Arendals Fossekompani

Governance roles

Reference: pages 45-46. Board expertise on sustainability matters is incorporated by reference to the Corporate Governance chapter.

The Board of Directors of Arendals Fossekompani ASA "comprises of seven members, all of whom are elected by shareholders and as non-executive members are considered independent of Group management. There are three women (43%) and four men (57%) in the Board, which is the same as in 2024." Employee representatives are not on the Board (page 45).

Responsibilities are set out body by body (pages 45-46):

• Board of Directors approves the sustainability strategy, targets, materiality assessments and sustainability reporting, including revisions to the Environmental Policy, and annually re-evaluates goals, strategies and the risk profile.
• Audit Committee prepares the Board's oversight and quality assurance of the sustainability reporting process and keeps the Board informed on the sustainability audit.
• Remuneration Committee reviews the Remuneration Policy, including incentivisation linked to sustainability matters.
• CEO leads compliance and sustainability work and updates the Board; the CFO implements the Code of Conduct and the Environmental Policy, with biannual reporting to the Board on progress against targets.

In 2025 "the sustainability responsibilities were moved from the Chief Sustainability Officer (CSO), to the CFO" (page 46). The index cross-tags this DR to G1 as G1.GOV-1 (page 55).

Reference: page 46.

The Board of Directors and its Audit Committee "are informed by the CFO about key developments relating to sustainability matters multiple times a year". This includes the process and findings of the double materiality assessment and "specifically a review of each material impact, risk and opportunity identified". All changes to material IROs were discussed by the Board of Directors in 2025. The Board also discusses previously established priorities for the year on implementing due diligence and on the effectiveness of policies, actions, metrics and targets adopted to address material IROs.

Sustainability IROs are incorporated into the Group risk management process, "which informs the Board's deliberations on strategy and major decisions by the company". In the annual wheel "the double materiality assessment takes place before the annual review of strategy, such that they can be considered in the company's direction", and "where relevant, sustainability-related matters must be assessed against financial conditions".

The instructions to the Board state that it should consider establishing plans and goals to ensure that the business model and strategy are compatible with the transition to a sustainable economy, "limiting global warming to 1.5 degrees in line with the Paris Agreement and climate neutrality by 2050" (page 46). No list of the specific matters addressed at each meeting, or of the dates, is given.

Reference: page 46.

The Remuneration Policy governs remuneration to Executive Management of Arendals Fossekompani ASA and is adopted by the General Assembly. It states that "variable compensation shall constitute approximately 15-40% of total remuneration".

The disclosure is a nil return: "Sustainability-related performance is not included in incentive schemes" (page 46). No sustainability or climate metric is tied to executive pay, so no percentage of variable remuneration linked to sustainability performance is reported and none is capable of being reported.

The ESRS index cross-tags this disclosure to climate as E1.GOV-3 (page 55), so the nil return is also the company's answer on climate-related incentives. The Remuneration Committee still "reviews and proposes updates to the Remuneration Policy and Remuneration Report, including incentivisation linked to sustainability-related matters" (page 46), which leaves the possibility open without committing to it.

Reference: page 47.

Arendals Fossekompani maps the core elements of its due diligence process to the sections of the statement rather than presenting a standalone table (page 47):

• embedding in governance, strategy and business model - GOV-2, SBM-3 and G1-1
• engaging with affected stakeholders in all key steps - SBM-2, IRO-1, S1-1 and S1-2
• identifying and assessing adverse impacts - IRO-1 and SBM-3
• taking action to address adverse impacts - E1-3, E5-2, S1-4 and G1-1
• tracking effectiveness and communicating as necessary - performance against targets under E1-4, E5-3 and S1-5

The datapoints table records the paragraph 30 due diligence statement as covered under "General information: Governance" (page 56).

Business conduct due diligence is described separately (page 85): company-wide assessments of actual and potential compliance risks "related to all operations, business relationships and supply chains" take place "at least once a year", and business partner onboarding Integrity Due Diligence "must assess the business and background of the party, its ultimate beneficial ownership, the origin and destination of funds and property involved in the relationship, and risks relating to the country, potential bribery, corruption, sanctions violations". The Group "follows the OECD Guidelines for Multinational Enterprises, including its checklist for Responsible Business Conduct".

Reference: page 47.

The company states the inherent risk plainly: "As a group with a wide portfolio of companies across multiple countries, there are inherent risks in collecting complete sustainability data, especially related to consistent application of reporting assumptions and the collection of data from upstream and downstream activities and business partners."

