Aker Horizons

Administrative, Management and Supervisory Bodies

Aker Horizons ASA's Board of Directors (the "Board"), the highest governance body, is responsible for overseeing and safeguarding management of the sustainability work. The Board has five board members, of which none hold executive positions within or are employed with the Company. Two board members are independent (40 percent), and there are three male and two female members of the Board. The average ratio of female to male board members in 2024 has been 45 percent. The Executive Management of Aker Horizons consists of the CEO and the CFO, both male.

The Board has oversight responsibility of the management of the Company. It follows from the mandate that the Board shall approve the overall strategy and the financial and sustainability targets for the Company, and is responsible for approving the sustainability policy, the statutory reporting including the Sustainability Statement, as well as climate-related financial disclosures. The Board approves the double materiality assessment, hereunder the material impacts, risks and opportunities. The Sustainability Statement governs environmental, social and governance aspects of Aker Horizons' own performance, investment decisions, as well as the role as an owner of portfolio companies. Sustainability-related risks and opportunities are an integral aspect of evaluating potential new investments for the Group's portfolio and the Board considers whether they are within Aker Horizons' mandate.

Board of Directors' activities

The Board follows an annual plan for its work, which includes recurring key topics such as reviews of the company' strategy and portfolio companies, follow-up of risk and compliance, financial reporting, and budget review. The Board annually evaluates its own performance and collective expertise. Aker Horizons' Board of Directors held seven meetings in 2024, and its Audit Committee met six times. Board meeting attendance averaged 89 percent.

Audit Committee

The Audit Committee shall support the Board in oversight over the management and safeguarding of the Company's resources. It is a requirement under the mandate of the Audit Committee that it has the necessary competence within relevant areas of the Committee's work to perform its duties in a satisfactory manner, including audit, accounting and environmental, social and corporate governance experience. The Committee shall review the Company's financial and sustainability reporting, and hereunder focus on sustainability reporting and practices, policies, commitments and targets, as well as impacts, risks and opportunities.

Information provided to and sustainability matters addressed by the Board

During the reporting period, the Audit Committee and the Board have been informed about sustainability matters on a quarterly basis, including approving the sustainability reporting and Transparency Act Report in the Annual Report for 2023, the CSRD implementation project and the timeline for the project. In all meetings in 2024, the Audit Committee has been updated on status of the CSRD implementation. Further, the Board has approved the double materiality assessment and material impacts, risks and opportunities. The Audit Committee and the Board were also informed about human rights assessments, compliance audits, whistleblowing cases and other sustainability related issues on a quarterly basis.

Enterprise Risk Management

Aker Horizons has an Enterprise Risk Management ("ERM") procedure which sets out the requirements and systematic steps to assess and manage risk in Aker Horizons and its portfolio companies. The risk reporting activities shall be aligned with quarterly financial and non-financial (legal and compliance, and environment, social and governance ("ESG")) reporting cycles and annual risk management reviews both in the Audit Committee and the Board. Aker Horizons' management performs quarterly enterprise risk assessments, in which climate-related risks and opportunities are integrated. Contributors to the quarterly risk review include functions within compliance, investments, legal, treasury, sustainability and finance for the Group. Aker Horizons' management assesses on a quarterly basis the likelihood of the occurrence and impact of risks identified as part of the ERM process. The Board has overall responsibility for risk management, the CEO reports to the Board on the overall assessment of risk, new or significant changes in risk exposure and how risks are addressed.

Board and Committee Competence

The Board, the Audit Committee and the Management have relevant experience for the sectors in which the Group operates, the business of the Group and the geographic locations, as well as experience on sustainability matters from both Aker Horizons and other relevant positions. The Board members cover a broad range of expertise relevant to the Company's and portfolio's operations. With backgrounds in industrial development, data, technology and finance, the Board members have experience from board positions in and management of global companies. All members also have experience with sustainability work and sustainability reporting through board positions in other companies. The governing bodies also have access to expertise, both in relation to experts within the Group, the auditors and other relevant experts when required.

Integration of sustainability-related performance in incentive schemes

ESRS 2 GOV-3 is disclosed on page 16 of the sustainability statement.

No substantive information is provided about the integration of sustainability-related performance in incentive schemes. The disclosure appears limited to a page reference in the index table, but the excerpts provided do not contain the actual content from page 16 describing:

• Which roles are covered by sustainability-linked incentives
• Specific sustainability KPIs tied to remuneration
• Weighting of sustainability metrics in STI or LTI
• Performance periods or target structures
• Threshold/target/maximum performance definitions
• Actual payouts against sustainability KPIs in the reporting period

The document index on page 40 confirms that ESRS 2 GOV-3 "Integration of sustainability-related performance in incentive schemes" is addressed on page 16, but this page content is not included in the provided excerpts.

Sustainability due diligence

Aker Horizons continues to build on previous years' progress to improve its understanding of human rights risks through training, implementation of internal processes, and interaction with suppliers and business partners, including reviews, due diligence processes and audits. Human rights risks continue to be a complex area for most companies operating in the energy sector, in particular where large energy projects are being constructed. Some risks of adverse human rights impacts can be significantly reduced through the development and implementation of internal procedures and processes. Others are more profoundly challenging, particularly where such risks are inherent in the nature of current global value chains in the green transition – such as the need for metals and minerals, and the current concentration of the production of input factors in challenging geographies. Efforts have been made to mitigate these risks by enhancing policies and procedures across the Aker Horizons Group. This includes the Business Partner Code of Conduct and Integrity Due Diligence, as well as group-wide human rights training.

Risk management and internal controls over sustainability reporting

In 2024, the focus has been on implementing a process for assessing double materiality for the Group, as well as preparing the Group's first sustainability report in accordance with CSRD. Going forward, it is planned to introduce an internal control system for sustainability reporting. This will include processes for updating the Group's materiality assessment and controls for material topics. The framework will follow the principles of financial reporting, with risks prioritized based on the likelihood of errors and consequences. Furthermore, incorporating findings into relevant functions and processes will enable better follow-up across consolidated entities and departments within the Group, such as sustainability, finance, and legal departments.

