Aker Solutions

Norway|Oil & Gas – Services|Reporting year:FY2025FY2024|Auditor: PricewaterhouseCoopers AS|View original report →

Sustainability statement, in full

The complete text of Aker Solutions’s FY2025 sustainability statement is held here – 141 pages, captured from the published report. Every disclosure below also links to its own passage.

ESRS 2 – General Disclosures

GOV-1The role of the administrative, management and supervisory bodies
Reported

Governance roles

Reference: pages 24-25.

The Board of Directors has eleven members, none of whom hold executive positions: shareholders elect seven and employees four. There are four independent board members (36 percent), six male members (55 percent) and five female members (45 percent). Committees are an Audit Committee (four Board members) and a Remuneration Committee (three) (page 24).

The executive management team, led by the CEO, includes the CFO and seven executive vice presidents covering two functional areas and four operating segments (Life Cycle, Power Solutions, New Energies, New Build) plus the Fixed Facility Alliance Projects (page 24).

Allocation of responsibility (page 24):

  • The EVP for strategy and technology leads the sustainability agenda; business segments and functions are responsible for implementation. The same EVP oversees enterprise risk management, supported by an enterprise risk committee that reports quarterly.
  • The CEO reports sustainability and climate-related issues to the Board, including enterprise risk information and progress on mitigation measures. "Climate considerations are also prioritized in tender approvals."
  • The Audit Committee "safeguards the integrity of financial and ESG reporting and enterprise risk management" and oversees the enterprise risk framework "to ensure it reflects major risk areas, including climate-related risks".

On expertise, "several board members have worked with sustainability, compliance and ESG reporting", the Board draws on external consulting expertise and "dedicates time to enhancing competence in ESG topics and regulatory requirements" (page 25).

GOV-2Information provided to and sustainability matters addressed by the undertaking's administrative, management and supervisory bodies
Reported

Information provided to and matters addressed by the governance bodies

Reference: page 25.

There are eight ordinary board meetings per year, with extraordinary meetings when needed. Every ordinary board meeting includes an operational status report from the CEO and/or CFO, including project updates.

Sustainability is a standard agenda topic at the quarterly Audit Committee meetings, "where material impacts, policies, reporting and other key topics are discussed and agreed" (page 25).

Annual sustainability reporting, "including material impacts, risks and opportunities - IROs (covered in SBM-3), is discussed, reviewed and approved by the Board and Audit Committee in the first quarter of the year" (page 25).

The Board approves the company strategy and supporting business plans, "with scheduled agenda items such as the identified risks and progress against KPIs, including sustainable business performance" (page 25).

Related governance detail appears elsewhere in the statement: the status of internal control over sustainability reporting is reported quarterly to the Audit Committee (page 26); the compliance and integrity function reports quarterly to the Audit Committee on the business integrity programme, and meets it once a year without management present (page 96); and the executive management team and the Audit Committee both review the annual materiality assessment (page 30).

GOV-2(was GOV-3)Integration of sustainability-related performance in incentive schemes
Reported

Integration of sustainability-related performance in incentive schemes

Reference: page 25.

Aker Solutions "offers an annual variable pay scheme to senior managers globally", designed to incentivize senior management to achieve annual strategic objectives (page 25).

The 2025 variable pay scheme "is integrated with the company's performance management system and the corporate balanced scorecard, which includes common corporate objectives approved by the Board of Directors. All eligible employees, regardless of their business segment or function, are evaluated based on these shared commitments" (page 25).

Weightings disclosed for 2025 (page 25):

  • The 2025 scorecard "features KPIs aligned with Aker Solutions' long-term transitional targets, including KPIs for climate action and emissions reduction, and revenue growth from transitional, electrification and renewables".
  • "Operational and transitional KPIs together account for a 20 percent weighting and HSSE KPIs account for a 10 percent weighting of the variable pay total."

The climate link is corroborated in E1-1, which states that the company has "KPIs as part of our balanced score card related to scope 1 emissions reductions, both at corporate and segment level" (page 47). The statement does not separately quantify the proportion of remuneration recognised that is linked to climate considerations.

GOV-3(was GOV-4)Statement on due diligence
Reported

Statement on due diligence

Reference: page 26.

The statement maps the five core elements of due diligence, "as delineated in international instruments such as the UN Guiding Principles on Business and Human Rights and the OECD Guidelines for Multinational Enterprises", to pages in the sustainability statement (page 26):

Core elementPages in the statement
(a) Embedding due diligence in governance, strategy and business model24, 59, 76
(b) Engaging with affected stakeholders in all key steps of the due diligence29
(c) Identifying and assessing adverse impacts32, 76, 85, 97, 100
(d) Taking actions to address those adverse impacts49, 64, 67, 70, 77, 87, 97, 100
(e) Tracking the effectiveness of these efforts and communicating77, 88, 97, 101

The due diligence process is described as "a comprehensive approach to identifying, preventing, mitigating, and accounting for the actual and potential negative impacts on the environment and society linked to our business activities" (page 26).

GOV-4(was GOV-5)Risk management and internal controls over sustainability reporting
Reported

Risk management and internal controls over sustainability reporting

Reference: page 26.

Aker Solutions "has established a framework to ensure the accuracy, reliability and integrity of our sustainability reporting in accordance with the European Sustainability Reporting Standards (ESRS)". The approach "aligns with principles from ISO 31000, PMI, and COSO frameworks, and climate-related risks are evaluated using the guidelines set forth by the Task Force on Climate-related Financial Disclosures (TCFD)" (page 26).

Scope and main features: "The scope of our risk management and internal control processes includes all parts of sustainability reporting. The main features of the system are risk identification, risk assessment, risk mitigation and internal controls." An annual risk assessment identifies "the risks of material misstatements in the sustainability reporting based on materiality, complexity in processes, and the probability of errors" (page 26).

Risks identified: exposure "to risks associated with incomplete or inconsistent reporting of sustainability data", plus "risks related to the accuracy of data inputs and manual errors in the reporting process" (page 26).

Controls: "for 2025 the implemented controls are review controls." Status is "reported on a quarterly basis to the Audit Committee", with annual reviews of system effectiveness. The company concludes that internal control over sustainability reporting "is an ongoing journey and we expect this area to improve and mature going forward" (page 26).

SBM-1Strategy, business model and value chain
Reported

Strategy, business model and value chain

Reference: pages 27-29.

"Sustainability is embedded into Aker Solutions' enterprise strategy and is not a separately developed strategy" (page 27).

Business (page 27): products, systems and services from concept studies and front-end engineering to integrated project execution and services for the global oil and gas industry, plus consultancy, engineering and technical solutions for offshore wind, electrification, hydrogen, carbon capture and storage and hydropower. At the end of 2025 headcount was 11,818 employees across 14 countries, with operations in 13 countries.

Revenue mix (page 27): "Aker Solutions has no revenue directly related to actual drilling, exploration or extraction of oil and gas." Products and services delivered to oil and gas customers were 84 percent of total revenue from customer contracts in 2025 (82 percent in 2024); renewables and transitional energy projects were 20 percent of revenues (18 percent in 2024).

Segments (page 27): New Build, New Energies, Life Cycle and Power Solutions, reported externally as Renewables and Field Development, and Life Cycle.

Value chain (pages 28-29): a value chain overview diagram maps material topics across the chain. Upstream purchasing covers steel, electronics, metals, composites and specialised equipment; supplier types are raw material suppliers, equipment manufacturers, technology providers, service providers, engineering and construction firms, and logistics and transportation companies. Customers are major oil and gas companies, renewable energy developers, infrastructure providers, utilities, government agencies and private investors.

SBM-2Interests and views of stakeholders
Reported

Interests and views of stakeholders

Reference: pages 29-31.

Aker Solutions "has in-depth and ongoing dialogue with our key stakeholders on sustainability impacts and other topics throughout the year". Key stakeholders are "customers, investors, financial institutions, employees, non-governmental organizations (NGOs), unions, governments and national authorities, partners and suppliers" (page 29).

A stakeholder table sets out engagement type, frequency and key topics for seven groups (pages 30-31):

  • Customers and collaboration partners - meetings, tradeshows, site tours and audits, satisfaction surveys; daily to annually; topics include anti-corruption and bribery, climate risks, GHG emissions, human rights, occupational health and safety, responsible supply chain.
  • Employees and potential employees - internal channels, performance dialogues, code of conduct training, employee surveys; topics include diversity and equal opportunity, health, safety and well-being including mental health, talent attraction and employment conditions.
  • Financial community and owners - investor meetings and roadshows, quarterly reporting; topics include climate risks, compliance and governance, strategy.
  • Suppliers - supplier visits and audits, business reviews, negotiations; topics include human rights, Modern Slavery Act statement, responsible supply chain.
  • Governments, authorities, NGOs and industry groups; media; and unions (labour/works council meetings, formal negotiations, board representation).

"Both Aker Solutions' executive management team and the Board's Audit Committee review the annual materiality assessment, including the views and interests of affected stakeholders concerning our sustainability impacts" (page 30).

SBM-3Material impacts, risks and opportunities and their interaction with strategy and business model
Reported

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

Reference: pages 35-39, 42-43.

"After the assessment process, we determined that eight out of the ten ESRS topics are material to Aker Solutions" (page 35). E3 Water and marine resources and S4 Consumers and end-users are not material; cybersecurity is carried as an entity-specific topic (pages 32, 34, 39).

Material IROs are tabulated by topic and sub-topic on pages 36-39, each row showing whether the impact is in own operations (OO) or value chain (VC), potential (P) or actual (A), and its time horizon. The same tables are repeated at the head of each topical chapter (pages 45, 62, 65, 68, 74, 84, 90, 93). Counted from those tables there are 46 rows: E1 9, E2 1, E4 1, E5 4, S1 10, S2 12, S3 1, G1 7 and one entity-specific cybersecurity row.

"Due to the medium term horizons (1-5 years) for all of our material risks and opportunities, for the significant part of our operations there are no current financial effects" (page 35).

Topic-level SBM-3 commentary (page 43):

  • E1-SBM-3 - "All material climate-related risks identified were climate-related transition risks", listed as geopolitics affecting energy markets, lost opportunities in energy transition, and failure in project execution and delivery.
  • S1-SBM-3 - 11,818 employees, 95.4 percent permanent, 78.0 percent in Norway, approximately 1.7 percent part-time, and 10,827 non-employee self-employed or agency workers (8,366 in 2024).
  • S2-SBM-3 - a cross-functional Human Rights Committee with HSSE, compliance and integrity, people and transformation, data protection, sustainability, supply chain and union representation.
  • S3-SBM-3 - fabrication yards at Egersund, Sandnessjøen, Stord and Verdal are the key communities with potential positive impact.