Controls described for 2025 (page 47):

• early and regular dialogue with the individuals responsible for reporting on behalf of the portfolio companies, described as "fundamental to preparing the process for sustainability reporting"
• continuity of the reporting systems used, and training in those systems
• built-in control checks and year-on-year learnings
• quality assurance by external system providers and by members of the team
• a debrief with all parties involved in the first year of CSRD reporting, "undertaken to strengthen data sources, internal controls and reporting processes", with timelines and guidelines adjusted to incorporate learnings

"The Board of Directors is ultimately responsible for the integrity of the contents of the sustainability report and considers risks associated with reporting and internal controls annually as part of its review of the company's most important risk areas relative to the Group's net asset value or reputation (severity) and likelihood."

The findings of that risk assessment, and how they are integrated into internal functions and processes, are not reported.

Reference: pages 11, 47. Employees, business model, value chain and activities are incorporated by reference to the About Arendals Fossekompani chapter (page 45).

Arendals Fossekompani is an industrial investment company whose approach spans two phases (page 47):

• Investment phase - ESG is "an essential consideration" when screening and sourcing new companies for M&A, and "new investments must contribute, or have a path to contribute, to at least one of the six environmental goals outlined in the EU Taxonomy".
• Ownership phase - "ESG is part of the business value creation process, and at times a key value creation lever for our portfolio companies."

Upstream, the portfolio companies "depend on a wide variety of business actors supplying and processing raw materials, manufacturing electronics, data hosting, construction and transportation". Own operations cover software development, plasma and induction technologies, hydropower generation and property management. Downstream, portfolio companies "serve a broad range of customers in sectors such as energy, infrastructure, defence, aerospace and automotive, and collaborate with partners in transportation, recycling and waste management".

Because sustainability reporting follows the financial consolidation and excludes Volue, the Group "reports over 1,500 employees in 23 countries rather than over 2,100 employees in 26 countries" (page 47).

Reference: pages 53-54. Cross-tagged in the index as S1.SBM-2 (page 55).

External stakeholder groups are "investors, customers, suppliers, regulators, NGOs and the local community"; internal stakeholders are "employees, Board of Directors and representatives from our portfolio companies" (page 53).

Engagement in 2025: "our Sustainability team conducted semi-structured interviews with a selection of external stakeholders, specifically asking them to give input on our IROs and more general our sustainability efforts. The interviews held in 2025 were conducted at the end of the process and used as a validation of the DMA's findings." Internal stakeholders were involved in workshops and meetings through the DMA project (page 53).

A table sets out, per stakeholder group, the arena for dialogue, the purpose of engagement and examples of outcomes - for example employee development talks, satisfaction surveys, workplace assessments and town halls feeding "action plans for improvement" and "addressing concerns raised about potential breach of Code of Conduct" (page 54).

The outcome is stated as a nil change: "In 2025, no adjustments were made to our material IROs based on the external interviews, as the information provided validated our existing findings. No further steps are currently planned" (page 54).

Reference: pages 49-50, with topic-level repetitions at pages 59-60 (E1), 65 (E5), 77 (S1), 84 (G1) and 86 (entity-specific cyber security). Cross-tagged as E1.SBM-3 and S1.SBM-3 (page 55).

Twenty material IROs are tabled across four ESRS topics plus one entity-specific topic, each with a scope tag (upstream value chain, own operations, downstream value chain) and a time horizon (page 49-50):

• E1 Climate change - 4 risks, 2 negative impacts, 3 positive impacts, 1 opportunity
• E5 Resource use and circular economy - 2 negative impacts, 1 positive impact, 1 opportunity
• S1 Own workforce - 2 negative impacts, 1 risk, 1 opportunity
• G1 Business conduct - 1 risk ("Dependency on corporate culture")
• Entity-specific: Cyber security - 1 risk ("Exposure to critical cyber-attacks")

"There have been no changes in material topics from previous years. IROs are marked as [NEW] in the table are either newly identified or newly material. Some IROs have been separated into two where they were previously merged; this is not highlighted as new" (page 50). Four IROs are flagged NEW: technological advancement for climate change mitigation, reduction of resource intensity from additive manufacturing, cost savings from more resource efficient products, accidents at production sites and low employee satisfaction in times of uncertainty.

Anticipated financial effects are not quantified; the company intends to estimate them in 2026 (page 62).

Reference: pages 51-53. Cross-tagged as E1.IRO-1 (page 52), E5.IRO-1 and G1.IRO-1 (page 53).

The 2024 DMA was carried forward and refreshed: "the material topics and impacts, risks and opportunities (IROs) identified in previous years were used as a starting point, supplemented with newly identified IROs specific to the last twelve months" (page 51). IROs "were identified at the portfolio company level, but scored and assessed in relation to the Group".

