. Once contracted, suppliers must sign our supplier declaration, committing to responsible management of their operations, ongoing dialogue and consideration of local needs. The management of the IDD process is overseen by Aker BP's risk and sustainability team within the supply chain management department."

Monitoring and effectiveness (page 117): "Throughout 2025, we have continued monitoring the effectiveness of our policies and actions through supplier audits and regular engagement with affected communities. We also continue to require transparency from our suppliers in their interactions with local stakeholders and provide accessible channels for raising concerns. The effectiveness of these initiatives is assessed as part of our supplier audit programme." That programme delivered three on-site audits covering 160 workers in 2025 (page 114).

Prevention through project planning (pages 47-48, 91): impact assessments are mandatory before project sanction and go to public consultation, so "material impacts associated with major projects, such as the decommissioning of oil and gas installations, are evaluated in impact assessments that are available for public consultations with the affected stakeholders" (pages 47, 91). "Before starting new projects, Aker BP is required to submit an impact assessment which seeks to identify and minimise potential negative effects on the environment, and actual impacts are regularly monitored by the Norwegian Environment Agency" (page 48).

Positive contribution (page 38): operated development projects "are projected to contribute to approximately 150,000 full-time equivalents at Norwegian suppliers", alongside donations and sponsorships governed by a sponsorship policy (page 116). No monetary amounts are attached to community actions.

Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities

Reference: page 117 (section 9.3).

A nil return with a stated reason, followed by two nil incident metrics. "We believe that Aker BP is well-positioned to minimise the risk of adversely impacting affected communities, and to generate positive ripple effects where possible. We have not yet established defined and measurable targets in this area, as we have not identified any targets that are likely to result in changes for the affected communities" (page 117).

Metrics reported in place of targets (page 117):

• "In 2025, as in 2024, we did not receive any reports of human rights issues or incidents affecting communities through our integrity channel."
• "Further, we are not aware of any cases of non-respect of the UN Guiding Principles in Business and Human Rights, ILO Declaration on Fundamental Principles and Rights at Work or OECD Guidelines for Multinational Enterprises that involve affected communities by our own operations or in our upstream or downstream value chain."

Table 6 maps both the S3-1 "Non-respect of UNGPs on Business and Human Rights, ILO principles or OECD guidelines paragraph 17" and the S3-4 "Human rights issues and incidents paragraph 36" datapoints to section 9.3 (page 55), so these nil returns are the company's formal answer to the EU-legislation datapoints.

Effectiveness is otherwise tracked through the supplier audit programme and continuous engagement rather than against a target: "throughout 2025, we have continued monitoring the effectiveness of our policies and actions through supplier audits and regular engagement with affected communities. The effectiveness of these initiatives is assessed as part of our supplier audit programme" (page 117).

The single material IRO for this topic is a potential negative impact - "Impacts on affected communities... may have unintended negative impacts on people in affected communities. This is particularly relevant during new project phases when yard activity, vessel and road traffic, and temporary construction noise can cause disturbance" (table 32, page 116) - which is consistent with the absence of any realised incident to measure against.

Business conduct policies and corporate culture

Reference: pages 120-121 (section 10.1.1), pages 122-123 (section 10.2.1).

Aker BP's index maps G1-1 to sections 10.1 and 10.2 (page 53). Table 6 marks the G1-1 datapoints "United Nations Convention against Corruption paragraph 10(b)" (material, no location given) and "Protection of whistleblowers paragraph 10(d)" (material, section 10.1.3) (page 55).

Code of conduct (pages 120-121). "Our code of conduct is our main governance tool and is intended to be a source to help Aker BP representatives act in accordance with Aker BP's core values. It provides guidance for conducting our business ethically and transparently, in compliance with applicable rules and regulations related to anti-corruption, money laundering, fraud, modern slavery, human rights and labour standards, environment and other applicable rules. The code of conduct also includes a separate chapter on reporting of concerns and protection of whistleblowers." It is "owned by the CEO and approved by the BoD" and applies "to all employees and those acting for or on behalf of Aker BP".

Anti-corruption procedure (page 120): it "establishes a framework for preventing all forms of corruption and guidance for our employees and business partners on how to apply these principles in their work. As stated in our anti-corruption procedure, Aker BP prohibits all forms of corruption, including bribery."