Resilience of the strategy and business model is described on page 42, including five strategic priorities and the material topics each covers.

IRO-1Description of the processes to identify and assess material impacts, risks and opportunities
Reported

Processes to identify and assess material impacts, risks and opportunities

Reference: pages 32-35.

The 2025 review is "based on the implementation guidance for the Double Materiality Assessment (DMA) requirement of the European Sustainability Reporting Standards (ESRS)" (page 32).

Scope (page 32): "During the assessment, Aker Solutions' full value chain was mapped. Value chain assessments were based on internal knowledge and main focus was on Tier 1 suppliers, especially when identifying and assessing impacts related to ESRS S2." The company states plainly: "No IROs were identified related to ESRS S4: Consumers and end-users."

Scoring (page 32): impact severity from scale, scope and irremediable character (each 1-5), combined with likelihood scored from very low (<20 percent) to very high (>80 percent). "For actual impacts, likelihood was set at 100 percent... they must also have a combined severity score of over 2.75." Human-rights impacts "utilized a lower threshold for severity, per ESRS guidelines". Risks and opportunities were scored on "percent impact on EBITDA", from "minor" (<2 percent of EBITDA) to major (>20 percent), against the enterprise risk management threshold.

Process (page 32): six steps - mobilisation and identification, initial assessment, calibration, stakeholder engagement, finalisation and documentation (all IROs "extracted and provided to the auditor to support its assurance process"), and validation with the EMT and Audit Committee.

Changes (pages 32-33): "Some similar or duplicated IROs were combined reducing the number of IROs from 2024 by seven. In addition, reassessment and updated scoring of existing IROs further reduced the total number of IROs from 2024 by five. There was no change to the list of material topics." Five impacts were assessed as no longer material, four impact groups and one risk group were combined, and "There were no new IROs for 2025."

Topic-specific additional processes are described for climate change (page 33, TCFD scenario analysis), pollution (page 34, environmental aspect and impact process, risk assessment, Best Available Technique), water and marine resources (page 34, screened and found not material), biodiversity (page 34, screening of sites against key biodiversity areas) and resource use (pages 34-35, procurement-database screening of purchased materials).

IRO-2Disclosure requirements in ESRS covered by the undertaking's sustainability statement
Reported

Disclosure requirements covered by the sustainability statement

Reference: pages 20-21 (ESRS content index) and pages 102-108 (datapoints derived from other EU legislation).

The statement prints a genuine ESRS content index on pages 20-21: "This content index lists the disclosure requirements that have been adhered to in this statement. It serves as a navigational tool, guiding stakeholders to the respective sections where detailed disclosures are presented" (page 20).

The index lists, with page references: BP-1, BP-2, GOV-1 to GOV-5, SBM-1, SBM-2, SBM-3, IRO-1 and IRO-2; E1-1 to E1-6 plus EU Taxonomy; E2-1 to E2-4; E4-2 to E4-5; E5-1 to E5-5; S1-1 to S1-6, S1-8, S1-9, S1-14, S1-16, S1-17; S2-1, S2-4, S2-5; S3-1, S3-2, S3-4, S3-5; G1-1 to G1-6; and Cybersecurity as an entity-specific topic (pages 20-21).

The index carries an explicit phase-in footnote: "Aker Solutions is utilizing the phase-in options for 2025 reporting for anticipated financial effects, S1-7, S1-12, S1-13, S1-15 and for E4, S2 and S3 reporting on policies, actions and targets only" (page 21).

BP-2 states that the list of datapoints deriving from other EU legislation "is incorporated by reference and is located at the end of the Sustainability Statement" (page 23); that table runs across pages 102-108 and marks each datapoint with either a page number or "Not Material". Datapoints marked Not Material there include ESRS 2 SBM-1 chemical production, controversial weapons, fossil fuel activities and tobacco; E1-7; all five E1-9 rows; E3-1 and E3-4; several E4-2 rows; S3-4; and S4-1 and S4-4 (pages 102-108).

E1 – Climate Change

E1-1Transition plan for climate change mitigation
Reported

Transition plan for climate change mitigation

Reference: pages 46-47.

"Aker Solutions does not have a transition plan but we have a decarbonization strategy which we call our 'climate action plan'." Launched in 2022, its actions focus on three areas: "shifting energy use toward renewables, improving energy efficiency and supporting the transition to new energy sources while maintaining reliable operations and sound financial health" (page 46).

Targets: reduce scope 1 and 2 emissions by 50 percent by 2030 against 2023, and net zero (scopes 1, 2 and 3) by 2050 (page 46). "While we do not yet have a scope 3 emissions reduction target", value chain emissions are to be reduced through low emissions products and services (page 46).

Investments and funding (page 46): "Aker Solutions has sufficient funds, capacity and capabilities to implement the remaining actions in our climate action plan." To meet the 2030 target "and to ensure compliance with anticipated changes in Norwegian environmental legislation, we anticipate total investment of at least NOK 200 million through 2030". In 2025 the company "invested approximately NOK 7 million in actions which are not part of the EU taxonomy but are supporting our decarbonization strategy", covering energy attribute certificates and measures replacing fossil energy sources.

Locked-in emissions (page 46): "There are locked-in scope 1 emissions from equipment at our sites... primarily for heating, mobile equipment and hot work." Value chain emissions "can be locked in due to long-term supplier agreements and project design restrictions". No quantification is given.

"In 2025, Aker Solutions did not have any capital expenditures related to coal, oil and gas-related extraction activities" (page 46). On benchmarks: "Our long-term net zero target is aligned with the EU Paris Agreement. Our near-term scope 1 and 2 emissions reduction target is also aligned with this agreement, but we do not currently have a near-term scope 3 emissions reduction target" (page 46).

Approval: "The climate action plan has been approved by our executive management team" (page 47). Four specialised technical groups for scope 1 and scope 3 reductions were established in 2025 and "will be launched in 2026" (page 46).

E1-2(was covered under ESRS 2 IRO-1)Identification of climate-related risks and scenario analysis
Reported

Identification of climate-related risks and scenario analysis

Back-filled from ESRS 2 IRO-1 and E1-SBM-3, where this content is disclosed in the FY2025 report (pages 33, 43). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Reference: pages 33, 43.

Classification of risks (page 43): "All material climate-related risks identified were climate-related transition risks". Three are listed: geopolitics affecting energy markets, lost opportunities in energy transition, and failure in project execution and delivery. No physical risk was assessed as material.

Methodology and scope (page 33): "Aker Solutions conducted a climate-related scenario analysis using the guidelines set forth by the Task Force on Climate-related Financial Disclosures (TCFD). Aker Solutions reviewed three climate scenarios and considered our full value chain including upstream oil and gas production and downstream customer demand, as well as the production and demand for renewable energy fuels and technologies such as offshore wind, hydrogen, and CCS." Time horizons are defined as short 2026, medium 2030, long 2050.

Scenarios and temperature projections (page 33):

  • IEA Net Zero 2050 (1.5°C) - a 1.5°C-aligned transition scenario; carbon prices in advanced economies rise to around USD 250/tCO2 in 2030, USD 280-300 in 2040 and USD 300-350 in 2050.
  • IEA Announced Pledges (1.7-2°C) - "the temperature rise in 2100 is 1.7°C"; carbon prices USD 130-140/tCO2 in 2030 rising to USD 200-220 in 2050.
  • IEA Stated Policies (2.4-3°C) - "the temperature rises to 2.0°C in 2050 and 2.4°C in 2100"; EU carbon prices USD 140/tCO2 in 2030 to USD 250 in 2050.
  • Physical risk: IPCC SSP3-7.0 - "By the end of the century, average temperatures have risen by 3.6°C." Under it, "Aker Solutions' operations are based in areas that may be exposed to rising acute and chronic physical risks, including heat waves and/or drought, water stress, severe storms, and flooding and/or sea level rise, however these were not considered material risks."

Consistency with financial reporting: "The scenarios used are the same scenarios used in the financial impairment testing described in note 12 of the consolidated financial statements" (page 33).

The report does not state the year in which the scenario analysis was carried out or whether it was refreshed in 2025.

E1-3(was covered under ESRS 2 SBM-3)Resilience in relation to climate change
Reported

Resilience in relation to climate change

Back-filled from the "Resilience of Strategy and Business Model" section and E1-SBM-3, where this content is disclosed in the FY2025 report (pages 42-43). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Reference: pages 42-43.

Results of the analysis and implications for strategy (page 43): "The results of the analysis were used to inform the development of our corporate strategy and improve our resilience. As a result of declining demand for oil and gas under the NZE and APS scenarios, and the growth of renewable energy under all scenarios, Aker Solutions has made a strategic shift to grow in renewables and low-carbon markets including offshore wind, CCS and hydrogen by working closely with our customers and partners and leveraging our core capabilities."

How resilience is built into the strategy process (page 42): "The company's business targets and strategy are evaluated on an annual basis by the Board under a designated strategy process... The strategy process includes building views on market trends, monitoring how customers and peers develop, reviewing performance of business units and strategic initiatives, evaluating impact of different climate-related scenarios, and utilizing the information to formalize our strategic beliefs."

Capacity to adjust and adapt (page 42): "A sound financial position combined with a culture of innovation and problem solving enables Aker Solutions to handle uncertainty, drive change and stay competitive. Furthermore, we anticipate that our investments in technology and digital solutions will ensure business continuity, operational efficiency and flexibility and a more data driven decision making." The 2025 strategy process produced five priorities, of which "Strong, efficient and sustainable project delivery by improving our core" and "Develop commercially robust energy transition growth engines" are both mapped to climate change as a material topic (page 42).

Uncertainty: BP-2 identifies "ranges of financial estimates within the climate action plan, GHG emissions estimates in some categories within scope 3, and estimates of future emissions reductions" as the areas of high estimation uncertainty (page 23).

The report does not present a separately labelled ESRS climate resilience analysis, does not quantify resilience outcomes and does not state whether a resilience analysis was refreshed in 2025.

E1-4(was E1-2)Policies related to climate change mitigation and adaptation
Reported

Policies related to climate change mitigation and adaptation

Reference: page 48.

"The material impacts related to climate change are addressed and mitigated by the following policies. Both policies are signed at the top management level and are applicable to all Aker Solutions' operated sites" (page 48).

Sustainability Policy - "Describes our commitment to support the UN SDGs, Global Compact principles, and the Paris Agreement by making sustainability a core value in our strategy, prioritizing renewable solutions and energy efficiency, and promoting recycling, reuse and circular design in our solutions and responsible practices across our value chain." IROs addressed: climate change mitigation, climate change adaptation, energy. Owned by the EVP Strategy and Technology (pages 40, 48).

HSSE Policy - "Promotes safe, reliable and sustainable operations. Focuses on our commitment to achieving zero harm to personnel, the environment, and assets." IROs addressed: climate change mitigation, climate change adaptation, energy (page 48).