Scoring rubric (page 51). Impacts were scored on scale, scope, irremediability (negative impacts only) and likelihood, with actual impacts assigned 5 on likelihood; scale, scope and irremediability were averaged into severity. Risks and opportunities were scored on financial consequence and likelihood. "Each IRO's severity and likelihood scores were multiplied to generate the total score per IRO. A maximum of 25 ... could be achieved."

Threshold (page 51). "Out of a total possible score of 25, a threshold of 12 was applied to IROs, distinguishing between IROs that are immaterial (scoring between 0-11.99) and those that are material (scoring between 12-25)."

Immaterial environmental topics E2, E3 and E4 were screened using external tools (Stockholm Environment Institute pollution diagrams, WWF and UN Biodiversity Lab water and biodiversity mapping, WWF Biodiversity Risk Filter). "No material impacts were identified" (page 53).

Reference: page 55.

The report prints a full ESRS content index headed "IRO-2 ESRS index", with a CODE / DISCLOSURE REQUIREMENT / PAGE IN THE ANNUAL REPORT structure, stating: "All disclosures relevant to our material IROs have been included in this Sustainability Statement. The threshold for materiality in the financial statements is used as a basis for the materiality of sustainability metrics."

The index lists the twelve ESRS 2 disclosures (BP-1, BP-2, GOV-1 to GOV-5, SBM-1 to SBM-3, IRO-1, IRO-2), the topic-level cross-tags (E1.SBM-3, E1.IRO-1, E1.GOV-3, E5.IRO-1, S1.SBM-2, S1.SBM-3, G1.GOV-1, G1.IRO-1), and the topical requirements E1-1 to E1-6; E5-1 to E5-4; S1-1 to S1-6, S1-8 to S1-11 and S1-14; and G1-1. Nothing else is listed - E1-7 to E1-9, E5-5, E5-6, S1-7, S1-12, S1-13, S1-15 to S1-17 and G1-2 to G1-6 do not appear.

A separate table of "Datapoints That Derive from Other EU Legislation" (page 56) gives the SFDR, Pillar 3, Benchmark Regulation and EU Climate Law references, marking four E1-9 datapoints "Subject to phase-in" and marking the S1-16 pay gap and CEO pay ratio, the G1-1 UN Convention against Corruption datapoint, and both G1-4 datapoints "Not relevant".

How to read the codes is explained up front at page 2, pointing readers to the index on page 55.

Transition planning

Reference: page 62.

Arendals Fossekompani has no transition plan in place for FY2025. "Arendals Fossekompani ASA is preparing a transition plan, due to be completed in 2026, to be developed in line with EFRAG Implementation Guidance. It will build on the Arendals Fossekompani Group's existing decarbonisation targets relating to our own operations, and where available, our value chain as outlined in E1-4."

Accountability is stated: "Arendals Fossekompani's Board of Directors is ultimately responsible for establishing plans and goals to ensure that Arendals Fossekompani's business model and strategy are compatible with the transition to a sustainable economy, limiting global warming to 1.5°C in line with the Paris Agreement and climate neutrality by 2050. Accordingly, Arendals Fossekompani's management team and members of the Boards of Directors and ownership teams of our portfolio will coordinate on identifying the decarbonisation levers, actions and resource allocations required."

Two consequences are disclosed elsewhere in the chapter. Decarbonisation levers are not yet attached to the targets - "Targets have not yet been mapped to decarbonisation levers" (page 61). And locked-in emissions are not assessed: "While locked-in GHG emissions have not been assessed, thus far no assets or business activities have been assessed as incompatible with the transition to a climate-neutral economy" (page 52).

Identification of climate-related risks and scenario analysis

Back-filled from ESRS 2 IRO-1, where this content is disclosed in the FY2025 report (pages 52-53). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

"A climate risk assessment was conducted in 2024 and reviewed in 2025" (page 52).

Scenarios. Two were used and both are named: a high-emission scenario, "Fossil-fuelled Development (SSP5-8.5)" from the IPCC (AR6), and a low-emission/transition scenario, "Net Zero 2050" from the NGFS, which "assumes the 1.5°C target is met". A table gives global warming per scenario - SSP5-8.5 at 1.7°C (2030), 2.4°C (2050) and 4.4°C (2100); Net Zero 2050 at 1.4°C, 1.6°C and 1.4°C - alongside CO2 price, energy price and assumptions on GDP growth, technology, international cooperation and environmental policy.

Scope and method. Risks were assessed for sub-groups of the portfolio by business activity - hydropower, electrification and materials (Tekna, ENRX), digitalisation and big data (NSSLGlobal, software), and property (AFK Eiendom). Physical risk was "supported by an assessment of climate hazards at the asset level". Time horizons were 2030, 2040, 2050 and 2085.