In 2024, the following risks have been assessed, with corresponding measures:

Completeness and accuracy in mapping material topics: The double materiality assessment is based on reporting from consolidated entities. Therefore, there is a risk that the Group does not get a complete picture of material topics in its own operations and in the value chain. The risk is managed through ongoing dialogue with the relevant entities. The purpose is to understand the portfolio companies' process for assessing material topics, obtain relevant decision-making basis, and, where applicable, communicate with the auditors of consolidated entities and other portfolio companies. CSRD is still in the implementation phase, and going forward a more formalized process for completeness and accuracy in materiality assessments is expected.

Completeness and accuracy related to data: There is a risk of lack of completeness and accuracy in data reporting from consolidated entities. The risk is managed through, among other things, standardized instructions for reporting, implementation of reporting tools for data collection, description of principles in line with the data points in ESRS, ongoing dialogue with portfolio companies about reporting requirements, and review and analysis of reported data and parameters.

The Company expects to report annually to the Audit Committee on identified risks within the Group and the internal control framework for sustainability reporting.

Strategy and business model

Aker Horizons Group develops green energy and green industry to accelerate the transition to net zero emissions. As an active owner, Aker Horizons develops and strengthens its portfolio companies by driving strategy development, financing, restructuring and transactions. Aker Horizons leverages the significant industrial, financial and technological capabilities of the Aker Group to identify and develop opportunities. Each portfolio company of the Group works to maximize value individually, with separate management teams and boards, but with strong, continuous support from Aker Horizons ASA. This support ensures that activities are optimized across the entire value chain and capitalize on internal expertise in the broader Aker group.

Value chain

The Aker Horizons Group's value chain can be separated into upstream, internal, and downstream value chain. When assessing significant impacts, risks, and opportunities, the value chains of the Group have been mapped in dialogue with the largest companies in the Group. The purpose has been to uncover which significant topics are important across the portfolio of Aker Horizons Group.

For the investment activities of Aker Horizons, the upstream activities focus on acquiring the necessary capital and resources to fund investments. The main source of funding is dividends, proceeds from sale of assets and external financing from banks and bond market. The upstream activities related to consolidated entities include a focus on input factors as for example raw materials, waste, energy, workers in the value chain and affected communities.

The internal activities in Aker Horizons focus on activities related to the investments, as managing and optimizing the investment portfolio through investment management, risk management and operational activities. The internal activities where consolidated entities are concerned, also include for example construction work. The downstream activities involve managing the relationships and communication with shareholders and ensuring effective distribution of returns which includes dividend distribution, shareholder communication, exit strategies and financial reporting.

The activities of the Group are assessed including the main activities of Mainstream as a consolidated entity in the Aker Horizons Group. Upstream activities for Mainstream typically begins in development, at the initial greenfield field phase of a project, where Mainstream works with financial stakeholders, landowners, affected communities, and site designers to evaluate the financial, social, and environmental feasibility of a given renewable project as upstream activities. As a project develops through the Environmental Impact Assessment stage, Mainstream will assess the likely impacts in areas such as environment and biodiversity, in order to ensure the project meets both the relevant international and local standards, before an investment decision is made.

After the development phase, successful projects move into pre-construction which involves engineering and procurement before moving into the construction phase and EPC management followed by commissioning. Once commissioned, the project moves into the operations where the operations and maintenance team take over for the lifetime of the assets, as part of the internal activities. Downstream activities involve dividend distribution to owners, communication with communities and other stakeholders, and activities related to consumption of product and services, e.g. sale of generated power through power purchase agreements. Finally, at the end of the assets' useful life, a project enters either decommission or re-powering, where renewable assets are upgraded or replaced to extend a project's life.

Interest and views of stakeholders

Ongoing stakeholder engagement helps clarify stakeholders' expectations and priorities. This dialogue is essential to the Group companies' due diligence and the process for identifying and assessing the Group's impacts, risks and opportunities ("IROs"). The management and the Board are informed about views and interests of affected stakeholders with regard to sustainability-related impacts, as part of the oversight of IROs.

The Group's stakeholder dialogue includes, but are not limited to, affected stakeholders such as employees, contractors, business partners, and subcontractors, as well as other users of information, including shareholders, banks, and analysts.

Material impacts, risks and opportunities

The materiality assessment identified that the following topical standards (ESRS') within environmental, social, and governance represent material impacts, risks, and opportunities across the Group's own operations and value chain:

• E1 Climate change
• E4 Biodiversity and ecosystems
• E5 Resource use and circular economy
• S1 Own workforce
• S2 Workers in the value chain
• S3 Affected communities
• G1 Business conduct

The topical ESRS' E2 Pollution, E3 Water and Marine Resources and S4 Consumers and End-Users are not assessed as material for Aker Horizons Group.

Material impacts, risks and opportunities by topic

E1 Climate change

• Climate change mitigation: GHG emissions from construction - Actual negative impact, short to long term (Upstream value chain, Own operations)
• Climate change mitigation: GHG emissions: Renewable energy production - Actual and potential positive impacts, long term (Downstream value chain)
• Climate change mitigation: Transition risk - Financial risk, short to long term (Upstream value chain)
• Climate change mitigation: Transition opportunity - Financial opportunity, short to long term (Upstream value chain)

E4 Biodiversity and ecosystems

• Impacts on the state of species - Potential negative impact, medium term (Own operations, Upstream value chain)

E5 Resource use and circular economy

• Resources inflows, including resource use - Actual negative impact (Own operations)

S1 Own workforce

• Working condition/Secure employment, and working time - Actual and potential negative impact, financial risk, short term (Own operations)

S2 Workers in the value chain

• Working condition/Health and safety - Potential negative impact, short to medium term (Upstream value chain)
• Other work-related rights/Forced labour - Potential negative impact, short to medium term (Upstream value chain)

S3 Affected communities

• Communities' economic, social and cultural rights: Land-related impacts - Potential negative impact, short to medium term (Downstream value chain)
• Rights of indigenous people/Cultural rights - Actual negative impact and financial risk, short term (Own operations, Upstream value chain)

G1 Business conduct

• Corruption and bribery - Potential negative impact, medium term (Upstream value chain)

Interaction with strategy and business model

Aker Horizons' overall business and strategy are founded on a commitment to accelerate the transition to net zero emissions by developing green energy and green industry. Aker Horizons' strategy is shaped as a response to climate-related risks and opportunities. As an active owner, Aker Horizons engages with its portfolio companies to ensure that the greenhouse gas ("GHG") emissions are calculated and reported and has encouraged the companies to set GHG emission reduction ambitions.

