Austevoll Seafood

The role of the administrative, management and supervisory bodies

Composition of the Board of Directors

According to the Articles of Association § 6, the Company's Board of Directors shall consist of 5–9 directors elected by the shareholders. At year-end 2024, the Board of Directors comprises eight members with an even gender balance (50% women, 50% men).

Board Members (as of 2024):

Independence: Board members Hege Charlotte Bakken, Hege Solbakken and Petter Dragesund are independent of the Company's major shareholders, management and significant business relationships. The majority of shareholder-elected members are not independent of the Company's major shareholders.

Executive vs Non-executive: No members of Group management are Directors. The Board does not include executive personnel.

Term of office: The term of office for members of the Board of Directors is two years at a time.

Board Committees with Sustainability Oversight

Audit Committee:

• Established at the end of 2008
• Members: Hege Charlotte Bakken (Chair) and Lill Maren Møgster
• Total meetings in 2024: 8
• Responsibilities related to financial reporting, the independent auditor and risk management

Committee for Social Responsibility and Sustainability:

• Established in 2020
• Members: Hege Charlotte Bakken, Lill Maren Møgster and Siren Grønhaug
• Total meetings in 2024: 8 (coordinated with Audit Committee meetings)
• Extended responsibility for the Company's social responsibility and sustainability, and to pursue and monitor the development of this ambition further

Sustainability-related Expertise

The Board of Directors comprises members with diverse expertise including:

• Solid background from the seafood business
• Experience within economics, ESG, finance and accounting
• Strategy and organizational processes
• Substantial board experience from various subsidiaries
• Experience within sustainability (ESG)

The annual report provides information on the expertise of the members of the Board of Directors, including their backgrounds in finance, ESG, economics, and seafood industry operations.

Frequency of Sustainability Discussions

In total, 11 Board meetings were arranged during 2024. The Committee for Social Responsibility and Sustainability held 8 meetings in 2024, coordinated with the Audit Committee meetings.

From 1 January 2024, sustainability reporting has been an integral part of the Board of Directors' report.

Specific Roles Assigned

Corporate Management:

• CEO: Arne Møgster (CEO of Austevoll Seafood ASA since 2006)
• CFO: Britt Kathrine Drivenes (CFO of Austevoll Seafood ASA since 2006)

Portfolio Company CEOs:

• Henning Beltestad: CEO of Lerøy Seafood Group ASA since 2010
• Adriana Giudice: CEO of Austral Group S.A.A. since 2005
• Andrés Daroch Coello: CEO of FoodCorp Chile S.A since 2016
• Ingebrigt Gunnar Landa: CEO of Kobbevik og Furuholmen Oppdrett AS since 2008
• Egil Magne Haugstad: CEO of Pelagia Holding AS since 2014

Board Work and Instructions

The Board's instructions are extensive and were last revised on 16.02.2022. The instructions cover:

• The Board's responsibility and obligations
• The CEO's information obligations to the Board
• The procedures of the Board
• How the Board of Directors and executive management shall handle agreements with related parties

Norwegian law lays down the tasks and responsibilities of the Board of Directors, including overall management and supervision for the Company. Towards the end of each year the Board adopts a detailed plan for the following financial year covering the follow-up of the Company's operations, internal control, strategy development and other issues.

Effectiveness Arrangements

Board Self-evaluation: Each year, a special Board meeting shall be organised on topics related to the Group's operations and the Board's duties and working methods.

Risk Management: The Board of Directors must ensure that the Company has sound internal control and systems for risk management that are appropriate in relation to the extent and nature of the Company's activities. The Board carries out an annual review of the Company's most important areas of exposure to risk and its internal control arrangements.

External Auditor: The Company has an external and independent auditor. The Board invites the auditor to meetings that deal with the annual accounts, and holds at least one meeting per year with the external auditor without the presence of the administration.

Remuneration

Board Remuneration: The remuneration of the Board of Directors is not linked to the Company's performance. The Company does not grant share options to members of its Board. Directors' fees are decided by the Annual General Meeting.