Classification. Each material E1 risk is labelled acute/chronic physical, policy and legal, or technology (pages 59-60). The hazard list "complies with the requirements of the list in the appendix A of Annex I of the EU Taxonomy".

Resilience in relation to climate change

Back-filled from ESRS 2 SBM-3 in the E1 chapter (page 60), where this content is disclosed in the FY2025 report. This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

"A resilience analysis was conducted in 2024 along with the update to our climate risk assessment, and reviewed as part of the DMA in 2025 to ensure the results remain applicable and relevant. We evaluated gross transition risks and physical risks informed by different climate scenarios and considered the resilience of our business model and strategy. The scenarios used are Net Zero 2050 and Fossil-fuelled development as outlined under IRO-1."

Result. "The resilience analysis found that Arendals Fossekompani demonstrates resilience in the Net Zero 2050 scenario, with investments supporting the transition to a low-carbon economy." The stated condition on that finding is that "it is crucial that our portfolio understand and manage the transition relating to the risks associated with a Net Zero 2050 future".

Uncertainty. "The analysis is dependent on assumptions and scenarios that entail some uncertainty. It must be revisited periodically to ensure the conditions considered remain accurate and the mitigating actions our resilience is founded on continue to meet our needs."

Policies related to climate change mitigation and adaptation

Reference: pages 57, 60.

"Relating to climate change, our IROs are primarily managed through the Environmental Policy" of Arendals Fossekompani ASA, supplemented by the Group Code of Conduct and by equivalent policies at ENRX, NSSLGlobal and Tekna (page 60).

Environmental Policy objectives, mapped to the IROs (page 60):

• "To make necessary changes to adapt facilities and business decisions to withstand the effects of a changing climate"
• "To reduce GHG emissions in Scope 1 and 2, and Scope 3 where possible, and to leverage the innovation and technology of our portfolio to further decrease GHG emissions"
• "To use all energy as efficiently as possible and encourage portfolio companies to set Paris Agreement-aligned energy consumption targets"

Scope is Arendals Fossekompani ASA employees and own operations; responsibility sits with the Board of Directors; monitoring is "via climate targets"; and the policy is shared internally and published on the website.

Portfolio policies are monitored through ISO 14001 at ENRX's Norway, China, United States and India sites, NSSLGlobal's Carbon Reduction Management Plan and UK ISO 14001, and an annual compliance evaluation by Tekna's Board. "AFK Eiendom and the smaller software companies in the Group do not have dedicated policies on climate change, but are in scope of the Code of Conduct's overarching sustainability objectives" (page 60).

Actions and resources in relation to climate change policies

Reference: page 62.

Group-level actions are preparatory rather than abatement actions. "Arendals Fossekompani Group developed the first baseline of Scope 3 GHG emissions and updated its climate risk assessment in 2024. In 2025, we worked on improving the quality and availability of this data ... Actions will be identified as part of the new transition plan in 2026."

Resourcing is a disclosed nil: "There are no actions planned at ENRX or in our Other Investments. ... The precise GHG emissions reductions and monetary amounts of CapEx and OpEx required to implement each action have not yet been calculated."

Portfolio actions in motion (page 62):

• Tekna expects to "update, expand and finalise its decarbonisation plan and set Scope 3 reduction target(s) for the remaining material categories in 2026-27 (previously planned for 2025)".
• NSSLGlobal maintains an annually reviewed Carbon Reduction Plan; "No additional actions have been defined for 2025 or 2026."
• AFK Eiendom "began incorporating GHG data requirements into new tenders for construction".
• AFK Vannkraft completed a new flood overflow channel at the Flatenfoss dam in 2025, mandated by NVE, "amounting to NOK 35.1 million in 2025", with further dam upgrades to withstand new NVE flood calculations carrying "a budget of NOK 52.1 million allocated for 2026 and 2027".

Targets related to climate change mitigation and adaptation

Reference: page 61.

There is no Group-wide absolute reduction target: the E1-6 target columns state "No collective targets have been set yet" (page 63),. "No new targets or changes to targets have been made in 2025."

Entity-level targets and 2025 performance (page 61):

The ASA targets, and a commitment for "60% of its eligible private equity and listed equity portfolio by book value setting SBTi-validated targets by 2027 from a 2021 base year", are SBTi-approved, and "a revalidation exercise is underway". Tekna and NSSLGlobal "sought to be science-based" but are not SBTi validated.

Coverage is limited: the three targeted entities "represent 26% of the Arendals Fossekompani Group's total Scope 1 and 2 emissions in 2025". "Targets have not yet been mapped to decarbonisation levers." Group emissions intensity is monitored as a benchmark and is "10.5% lower than the 2021 baseline".