2025 revisions (page 121): both documents were updated on the two-year review cycle. "The updates to the code of conduct included reinforcing our zero tolerance for all forms of corruption and clarifying guidelines related to conflicts of interest, confidentiality and data privacy, cyber security, responsible use of AI, and diversity, equality and inclusion. A new chapter was introduced outlining expectations for Aker BP employees serving in board positions on behalf of Aker BP." Internal guidelines on gifts and hospitality and conflicts of interest were also updated, and "a new compliance app was launched to simplify the registration and approval processes".

Corporate culture metric (pages 120, 122): "In 2025, 100 (93) percent of Aker BP's own workforce and 100 percent of the shareholder-elected board members completed the annual code of conduct refresher course", the 2025 rate being calculated on a population excluding workforce on sick leave or statutory leave and including completions during January of the following year.

Whistleblower protection (pages 122-123): an internal speaking up policy, owned by the CEO, "builds on a strict non-retaliation principle, ensuring that no retaliatory actions are taken against whistleblowers", supported by a documented procedure for handling whistleblowing reports.

Management of relationships with suppliers

Reference: page 124 (section 10.3), page 117.

Supply chain management policy (page 124). "It is applicable to all geographical areas where Aker BP operates... The policy affects various stakeholder groups, including suppliers, alliance partners, strategic partners and internal stakeholders." It "is approved and owned by the VP supply chain management and logistics and is reviewed once a year", available to the workforce through the business management system. "We monitor adherence to the principles of the policy through supplier engagement and audits."

Objectives (page 124): "to ensure that Aker BP's supply chain is efficient, ethical and capable of supporting the company's business goals through strategic partnerships, effective risk management and continuous improvement."

Alliances and segmentation (page 124): "Aker BP manages supplier relationships responsibly through alliances and strategic partnerships that drive long-term collaboration and mutual growth. These partnerships are integral to our operations and encompass most of our procurement activities... Our supplier relationship management framework ensures strong, resilient partnerships governed by clear standards for performance, integrity and sustainability, as well as compliance with anti-corruption and HSSEQ requirements." Beyond alliances, "we segment procurement activities into categories to optimise strategies and reduce costs. Potential suppliers are identified and evaluated based on criteria such as cost, quality and sustainability, with integrity due diligence as a key step to assess financial stability, operational capabilities and compliance with legal and ethical standards."

Supplier declaration (page 124): "All suppliers, except for those categorised as exempt, are required to sign a supplier declaration to ensure adherence to our requirements. Suppliers assessed to have low inherent and material risk to Aker BP are categorised as exceptions."

Communication (page 124): "Aker BP communicates the content of its business ethics policies to suppliers by referencing the company's code of conduct and anti-corruption procedure within contractual clauses. Additionally, we promote awareness of these standards through regular supplier follow-up meetings."

Scale and engagement: approximately 1,600 (1,600) tier 1 suppliers, and in 2025 "approximately 130 SRM meetings with 57 key strategic suppliers" (page 124). No payment-practice or SME-specific supplier considerations are disclosed here; G1-6 is marked not material (page 53).

Prevention and detection of corruption and bribery

Reference: pages 120-122 (sections 10.1.1 and 10.1.2), figures 42 and 43 (pages 121-122).

Risk assessment (page 121): "Each year, Aker BP conducts a compliance risk assessment, led by the compliance department in collaboration with key company functions (such as legal, finance, supply chain and projects). The compliance risk assessment aims to identify areas with the highest risk of non-compliance, including corruption and bribery." Result for the year: "The compliance risk assessment conducted in 2025 indicated that the key areas with potential exposure to the risk of bribery and corruption relate to project activities and interactions with third parties."

Separation of investigation from management (page 120): "Aker BP's compliance department oversees the risk of corruption and bribery and reports on a quarterly basis to the executive management team and the audit and risk committee. The investigation team operates separately from the management involved in the matter." The compliance function is the second line of assurance and internal audit the third, with internal audit reporting to the BoD through the ARC (pages 41-42).

Reporting mechanism (page 120): "All allegations or incidents of corruption and bribery shall be reported in accordance with the established processes for reporting of concerns and handled in line with the internal procedure for handling whistleblowing reports, applicable laws and regulations."