Operational procedures "cover the assessment of environmental aspects and impacts, required to be conducted in projects and at locations", and further procedures "identify the monitoring and measurement of the HSSE KPIs, including environment and climate", supported by "a prescribed methodology statement on the calculations of emissions for all scopes" (page 48).

The four key areas addressed are set out explicitly (page 48): (a) climate change mitigation - an emissions reduction target for scope 1 and 2 and net zero by 2050; (b) climate change adaptation - renewable and transitional solutions, recycling, reuse and circular design, plus employee training and upskilling; (c) energy efficiency - "continuously improving productivity, minimizing energy waste and investing in technology that reduces consumption"; and (d) renewable energy deployment - purchase of energy attribute certificates, with "approximately 132,114 megawatt hours of electricity for our own consumption" purchased in 2025 versus approximately 118,087 MWh in 2024.

E1-5(was E1-3)Actions and resources in relation to climate change policies
Reported

Actions and resources in relation to climate change policies

Reference: page 49.

Decarbonisation lever 1 - reducing own emissions (scope 1 and 2): "Aker Solutions' biggest decarbonization lever for scope 1 and 2 is renewable energy such as increased use of electricity and bio-based solutions. This includes key actions such as replacing fossil fuels with biofuels, upgrading heating systems, increasing energy efficiency through ISO 50001 activities, purchasing EACs, and achieving continued reductions from previous facility-upgrade investments." Quantified: "Investments performed and investments included in our near-term financial planning are expected to reduce our scope 1 and 2 emissions by approximately 50 percent by 2030, compared to our 2023 baseline", and "Our yards have decreased emissions by approximately 35 percent compared to 2023 after the replacement of heating from fossil sources and replacement of biofuels" (page 49).

Decarbonisation lever 2 - reducing value chain emissions (scope 3): actions include "the promotion of fossil free transport across the supply chain and purchasing low emissions steel". "By joining the First Movers Coalition (FMC), Aker Solutions commits to buying at least 10 percent (by volume) of our steel from low-emissions sources by 2030... This is estimated to reduce our scope 3, category 1 emissions by 5 percent." An internal transportation management system was developed to optimise and consolidate trips (page 49).

Innovation and scaling gap: the company discloses the actions "where direct emissions reductions are not yet assured" - data-driven decision making, industry collaboration, and procurement and contracts - and states that "The effectiveness of these potential measures in reducing GHG emissions is highly uncertain" (page 49).

Resources: "Aker Solutions has sufficient funds, capacity, and capabilities to fulfill the plan towards 2030, as laid out in our financial strategy plan. Beyond the 2030 scope 1 and 2 target, Aker Solutions is also dependent on effective solutions to further reduce emissions" (page 49). CapEx and OpEx consistency is cross-referenced to E1-1 (page 49).

E1-6(was E1-4)Targets related to climate change mitigation and adaptation
Reported

Targets related to climate change mitigation and adaptation

Reference: pages 50-51.

Scope 1 and 2 target (page 50): "Reduce absolute scope 1 and 2 emissions 50 percent by 2030 from a 2023 baseline." Current status: "At year-end 2025, we have attained a 40.0 percent reduction from 2023 baseline." Tracking: "Scope 1 and 2 emissions are accounted for and tracked on a monthly basis, following our emissions accounting procedure."

All scopes target (page 50): "Reach net-zero greenhouse gas emissions across the value chain by 2050." Current status: "At year end 2025, we have increased the total for all scopes by 5.2 percent over 2023 baseline." The company expects "to reduce all scopes by 90 percent and neutralize the remaining 10 percent of emissions using carbon offsets, in accordance with the criteria of the SBTi".

Paris alignment (page 50): "Our long-term net zero target is aligned with the EU Paris Agreement and a 1.5°C pathway. Our near-term scope 1 and 2 emissions reduction target is also aligned with this agreement and a 1.5°C pathway, but we do not currently have a near-term scope 3 emissions reduction target."

Methodology (page 51): "The target-setting process involved discussions and workshops with key stakeholders, utilizing the Science Based Target initiatives' (SBTi) methodology. The target was set in alignment with the SBTi Corporate Net Zero Standard." The calculation "follows the Absolute Contraction Approach and the cross-sector absolute reduction pathway". The report does not state that the targets have been validated by SBTi.

Gross targets (page 51): "The scope 1 and 2 target encompasses all accounted scope 1 and 2 emissions according to our emissions inventory, and do not include any avoided GHG emissions, emissions removals or other type of carbon credits."

The company also discloses a limitation: "Aker Solutions' long-term decarbonization strategy is currently not defined as it relies on technological innovation as well as new production methods in the value chain. More details will be unfolded in the coming years" (pages 50-51). Scope 1 emissions "are tracked and monitored on a quarterly basis at the corporate and business segment levels" (page 51).

E1-7(was E1-5)Energy consumption and mix
Reported

Energy consumption and mix

Reference: pages 51-53.

Total energy consumption 2025: 202,782 MWh (2024: 187,256 MWh), of which fossil 45,269 MWh and renewable 157,513 MWh (page 52).

Energy consumption (MWh)20242025
Coal and coal products00
Crude oil and petroleum products23,83820,249
Natural gas21,66016,836
Other fossil sources5,0783,003
Purchased electricity, heat, steam, cooling from fossil sources6,2945,181
Total fossil56,87045,269
Nuclear00
Fuel from renewable sources, including biomass1,54513,487
Purchased electricity, heat, steam, cooling from renewable sources128,841144,026
Self-generated non-fuel renewable energy00
Total renewable130,386157,513

Shares: fossil 22.3 percent in 2025 (30.4 percent in 2024); renewable 77.7 percent (69.6 percent); nuclear 0.0 percent (pages 51-52).

Energy intensity in high climate impact sectors: total energy consumption from those activities per net revenue from them was 3.04 MWh/MNOK in 2025 against 3.28 in 2024, a -7.37 percent change; net revenue from activities in high climate impact sectors was MNOK 60,039 of MNOK 62,202 total (pages 52-53). "Our activities occurring in high climate impact sectors include fabrication, manufacturing and decommissioning" (page 52).

"Aker Solutions had no nuclear energy sources", "did not have any self-generated non-fuel renewable energy" and "did not produce renewable or non-renewable energy in 2025" (pages 51-52). Renewable electricity is secured through energy attribute certificates including guarantees of origin; renewable fuel consumption "includes biogenic fuels... compatible with hydrotreated vegetable oil (HVO) or similar alternatives" (page 52). Energy data "is collected locally at each site through meter readings or utility invoices", submitted monthly (page 52).

E1-8(was E1-6)Gross Scopes 1, 2, 3 and Total GHG emissions
Reported

Gross Scopes 1, 2, 3 and total GHG emissions

Reference: pages 53-56.

tCO2e2023 base202420252025/2024
Gross Scope 113,69211,1639,062-18.8%
Gross location-based Scope 24,0513,6364,009+10.3%
Gross market-based Scope 25,6832,9572,558-13.5%
Total Scope 1 and 2 (market-based)19,37514,12011,620-17.7%
Total gross Scope 3997,0381,130,7051,057,918-6.4%
Total GHG emissions (market-based)1,016,4131,144,8251,069,538-6.6%

"Percentage of Scope 1 GHG emissions from regulated emission trading schemes" is 0.0 percent in all years (page 54).

Largest Scope 3 categories in 2025 (page 55): "Category 1: Emissions from purchased goods and services (56.9 percent); Category 15: Investment-related emissions (28.9 percent); Category 4: Upstream transportation and distribution (6.2 percent)." In absolute terms category 1 was 602,202 tCO2e, category 15 305,321 tCO2e and category 4 65,654 tCO2e (page 54). "In 2025, our scope 3 emissions increased by 6.1 percent over 2023 driven by high procurement activity" (page 55).

Intensity: total GHG emissions per net revenue fell from 21.9 to 17.2 tCO2e/MNOK (market-based), a -21.6 percent change (page 55).

Data quality: "The inventory was based on seven percent primary data provided by suppliers of raw materials, travel and logistic suppliers, while the remaining emissions were calculated with data from our own operations and databases" (page 55). Category 1 uses a hybrid approach with spend-based data covering approximately 78 percent of emissions (page 55).

Biogenic and excluded: biogenic CO2 reported separately was 3,456 tCO2e in 2025 against 401 in 2024 (page 55). Excluded scope 3 categories are upstream and downstream leased assets, processing of sold products and franchises, as "not relevant to Aker Solutions' business activities or are already incorporated in scope 1 and 2" (page 56). "No emission reductions from offset projects or purchased carbon credits were included in the scope 3 calculations" (page 55).

Restatement: category 15 "has been updated to include our ownership in SLB. The ownership in SLB has also been reflected in the 2023 and 2024 emissions data and results in an increase in the 2023 baseline. In 2026 the shares have been disposed" (pages 23, 54).

E1-9(was E1-7)GHG removals and GHG mitigation projects financed through carbon credits
Not Material
E1-10(was E1-8)Internal carbon pricing
Not Material
E1-11(was E1-9)Anticipated financial effects from material physical and transition risks and potential climate-related opportunities
Omitted

E2 – Pollution

E2-1Policies related to pollution
Reported

Policies related to pollution

Reference: page 63.

"Our policies and procedures are crafted to identify, manage, and mitigate material impacts. The primary potential impact related to pollution stems from spills, given our operations near or within marine environments. The policies and procedures are applicable across all of Aker Solutions operations. Aker Solutions' locations that could be affected are the construction and fabrication sites, either during our control or if the facilities are used by others" (page 63).

Four governing documents are tabulated, each mapped to the single material IRO, spills management (page 63):

  1. HSSE Policy - "Sets an ambition to prevent harm to the environment, people and assets and work together with key stakeholders, such as supply chain and customers to ensure this... prevent major hazards through process management and with the implementation of barriers."
  2. Aspect and Impact Procedure - "Describes evaluation of environmental aspects and impacts (A&I) to identify risks, opportunities, and mitigation actions for the project and locations... considers impacts that are controlled and/or influenced, as well as situations such as normal, abnormal, and emergency conditions." Owned by the Head of Environment.
  3. Emergency Management Procedure - "Procedure to manage and minimize environmental pollution, including emergency response and remediation. Incidents must be reported and escalated appropriately. Emergency plans are periodically tested." Owned by the Head of HSSE.
  4. Incident Follow-up and Case Handling Procedure - "Ensures transparency and learnings if there is an incident, including spills or discharges. If the incident is rated high or extreme, then the incident is considered reportable." Owned by the Head of HSSE.
E2-2Actions and resources related to pollution
Reported

Actions and resources related to pollution

Reference: page 64.