Chair Remuneration: Director's fee to the Chair of the Board is not paid as taxable remuneration. AUSS is invoiced for the Chair's services and for consultancy fees by the Group head entity Laco AS, with which the Chair is employed. The total amount paid in 2024 of TNOK 3,749 includes Board remuneration of TNOK 513.

Corporate Governance Compliance

The Board of Directors follows the Norwegian Code of Practice for Corporate Governance (NUES) and the UN Global Compact's ten principles for responsible business. The Board is of the opinion that AUSS is appropriately organised and that its activities are carried out in compliance with relevant legislation and regulations.

Insurance policies have been taken out for members of the Board of Directors and senior executives to cover their personal liability for compensation for economic loss in connection with exercising their duties (Directors' and management liability).

Integration of sustainability-related performance in incentive schemes

Sustainability-related considerations are currently not included in the remuneration policies for the Board of Directors, management, or supervisory bodies.

Strategy, business model and value chain

Description of products/services and key markets

AUSS's strategy as a holding company focuses on supporting and guiding its portfolio companies operating within ocean-based industries, including aquaculture, fisheries, primary and secondary processing and end products to consumers (human consumption, animal and fish feed). The Group's activities are deeply connected to the ocean, and AUSS is strategically committed to creating lasting value through the sustainable use of ocean resources, which remains core to our business.

The Group's vision is to be a "Passionate owner of globally leading seafood companies", and the business strategy for the Company is long-term value creation via sustainable, competent use of freshwater resources and the oceans, in thriving local communities.

The value chain in the Company's portfolio companies "originates" from sustainable use of the sea, and the Group is a world leader within the production of Atlantic salmon and trout, and also whitefish, covering the entire value chain from egg and catches to final product to consumer. The Group's pelagic operations comprise fisheries, production of fishmeal and fish oil, and production of pelagic products for human consumption.

Since it was established in 1981, AUSS has sought to remain loyal to its strategic foundation of "creating lasting values through sustainable and expert use of both freshwater resources and the ocean, in thriving communities".

Significant groups of products/services

Operating revenue and other income (2024):

• LSG: 85% / MNOK 31,121
• AUSS EX. LSG: 15% / MNOK 5,524

EBITDA (2024):

• LSG: 62% / MNOK 4,383
• AUSS EX. LSG: 38% / MNOK 2,690

The Group's segment reporting comprises the following portfolio companies:

• Lerøy Seafood Group ASA (LSG) - Europe
• Austral Group S.A.A - Peru
• FoodCorp Chile S.A. - Chile
• Br. Birkeland AS - Norway
• Kobbevik og Furuholmen Oppdrett AS (KFO) - Norway

In the consolidated financial statements, Pelagia Holding AS (Europe) is defined as a joint venture and accounted for according to the equity method.

Significant markets / geographies

Lerøy Seafood Group ASA (LSG):

• LSG is a leading fully integrated seafood corporation with a global reach
• Operates in three regions in Norway: Troms and Finnmark, Nordmøre and Trøndelag, and the county of Vestland
• Owns 50% of Norskott Havbruk AS (Scottish Sea Farms Ltd) in Scotland
• Every day, LSG supplies Norwegian seafood corresponding to five million meals to more than 80 different markets
• Operations divided into: Farming, Wild Catch and VAP (processed products), Sales & Distribution
• 6,194 employees (2023: 6,013)
• Revenue: 31.1 BN. NOK (2023: 30.9)
• EBITDA: 4.4 BN. NOK (2023: 4.7)
• Total assets: 42.8 BN. NOK (2023: 41.4)
• Equity ratio: 49% (2023: 48%)
• Slaughtered volume salmon and trout: 171,228 GWT (2023: 159,620)
• Catch volume: 64,991 GWT (2023: 75,893)

Austral Group S.A.A (Peru):