Training (pages 121-122). A compliance training plan "tailored for all levels within the organisation... Since certain positions are at higher risk, this customised plan ensures that all employees, including those in functions-at-risk, receive training to help them manage the risks they encounter." All new employees and non-employees complete mandatory ethics and compliance onboarding; the workforce, EMT and BoD take an annual code of conduct refresher. "In 2025, the compliance department delivered ten compliance training sessions to various business units, focusing on the topics of conflicts of interest, gifts and hospitality, whistleblowing and business ethics", distributed as four for supply chain management, two for projects, and one each for the asset organisation, digital, operations, finance and exploration and reservoir development. Figure 43 maps training requirements to audience groups.

Verification (page 122): "the compliance department carried out several verification activities... These activities comprised compliance audits of five recruitment agencies in Norway, one supplier in Norway and one supplier located outside Norway. All audit findings are registered internally and are being followed up with the respective suppliers."

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

Reference: page 122 (section 10.1.3), page 123 (section 10.2.3), page 124 (section 10.3.3).

Aker BP's FY2025 statement was prepared under the 2023 ESRS, where business conduct targets fell under MDR-T rather than a numbered G1 targets disclosure. The company gives an explicit nil return on formal targets across all three G1 sub-topics, and describes what it tracks instead.

Business ethics and corruption (page 122): "We have not set any time-bound outcome-oriented targets for business ethics and corporate culture, including corruption and bribery. However, we have two ambitions. Firstly, we aim to maintain zero incidents of corruption, in compliance with Norwegian anti-corruption legislation. In 2025, there were no reported incidents of corruption, and no convictions or fines for violation of anti-corruption and anti-bribery laws (zero incidents in 2024). Secondly, we aim for all employees to complete the annual code of conduct refresher course. In 2025, 100 (93) percent of Aker BP's own workforce and 100 percent of the shareholder-elected board members completed the course."

Whistleblower protection (page 123): "We have not set any time-bound outcome-oriented targets for speaking up and protection of whistleblowers. However, the compliance department carefully evaluates the integrity reports that we receive. 13 (21) whistleblowing cases were received via the integrity channel and via reports directly to the compliance department in 2025." Effectiveness is tracked through a 2025 dashboard covering "internal KPIs, including handling time and follow-up of whistleblowing cases", and "we regularly conduct evaluations of the effectiveness of our integrity channel".

Supplier relationships (page 124): "Aker BP has not set any time-bound, outcome-oriented targets for the management of supplier relationships. We do not have any procedures for measuring the effectiveness of our policies and actions. However, we have set an ambition of achieving at least an 80 percent response rate for environmental performance data requests from our 26 most relevant suppliers regarding environmental impact. These requests, issued through the CDP Supply Chain module, address questions regarding climate change and biodiversity. In 2025, we received 23 responses, corresponding to a response rate of 88 percent (same response rate as in 2024)."

Also tracked: approximately 130 supplier relationship management meetings with 57 key strategic suppliers in 2025 (page 124).

Incidents of corruption or bribery

Reference: page 122 (section 10.1.3).

A nil return for both years. "We aim to maintain zero incidents of corruption, in compliance with Norwegian anti-corruption legislation. In 2025, there were no reported incidents of corruption, and no convictions or fines for violation of anti-corruption and anti-bribery laws (zero incidents in 2024)" (page 122).

Table 6 confirms the treatment of the two EU-legislation datapoints (page 55): "ESRS G1-4 Fines for violation of anti-corruption and anti-bribery laws paragraph 24(a)" is marked material and located in section 10.1.3; "ESRS G1-4 Standards of anti-corruption and antibribery paragraph 24(b)" is marked material with location "NA".

Related detection data (page 123, figure 44): 13 (21) whistleblowing cases were received in 2025, categorised as employee relations 9 (12), safety and security 2 (1), inquiries and other 2 (1), business integrity 0 (5) and supply chain and business partners 0 (2). The absence of business integrity cases in 2025 is consistent with the zero corruption incidents reported. All integrity reports are reviewed by the compliance department, with the investigation team operating "separately from the management involved in the matter" (pages 120, 123).

Verification activity in the year (page 122): compliance audits of five recruitment agencies in Norway, one Norwegian supplier and one supplier outside Norway; "all audit findings are registered internally and are being followed up with the respective suppliers". Those findings are not characterised as corruption incidents.

"None of the metrics reported on in this chapter have been validated by an external body" (page 122). No breakdown by number of convictions, amount of fines, or number of confirmed incidents in which employees were dismissed or contracts with business partners terminated is given beyond the zero figures; a nil return leaves nothing to disaggregate.