"Aker Solutions' approach to pollution management is on the prevention of pollution, and control of pollution in the event of unexpected events. In our operations, quay-side areas are also leased, which could also be of impact within our value chain" (page 64).

Pollution-related action plans (page 64):

  • "Project engineering utilizes the Best Available Technologies-process to reduce and minimize impact. This could be by introducing alternative chemicals, change of material or equipment to reduce effluents, depending on the cost benefit analysis including CapEx and OpEx assessments... This is conducted for all applicable projects, especially in the North Sea."
  • "The aspects and impacts register is updated annually by all sites and projects... The identified impacts are quantified, ranging from low to extreme, and an adequate level of mitigation is required before proceeding with any task." Requirements are integrated "into the design of products procured and produced through barrier management, and secondary storage is identified for the containment of any unexpected releases." There is "a focus on eliminating and substituting hazardous chemicals with less impactful materials where possible".
  • "All operational sites periodically test the emergency responses to spills for effectiveness and readiness", ensuring adequate supply of emergency kits.
  • "There are continuous inspections and audits conducted at the locations to ensure preventive measures identified are implemented as part of the ISO 14001 certification."
  • "In 2025, workshops were held to further improve the aspects and impacts process with the segments and improve the classification of impacts."

The sites with potential for spills are named in IRO-1: Stord, Verdal, Egersund and Sandnessjøen in Norway, "due to activities related to vessels and our operations in proximity to waterways" (page 34).

E2-3Targets related to pollution
Reported

Targets related to pollution

Reference: page 64.

"We do not have specific targets in place on pollution and spills. In 2025, we did not have any reportable spills and our ambition is to prevent spills in our operations. We continue to ensure the objectives of our polices through the actions identified in the pollution-prevention action plans" (page 64).

In the absence of a measurable target, effectiveness is tracked through the incident reporting system: "The governance on incident reporting covers the reporting of spills, leaks and discharges. This reporting is available to all employees and reported in Aker Solutions' reporting tool, Synergi. This allows for transparent management of spills and is tracked monthly for performance and internal reporting" (page 64).

Further monitoring routines sit in E2-2: annual updating of the aspects and impacts register by all sites and projects, periodic testing of spill emergency response at all operational sites, and continuous inspections and audits under the ISO 14001 certification (page 64).

E2-4Pollution of air, water and soil
Reported

Pollution of air, water and soil

Reference: page 64.

The material sub-topic is pollution of water only; the single material IRO is spills management, a potential negative impact in own operations and the value chain, medium term (page 62).

Nil return disclosed (page 64): "In reference to this database we have no spills that are reportable within our direct control or at our sites and discharges were within the limits for pollutants classified under Annex II of Regulation (EC) No 166/2006. This is supported by good operational control practices at the locations, and use of secondary containment to capture any potential spills. We also work closely with business partners to ensure the risk management process is utilized to prevent spills."

The datapoints table derived from other EU legislation carries the E2-4 row - "Amount of each pollutant listed in Annex II of the E-PRTR Regulation... emitted to air, water and soil, paragraph 28" - with a page reference to page 64 rather than a materiality note (page 104).

The company also states: "In 2025, we did not have any reportable spills and our ambition is to prevent spills in our operations" (page 64). No quantified pollutant amounts are tabulated, consistent with the nil position reported.

E2-5Substances of concern and substances of very high concern
Not Material
E2-6Anticipated financial effects from pollution-related impacts, risks and opportunities
Omitted

E4 – Biodiversity and Ecosystems

E4-1Transition plan on biodiversity and ecosystems
Omitted
E4-2Policies related to biodiversity and ecosystems
Reported

Policies related to biodiversity and ecosystems

Reference: page 66.

"The material impact related to biodiversity and ecosystems is addressed and mitigated by the following policies and procedures. The policies and procedures are applicable across all Aker Solutions operations" (page 66). All three are mapped to the single material IRO, impact on species population size.

  1. Sustainability Policy - "Describes our commitment to support the UN SDGs, Global Compact principles, and governs the overall prevention of environmental harm and ensures collaboration with relevant stakeholders to uphold these standards. Additionally, our policies mandate that projects include mitigation plans when operating in environmentally sensitive areas."
  2. HSSE Policy - "Promotes safe, reliable and sustainable operations. Focuses on our commitment to achieving zero harm to personnel, the environment and assets."
  3. Aspect and Impact Procedure - "Identifies environmental impacts related to projects and sites, including those related to biodiversity, ensuring these impacts are managed. This review process ensures a holistic approach to evaluation and mitigation of biodiversity impacts for our own operations." Owned by the Head of Environment.

The datapoints table derived from other EU legislation marks the E4-2 rows on sustainable land and agriculture practices (paragraph 24(b)), sustainable oceans and seas practices (24(c)) and policies to address deforestation (24(d)) as "Not Material" (page 105).

E4-3Actions and resources related to biodiversity and ecosystems
Reported

Actions and resources related to biodiversity and ecosystems

Reference: page 67.

"Relevant biodiversity-related requirements are incorporated into the environmental assessment process, including project design considerations and scope definition. These requirements are part of the project executions milestones. Biodiversity expectations are also communicated across the value chain to promote alignment with these requirements" (page 67).

The identification process behind these actions is described in IRO-1: "We conducted a screening of all operational sites to determine their proximity to key biodiversity areas and to identify any sites with impacts. In the downstream value chain, biodiversity assessments are integrated with the environmental impact assessments of the overall projects, and the requirements are integrated into the overall technical requirements. In Aker Solutions' upstream value chain, there is limited verification if and how our suppliers impact biodiversity. Our operations do not result in impacts to land degradation, desertification or soil sealing" (page 34).

Design-stage controls are covered under E4-SBM-3: structural designs and offshore work plans "are subject to the requirements established in the environmental impact assessments and relevant development approval processes that are conducted by the customer", with those criteria included in the design "in addition to the engineering controls that are inherent to the design and fabrication processes for operations of our customers that might be in key biodiversity areas (KBA)" (page 43).

No monetary resources are allocated or quantified for biodiversity actions.

E4-4Targets related to biodiversity and ecosystems
Reported

Targets related to biodiversity and ecosystems

Reference: page 67.

"We do not have specific targets related to biodiversity and ecosystem. Implementation of environmental aspects and impacts are monitored periodically, including those that address biodiversity. Where relevant, these considerations are integrated into project execution plans in the project to ensure that biodiversity aspects are managed" (page 67).

The disclosure closes with a cross-reference: "For further information on impact assessment and interaction with Aker Solutions' strategy, refer to SBM-3 in ESRS 2" (page 67).

In the absence of a measurable target, the tracking mechanism disclosed is the periodic monitoring of the environmental aspects and impacts register, which is "updated annually by all sites and projects to ensure all aspects and impacts are captured" (page 64), and the integration of biodiversity requirements into project execution milestones (page 67).

E4-5Impact metrics related to biodiversity and ecosystems change
Reported

Impact metrics related to biodiversity and ecosystems change

Reference: page 67.

"In line with our commitment to promoting sustainable business practices, Aker Solutions is devoted to mitigating adverse impacts on biodiversity and ecosystems. We have identified a potential negative impact related to biodiversity due to offshore operations in our value chain and the associated design of equipment placed in the marine environment.

At present, no biodiversity offset arrangements are in place" (page 67).

The single material IRO is "Impact on species population size - Offshore and engineering activities may reduce species population sizes", a potential negative impact in the value chain over the long term, under the sub-topic "Impacts on the state of species" (page 65).

No quantitative biodiversity metrics are given: there is no land-use figure, no count of sites in or near protected areas or key biodiversity areas, and no species-level measure. IRO-1 records that a proximity screening of all operational sites against key biodiversity areas was carried out and that "our operations do not result in impacts to land degradation, desertification or soil sealing" (page 34), but the screening result is not quantified.

E4-6Anticipated financial effects from biodiversity and ecosystem-related impacts, risks and opportunities
Omitted

E5 – Resource Use and Circular Economy

E5-1Policies related to resource use and circular economy
Reported

Policies related to resource use and circular economy

Reference: page 69.

"The material impact risks related to resource use and circular economy are addressed and mitigated by the following policies and procedures. The policies and procedures are applicable across all of Aker Solutions' operations" (page 69).

  1. Sustainability Policy - commitment to the UN SDGs and Global Compact principles, governing "the overall prevention of environmental harm", and including a "commitment to promote recycling, reuse and circular design in our solutions". IROs addressed: enhancing circular economy, resource inflows and consumption, resource outflows, waste management and segregation.
  2. HSSE Policy - "Promotes safe, reliable and sustainable operations... promotes efficient use of materials and energy and the design of products and services that have no undue environmental impact." Same four IROs addressed.
  3. Waste Management Procedure - "Prescribes a waste management hierarchy that is committed to an effective waste management system that conserves natural resources and minimizes environmental harm." Owned by the Head of Environment. IROs addressed: resource outflows, waste management and segregation.
  4. Management of Materials Reconciliation and Disposal of Surplus and Scrap Work Instruction - "Provides instructions on how to manage materials reconciliation and disposal of surplus and scrap." Owned by Supply Chain Excellence. IRO addressed: enhancing circular economy.
E5-2Actions and resources related to resource use and circular economy
Reported

Actions and resources related to resource use and circular economy

Reference: page 70.

"We are dedicated to minimizing waste and reducing the use of virgin materials in our purchased products. Some integration has already been achieved in the design and execution phases. However, there are still opportunities to enhance the reuse of project equipment, despite the challenges posed by the bespoke nature of our products" (page 70).

Actions in 2025 (page 70):

  • "Drone technology remains a priority for remote operations, especially offshore and in hard-to-access areas and supports circularity by enabling more efficient asset inspections and maintenance, helping extend asset life. In 2025, the drone program expanded offshore inspections, and is advancing toward fully remote flights."
  • "At the Verdal technology center, development continued on robotic technology for jacket production to optimize material use and improve efficiency."
  • "We are continuing to investigate the use of 3D printing and additive manufacturing to recycle and reuse materials."
  • "By reusing more materials across projects, we enhanced our resource utilization and achieved a reduction in waste." The reuse figure is given under E5-5: 10,711 tonnes of material reused in 2025 (page 71).

Resources (page 70): "No significant CapEx investments have been identified at this stage, as the initiatives described below are in a test phase and expected to be evaluated and potentially scaled over the next two years." Going forward the company "will review existing policies to implement a more holistic approach towards the value chain and work to integrate circular design and resource efficiency into the early phases of the projects".

E5-3Targets related to resource use and circular economy
Reported

Targets related to resource use and circular economy

Reference: page 70.

"We do not have targets or metrics in place related to resource use and circularity. Over the next two years, project leads will track the resource use and circularity actions to determine their effectiveness and viability" (page 70).