• Austral Group S.A.A. is a Peruvian public company listed on the Lima Stock Exchange
• Integrated value chain comprises fisheries, production of fishmeal and oil, and production of consumer products
• Fishing rights: just under 7% of total quota for anchoveta fishery in North/Central Peru, and just under 4% of quota in South Peru; also fishing rights for horse mackerel and mackerel
• Four factories located in Coishco, Chancay, Pisco and Ilo
• Main fishing seasons for anchoveta in North/Central Peru: April to July (first season) and November to January (second season)
• 1,464 employees (2023: 1,550)
• Revenue: 2.2 BN. NOK (2023: 1.0)
• EBITDA: 0.8 BN. NOK (2023: -0.2)
• Total assets: 3.6 BN. NOK (2023: 3.1)
• Equity ratio: 50% (2023: 43%)
• Wild catch: 463,000 tonnes (2023: 185,000)

FoodCorp Chile S.A. (Chile):

• FoodCorp Chile S.A. is a Chilean private company within the pelagic sector
• Integrated value chain comprises fisheries, production of consumer products, and production of fishmeal and fish oil
• Fishing rights: 8.6% of horse mackerel quota; also quota for sardine/anchoveta
• Main season for horse mackerel fisheries: December to July
• Main season for sardine/anchoveta: March to July/August (first season) and October/November to end of December (second season)
• All onshore industrial activities share premises in Coronel
• 736 employees (2023: 704)
• Revenue: 1.3 BN. NOK (2023: 1.0)
• EBITDA: 0.3 BN. NOK (2023: 0.2)
• Total assets: 1.8 BN. NOK (2023: 1.4)
• Equity ratio: 82% (2023: 85%)
• Wild catch: 150,000 tonnes (2023: 120,000)

Br. Birkeland AS (Norway):

• AUSS owns 42.9% of the shares
• Private company within the fishing segment; now consists of two vessels used for snow crab fishing
• Sold pelagic fishing activity in June 2024
• 78 employees (2023: 125)
• Revenue: 2.1 BN. NOK (2023: 0.4) [includes gain from sales of shares of BN. NOK 1.85 in 2024]
• EBITDA: 1.9 BN. NOK (2023: 0.1)
• Total assets: 0.6 BN. NOK (2023: 0.7)
• Equity ratio: 84% (2023: 54%)
• Wildcatch pelagic: 23,476 MT (2023: 36,843)
• Snow crab: 825 MT (2023: 665)

Kobbevik og Furuholmen Oppdrett AS (Norway):

• AUSS owns 55.2% of the shares
• Private company within the farming segment
• Holds seven salmon farming licences in the Western Region of Norway
• 45 employees (2023: 49)
• Revenue: 0.9 BN. NOK (2023: 0.8)
• EBITDA: 0.3 BN. NOK (2023: 0.3)
• Total assets: 1.5 BN. NOK (2023: 1.4)
• Equity ratio: 51% (2023: 44%)
• Slaughtered volume salmon: 8,855 GWT (2023: 7,416)

Pelagia Holding AS (Europe):

• Accounted for as joint venture in consolidated financial statements
• Operations comprise production of marine protein and oil (FEED), frozen pelagic consumer products (FOOD) and omega-3 products (HEALTH)
• Pelagia processed approximately 1.3 million tonnes of raw materials in 2024 (2023: approximately 1.4 million tonnes)
• Revenue: MNOK 15,038 (2023: MNOK 13,001)
• EBITDA: MNOK 1,402 (2023: MNOK 1,725)
• EBIT: MNOK 972 (2023: MNOK 1,266)
• Balance sheet total: MNOK 11,656 (2023: MNOK 10,044)
• Net interest-bearing debt: MNOK 5,917 (2023: MNOK 4,483)

Number of employees by geography

The total number of full-time equivalents in the Group in 2024 was 7,320, of whom 1,917 were in South America. The corresponding figures for 2023 were 7,022 full-time equivalents with 1,667 in South America.

At year-end 2024, the Group had just over 8,500 employees in permanent and temporary positions, including 1,000 contract workers. Of this total number, 33% were women and 67% men. At year-end 2023, the Group had just under 8,500 employees in permanent and temporary positions, and the gender balance was 35% women and 65% men.

For more detailed breakdown of employees by country, see S1-6 in the sustainability statement.