As the commercial opportunities are created by climate action, Aker Horizons investments are currently placed within areas such as onshore wind and solar power, poised to benefit from increased climate action. To realize projects and opportunities, Aker Horizons aims to create robust business entities and establish good models for partnerships and alliances. Aker Horizons aims to foster the expansion of solutions within renewables and decarbonization of industry, through mergers and acquisitions as well as organic growth and project development.

Disclosures on the materiality assessment process

Aker Horizons has performed a double materiality assessment ("DMA") to identify impacts, risks and opportunities ("IROs") in the company's own operations and its value chain.

Aker Horizons has performed a full DMA in accordance with the CSRD, applying the process recommended under the CSRD using the steps described in the next paragraphs. Sustainability aspects with a high likelihood of negative impact were prioritized throughout the process, especially in geographical areas and among business partners that are crucial for the company's operations and value chain. Both direct impacts from the companies' activities and broader impacts arising through the business partners were assessed. This approach expanded the scope of the materiality assessment and enabled a more detailed analysis of impacts and relationships across the companies' value chain. Although the materiality assessment was conducted as a separate process, it contributed to the prioritization of risks. Regular updates of the risk register provide management with a basis for managing and prioritizing risks and opportunities in line with the company's strategy and risk profile. This strengthens a holistic approach to risk management.

The reporting year 2024 represents the first reporting cycle in which a full double materiality assessment is performed in accordance with the CSRD, and as such there are no changes in conclusions about material topics or other changes compared to previous years. In the future, the materiality assessment will be updated and reviewed on an annual basis in order to maintain a continuous improvement and relevance.

Step A: Understanding the context in which Aker Horizons operates

In this step, the Group's activities were analyzed, discussed and described, including business model, stakeholders and value chain. An overview of the strategy, activities, business model, value chain, business relationships and the main stakeholders provided important inputs to identify the IROs, and the basis for the content of this Sustainability Statement. The previous DMA's of both Aker Horizons ASA and Mainstream have also, as well as previous sustainability reports, due diligence reports and human rights risk assessments.

Step B: Identification of the actual and potential IROs related to sustainability matters

In this step, the actual and potential IROs relating to environmental, social and governance matters across the own operations and the upstream and downstream value chain were identified. Aker Horizons discussed the actual and potential IROs in several 1-1 meetings with internal stakeholders and portfolio companies, to conclude on a long list of possible matters as well as consider connections of impacts and dependencies with risks and opportunities. Further, Aker Horizons analyzed sustainability matters identified by peers.

Step C: Assessment and determination of material IROs related to sustainability matters

In this step, the identified IROs were analyzed and scored, and criteria was applied in order to determine the material actual and potential impacts, and the material risks and opportunities, based on affected stakeholders either related to people or the environment. The criteria were severity (scale, scope and irremediability character) of the impact for actual negative impacts, while for potential negative impacts, the likelihood of the impact occurring, and the relevant time horizon were also assessed. For actual positive impacts, the criteria were scale and scope, and for potential positive impacts, the likelihood of occurrence and relevant time horizon were also assessed. If an impact includes a potential negative human rights impact, the severity of the impact is prioritized over its likelihood. Financial risks and opportunities were assessed based on likelihood of occurrence and the potential magnitude of the financial effects in the short-, medium- and long-term. Connections of impacts and dependencies with risks and opportunities were considered, as well as potential integration with the risk register of Aker Horizons.

The assessment was discussed in 1-1 meetings with relevant internal stakeholders, including management. Aker Horizons did not perform a review with external stakeholders but have considered the outcome from previous processes and stakeholder engagement.

Sustainability matters were considered material if at least one impact, risk, or opportunity exceeds the threshold value set by the company. This indicates either materiality for impacts, financial materiality, or both. Sustainability aspects without identified impacts, risks, or opportunities, and/or where all assessments are below the threshold value, are considered non-material sustainability aspects.

Representatives from the Group companies participated in the process. Each sustainability matter was assessed for significant impacts, risks, and opportunities, in line with documented guidelines and methodology. The process included a structured review and validation by the representatives and the Audit Committee to support quality and traceability in the final decision-making basis.

The result of this assessment serves as the foundation for the further content of the Sustainability Statement.

Process descriptions for specific topics

E1.IRO-1 Climate-related impacts, risks and opportunities

To identify climate related impacts, risks and opportunities, both the Group and also the subsidiary Mainstream Renewable Power has previously performed a climate-related assessment and reported in accordance with the TCFD framework (Task Force on Climate-related Financial Disclosures). Mainstream Renewable Power conducted a portfolio risk assessment across all assets in 2023, which included both assessments of physical and transition risks, as well as biodiversity impact risks. The risk assessment showed that Mainstream's portfolio was robust and had an overall low level of climate-related risk. The scenarios used to assess physical risks were: IPCC SSP2-4.5 (medium-emission scenario) and SSP5-8.5 (high-emission scenario), while the scenarios used to assess transition risks were: NDC (Nationally determined contribution), and net zero 2050 (Orderly). Mainstream used the AXA Climate Altitude database to conduct climate risk assessments of projects and to consider both individual project risks as well as cumulative risks across the portfolio.

E2.IRO-1, E3.IRO-1 Pollution and water resources

For pollution, water, and marine resources, the Group's impacts, risks, and opportunities were assessed. An overall screening of the Group's own operations and value chain was conducted. This included a general mapping of exposure, a review of available data from the companies, and the use of third-party sources where relevant. No dialogue was initiated with affected local communities, as the Group does not consider that any specific communities are more affected than others.