In the absence of targets, the effectiveness mechanism disclosed is project-level tracking by project leads over a two-year horizon, with the initiatives described as being "in a test phase and expected to be evaluated and potentially scaled over the next two years" (page 70).

The company also commits to a policy review: "Going forward, Aker Solutions will review existing policies to implement a more holistic approach towards the value chain and work to integrate circular design and resource efficiency into the early phases of the projects. Our initiatives are designed to address the entire lifecycle of our products, from design to end-of-life" (page 70).

Progress is nonetheless measured through the E5-4 and E5-5 metrics, where the recycled and secondary content of inflows fell from 18.2 percent in 2024 to 8.6 percent in 2025, while materials repurposed in new projects rose from 980 to 10,771 tonnes (pages 70-71).

E5-4Resource inflows
Reported

Resource inflows

Reference: pages 70-71.

"Aker Solutions' inflows are materials that are purchased to fabricate relevant products and services. Of these, the main inflow materials are steel and metals" (page 70).

Resource inflows20242025
Total weight of materials used (tonnes)106,10085,576
Percentage of biological materials0.0%0.0%
Weight of secondary reused or recycled components (tonnes)19,2897,333
Percentage of secondary reused or recycled components18.2%8.6%
Weight of materials repurposed in new projects (tonnes)98010,771

"Aker Solutions utilized approximately 85,576 tonnes of materials and products in 2025. This includes bulk raw materials, components, consumables and equipment. The weight of the recycled and secondary materials is estimated at 7,333 tonnes (8.6 percent). There are no biological materials utilized in the inflows" (page 70).

Materials named: the IRO-1 screening grouped major materials "at article level" into four categories - "bulk steel, stainless steel, aluminium and carbon steel pipes" (page 34).

Methodology (pages 70-71): weights come from the procurement database for products purchased in the reporting year. "Recycled content: The information provided is an estimate based on industry average values for the metal sector in Europe, like steel, stainless steel and aluminium... Data is supported by the secondary material information from available raw material EPDs." Secondary material content was verified using the EcoInvent v3.10 database (page 34). "All materials are accounted for once, when delivered. Any internal processing is identified through the procurement system to prevent double counting", and "Materials are traceable though an established tagging system". The key assumption is stated openly: "There were no calculations with product specific or supplier specific recycled content rates" (page 71).

E5-5Resource outflows
Reported

Resource outflows

Reference: page 71.

"Aker Solutions' outflows are related to circularity elements of deliverables to customers and disposal/reuse of materials at the end of life, decommissioning activities to extract materials for recirculation into other industries and waste generated from our production processes" (page 71).

Products (page 71): "The products we deliver are tailored to specific design requirements... Generally, the macro structures have a lifespan of 20 years, which can be extended with refurbishment and needs." Materials and equipment for maintenance and modification work, including cables and electronic components, "based on the inflows in 2025, have a recyclability content of approximately 9 percent, compared to 18 percent in 2024".

Reuse (page 71): "In 2025, we made a greater effort to reuse materials from old projects instead of recycling or disposing of these materials. As a result, we reused 10,711 tonnes of material, which is higher than the prior year."

Decommissioning (page 71):

  • "Outflow of materials from decommissioning activities: 18,599 tonnes compared to 15,302 tonnes in 2024"
  • "Recycling content: 90 percent of materials, mainly comprising of metal structures, compared to 91 percent in 2024"

Methodology (page 71): outflow information is based on project engineering information on product reliability, durability and lifetime expectancy for projects delivered in the year; "Decommissioning data is provided by suppliers based on material composition and handling, measured by weight for the reporting year"; and "Waste data is reported per site on waste usage for the reporting year".

E5-6Anticipated financial effects from resource use and circular economy-related impacts, risks and opportunities
Omitted
E5-5(was E5-5-Waste)Waste
Reported

Waste

Reference: pages 71-72.

"In 2025, Aker Solutions generated 21,535 tonnes of waste, compared to 19,117 tonnes in 2024, an increase of 12.6 percent. The waste reported is from our direct operations and includes decommissioning projects" (page 71).

Top three waste categories (page 71):

Category20242025
Metal waste, includes residual from fabrication/construction activities36.6%39.9%
Residual waste, includes sandblasting residues that are sent to landfill32.7%36.4%
Wood waste, includes packaging material14.2%14.7%

Hazardous waste (page 71): "In 2025, Aker Solutions generated 1,077 tonnes of hazardous waste" (2,284 tonnes in 2024). "We did not generate any radioactive waste as defined in Article 3(7) of Council Directive 2011/70/Euratom." Hazardous waste generated "includes electronic waste".

Recycling (page 71): "The overall recycling factor, excluding hazardous waste, was 51.0 percent, with 10,443 metric tons of total waste recycled. The non-recycling rate, including hazardous waste, stood at 50.4 percent, highlighting further opportunities to improve circular waste management practices."

Treatment breakdown, non-hazardous waste, tonnes (page 72): total 20,458 (2024: 16,833); recycled 10,443 (8,931); non-recycled 10,015 (7,902); reuse 15 (67); composting 560 (213); landfill 3,119 (2,279); incineration without energy recovery 2 (3); incineration with energy recovery 6,306 (5,324); other 13 (16). For hazardous waste, treatment handled by a waste company 112 tonnes, recycling 232, incineration with energy recovery 584, landfill 37, other 112 (page 72).

The material IRO behind the disclosure is "Waste management and segregation - Improper segregation and lack of resource reuse in waste generation and management could result in environmental harm", a potential negative impact in own operations over the medium term (page 68).

S1 – Own Workforce

S1-1Policies related to own workforce
Reported

Policies related to own workforce

Reference: page 75.

Eight governing documents are tabulated, each mapped to the S1 IROs it addresses (page 75):

  • Code of Conduct - overall commitments on compliance and ethical business practice. IROs: diversity imbalance and discrimination, workplace harassment.
  • Human Rights Policy - "Applicable to own workforce and aligned with the International Bill of Rights and the International Labor Organization Fundamental Conventions... The policy also states that the company has a zero-tolerance approach to modern slavery and human trafficking as well as child and forced labor." IROs: work-life balance, diversity imbalance and discrimination, gender pay gap, workplace harassment.
  • People Policy - "Describes Aker Solutions' commitment to the principles of non-discrimination and equal opportunity regardless of gender, age, nationality, or other factors." IROs: work-life balance, well-managed workforce, diversity imbalance and discrimination, gender pay gap, workplace harassment, training and skills development.
  • HSSE Policy - IROs: work-life balance, health and safety impacts.
  • Global Framework Agreement - "Aker Solutions has committed to respecting and supporting fundamental human rights and trade union rights including collective bargaining rights, payment of living wage, health and safety and other employment condition. Agreement is for Aker ASA portfolio of companies." IROs: collective bargaining rights, employee engagement.
  • Housing Procedure - "Ensuring adequate housing of workers by setting standards and procedures for identifying and rectifying any deficiencies. Owned by the facility function in the Yards." IRO: adequate housing.
  • Employee Survey Procedure - owned by the business process manager for Engagement Surveys. IRO: employee engagement.
  • Global Whistleblowing Procedure - IROs: adequate housing, health and safety impacts.
S1-2Processes for engaging with own workforce and workers' representatives about impacts
Reported

Processes for engaging with own workforce and workers' representatives

Reference: page 76.

"Aker Solutions engages both directly with our workforce and through workers' representatives... We employ a variety of methods, such as digital surveys for broad input, interactive workshops for in-depth discussions and formal meetings with workers' representatives. This engagement occurs on a quarterly basis, and additionally, as needed" (page 76).

Employee survey (page 76): "Our main employee survey was distributed to all employees three times in 2025. The survey is comprised of twelve short statements, of which half address employee motivation and engagement while the other half address collaboration and organizational conditions." Results are discussed by line managers and teams, and "are also discussed in company democracy forums with union and safety representatives to ensure stakeholder engagement".

Working Environment Committee (page 76): "The goal of Aker Solutions' Working Environment Committee (WEC) is to progress and implement a safe working environment in the company... Leadership of the committee alternates between Aker Solutions management and employees every second year... The chief safety representative is a permanent member, while other employee representatives are chosen by the trade unions... The WEC meets at least four times per year." There is "one corporate WEC and sub-committees per segment".

2025 initiatives (page 76): the 'Our Core' booklet was introduced to build a common culture; and following a 2024 DEI survey and inclusive e-learning modules, "A new DEI survey was launched in January 2026 to capture progress and identify new areas of focus."

S1-2(was S1-3)Processes to remediate negative impacts and channels for own workforce to raise concerns
Reported

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

Reference: page 76.

"Aker Solutions works to build a culture of trust where employees feel comfortable to ask questions, seek guidance, raise concerns and report suspected breaches or violations. Our whistleblowing channel allows employees and external parties to report concerns, incidents, breaches or suspected breaches of internal policies, or laws and regulations" (page 76).

"Aker Solutions is committed to ensuring that our workforce is not only aware of but also trusts the structures and processes in place for raising concerns or needs" (page 76). The disclosure cross-refers to G1-1 and G1-3 for the channel and procedure (page 76).

The Global Whistleblowing Procedure is described in the governing documents chapter: reporting is possible for anyone including external parties via the company website or a dedicated mailbox; "Whistleblowers are protected from retaliation and may report anonymously"; "All notifications are received and managed, with strict confidentiality, by the C&I department, which has a mandate from the Board to investigate suspected compliance and Code of Conduct violations"; and the procedure was "Developed in compliance with Norwegian laws, including the Working Environment Act and Data Protection Act/General Data Protection Regulation (GDPR)" (page 41).

Volumes are reported under G1-3: "There were 75 reports recorded in 2025, compared to 49 reports in 2024. Around half of the received reports in 2025 concerned employee relations and human resources issues" (page 97). Remediation of workforce impacts is set through the local and corporate working environment committees (page 77).

S1-3(was S1-4)Taking action on material impacts on own workforce
Reported

Taking action on material impacts on own workforce

Reference: pages 77-78.

(a) Preventing and mitigating negative impacts (page 77): regular risk assessments, safety protocols and ongoing training; a dedicated health team covering mental health and well-being; and worker housing standards - "We set minimum standards for worker housing that ensure clean, safe and well-maintained living conditions, with regular cleaning, laundry changes, maintained common areas, and 24/7 reception, safety checks and building oversight", with catering, welfare facilities, lounges, TV rooms, gym and leisure spaces. "Following any actual incidents an investigation will be performed and actions identified to correct any defects and/or actions to prevent reoccurrence."

(b) Remedial actions (page 77): "Actions are discussed and set between management and employee representatives through local working environment committees as well as on the company wide or regional level in the corporate working environment committee."