Sustainability-related goals embedded in the business model

Sustainable growth places stringent requirements on the Group within the areas of finance, corporate governance, climate and the environment as well as social conditions. Knowledge-based, uniformly sustainable operations are a prerequisite for access to capital and vital to the Group's existence and continued development.

The Group's strategy includes regularly monitoring and follow up on the performance through quarterly reporting. Key performance indicators (KPIs) are used to track progress across the following strategic focus areas:

• Climate transition
• Fish health and welfare
• Resource efficiency and circularity
• Social responsibility
• Biodiversity and ecosystem preservation

The Group has set challenging targets within ESG, including reducing greenhouse gas emissions by 46% by 2030. A number of measures with long lead times have been implemented. The Group is concentrating in particular on solutions within transport and fish feed. As part of the CSRD reporting the Science Based Targets will be reviewed in 2025, and may be subject to change.

While Group-level sustainability targets have yet to be formally established for all ESRS standards, AUSS's strategy is to integrate structured sustainability goals into governance and decision-making processes. This approach enables AUSS to drive positive impact across all operations within the Group.

AUSS identifies climate adaptation, regulatory changes, and transparency regarding the Group's value chain workers—particularly in high-risk regions—as key industry challenges. In response, The Group will enhance data-driven decision-making by improving impact assessment tools and monitoring systems. Additionally, the Group is exploring investments in research and development to introduce innovative products and improve sustainability, thereby enhancing the overall customer experience.

Description of the upstream and downstream value chain

Upstream activities:

Pelagic value chain:

1. Fishery from third parties: Austral and Foodcorp buy fish from third-party fishers, both industrial and artisanal (smaller boats). The pelagic fish is harvested from the coastal areas outside Peru and Chile, within their respective quotas and delivered for primary processing. The fish is caught by purse seine.

Whitefish value chain: 6. Fishery from third parties: The group purchases whitefish from coastal fishing vessels, depending on specific operational needs or market conditions.

Fish farming value chain: 11. Roe hatchery (third party): The process for farming of salmon and trout begins with the production of roe. Broodstock are used to produce fertilized eggs. The roe is purchased from Norwegian producers and transported for smoltification.

Own operations:

Pelagic:

1. Fishery: The pelagic fish is harvested from the coastal areas outside Peru and Chile, through the Group's owned fishing vessels operating under national quotas. Pelagic fish in Peru and Chile includes species such as mackerel, horse mackerel, anchoveta and sardine. The fish is caught by purse seine.

2. Primary processing: The catch is delivered to own primary processing facilities, located in Peru or Chile. Depending on the species and quality of the catch, it is either processed into fishmeal and oil, or frozen products for human consumption.

Whitefish: 7. Fishery: The whitefish is harvested from the cold arctic waters of Norway spanning from the North Sea to the Barents Sea, through the Group's fishing vessels operating under national quotas. The fish is gutted onboard the vessel, and delivered fresh or frozen. Fresh fish is delivered to processing industry on shore.

1. Primary processing: Own and purchased fish is delivered to storage facilities and stored in large cold storage facilities. The fish is sold internally and externally. When a sale is agreed the fish are filleted or dispatched from storage and transported to the customer, normally a processing facility.

Fish farming: 12. Roe hatchery: Roe is hatched in trays that simulates the riverbed with recycled freshwater. Hatching takes about 60 days. After hatching it is called fry. Fry lives on nutrition from yolk sac for about 1.5 months.

1. Smolt production: When fry is ready to receive feed it is transferred to bigger tanks with more room. Here it is acclimated to life in seawater. This process is called smoltification. This takes about 8–15 months. This occurs in specialized smolt facilities in multiple locations in Norway.

2. Farming: After the smolt phase the fish is moved from tanks on land to cages at sea. Here it is kept til it reaches a weight between four to six kilograms (three to five kilograms for trout). This takes about 14–22 months. The farming sites are located in multiple locations in Norway.

3. Primary processing: When the fish is ready for slaughter it is transported from the sea facility to the factory with the help of wellboats. Here it is stunned, bled, washed, sorted after size and quality before it is either packed or filleted. The factories are located in multiple locations in Norway.