E4.IRO-1 Biodiversity and ecosystems

Material impacts, risks, dependencies, and opportunities related to biodiversity have been assessed across the Group's own operations and value chain. Actual and potential impacts on biodiversity and ecosystems have been considered, in particular related to Mainstream's operations as the companies with the longest history of operations in the Group. Dependencies were also assessed, but none was identified. Systemic risks, including cumulative impacts from industrial activity on regional ecosystems, were also assessed by relevant consolidated entities. No dialogue was initiated with affected local communities as part of the materiality assessment, as the Group does not consider that certain local communities are more affected than others.

E5.IRO-1 Resource use and circular economy

When assessing the potential material matters related to resource use and circular economy-related impacts, risks and opportunities, Aker Horizons has considered activities, geographies and business relationships in several 1-1 meetings with stakeholders and management. Previous materiality assessments, climate risk analyses and assessments are also considered. The assessment is performed in close dialogue with the portfolio companies, and operations and construction activities related to the asset types onshore wind and solar in Mainstream Renewable Power are considered most relevant for this area. Aker Horizons has not found it relevant to conduct consultations with affected communities for this area.

G1.IRO-1 Business conduct

When assessing the potential material matters related to business conduct-related impacts, risks and opportunities, Aker Horizons has considered activities, geographies and business relationships in several 1-1 meetings with stakeholders and management. Previous materiality assessments and assessments are also considered. The assessment has also included input from the risk management system and internal reporting of compliance-related matters to the Audit Committee and the Board. The purpose was to map geographical areas, activities, and/or sectors with increased potential impacts or risks related to corruption and bribery, as well as human rights violations. There have also been reviews and interviews with key internal functions.

The result of this assessment serves as the foundation for the further content of the Sustainability Statement. At the end, a content index with an overview of the disclosure requirements complied with in the Sustainability Statement is included, together with a reference to where the disclosures are located. A table of data points deriving from other EU legislation is also included.

Transition plan for climate change mitigation

Status of transition plan adoption

Aker Horizons has not yet adopted a transition plan for climate change mitigation and has not set a date for adoption of a transition plan.

Material climate-related impacts, risks and opportunities

The double materiality assessment for Aker Horizons has identified the following material climate-related impacts:

• Actual negative impact from GHG emissions mainly from construction of solar and wind plants in the upstream value chain, and in a smaller extent from office activities and travels.
• Actual and potential positive impacts from renewable energy production, leading to less GHG emissions by replacing fossil-based energy production with new renewable capacity in the downstream value chain.

Policies related to climate change

The policies and governance structures relevant for climate-related matters are the following:

• Sustainability policy: Governing environmental aspects.
• The Code of Conduct: Describing Aker Horizons' commitments and requirements regarding ethical business practices, also relating to sustainability.
• Enterprise risk management ("ERM") procedure: Lays out the requirements and systematic steps to assess and manage risk in Aker Horizons' operations and its portfolio companies.

The Sustainability Policy sets out that Aker Horizons shall contribute to a climate positive environment by working to commercialize and scale climate solutions and contributing to the creation of new industries and green jobs. The scope of the policy is Aker Horizons' own performance, investment decisions and Aker Horizons' role as an owner of companies. The policy also sets the environmental expectations for portfolio companies, throughout all supply chains and for other relevant stakeholders.

The following framework are core to the sustainability policy:

• EU's Sustainable Finance package, including the EU Taxonomy regulation and the Corporate Sustainability Reporting Directive
• The UN Sustainable Developments Goals and UN Global Compact SDG implementation framework
• The OECD Guidelines for Multinational Enterprises
• The UN Global Compact. Since 2021 Aker Horizons has been committed to the UN Global Compact corporate responsibility initiative and its principles in the area of the environment.
• The Norwegian Code of Practice for Corporate Governance ("NUES") and the Norwegian Transparency Act

The Code applies to employees, officers and directors in Aker Horizons, and to entities and their personnel where Aker Horizons controls 90 percent or more of the shares and votes.

Actions and resources in relation to climate change policies

In the ERM procedure, climate risk is included in two of the main categories, strategic and market risk (transition risk), and project and operational risk (physical risk). Aker Horizons expects its portfolio companies to identify and manage both physical as well as transitional climate-related risks as part of their core business procedures.

The quarterly risk review involves reviewing changes in estimated impact or probability of previously identified risks, newly identified risks, including an estimate of impact and probability, and proposed mitigating actions, progress of mitigating actions taken, how they have affected the risk assessment and, where applicable, additional mitigating actions. Thus, the ERM process is used to evaluate strategies to mitigate risk at the management and board level, including climate-risks to the extent they are considered critical enough to be included in the short-list.

In addition to Aker Horizons' procedure for enterprise risk management, the portfolio companies have individual processes for managing climate-related risks. Management of project and operational risk, including physical climate-related risk affecting projects and operations, lies primarily with the portfolio companies. Nevertheless, Aker Horizons monitors and follows up risk through regular dialogue with the managements of the portfolio companies and through participation on their boards.

Aker Horizons currently has no other mitigating actions to reduce climate risks. The Group has four persons involved with compliance and ESG matters, one of which is primarily responsible for follow up on sustainability including climate reporting.

Targets related to climate change

Aker Horizons' impact on climate change is primarily driven by its investments and varies with the portfolio composition. The impact from own operations for Aker Horizons as an owner of companies is limited. Thus, setting climate-related targets for Aker Horizons or the broader portfolio has not been deemed appropriate.

Independently, the Group companies have yet to set targets in line with CSRD requirements, and Aker Horizons has not established specific targets to track identified material IROs.

As a developer of green projects, Aker Horizons and portfolio companies also aim to minimize the footprint of their own operations. The business of the Group includes investments in companies that can meaningfully reduce CO2 emissions, however the development of such projects may also lead to increased GHG-emissions during construction. The Group shall contribute to a climate positive environment by working to commercialize and scale climate solutions and contributing to the creation of new industries and green jobs.