Energy consumption and mix

Reference: pages 62-63.

Total energy consumption fell from 27,623 MWh in 2024 to 22,843 MWh in 2025 (page 62).

Energy intensity "relating to activities in high climate impact sectors" rose from 8.0 to 8.8 MWh per million NOK (page 63).

The renewable share is deliberately conservative: "only consumption of electricity, heat, cooling or fuel covered by energy attribute certificates ... is considered to be from renewable sources. In the absence of such certificates, energy is considered to be fossil fuel based, regardless of the local electricity mix." Certificates covered 12% of total Scope 2 energy, up from 4% (page 61). The Group produced 462.5 GWh of hydropower in 2025, down from 606.6 GWh, selling Guarantees of Origin on 85% of it (page 62).

Gross Scopes 1, 2, 3 and Total GHG emissions

Reference: pages 63-64.

Scope 3 is 99% of the footprint (page 59) and is dominated by category 11 use of sold products at 541,495 tCO2e (-14%), with category 1 purchased goods and services 27,535 (-23%), category 10 processing of sold products 13,593 (0%), category 2 capital goods 5,126 (+93%) and category 15 investments 1,014 (+84%). Categories 5, 8, 9, 12, 13 and 14 "are not relevant or material to AFK Group".

GHG emissions intensity per net revenue rose from 119 to 162 tCO2e per million NOK on both location and market basis (page 63).

Uncertainty is material and stated: "It is estimated that 1% of Scope 3 emissions are calculated from primary data, in line with 2024 reporting" (page 64). Category 1 is primarily spend-based; category 10 uses an average-data method with "a grid emission factor of 0.45 kg CO2e/kWh"; category 11 rests on assumptions about energy use after point of sale.

Policies related to resource use and circular economy

Reference: pages 57, 65-66.

"Our circularity-related IROs are managed through the same policies as outlined under E1: Climate change, and primarily the Environmental Policy, which sets resource efficiency and sustainability as key objectives" (page 65). Coverage is stated to be complete for the relevant entities: "Arendals Fossekompani Group's material IROs under E5: Resource use and circular economy relates to AFK Eiendom, AFK Vannkraft, ENRX and Tekna, such that these policies cover all relevant companies and activities."

Objectives mapped to the IROs (page 66):

• Environmental Policy - "To reduce and optimise our usage of natural resources"; "To contribute to the green transition, including through improved resource efficiency and investing in new technologies and innovations"
• Code of Conduct - "To reduce and optimise use of natural resources"; "To seek solutions that will minimise our negative environmental impact"
• ENRX - "to responsibly source and use natural resources"
• Tekna - "to responsibly source natural resources and use them as efficiently as possible; to regenerate resources and protect ecosystems"

Scope, responsibility (Board of Directors), monitoring and availability are "as described under E1-2".

No policy addresses resource outflows or waste, consistent with the sub-topic scope of the DMA (page 48).

Actions and resources related to resource use and circular economy

Reference: page 66.

The action for 2025 is a data quality exercise rather than a circularity intervention. "The companies within Arendals Fossekompani Group that have material resource inflows are AFK Eiendom, AFK Vannkraft, ENRX and Tekna. Across all companies, the focus for 2025 has been on improving the quality of the data collected to refine our understanding of the resource inflows required in our products and business models. This is expected to continue in 2026."

Context from the surrounding chapter explains why: the negative impact "is a result of the difficulty of sourcing more circular materials, both in the market and at the price points at which we operate and on which our business models depend. It is also a result of the difficulty in specifying material preferences (i.e. purity of material)", and for construction "of the non-availability of secondary or recycled equivalents of these materials, or inability to compete at the right price point to customers when using them" (page 65).

The related methodology change is recorded under BP-2: materials used in construction activities were separated out from the production and manufacturing total, and "Construction-related resource inflows now represent an entity-specific metric" (page 45).

No monetary amounts, CapEx or OpEx are allocated to E5 actions, and no expected outcomes are quantified.

Targets related to resource use and circular economy

Reference: page 66.

Arendals Fossekompani discloses that it has no E5 target: "We have not yet set targets regarding the sourcing of sustainable resources at the Arendals Fossekompani Group level. For the first time in 2024, we collected new data on the types, volumes, and characteristics of the resources required across our portfolio. This data is forming the foundation of a new area of work aimed at establishing a baseline for a future target on sustainable resource sourcing."

The same position is stated in the strategy table, where the E5 target column reads "New data collected in 2024 and refined in 2025 is forming the foundation of a new area of work. There is currently no target" (page 48).