(c) Initiatives for positive impact (page 77): "career development programs, flexible working arrangements and initiatives that promote work-life balance".

(d) Tracking effectiveness (page 77): "employee satisfaction surveys, health and safety records and performance evaluations".

Material opportunities (page 77): the #SKILLS competency lift project, launched in 2022, provides "access to world-class online learning content, such as Coursera", with university and partner collaborations. "On average, our employees spent 12.3 hours each on formal training in 2025 (up from 10.3 in 2024)." Since 2020 the company has delivered the industry Always Safe programme of quarterly safety modules, and in 2025 "we held Always Home Safely events globally to reinforce our HSSE culture" (pages 77-78).

Resources (page 78): "We have a dedicated team of HSSE advisors across the globe which is regularly reviewed against the business need and workload. HR also supports our key projects... A centralized learning function supports the business with both operational and strategic competence development." Certification to ISO 45001 and ISO 14001 underpins the management system, with "regular internal audits at location level and an annual external audit" (page 78).

S1-4(was S1-5)Targets related to own workforce
Reported

Targets related to own workforce

Reference: pages 78-79.

"We have an annual HSSE plan which includes targets aimed at reducing negative impacts on our workforce year on year. The targets are anchored with our executive management team and ultimately approved by our CEO" (page 78).

Health and safety targets (page 78):

MetricTarget 2025Actual 2025Target 2026
SIF (serious incident frequency)0.270.220.27
TRIF (total recordable injury frequency)2.22.72.7
Sick leave<4.0%4.3%4.0%

SIF was met (0.22 against a target of 0.27, and 0.28 in 2024): "These incidents were near misses and none resulted in injury to personnel." TRIF missed: "This exceeded our target but was reflective of a record high number of exposure hours in operational areas. The performance prompted a number of corrective activities, plans and initiatives to improve the negative trend." Sick leave missed at 4.3 percent, "partly due to two influenza seasons in 2025" (page 78).

Gender balance target (page 79): Aker Solutions "has a target to achieve gender balance" (footnoted as "no gender <40%") "among our top 200 leaders by 2030". The target "was decided by our executive management team and launched in early 2024". Progress: "By year end 2025, 30 percent of our top 200 leaders were female, compared to 27 percent at the end of 2024. We reached our 2025 target of a gender balanced graduate recruitment."

Process (page 79): targets are set with stakeholder groups including the Working Environment Committee; performance is measured "using a balanced scorecard"; and lessons are identified using the Kelvin Topset root cause method, shared through monthly HSSE reports.

S1-5(was S1-6)Characteristics of the undertaking's employees
Reported

Characteristics of the undertaking's employees

Reference: pages 79-80.

"As of December 31, 2025, Aker Solutions had 11,818 employees located in 14 countries" (page 79).

By gender, headcount (page 79): male 9,094; female 2,639; other 0; not reported 85. Total 11,818 (2024: 11,777).

By contract type, headcount (page 80):

20242025
Permanent employees11,30311,276
Temporary employees454542
Non-guaranteed hours employees2019
Full-time employees11,59211,623
Part-time employees185195

By country, at least 50 employees (page 79): Norway 9,216; India 1,159; UK 465; Canada 379; Brunei 304; Malaysia 155. Norway, the only country with more than 10 percent of the workforce, is broken out separately: 8,747 permanent, 387 temporary, 19 non-guaranteed hours, 8,964 full-time and 170 part-time (page 80).

Turnover (page 79): "During 2024, 874 employees left the company, or 7.4 percent of employees. During 2025, 794 employees left the company, or 7.0 percent of employees."

Methodology (page 80): "Employee numbers are reported on headcount and at the end of the reporting period, December 31, 2025. Employees not reported in SAP are not included and diversity information, including gender, is not available. For 2025 there were 85 employees not reported in SAP (3 in Brazil and 82 in Norway)." Non-guaranteed hours employees "are summer interns".

S1-6(was S1-7)Characteristics of non-employee workers
Omitted
S1-7(was S1-8)Collective bargaining coverage and social dialogue
Reported

Collective bargaining coverage and social dialogue

Reference: page 81.

"Approximately 60 percent of Aker Solutions' global workforce was covered by collective agreements in 2025, which is the same as the 60.0 percent in 2024. Collective bargaining takes place at a frequency agreed with the local unions" (page 81).

"Aker Solutions' sites that are covered by unions are Norway, Sweden, Finland and Canada. The UK, USA and Canada recognize all unions, but due to legislation, union membership is not registered in the company's HR records" (page 81).

The coverage and social dialogue tables report Norway - the only country with more than 50 employees representing more than 10 percent of total employees - in the 80-100 percent band for employee coverage in the EEA and for workplace representation. "Aker Solutions does not have more than 50 employees representing more than 10 percent of total employees in any non-EEA countries" (page 81).

"Aker Solutions has maintained a Global Framework Agreement for several years, and our latest global works council agreement was revised in 2023. Discussions with employee representatives cover topics such as Aker Solutions' people strategy, policies and procedures. Key focus areas include health and safety, standards for decent work, human rights, labor rights and compliance" (page 81).

"In Norway, non-organized workers typically benefit from the same compensation adjustments negotiated at the industry level... In regions where union representation is not so common, we use the global work council set-up to discuss worker management relations to ensure fair treatment." The company also reports: "In 2025, there were no strikes exceeding one week and no lockouts" (page 81).

S1-8(was S1-9)Diversity metrics
Reported

Diversity metrics

Reference: page 82.

Top management gender diversity (page 82). The definition is stated: "For the purpose of disclosing gender diversity at the top management level, Aker Solutions adheres to the definition of one and two levels below the supervisory bodies. This includes our CEO, executive management team and their direct reports."

Gender20242025
Female23 (33.3%)24 (36.4%)
Male46 (66.7%)42 (63.6%)
Other0 (0.0%)0 (0.0%)
Not reported0 (0.0%)0 (0.0%)

Age distribution across the workforce (page 82):

Age group20242025
Under 30 years old2,017 (17.1%)1,952 (16.5%)
30-50 years old5,650 (48.0%)5,668 (48.0%)
Over 50 years old4,025 (34.2%)4,113 (34.8%)
Unreported age85 (0.7%)85 (0.7%)

Board-level diversity is disclosed under GOV-1: six male members (55 percent) and five female members (45 percent), with four independent members (36 percent) (page 24). The S1-5 target of gender balance among the top 200 leaders by 2030 stood at 30 percent female at year-end 2025, against 27 percent at the end of 2024 (page 79).

S1-9(was S1-10)Adequate wages
Not Material
S1-10(was S1-11)Social protection
Not Material
S1-11(was S1-12)Persons with disabilities
Omitted
S1-12(was S1-13)Training and skills development metrics
Omitted
S1-13(was S1-14)Health and safety metrics
Reported

Health and safety metrics

Reference: page 82.

Health and safety metrics20242025
Own workforce covered by the health and safety management system100%100%
Fatalities from work-related injuries and work-related ill health00
Recordable work-related accidents for own workforce106122
Rate of recordable work-related accidents (TRIF)2.52.7
Sick leave4.1%4.3%

"Health and safety metrics are calculated based on actual data from incident reports and timesheets. Rates are calculated per million man hour. The rate of recordable work-related accidents is based on total man hours in 2025 of 44,591,759" (page 82).

Scope (page 82): "Apart from sick leave, Aker Solutions' reporting includes employees and non-employees and follows the methodology prescribed in the ESRS application requirements for these metrics." The HSSE management system "includes requirements for all employees (full-time, part-time and temporary staff), external personnel, suppliers and visitors working or visiting all Aker Solutions locations" and "is certified to ISO 45001".

Sick leave methodology (page 83): "Sick leave represents workdays lost due to illness and is reported for own employees only. Calculation of sick leave percentage is based on the ratio of sick leave work hours to planned work hours... Data from entities not in SAP is not included in the report (e.g. China)." Reported figures include monthly total, long-term (more than 16 consecutive days) and short-term sick leave. A country-specific caveat is given: "In some countries, such as India, the concept of a formal medical sick leave certificate does not exist... This is registered as casual leave in accordance with local regulations."

Serious incident frequency (SIF) was 0.22 in 2025 against 0.28 in 2024 and a target of 0.27 (page 78).

S1-14(was S1-15)Work-life balance metrics
Omitted
S1-15(was S1-16)Compensation metrics (pay gap and total compensation)
Reported

Compensation metrics (pay gap and total compensation)

Reference: page 83.

Gender pay gap (page 83):

20242025
Number of male employees in data pool7,9397,866
Number of female employees in data pool2,2412,278
Gender pay gap7.0%6.0%

Total compensation ratio (page 83): "The remuneration ratio of our highest paid individual (CEO in Norway) to the median annual total remuneration for all employees (excluding the highest-paid individual) is 14:1. In 2024, the remuneration ratio was 15:1. This ratio does not account for cost-of-living adjustments, local market rates and economic conditions."

Methodology (page 83): "The data pool in the gender pay gap and the total compensation ratio analysis includes active employees, who worked the full year from year-end 2024 to year-end 2025, encompassing both permanent and temporary office and non-office workers. Due to the size and limited number of females in some office locations, the 2025 analysis includes employees from our larger locations; Aker Solutions offices in Norway, India, Brunei, Malaysia, Canada and UK." The gap "shows the percentage difference in male-female gross earnings based on contractual yearly hours", with pay components covering "Base salary, overtime pay, shift premiums, allowances and bonuses".

The data pool of 10,144 employees for 2025 is smaller than the 11,818 total headcount, so the metric does not cover the whole workforce. Separate statutory disclosures are cross-referenced: "The UK pay gap is reported in accordance with UK government requirements and is published on Aker Solutions' webpage. The Norwegian pay gap reporting requirements under Norwegian Equality and Discrimination Act methodology (ARP) is reported in the ARP section at the end of the annual report" (page 83).

S1-16(was S1-17)Incidents, complaints and severe human rights impacts
Reported

Incidents, complaints and severe human rights impacts

Reference: page 83.

"During 2025, there were 2 cases reported of alleged discrimination, including harassment. One of the cases was concluded as partly substantiated and the other case is currently still subject to internal investigation" (page 83).

"Our monitoring has not revealed severe human rights incidents connected to our workforce" (page 83).

"Aker Solutions firmly opposes all forms of human trafficking, slavery, servitude, forced labor and any related activities, as clearly stated in our Human Rights policy" (page 83).

No fines, penalties or compensation for damages arising from workforce incidents are reported, and no separate figure is given for complaints filed through the whistleblowing channel that relate to own workforce discrimination or harassment specifically. Total whistleblowing volumes are reported under G1-3: 75 reports in 2025 against 49 in 2024, of which "Around half of the received reports in 2025 concerned employee relations and human resources issues" (page 97).