Climate-related policies

The most relevant policies and procedures related to governance of climate-related matters are the following:

• Sustainability policy: Governing environmental aspects. • The Code of Conduct: Describing Aker Horizons' commitments and requirements regarding ethical business practices, also relating to sustainability. • Enterprise risk management ("ERM") procedure: Lays out the requirements and systematic steps to assess and manage risk in Aker Horizons' operations and its portfolio companies.

The Sustainability Policy sets out that Aker Horizons shall contribute to a climate positive environment by working to commercialize and scale climate solutions and contributing to the creation of new industries and green jobs. The scope of the policy is Aker Horizons' own performance, investment decisions and Aker Horizons' role as an owner of companies. The policy also sets the environmental expectations for portfolio companies, throughout all supply chains and for other relevant stakeholders. The following framework are core to the sustainability policy:

• EU's Sustainable Finance package, including the EU Taxonomy regulation and the Corporate Sustainability Reporting Directive • The UN Sustainable Developments Goals and UN Global Compact SDG implementation framework • The OECD Guidelines for Multinational Enterprises • The UN Global Compact. Since 2021 Aker Horizons has been committed to the UN Global Compact corporate responsibility initiative and its principles in the area of the environment. • The Norwegian Code of Practice for Corporate Governance ("NUES") and the Norwegian Transparency Act

The policy is relevant for all material IROs identified in the DMA process. The policy is owned by the sustainability director, reviewed by the CEO, approved by the Board of Directors and available on Aker Horizons' website.

The Code of Conduct outlines the values and principles guiding how to work, ensuring that Aker Horizons and its portfolio companies adhere to standards of integrity, transparency and sustainability. In relation to climate issues, the Code outlines that Aker Horizons shall act responsibly with an ambition to reduce direct and indirect negative influences on the external environment, adhere to relevant international and local laws and standards, strive to minimize the environmental impact and take a sustainable approach in the day to day operations. The Code is relevant for IROs related to climate change, social and business conduct. The Code applies to employees, officers and directors in Aker Horizons, and to entities and their personnel where Aker Horizons controls 90 percent or more of the shares and votes. It also applies to intermediaries, consultants and others acting on behalf of the Group. Aker Horizons also expects that all companies that are consolidated for accounting purposes implement their own Codes of Conduct that adequately address the principles in the Code of Conduct, and both Mainstream and ACC have corresponding policies The Code of Conduct of Aker Horizons ASA is prepared by the General Counsel, owned by the CEO, approved by the Board of Directors and available on Aker Horizons website, and the same applies for Mainstream and ACC.

The ERM procedure as described in section 1.2 Governance has, related to sustainability, the purpose of reducing unwanted risks impacting compliance with sustainability standards and reputation. In the ERM process, transition risk shall be reflected in strategic and market risk, while physical risk shall be assessed as part of project and operational risk. The ERM procedure is owned by the Director of Corporate Development and Business Excellence and approved by the CEO.

Actions and resources in relation to climate change policies

In the ERM procedure, climate risk is included in two of the main categories, strategic and market risk (transition risk), and project and operational risk (physical risk). Aker Horizons expects its portfolio companies to identify and manage both physical as well as transitional climate-related risks as part of their core business procedures.

The quarterly risk review as described in section 1.2 Governance involves reviewing changes in estimated impact or probability of previously identified risks, newly identified risks, including an estimate of impact and probability, and proposed mitigating actions, progress of mitigating actions taken, how they have affected the risk assessment and, where applicable, additional mitigating actions. Thus, the ERM process is used to evaluate strategies to mitigate risk at the management and board level, including climate-risks to the extent they are considered critical enough to be included in the short-list.

In addition to Aker Horizons' procedure for enterprise risk management, the portfolio companies have individual processes for managing climate-related risks. Management of project and operational risk, including physical climate-related risk affecting projects and operations, lies primarily with the portfolio companies. Nevertheless, Aker Horizons monitors and follows up risk through regular dialogue with the managements of the portfolio companies and through participation on their boards. Aker Horizons currently has no other mitigating actions to reduce climate risks. The Group has four persons involved with compliance and ESG matters, one of which is primarily responsible for follow up on sustainability including climate reporting.

Metrics and targets

Aker Horizons' impact on climate change is primarily driven by its investments and varies with the portfolio composition. The impact from own operations for Aker Horizons as an owner of companies is limited. Thus, setting climate-related targets for Aker Horizons or the broader portfolio has not been deemed appropriate. Independently, the Group companies have yet to set targets in line with CSRD requirements, and Aker Horizons has not established specific targets to track identified material IROs. As a developer of green projects, Aker Horizons and portfolio companies also aim to minimize the footprint of their own operations. The business of the Group includes investments in companies that can meaningfully reduce CO2 emissions, however the development of such projects may also lead to increased GHG-emissions during construction. The Group shall contribute to a climate positive environment by working to commercialize and scale climate solutions and contributing to the creation of new industries and green jobs.

Energy consumption and mix

Scope 1 and Scope 2 GHG emissions (energy-related)

Aker Horizons has applied phase-in provisions under ESRS 1.137 appendix C, omitting Scope 3 and total emissions disclosures for undertakings with less than 750 employees.

The majority of Scope 1 and 2 emissions take place in Mainstream's operations, including consumption of diesel and petrol. Scope 2 emissions relating to electricity are calculated using both location-based and market-based emission factors.

Methodology and scope: GHG emissions data is collected through a combination of direct measurements, internal reporting systems, external data sources, and estimates for some smaller office locations late in the year (estimates account for less than 1% of total Scope 2). Operational data from facilities, energy usage records, and emissions factors from recognized databases such as DEFRA are relied on. Emissions factors are used to recalculate consumption data into CO₂ emissions in accordance with the GHG Protocol.

Energy consumption and mix disclosure: No disaggregated energy consumption data (fossil fuels, nuclear, renewable energy by source, total energy consumption in MWh/GWh/TJ) is disclosed in the Sustainability Statement. The company has not reported energy consumption metrics under ESRS E1-7 (formerly E1-5) for the 2024 reporting period.

The company states it aims to minimize the footprint of its own operations and that the business includes investments in companies that can meaningfully reduce CO₂ emissions. However, quantitative energy consumption and mix metrics are not provided.