No target date is given for when the baseline or the target itself is expected, and no interim measure of effectiveness is offered in place of a target. Progress on the material E5 IROs is therefore tracked only through the E5-4 resource inflow metrics.

Resource inflows

Reference: page 66.

The materials named are "metals in various forms such as steel, copper, titanium, aluminium, brass, tungsten and tantalum, various electrical materials, wood, plastics, and gases including argon and oxygen".

Measurement is estimated, and the company says so: inflows are measured "by identifying and estimating the weight of the materials required to manufacture or produce goods and services", and "where information was not available to determine the origin of the material, it was assumed to be virgin, such that the absolute weight of known secondary materials continues to be fairly low in 2025". Estimations were applied "based on standard dimensions or weights of materials used in construction or manufacturing".

The 2024 comparative was restated: the entity-specific construction figure "is adjusted from 14,247 tonnes to 1,339 tonnes" because the metric now uses "the construction schedule as a proxy for the stage of completion, rather than the resources at the time of handover" (pages 45, 66).

Policies related to own workforce

Reference: pages 57, 77-78.

"The core policy that governs our workforce-related IROs is the Code of Conduct, supported by the process outlined in the Whistleblower Policy, which allows us to detect any incidents", supplemented by the Diversity & Inclusion Policy for Arendals Fossekompani ASA and by equivalent policies at NSSLGlobal and Tekna (page 77).

Objectives mapped to the IROs (page 78):

• Code of Conduct - "To ensure a safe and secure working environment, characterised by transparency, honesty and trust"; "To treat all individuals with respect and dignity with zero tolerance for discrimination on any basis as well as bullying and harassment".
• Diversity & Inclusion Policy - "To foster a diverse and inclusive workplace free from bias, discrimination or harassment ... by providing equal opportunities in recruitment, professional development and promotions, as well as education".
• Whistleblower Policy - covers all S1 IROs, and applies to Group employees and relevant third parties.

Monitoring runs through employee signature and training rates on the Code of Conduct, HSE systems and risk assessments in production companies, ISO 45001 at ENRX's Germany, China and India sites, and the number and review of whistleblowing cases. "The principles outlined in these policies apply the major internationally-recognised instruments such as the UN Guiding Principles on Business and Human Rights" (page 78).

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

Reference: pages 78-79.

"Our employees' interests, perspectives, and rights are ... central to informing our strategy and business model, and we rely on our workforce to deliver on our strategy of long-term value creation." Engagement runs through "employee or whistleblower cases and formal and informal employee engagement", and "In most parts of the Group, annual professional development conversations with employees ensure that every individual has access to the conditions they need to perform their work and grow in the company." (page 78).

Representation is described by site: "union representatives, safety representatives, and additional employee representatives in some places where employees choose to elect a common representative if multiple unions are involved. Engagement via representatives typically occurs multiple times a year. In several companies, employees are formally or informally represented on the Board of Directors" (page 79).

Accountability: "The CEO has the overall responsibility for ensuring that engagement takes place and for employees' human and labour rights", and the CFO holds operational responsibility for policy implementation.

Effectiveness is assessed "through this whistleblowing process, as well as KPIs related to employee retention and absenteeism" (page 79).

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

Reference: page 79.

"All Arendals Fossekompani Group's own employees and relevant third parties are encouraged to report concerns about circumstances that might be in violation of applicable laws and regulations, internal policies, guidelines and procedures as well as any other unethical conduct that employees are aware of or suspect."

Channels (page 79):

• "The first line of reporting is always the employee's direct manager."
• Employees "may also contact the CFO or safety representative, as well as the CEO, the Chair or any member of our Board of Directors."
• An internal or external whistleblowing channel at mittvarsel.no, "shared via company leadership and available on our webpage arendalsfossekompani.no".

Handling: "The Board of Directors of each company in the Group is alerted to critical whistleblower cases raised in their respective company, often reviewed and investigated by a compliance function and reported periodically by Management. Depending on the situation, Management and other relevant functions may collaborate to resolve or continually monitor a case or other negative impact."

Awareness is tracked: "Employee awareness of the whistleblowing process is closely monitored through our KPI on employee training rates in the Code of Conduct, which includes units on whistleblowing" - 86% trained in 2025 (pages 79, 85).

Taking action on material impacts on own workforce

Reference: page 79.

The action taken in 2025 addresses the material opportunity on diversity: "Arendals Fossekompani ASA's new Diversity and Inclusion Policy was circulated through the Group in 2025 for each portfolio company to implement or adapt to its own policy and practices. The policy cements best practices and commitments towards diversity and inclusion, especially in relation to recruitment and retention, in support of our material opportunity."