Downstream activities:

Pelagic: 4. Secondary processing: Finished goods from primary processing, such as fishmeal, fish oil, and frozen products, are transported globally by cargo. Part of the processed fish oil is further processed into Omega-3 products. Fishmeal and fish oil are used in feed production for animals and fish farming. Frozen fish is not subject to further processing.

1. Market and delivery to end-customer: Frozen fish is either sold in local markets (frozen or defrosted), while finished products from fishmeal and fish oil are distributed for further processing to feed for animal or fish farming consumption globally.

Whitefish: 9. Secondary processing: Finished goods from primary processing, are transported by cargo for processing into final and value added products such as consumer packaged products (fresh) and ready meals.

1. Market and delivery to end-customer: The final products are sold to processors, retailers (for sales to end customers) and HoReCa (Hotels, Restaurants, and Catering) all around the world.

Fish farming: 16. Secondary processing: A share of the fish continues to further processing to make further processed products such as consumer packaged products (fresh and smoked) and ready meals.

1. Market and delivery to end-customer: The finished product is distributed to markets and stores, where it is sold to consumers. The final part of the value chain is when the product reaches the consumer, either through retail, restaurants, or other sales channels.

Key inputs and outputs

Main inputs:

• Energy - electricity, fuel
• Water
• Materials - feed, nets
• Knowledge - own workforce, employees working on production facilities, farming sites, processing facilities and supporting administrative activities
• Infrastructure - wellboats, service boats, workboats, packaging

Stakeholders:

• Supply chain workers
• Whistleblowing channels (upstream and downstream)
• End users
• Whistleblowing

Key outputs:

Raw material volumes (2024):

• Harvested salmon and trout: 200,000 GWT (2023: 179,000)
• Catch Whitefish: 65,000 MT (2023: 76,000)
• Catch and purchase Pelagic fish: 1,961,000 MT (2023: 1,721,000)

Emissions (tCO2e) 2024:

• Scope 2 (location based): 6% / 18,429

Paid corporate tax 2024:

• AUSS EX. LSG: 18% / MNOK 247

Gender balance:

• Female representation noted but specific percentage not disclosed in these sections

Net interest bearing debt (NIBD) 2024:

• AUSS EX. LSG: 4% / MNOK 310
• LSG: 96% / MNOK 7,705

Interests and views of stakeholders

Overview

For AUSS as a holding company, collaboration, dialogue, and common interests with stakeholders are critical to the way AUSS work. The Group operates across several continents within both aquaculture and fisheries, and business affects a variety of stakeholders throughout the Group's value chain. At the same time, the Group's stakeholders influence the decisions being made. Therefore, active engagement with key stakeholders is necessary to fulfil the mission of creating lasting value through healthy oceans and thriving communities.

Engagement approach

To ensure continuous and structured engagement, AUSS follow a systematic approach where key stakeholders are involved through board representation, regular reporting, partnerships, and direct dialogue. Engagement is an ongoing process, with no fixed timeline, but regular meetings and reviews ensure that strategies and the business model are updated as needed. The interests and views of stakeholders play an important role in forming the strategy and business model, as well as in efforts to increase positive impacts and mitigate negative impacts.

Key stakeholder groups and engagement

Integration into strategy and business model

The interests and views of stakeholders play an important role in forming the strategy and business model, as well as in efforts to increase positive impacts and mitigate negative impacts. The table above provides an overview of key stakeholders, how engagement occur, their interests, and the outcomes of engagement.

Stakeholder input in double materiality assessment

Step 2: Stakeholder engagement

Key stakeholders—including customers, suppliers, employees, regulators, NGO, and community representatives—were identified and engaged as part of the process. Stakeholder input was gathered through a combination of surveys and interviews conducted in 2024, supplemented by insights from prior materiality assessments carried out by the Group's largest subsidiary, LSG. As part of this engagement, stakeholders were asked to provide insights on heightened risks associated with business relationships and geographic exposure, ensuring that stakeholder perspectives helped validate and refine the identification of adverse impacts.