Gross Scopes 1, 2, 3 and Total GHG emissions

Aker Horizons has applied the phase-in provisions available under ESRS 1.137 appendix C for companies with less than 750 employees. As a result, the company has omitted Scope 3 and Total GHG emissions disclosures for the first year of reporting under CSRD.

Scope 1 GHG Emissions

Scope 2 GHG Emissions

Scope 3 GHG Emissions

Not disclosed (phase-in provision applied).

Total GHG Emissions

Not disclosed (phase-in provision applied).

GHG Intensity

Not disclosed.

Methodology and Scope

Aker Horizons' reporting on direct and indirect GHG emissions is done in accordance with the GHG Protocol. The majority of Scope 1 and 2 emissions take place in Mainstream's operations, including consumption of diesel and petrol. Scope 2 emissions relating to electricity are calculated using both location-based and market-based emission factors.

Mainstream's GHG emissions data is collected through a combination of direct measurements, internal reporting systems, external data sources, and estimates for some smaller office locations late in the year. The estimates account for less than 1 percent of total Scope 2 emissions. For Scope 1 and Scope 2 emissions, operational data from the facilities, energy usage records, and emissions factors from recognized databases such as the Department for Environment Food and Rural Affairs (DEFRA) are relied on.

No comparative information for prior years is presented, in accordance with ESRS 1.136 transitional provision for first-time CSRD reporting.

Anticipated financial effects from material physical and transition risks and potential climate-related opportunities

Use of phase-in provisions

Aker Horizons has applied the phase-in provisions available for companies not exceeding an average of 750 FTEs for the first year of reporting under CSRD. This applies to the E1 Climate Change standard.

As stated in the consolidated financial statements index:

The phase-in provisions are referenced in the document: "In accordance with ESRS 1.137 appendix C, Aker Horizons has applied phase-in provisions for certain eligible disclosures available for companies not exceeding an average of 750 FTEs for the first year of reporting under CSRD. This applies to the standards E1 Climate change."

Specific assets / business lines flagged for transition risk

The Group has identified specific transition risks related to affected communities in the context of land-related impacts and cultural rights of indigenous people:

Chile projects: Issues have been related to concerns such as archaeological heritage impacts and land claims. These issues have led to increased costs, and there is a risk for similar issues in future projects even if international guidelines for project development are followed, including the principle of Free, Prior and Informed Consent (FPIC).

Financial risk relating to cultural rights of indigenous people: The issues related to indigenous people for some of the development projects in Chile have led to increased costs, and there is a risk for similar issues in future projects. This inherent financial risk is considered to be present both in the value chain and in own operations, on a short term basis.

Workers in the value chain - transition considerations

There is a potential negative impact related to resource inflows including resource use regarding utilization of virgin raw materials (such as iron ore, glass and aluminum) in the upstream value chain. A majority of the supply chain for both the wind and solar sector use virgin raw materials, however the recyclability of these materials at their end of life (circa 20-35 years) is quite high.

The challenge to achieve full transparency in the wind and solar power supply chain continues to be significant, particularly regarding forced labor risks in high-risk markets such as China and the Xinjiang province.

Aker Horizons has applied the phase-in provisions for disclosure requirements that may be omitted related to ESRS E4 Biodiversity and ecosystems, in accordance with ESRS 1.137.

The Sustainability Policy sets out that Aker Horizons aims to protect, preserve and restore the environment and biodiversity and to explore nature-based solutions on land and in the ocean, and minimize impact on ecosystems, in particular in relation to operations in or near biodiversity sensitive areas and if affecting endangered species. Aker Horizons has not set any targets related to this matter. However, projects developed by the Group are required to undergo Environmental Impact Assessments ("EIA"), and Aker Horizons incorporates considerations concerning biodiversity impact in early-stage investment processes. Biodiversity impact is also addressed in Aker Horizons' Business Partner Code of Conduct. For Mainstream, their best practice and mitigation measures on biodiversity during construction, operation, maintenance and decommissioning are included in the Global Development Standard. This governing document was reviewed in 2023 and updated with enhanced climate and biodiversity requirements for all project stages. Mainstream has also utilized the AXA Climate Risk Assessment Tool, Altitude, which includes biodiversity risk assessments for all assets and across the Company's portfolio, based on geospatial data. Impacts on biodiversity are sought to be avoided, reduced or mitigated through project specific environmental and social impact assessments ("EISA") that assess and account for local circumstances and regulations.

An example of actions is related to a solar PV plant in South Africa. As part of the development, a project was conducted to relocate protected plant species before the project entered the construction phase. While no threatened plant species were discovered during the site pre-construction survey, a number of species which are protected under local conservation laws were identified. Following the survey, a plant search and rescue operation was conducted, with a large number of protected specimens removed and successfully replanted outside of the development footprint, with the project overseen by botanical experts.

For other parts of the business outside of solar and wind development, biodiversity impact is currently limited, due to the early stage of the activities.

None of the portfolio companies have reported having sites or operations with impacts for protected areas and/or biodiversity-sensitive areas, and as such the Group has not yet assessed the relevant metrics to report on.

Impact metrics related to biodiversity and ecosystems change

Disclosure approach

Aker Horizons has applied the phase-in provisions for disclosure requirements that may be omitted related to ESRS E4 Biodiversity and ecosystems, in accordance with ESRS 1.137.

Material impacts identified

Establishment of solar and onshore wind parks may have a negative impact on vulnerable species, in that their habitats may be disrupted and/or fragmented. The impact is assessed both in the upstream value chain and own operations, on a medium term time horizon.

Quantitative metrics

Protected areas and biodiversity-sensitive areas:

None of the portfolio companies have reported having sites or operations with impacts for protected areas and/or biodiversity-sensitive areas, and as such the Group has not yet assessed the relevant metrics to report on.

Biodiversity impact mitigation actions

South Africa solar PV plant example:

As part of the development of a solar PV plant in South Africa, during a pre-construction survey, a number of species which are protected under local conservation laws were identified. Following the survey, a plant search and rescue operation was conducted, with a large number of protected specimens removed and successfully replanted outside of the development footprint, with the project overseen by botanical experts.