Other planned actions were dropped: "Additional actions planned for 2025 at the Group level have been deprioritised in favour of a more targeted focus on reaching our collective targets, and in 2026, we will work with each portfolio company on a case-by-case basis to support their efforts to achieve our objectives, as relevant."

Effectiveness is tracked through the S1-5 targets: "These targets enable the monitoring of our IROs, including our actual negative impact and the effectiveness of any actions to support those affected by it."

Resourcing is a disclosed nil: "Dedicated financial resources beyond ongoing HR budgets have not been allocated to these actions."

No action is described against the two negative impacts identified in 2025 - accidents at production sites, and low employee satisfaction in times of uncertainty - beyond the HSE monitoring embedded in the Code of Conduct and the ISO 45001 processes at ENRX's Germany, China and India sites (page 78).

Targets related to own workforce

Reference: pages 79-80.

"There has been no change to the Group's targets in 2025." The targets "apply to all Arendals Fossekompani Group's employees", and where the year reads "in effect", "the target is expected to be achieved on an ongoing, annual basis" (pages 79-80).

The company reports movement against itself rather than only progress: "Progress on gender balance metrics has been trending in the wrong direction, despite increases in female representation in some parts of the Group. This is largely attributable to restructuring processes in ENRX and recruitment in predominantly male areas at NSSLGlobal." Sick leave rose above target "primarily driven by levels at ENRX and Tekna of 3.2% and 3.7% respectively, partly reflecting the impact of staff reductions and restructuring". LTIFR improved to 1.0 with "All portfolio companies reporting lost time injuries reduced their LTIFR".

Characteristics of the undertaking's employees

Reference: pages 80-81.

Headcount at 31 December fell from 1,772 in 2024 to 1,571 in 2025: 1,290 male and 281 female, with none recorded as other or not reported (page 80).

By contract type and gender, 2025 (page 81): permanent 1,510 (277 female, 1,233 male); temporary 61 (4 female, 57 male); non-guaranteed hours nil; full-time 1,533 (269 female, 1,264 male); part-time 38 (12 female, 26 male).

By region, 2025: Asia 473, Europe 856, North America 234, South America 8.

Employees by country are given for 23 countries (page 80), the largest being Norway 358 (from 407), India 262 (unchanged), United Kingdom 185 (from 183), China 179 (from 202), Canada 137 (from 161), United States 97 (from 115) and Germany 87 (from 145).

Departures during 2025 totalled 332, a 20% turnover rate: voluntary 148 (9%), involuntary 159 (10%) and other causes such as retirement or death 25 (2%), against 387 departures and 18% in 2024 (page 81).

Definitions: "employees are counted in headcount on 31 December 2025", the Group's FTE number is used in Financial Note 4, and the turnover denominator is "the average between the employee headcount on 1 January 2025 and on 31 December 2025" (pages 80-81). Volue is outside the reporting boundary, which is why the Group reports over 1,500 rather than over 2,100 employees (page 47).

Collective bargaining coverage and social dialogue

Reference: page 81.

Coverage by region is given in bands. In both years, the 80-100% band for employees with a CBA in the EEA holds South America, and Norway sits in the 40-59% band for 2024 moving to a different band position in 2025; employees with a CBA outside the EEA are recorded for "Asia, Europe (non-EEA), North America" in both years (page 81).

The reporting boundary is explained: "Within the European Economic Area (EEA), coverage of collective bargaining agreements and workplace representation (S1-8) is disclosed for countries in which we have significant employment, defined as at least 50 employees by headcount representing at least 10% of the total number of employees by the ESRS. At ENRX France and ENRX Germany, agreements are in place for employee representation by a Works Council. The denominator for the % of all employees in the EEA covered by workers' representatives is the total number of global employees, in accordance with ESRS definitions" (page 82).

No separate description of collective bargaining coverage for employees outside the EEA by country is given beyond the banded regional table.

Diversity metrics

Reference: pages 81-82.

Gender of company leadership, headcount at 31 December (page 81):

As percentages (page 82): Board of Directors 34% female in 2024 falling to 22% in 2025; C-suite 24% falling to 21%; non-executive level management 20% falling to 15%. Non-binary is recorded as 0% throughout, and "Data was also collected on the number of non-binary employees, for jurisdictions that recognise a gender other than male or female. The data amounted to 0 in 2025" (page 80).

These figures cover Boards and management across the Group's portfolio companies, not only the parent - "All targets related to our own workforce apply to Arendals Fossekompani Group as a whole. These figures therefore represent averages across the Group, rather than exclusively the management team of Arendals Fossekompani ASA" (page 80). The parent company Board is separately reported as three women and four men (page 45).