The related material IROs are workplace harassment - "Instances of harassment, whether verbal, physical, or sexual, can cause severe deterioration in employee well-being and safety", a potential negative impact over the short term - and diversity imbalance and discrimination (page 74).

S2 – Workers in the Value Chain

S2-1Policies related to value chain workers
Reported

Policies related to value chain workers

Reference: pages 85-86.

Scope (page 85): potential material impacts cover on-site contractors, upstream workers "involved in the extraction, refining and manufacturing stages, particularly in the sectors of metal and mineral extraction", downstream logistics and distribution workers, joint venture workers, and "Vulnerable groups: This includes migrant workers, home workers, young workers and women". High-risk geographies are named: "China, United Arab Emirates and Angola, where we source commodities including logistics, manufacturing and onward subcontractor management. The main risks here are forced labor and lack of social dialogue including ability to unionize and collectively bargain."

Supplier risk tiering (page 85): "Every supplier is reviewed and awarded a risk score from level 1 to level 4. The risk score denotes which policies the supplier must sign and adhere to." The supplier declaration applies to Level 2 to Level 4 suppliers, requires "sign-off from a senior leader" and must be cascaded down their own value chain; "In 2025 the supplier declaration was updated to note confidentiality and improve clarity of commitment." A new Supply Chain Sustainability procedure was created in 2025, combining several existing documents "under one umbrella".

Documents tabulated with the IROs each addresses (page 86): Code of Conduct; Business Integrity Policy; Human Rights Policy; Country risk procedure ("Reduce the risk exposure of Aker Solutions when conducting business in countries associated with high corruption, reputational and/or political risks"); HR Global recruitment principles; Business partner qualification and integrity due diligence procedure; Supplier approval procedure; Terms and conditions for suppliers; Business ethics training procedure; Global whistleblowing procedure; and Supply chain sustainability. The country risk, recruitment and business partner procedures are each mapped to child labour and forced labour in the supply chain.

"Our policies are based on well-known international guidelines, such as the UN Guiding Principles on Business and Human Rights, the ILO Declaration, and the OECD Guidelines", and statements are published under the UK Modern Slavery Act and the Norwegian Transparency Act (page 87).

S2-2Processes for engaging with value chain workers about impacts
Omitted
S2-2(was S2-3)Processes to remediate negative impacts and channels for value chain workers to raise concerns
Omitted
S2-3(was S2-4)Taking action on material impacts on value chain workers
Reported

Taking action on material impacts on value chain workers

Reference: pages 87-89.

2025 performance (page 87): "We reviewed and audited our value chain and investigated all whistleblower reports... The last on-site check at a key partner in the UAE was completed, and we expect the final report in early 2026." With several major projects moving into construction, "An external audit was done at one of our yards in Q3, and in Q4, we reviewed contracts and wage slips from over 30 resource companies. No major findings were identified, and all improvement opportunities were addressed quickly. Over 120 human rights evaluation forms from suppliers in 13 countries were completed, reviewed and followed up as needed." In addition, "Aker Solutions conducted a heightened due diligence in Israel, following Norwegian authority recommendations as a result of the ongoing conflict in this country. Following this, we have not identified an increased risk."

Approach (page 87): the company's "approach to human and workers' rights management is based on the OECD Due Diligence Guidance for Responsible Business Conduct".

Remedial actions (page 88): joint action plans agreed with suppliers, monthly then quarterly status reports, actions "only be marked as complete by a verified third party", with quarterly internal reporting to the Audit Committee, which "will decide if a dedicated member of staff is required on site to help close out actions, improve the overall standard of work and enhance visibility of on site activity".

Prioritisation process (page 88): five decision points - activity (only countries or companies with annual spend above NOK 1 million), country risk from an independent source, risk to people, connection to Aker Solutions, and supplier category. Primary stakeholders (VP sustainability and compliance, compliance officer, supply chain excellence, sustainable supply chain specialist) "will meet annually to review the prioritized list of suppliers", budget is cross-checked "against the scale of activity desired", and progress on the resulting action plan "will become one of the checkpoints in the following year's supplier assessment".

Outcomes (pages 87, 89): "During the reporting period, there were no reported cases of non-compliance with international standards in our value chain"; "No significant human rights cases were found in 2025"; and "No new major human rights issues were recorded in 2025".

S2-4(was S2-5)Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities
Reported

Targets related to value chain workers

Reference: page 89.

"While Aker Solutions does not have measurable targets for workers in the value chain, the following are focus areas for 2026 and will help us continuously improve to avoid harm to people" (page 89):

  • "Continued risk-based operationalization of the human rights framework in the supply chain"
  • "Continued awareness and competence building on human rights and business for our employees"
  • "Carry-out risk-based human rights and worker-centric audits of selected suppliers based on established plan"
  • "Enhance collaboration with key external stakeholders to ensure a lasting positive impact on human rights and working conditions for identified higher risk areas of common supply chains"

One quantified commitment is given: "Aker Solutions will continue to assess human rights at supplier onboarding and maintain a 100 percent completion of this" (page 89).

Effectiveness tracking in the absence of targets (page 89): "The effectiveness of Aker Solutions policies is monitored through our deviations process which captures any supplier that requests an exception to our policies and processes. The exceptions are manually reviewed on a case by case basis and recorded centrally. Over time the key stakeholder groups can review and assess if changes to any documentation should be made. In 2025 we are satisfied that our policies and processes are evolving at a pace that keeps the content effective and relevant."

The company also states that it "will not add to the focus areas highlighted below for 2026" in order to "maintain a worker focus and remain reactive to any human rights findings" (page 89).

S3 – Affected Communities

S3-1Policies related to affected communities
Reported

Policies related to affected communities

Reference: page 91.

"Aker Solutions does not have a policy in place for affected communities, however we work to communicate proactively, openly, transparently and consistently about status for ongoing business and operations as well as expected future development for our operations. In addition, Aker Solutions strives to be a desired neighbor in the communities where we have business activities" (page 91).

The gap is partly covered by the Human Rights Policy: "Our comprehensive Human Rights Policy follows the UN Guiding Principles on Business and Human Rights, including the eight fundamental conventions identified in the Declaration of the International Labor Organization and the International Bill of Human Rights. The policy also declares that the company shall conduct its business with integrity, respecting the laws, cultures, dignity and rights of individuals in all countries where we operate, with the ambition that our operations do not cause or contribute to any infringement of human and labor rights" (page 91).

The single material IRO is a positive one: "Local community value creation - Creating jobs and investing in initiatives that boost regional development helps support local communities", an actual positive impact in own operations over the medium term (page 90).

The datapoints table derived from other EU legislation carries the S3-1 row on non-respect of the UNGPs, ILO principles or OECD guidelines with a page reference to page 91 (page 108).

S3-2Processes for engaging with affected communities about impacts
Reported

Processes for engaging with affected communities

Reference: page 91.

"The responsibility for dialogue with local stakeholders sits with the EVP for each specific location. The day-to-day implementation of the ongoing dialogue is managed by the communications and/or human resource functions at the specific locations" (page 91).

"Aker Solutions' whistleblowing channel is anonymous and open to anyone. In addition, our website has an option to send feedback, comments and questions to communications staff in our locations around the world" (page 91).

"At several key locations, we also host information sessions for local businesses, potential suppliers, and subcontractors. These sessions may be organized by Aker Solutions alone or in collaboration with clients or trade organizations. Their purpose is to provide insight into supplier opportunities with Aker Solutions, ranging from general updates on company status and outlook to project-specific needs. During these meetings, we share details on upcoming project opportunities and communicate our expectations regarding HSSE, quality and compliance" (page 91).

S3-SBM-3 identifies the communities concerned: "Aker Solutions has fabrication yards in Egersund, Sandnessjøen, Stord and Verdal, which are key communities where the company has a potential positive impact on value creation through activities including employment opportunities, supporting local suppliers and boosting regional economies. The company actively engages with these communities to learn about their expectations and to create lasting benefits" (page 43). Engagement type, frequency and topics are cross-referenced to SBM-2 (pages 31, 35).

S3-2(was S3-3)Processes to remediate negative impacts and channels for affected communities to raise concerns
Omitted
S3-3(was S3-4)Taking action on material impacts on affected communities
Reported

Taking action on material impacts on affected communities

Reference: page 91.

"Aker Solutions engages with local public authorities and local businesses in and around key locations where we have potential for positive impact. Such contact is adapted to local conditions but typically includes engagement in local business associations and with local authorities to present forecasts for employment opportunities, as well as dialogue with local schools to communicate opportunities for apprenticeships and jobs" (page 91).

Tracking effectiveness (page 91): "Effectiveness of our actions is informally monitored through community engagement meetings. In addition, Aker Solutions participates in regional business associations with local authorities and stakeholders. Opportunities and potential risks are reported to site management and, if relevant, to corporate management."

The action relates to the single material IRO, local community value creation, an actual positive impact in own operations over the medium term (page 90). S3-SBM-3 frames the intent: "We want to be seen as a good employer and neighbor, known for responsible business practices, creating jobs and adding value for customers, owners, employees and society. In places where Aker Solutions has a significant impact, we talk with local stakeholders to understand their needs and concerns" (page 43).

No monetary resources are allocated or quantified for community actions, and no community investment figure is reported. The datapoints table derived from other EU legislation marks the S3-4 row on human rights issues and incidents (paragraph 36) as "Not Material" (page 108).

S3-4(was S3-5)Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities
Reported

Targets related to affected communities

Reference: page 91.

"No targets have been set in relation to the material opportunity of local community value creation" (page 91).

The same position is stated within S3-4: "While Aker Solutions does not have any targets in place for local community value creation, we strive to engage in dialogue with relevant stakeholders to understand their views and identify how opportunities and challenges can best be addressed. As much as possible, we communicate proactively, openly and transparently about status and planned further development for our operations" (page 91).

In the absence of targets, the tracking mechanism disclosed is informal: "Effectiveness of our actions is informally monitored through community engagement meetings. In addition, Aker Solutions participates in regional business associations with local authorities and stakeholders. Opportunities and potential risks are reported to site management and, if relevant, to corporate management" (page 91).

The single material S3 IRO is local community value creation, an actual positive impact in own operations over the medium term, at the fabrication yards in Egersund, Sandnessjøen, Stord and Verdal (pages 43, 90).

G1 – Business Conduct

G1-1Business conduct policies and corporate culture
Reported

Business conduct policies and corporate culture

Reference: pages 94-95.