Methodology note:

Projects developed by the Group are required to undergo Environmental Impact Assessments (EIA). Aker Horizons incorporates considerations concerning biodiversity impact in early-stage investment processes. For Mainstream, best practice and mitigation measures on biodiversity during construction, operation, maintenance and decommissioning are included in the Global Development Standard. Mainstream has also utilized the AXA Climate Risk Assessment Tool, Altitude, which includes biodiversity risk assessments for all assets and across the Company's portfolio, based on geospatial data.

Policies related to resources use

Aker Horizons is still at the early stages of developing an approach to resource use and circularity and does not have a specific resource use policy implemented that addresses transitioning away from use of virgin resources, sustainable sourcing and use of renewable resources. However, Aker Horizons' Sustainability Policy sets out the ambition of zero waste, sound resource utilization and the realization of the circular economy. More details on the key content, scope and other disclosures related to ESRS 2 MDR-P for the Sustainability Policy is described in the section 2.1 Climate change.

Actions and resources related to resource use

The Group has not yet implemented specific actions and resources related to resource use. The Group recognizes the critical importance of sustainable resource use and the challenges associated with reliance on virgin raw materials in our supply chain, along with the impact of extraction and processing of these resources on the environment and society. Aker Horizons acknowledges that there is a significant potential for improvement across the portfolio and aims to enhance its understanding of resource efficiency, identifying opportunities to adopt circular economy principles. At a portfolio level, Mainstream's Code of Conduct for Business Partners provides an important foundation for its ongoing engagement with business partners, including suppliers, on central sustainability-related topics. Mainstream expects business partners to strive in minimizing adverse environmental impact and optimize use of natural resources, and work towards circular business models.

Targets related to resource use

The Group has not yet set any targets related to resource use and circular economy, nor a timeframe for when targets will be set.

Sustainability matters related to resource inflows

Sustainability matters related to resource inflows are relevant for the portfolio company Mainstream. Construction of wind and solar plants are performed by contractors and suppliers in accordance with construction contracts entered into between the supplier/contractor and Mainstream. These contracts include details of the project to be constructed including project scope, specifications, schedule and similar but they do not typically include a detailed description of the virgin raw materials that were extracted and processed to complete the project. A majority of the supply chain for both the wind and solar sector use virgin raw materials (such as iron ore, glass and aluminium), however the recyclability of these materials at their end of life (circa 20 - 35 years), is quite high. As detailed description of material used in the construction are not part of the construction contracts and the construction activities are performed by suppliers in the value chain, the Group does not have detailed data for the materials used but will consider this in the future.

The Sustainability Policy sets out Aker Horizons shall respect and protect human rights, including through ensuring due diligence and remediation processes are in place. The policy is owned by the sustainability director, reviewed by the CEO, approved by the Board of Directors and available on Aker Horizons' website.

The Code of Conduct outlines the values and principles guiding how to work, ensuring that Aker Horizons and its portfolio companies adhere to standards of integrity, transparency and sustainability. The Code includes principles for human rights, workplace safety, working environment, equal opportunities, and development of competence. More details on the Code of Conduct, including key content, scope and other disclosures, are described in the section 2.1 Climate change.

People

At year-end 2024, a total of 345 employees worked for companies in which Aker Horizons was the main shareholder, compared to 624 employees at year-end 2023. The decrease is mainly is due to the sale by Aker Carbon Capture of 80 percent of its operating company, and the organizational restructuring of Mainstream Renewable Power. The proportion of women employees stood at 41 percent across the Group. The total workforce stood at 410 full-time equivalents (FTE), including all employees and contract staff, at year-end 2024. Aker Horizons, including Aker Horizons Asset Development, consisted of 34 employees and seven FTE contract staff at year-end 2024.

Aker Horizons is strongly committed to ensuring equality, diversity and inclusion throughout its business. Aker Horizons does not tolerate any form of discrimination on the basis of, for example, gender expression, sexuality, disability, race or religious beliefs.

At Aker Horizons, employees are offered competitive compensation and rewards and a flexible working model, with the opportunity to work from home and limited core hours. The Company offers healthcare and insurance plans, and access to on-site health services and a fitness center. In 2024, the total rate of absence due to illness at Aker Horizons, including Aker Horizons Asset Development, came to 3.5 percent.

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

Number of non-employee workers

Aker Horizons has 65 hired-ins and contractors as of the reporting date (31 December 2024).

Breakdown by gender

Methodology

The figures are reported as headcount at the reporting date (31 December 2024). No breakdown by type of non-employee worker (contractor, agency, self-employed) is provided beyond the general categorization as "hired-ins and contractors".

Collective bargaining coverage and social dialogue

Aker Horizons has participated in meetings with the Global Works Council (GWC), which includes labor union representatives from several Aker companies across the world and has held two conferences in 2024.

The employee representations provide Aker ASA and Aker Horizons with insights and facilitates implementation of active employment representation.

Aker Horizons recognizes the rights to freedom of expression, privacy, association and collective bargaining.

Phase-in provision applied: Aker Horizons has applied the phase-in provisions for the first reporting year under CSRD available for companies with less than 750 employees, except for some of the metrics related to characteristics of own workforce (S1-6).

Health and safety metrics

Work-related fatalities and injuries (2024)

Coverage: All Aker Horizons portfolio companies have established management systems and obtained certifications. Aker Horizons Asset Development uses a management system developed in line with ISO 45001 and 14001.

Methodology: No work-related fatalities were registered across Aker Horizons Group companies in 2024. There were zero work-related injuries (TRIs) reported among the Aker Horizons Group's employees, and thereby zero lost-time injuries (LTIs). Among contractors, there were thirteen work-related injuries, seven of which were lost-time injuries (LTIs).

Compensation metrics (ESRS S1-16)

Pay gap

Not disclosed. The company has applied phase-in provisions under ESRS 1.137 Appendix C for its first year of CSRD reporting.