Age distribution of employees (page 82): under 30 years 17% (from 19%), 30-50 years 57% (from 55%), over 50 years 26% (unchanged).

Adequate wages

Reference: page 82.

The disclosure is a single sentence: "In all parts of the Group, all employees are paid adequate wages, in line with applicable benchmarks."

This is a complete nil-gap return in ESRS terms - all employees are stated to be paid an adequate wage - so no breakdown of the countries or percentages of employees paid below an adequate wage benchmark is required. The company does not, however, name the benchmarks it applies, or say which reference wage was used per country.

Adequate wages sit within the material S1 risk rather than a separate sub-topic: the risk "Breach of employees' basic protections" is described as covering protections that "include basic health and safety, adequate wages, social protections and collective bargaining" (page 77).

The related datapoints table records no adequate wage entry; the S1 datapoints deriving from other EU legislation cover S1-1 ILO due diligence, trafficking prevention and accident prevention policy, S1-3 grievance mechanisms and S1-14 accident metrics, with S1-16 marked "Not relevant" (page 56).

Social protection

Reference: page 82.

"In most countries across the Group, employees are covered by social protection, either through governmental programmes or through company benefits, to protect them from a loss of income relating to major life events."

By event: "All employees in Arendals Fossekompani Group's own workforce are covered by social protection against a loss of income due to employment injury and acquired disability, parental leave or retirement. Most employees in the Group are also covered by social protection against a loss of income due to sickness, and unemployment starting from when the employee is working for the company."

The gap is named rather than left implicit: "However, ENRX's employees in India who are not covered under the Employees' State Insurance scheme are not protected against a loss of income relating to sickness or unemployment starting from when the employee is working for the company" (page 82).

The number or percentage of employees in that gap is not given, so the disclosure identifies the country and the entity but not the headcount affected. India is the Group's second largest country by headcount at 262 employees, unchanged year on year (page 80), though the report does not say how many of those sit outside the Employees' State Insurance scheme.

Health and safety metrics

Reference: page 82.

Coverage: "Percentage of the workforce covered by a health and safety management system based on legal requirements and/or recognised standards or guidelines" rose from 80% in 2024 to 94% in 2025.

Performance (page 82):

The lost time injury frequency rate, reported as a target under S1-5, improved from 1.7 to 1.0, and "All portfolio companies reporting lost time injuries reduced their LTIFR" (page 79). LTIFR "is calculated by dividing the number of injuries from work situations in the reporting period multiplied by one million, by the total hours worked in the reporting period. In situations where the total number of hours worked in the reported period is not known, the total available work hours in the reporting period is used instead" (page 80).

The datapoints table records the paragraph 88(b), 88(c) fatalities and accident datapoints, and the paragraph 88(e) days lost datapoint, against this section (page 56).

Business conduct policies and corporate culture

Reference: pages 84-85.

"The core policies that govern our corporate conduct are the Code of Conduct and the Business Partner Code of Conduct, supported by the process outlined in the Whistleblower Policy. These documents are relevant and applicable to Arendals Fossekompani Group as a whole, and are reviewed annually in light of new regulations and findings from the double materiality assessment" (page 84).

Objectives (page 84):

• Code of Conduct - "To ensure that the company's vision and high ethical standards are complied with by anyone associated with it, including clear principles in key areas of compliance and integrity such as anti-corruption and anti-bribery, facilitation payments, conflicts of interest, gifts and hospitality, human rights and labour rights, fair competition, anti-money laundering, sanctions and trade compliance."
• Business Partner Code of Conduct - applies to "all business partners supplying material, labour or services", establishing "zero tolerance for illegal or unethical behaviour".

Whistleblowing is open beyond employees: "We encourage our portfolio companies, suppliers and business partners to report to Arendals Fossekompani any issues of concern ... Anyone who reports such matters will be protected from retaliation" (page 85). Training is mandatory Group-wide, given on joining "and approximately every three years as a refresher".

Targets related to business conduct

Back-filled from the business conduct chapter (page 85), where targets are presented under the MDR-T heading "Metrics and targets relating to business conduct" rather than as a numbered disclosure requirement. G1-3 became a standalone DR only in the 2025/2026 ESRS.

Five Group-level targets are stated, "set by the Arendals Fossekompani Board of Directors and Executive Management" and applying "to Arendals Fossekompani Group collectively" (page 85):

"There has been no change to the Group's targets in 2025." The two 2025 deadlines were missed and the company says why: "A slight drop in the Group's total signature rate from 88% in 2024 is attributable to turnover in the companies within Other Investments, where this effort has been postponed to 2026. The remaining gap is largely attributable to ENRX ... A minor shortfall at Tekna is attributable to its new hires not having yet undergone training."