Seven governing documents are tabulated against the material G1 IROs (page 94): Code of Conduct (political engagement activities, deficiency in whistleblower protection, mismanagement of global supply chain, corruption and bribery, breach of data privacy and protection); Business Integrity Policy (corruption and bribery, breach of data privacy and protection, political engagement activities, mismanagement of global supply chain); HSSE Policy (lack of effective emergency response); Data Protection and Information Security Policy (breach of data privacy and protection), owned by the EVP Strategy and Technology; Global Whistleblowing Procedure (deficiency in whistleblower protection, corruption and bribery); Supplier Declaration (mismanagement of global supply chain), owned by Supply Chain; and the Enterprise Risk Management System and Procedures (unstable commodity and resource availability).

"We shall exercise zero tolerance for corruption and bribery and maintain an effective and risk-based anti-corruption compliance program as mandated by our Code of Conduct and Business Integrity Policy" (page 95).

Training (page 95): "Business ethics training is one of Aker Solutions' key initiatives to prevent corrupt and unethical behavior." Methods are an introduction to business integrity e-learning for new employees, in-person training for high risk roles or locations, an annual mandatory Code of Conduct e-learning, and targeted training for high risk roles. "For the purpose of our annual mandatory Code of Conduct e-learning, all office employees are defined as high risk roles."

Whistleblower protection (page 95): "Aker Solutions does not tolerate retaliation against anyone who speaks up in good faith." A gap analysis found no legal deviations; an integrity survey on speaking up was run in the first half of 2025 with another planned for Q1 2026. "Aker Solutions' whistleblowing procedure was updated during 2025 and will be implemented in the first quarter of 2026", complying with changes to the Norwegian Labor Code and "reviewed in the context of the EU Whistleblowing Directive: (EU) 2019/1937".

The Code of Conduct "is endorsed by the Board of Directors and is reviewed and approved by the Board every third year (most recent review was November 2024)" and "applies to all suppliers" (page 40).

G1-2Management of relationships with suppliers
Reported

Management of relationships with suppliers

Reference: page 96.

"In Aker Solutions, supplier relationships are handled by our supply chain function. Coordination meetings are held when necessary. As Aker Solutions is a project driven company with several established suppliers, a strong and transparent relationship is important to secure project execution" (page 96).

Payment practice in supplier relationships (page 96): "Aker Solutions regularly follows up on accounts payable to ensure timely and accurate payments. Our service provider assists by providing detailed accounts payable reports, including aging analysis and information on approvers... We do not distinguish between the size or segment of our suppliers, ensuring fair and consistent payment practices across all our supplier relationships."

Social and environmental criteria (page 96): "we look for and work with suppliers and subcontractors who act responsibly within environmental, social and governance areas. Hence, we require that they adhere to our supplier declaration including our standards for compliance and business ethics, health and safety, human and labor rights, environment, quality management, and corporate social responsibility."

Approved vendor list (page 96): "Our approved vendor list serves as the foundation for qualifying and monitoring our supplier base. Compliance with our standards is monitored and evaluated through a defined process, technical audits and due diligence analyses, of which the extent depends on the risk profile... The stringency of qualification requirements may be adjusted based on factors such as the complexity of the product or service needed and the supplier's country or location. The onboarding process includes a variety of checks related to HSSE, human rights and anti-corruption, and environmental and sustainability goals."

The four-level supplier risk scoring that determines which policies a supplier must sign is described under S2-1 (page 85).

G1-2(was G1-3)Prevention and detection of corruption and bribery
Reported

Prevention and detection of corruption and bribery

Reference: pages 96-98.

"Aker Solutions' compliance program is managed by the compliance and integrity function and has an independent reporting line to the Audit Committee... The compliance and integrity function reports quarterly to the Audit Committee on the design, implementation and effectiveness of the company's business integrity program... Once a year, in the third quarter, the Audit Committee meets separately with the head of compliance and integrity without members of management present" (page 96).

The programme has three elements - preventive, detective and responding measures - and includes "Periodic compliance risk assessments", policies and procedures, "Regular and systematic training", "an annual internal controls self-assessment done on all locations globally including a follow up and spot checks", "Risk-based internal audits", speak-up and whistleblowing processes, and business partner and third party risk management (page 96).

Risks identified at the end of 2025 (page 97): business partners in terms of corruption and integrity; geopolitical situation and use of tools such as sanctions and export control; potential breaches of human rights through the supply chain; and potential breaches of data protection and privacy. "Aker Solutions performs integrity due diligence of our customers, suppliers and other business partners such as joint venture partners, third-party representatives and alliance partners."

Training completion (page 97):

20242025
Own employees completing Code of Conduct e-learning8,4857,902
Percent of target group completing96.0%94.0%
Percent of total employees completing72.0%66.9%
Completing Introduction to Business Integrity e-learning3,8402,488
Trained by Compliance & Integrity team on business ethics836309

Whistleblowing volumes (page 97): "There were 75 reports recorded in 2025, compared to 49 reports in 2024", equal to 0.6 reports per 100 employees against 0.4 in 2024. "Around half of the received reports in 2025 concerned employee relations and human resources issues."

Responding (pages 97-98): "Aker Solutions investigates all reported concerns, captures lessons learned, implements response actions and reports to the CEO and the Audit Committee", following the Global Whistleblowing Procedure.

G1-3(part of MDR-T/GDR-T disclosures)Targets related to business conduct
Reported

Targets related to business conduct

Back-filled from the business conduct chapter, where targets are addressed through effectiveness tracking rather than as a numbered disclosure requirement. G1-3 Targets became a standalone DR only in the 2025/2026 ESRS; this statement was prepared under the 2023 ESRS.

Reference: pages 96-98.

Aker Solutions discloses no measurable outcome-oriented business conduct target. No target appears in the G1 chapter, and the ESRS content index lists G1-1 to G1-6 with no targets entry (page 21).

Consistent with MDR-T's second limb, effectiveness is tracked in the absence of a target:

  • Quarterly board-level reporting on effectiveness. "The compliance and integrity function reports quarterly to the Audit Committee on the design, implementation and effectiveness of the company's business integrity program and activities, and reviews performance in this respect. Particular focus is given to whistleblowing cases and independent investigations concerning the Code of Conduct, follow-up of high-risk business partners including third party representatives, and adherence with human rights and data privacy" (page 96).
  • Annual self-assessment and internal audit. "an annual internal controls self-assessment done on all locations globally including a follow up and spot checks performed by the business integrity and compliance team", plus "Risk-based internal audits of internal controls in business processes" (page 96). "We have an established process for an annual compliance self-assessment and internal control testing" (page 97).
  • Tracked indicators. Code of Conduct e-learning completion is reported against the target group at 94.0 percent for 2025 (96.0 percent in 2024), covering 66.9 percent of the total employee population; introduction to business integrity e-learning completions were 2,488 (3,840); and 309 employees were trained in person or online (836) (page 97). Whistleblowing volumes are tracked at 0.6 reports per 100 employees in 2025 against 0.4 in 2024 (page 97).
  • Planned improvement. In 2025 the team began designing a compliance analytics program including control testing, transaction monitoring data analytics and dashboards, to be "implemented and continuously refined during 2026" (page 97).
G1-4Incidents of corruption or bribery
Reported

Incidents of corruption or bribery

Reference: page 98.

"During the reporting period, there were 0 instances where individuals were convicted for violations of anti-corruption and anti-bribery laws. The total amount in fines imposed for these convictions amounted to NOK 0. This is the same as the prior year" (page 98).

The EU Taxonomy minimum social safeguards section repeats the position for the group: "Aker Solutions has not identified any corruption or bribery incidents in the financial year 2025" (page 60).

The datapoints table derived from other EU legislation carries both G1-4 rows - fines for violation of anti-corruption and anti-bribery laws (paragraph 24(a)) and standards of anti-corruption and anti-bribery (paragraph 24(b)) - with page references to page 98 (page 108).

No confirmed incidents, dismissals or contract terminations related to corruption or bribery are reported, and no public legal cases are disclosed. The related material IRO is "Corruption and bribery", a potential negative impact in own operations over the long term, described as arising because "The company's presence in energy sector in over 15 countries, some with higher corruption scores, makes it susceptible to corruption and bribery challenges" (page 93).

Whistleblowing volumes are reported separately under G1-3: 75 reports in 2025 against 49 in 2024, around half concerning employee relations and human resources issues (page 97).

G1-5Political influence and lobbying activities
Reported

Political influence and lobbying activities

Reference: page 99.

"Aker Solutions is not engaged in political contributions, nor in funding or support to political parties. In 2025, there were no financial or in-kind political contributions made by the company. The responsibility for oversight of these activities sits with the communications department" (page 99).

"Aker Solutions is not registered in the EU Transparency Register or any equivalent transparency register. We do not have any members of administrative, management or supervisory bodies that have held positions in public administration in the last two years" (page 99).

Scope of engagement (page 99): "Aker Solutions' input to dialogue with policy makers and civil servants focuses on providing facts and information regarding the company's ongoing activities and outlook for future development of the business, including information like potential future employment numbers. In addition, the input will in some cases include the company's view on different technical alternatives of possible relevance to future projects, and the effects of frame conditions such as taxes and financing research and development. There are established procedures to ensure the company's involvement in these activities is ethical, responsible and complies with the Code of Conduct."

Basis of the material IRO (page 99): "In Norway, Aker Solutions is among the larger companies when it comes to overall revenues and value creation, number of domestic employees, use of sub-suppliers and operations in rural regions... Aker Solutions' prominent role in this important industry may in some cases indirectly or directly influence government policies. This can also influence financial opportunities for the company."

The corresponding IRO is "Political engagement activities", classified as both a positive impact and an opportunity in own operations, medium term (page 93).

G1-6Payment practices
Reported

Payment practices

Reference: page 99.

"Aker Solutions' standard payment terms is 60 days which apply to all categories of suppliers. Minor retail transactions without a formal agreement with Aker Solutions will follow the standard terms of the retailer, resulting in an average payment period of less than 60 days" (page 99).

20242025
Average number of days to settle an invoice from the date it was received48.047.0
Payments related to suppliers of wholesale and retail trade39.0%33.0%
Remaining payments, primarily manufacturing goods and transportation services61.0%67.0%

"As of December 31, 2025, there are no open legal proceedings related to late payments" (page 99).

Methodology (page 99): "The representative sampling method used to calculate average time of payment is based on the global ERP system which comprise 98 percent of all cost in Aker Solutions. All invoices for the companies using the ERP system are processed through the system and we have calculated number of days by looking at the difference between invoice received date and the date of payment. We categorize suppliers based on NACE categories and 83 percent of all invoices are related to categorized suppliers and represent 90 percent of payments in 2025."

Context is given on contractual terms: "As Aker Solutions is a project driven organization with projects lasting up to five years, it is natural that the payment terms with the main suppliers are more favorable for Aker Solutions than the terms towards suppliers of bulk products and services. When processing invoices according to the payment terms, Aker Solutions does not differentiate between major suppliers or SMEs" (page 99).