Remuneration ratio

Not disclosed. The company has applied phase-in provisions under ESRS 1.137 Appendix C for its first year of CSRD reporting.

Methodology

Aker Horizons has applied phase-in provisions available for companies not exceeding an average of 750 FTEs for the first year of reporting under CSRD. The phase-in explicitly covers ESRS S1 disclosures, with the exception of some metrics related to characteristics of own workforce (S1-6). The compensation metrics required under S1-16 (pay gap and remuneration ratio) are among the disclosures omitted in this first reporting year.

At a portfolio level, Mainstream's Code of Conduct for Business Partners provides an important foundation for its ongoing engagement with business partners, including suppliers, on central sustainability-related topics. Mainstream expects business partners to strive in minimizing adverse environmental impact and optimize use of natural resources, and work towards circular business models.

Bidding and contractor selection processes undertaken by Aker Horizons and portfolio companies include screening of potential business partners and sub-contractors. This includes checks for sanctions, politically exposed persons, and adverse media. Health and safety performance is a key criterion in contractor selection, with preference given to contractors with strong safety records and certifications.

The Business Partner Code of Conduct and Integrity Due Diligence processes have been implemented across the Group to mitigate human rights risks, including those related to forced labour in the supply chain.

Policies related to affected communities

Aker Horizons has applied the phase-in provisions for ESRS S3-1. The company has indicated that disclosure requirements 16 and 17 under ESRS S3-1 are marked as "N/A (phase-in)".

No specific policies related to affected communities are disclosed in the provided excerpts for the reporting period.

Taking action on material impacts on affected communities

Asset-Based Community Development ("ABCD") methodology

Action description: Mainstream South Africa has implemented the ABCD methodology as a community development strategy since 2020. This approach focuses on community members as change agents, either already working to improve the lives of their fellow residents or planning to make a positive difference.

Scope: Own operations (Mainstream South Africa projects)

Time horizon: Ongoing since 2020

Resources allocated (non-financial):

• Mainstream South Africa has a dedicated team for this work
• During the construction phase, the team engages with stakeholders to assess the needs in communities surrounding the projects

Expected outcomes:

• Community investment plans based on stakeholder engagement and needs assessment

Link to material impact: This action addresses the material impact risk related to negative impacts on local and indigenous communities, particularly concerning Free, Prior and Informed Consent (FPIC) principles, which is considered present in both the value chain and own operations on a short-term basis.

The Code of Conduct outlines the values and principles guiding how to work, ensuring that Aker Horizons and its portfolio companies adhere to standards of integrity, transparency and sustainability. The Code includes principles for human rights, workplace safety, working environment, equal opportunities, development of competence, and business conduct including anti-corruption and bribery, fair competition, and responsible business partnerships. The Code applies to employees, officers and directors in Aker Horizons, and to entities and their personnel where Aker Horizons controls 90 percent or more of the shares and votes. It also applies to intermediaries, consultants and others acting on behalf of the Group. Aker Horizons also expects that all companies that are consolidated for accounting purposes implement their own Codes of Conduct that adequately address the principles in the Code of Conduct, and both Mainstream and ACC have corresponding policies. The Code of Conduct is prepared by the General Counsel, owned by the CEO, approved by the Board of Directors and available on Aker Horizons website.

The Business Partner Code of Conduct sets expectations for business partners regarding ethical business practices, including anti-corruption measures, human rights compliance, and environmental responsibility. This code is implemented as part of the due diligence and onboarding process for new business partners.

Management of relationships with suppliers

Bidding and contractor selection processes undertaken by Aker Horizons and portfolio companies include screening of potential business partners and sub-contractors. This includes checks for sanctions, politically exposed persons, and adverse media. Health and safety performance is a key criterion in contractor selection, with preference given to contractors with strong safety records and certifications.

The Business Partner Code of Conduct and Integrity Due Diligence processes have been implemented across the Group to mitigate human rights risks, including those related to forced labour in the supply chain. At a portfolio level, Mainstream's Code of Conduct for Business Partners provides an important foundation for its ongoing engagement with business partners, including suppliers, on central sustainability-related topics.

The assessment has also included input from the risk management system and internal reporting of compliance-related matters to the Audit Committee and the Board. The purpose was to map geographical areas, activities, and/or sectors with increased potential impacts or risks related to corruption and bribery, as well as human rights violations.

The Code of Conduct includes principles for business conduct including anti-corruption and bribery, fair competition, and responsible business partnerships. The Business Partner Code of Conduct sets expectations for business partners regarding ethical business practices, including anti-corruption measures, human rights compliance, and environmental responsibility.

Incidents of corruption or bribery

Confirmed incidents

During the reporting period, Aker Horizons has had no confirmed incidents of corruption or bribery.

Convictions and fines

No fines have been imposed related to corruption or bribery during the reporting period.

Breaches in procedures or standards

No breaches in procedures or standards of anti-corruption and anti-bribery are identified.

Investigation and speak-up mechanisms

Aker Horizons encourages reporting of concerns or breaches of the business conduct framework including potential incidents of corruption and bribery, and has internal routines in place for how to report a concern. The whistleblowing system provides a confidential channel for reporting of suspected corruption and bribery. The whistleblowing channel (Integrity channel) is operated by an independent third-party and available for concerns related to all Group companies. Mainstream and ACC's separate channels may also be applied. An issue or a concern can be reported in several ways, as well as on Aker Horizons' website and internal sharepoint site, and correspondingly for Mainstream and ACC. Aker Horizons enables parties to raise concerns and report suspected infractions through awareness-raising initiatives and internal training. Reports of potential incidents of corruption and bribery are included in the quarterly reporting by the Chief Compliance Officer to the Audit Committee.

Violations of the rules will result in disciplinary actions. Aker Horizons will not accept any violation of relevant laws, regulations or the Anti Corruption Policy without taking appropriate actions to mitigate such violation. Properly founded allegations or evidence of violations will result in investigations which will result in disciplinary actions if allegations are substantiated. Disciplinary actions will range from verbal warnings (from line managers or the P&O function) to dismissal. Aker Horizons will support criminal investigations and prosecutions if relevant.