Stakeholders were asked to prioritize and evaluate significant sustainability topics, providing critical input to the DMA process. This phase ensured that the assessment aligned with both societal and financial expectations.

Engagement with affected communities

The Group has not conducted direct consultations with affected communities regarding sustainability assessments of shared biological resources and ecosystems for this reporting period. However, findings from previous stakeholder analysis have been used as a basis for this year's double materiality assessment.

Own workforce engagement

The portfolio companies engage with their workforce on matters affecting working conditions, such as health and safety, adequate wages, freedom of association, and gender equality, through multiple channels.

The primary methods for engagement include staff meetings and workers' representatives, who participate in regular meetings and structured forums to communicate employee feedback, raise concerns, and discuss potential impacts on the workforce. This engagement specifically secures insights into the perspectives of fishing vessels workers, who are considered to be particularly vulnerable to HSE impacts, as well as women's perspectives on equality. The collaboration ensures that employees' voices are heard and that any issues impacting the workforce are addressed collaboratively. These methods apply to the Group's 100% hired, own employees.

Employee representatives also play a crucial role in the governance structures of the portfolio companies operating in Norway. For LSG this includes employee representatives in their Board and Working Environment Committees (AMU). This collaboration ensures that employees' voices are heard and that any issues impacting the workforce are addressed collaboratively. These engagements inform the importance of a secure and safe work environment, equal opportunities, especially related to gender, and promoting positive impacts through adequate wages and freedom of association.

Consumers and end-users engagement

For fish farm related products, branding on packaging and a dedicated feedback channel on the portfolio company's website enable customers to share their input. Engagement through this feedback channel occurs on a continuous basis. However, fishmeal, fish oil, and frozen fish from the pelagic sector are typically sold through intermediaries rather than directly to end-users, making it difficult for customers to identify the original producer.

Any engagement primarily occurs post-market through online feedback, direct dialogue with intermediaries, or industry initiatives. Quality teams within the portfolio companies manage these interactions, under the oversight of the Head of Quality & Compliance, and report quarterly to AUSS on any product recalls.

Within the fish farming and whitefish segment the Group gain valuable insights into the customers' expectations, including those of vulnerable groups, through relevant journals, food safety competence groups, and customer feedback. Based on these insights, necessary adjustments to products or labelling are being performed to meet customers' needs and ensure their safety.

Value chain workers engagement

Portfolio companies in the pelagic sector ensure food safety through quality checks before a product is dispatched. These checks are embedded in production routines, ensuring that only compliant products reach the market.

To ensure transparency and compliance, LSG provide clear product specifications for all business-to-business sales, detailing the intended use of products.

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

List of Material Impacts, Risks and Opportunities

Through the double materiality assessment (DMA) conducted in 2024, AUSS identified material impacts, risks, and opportunities (IROs) across environmental, social, and governance topics. The assessment was based on methodology from ESRS 1 and 2, with guidance from EFRAG.

Summary of Material ESRS Standards

The following ESRS standards are considered material (indicated in dark blue in the original assessment):

• E1: Climate Change
• E4: Biodiversity and Ecosystems
• S1: Own Workforce
• S2: Value Chain Workers
• S4: Consumers and End-users
• G1: Business Conduct
• Entity Specific: Fish Health and Fish Welfare

Detailed IRO Tables by Topic

E1 Climate Change

E4 Biodiversity and Ecosystems

S1 Own Workforce

S2 Value Chain Workers

S4 Consumers and End-users

G1 Business Conduct

Entity Specific: Fish Health and Fish Welfare

Linkage Between IROs and Strategy / Business Model

Climate Change (E1)

The identified environmental impacts related to E1 Climate Change are closely linked to the Group's operations, particularly within fish farming and fisheries, along with their respective value chains.

Current Financial Effects:

• In 2024 LSG invested NOK 1.8 billion in technology to improve innovations in farming operation, MNOK 400 was allocated to shielding technology in order to improve fish health and fish welfare.
• In 2024, 59% of the Group's emissions comes from fishing vessels with a lifespan of 10–50 years, resulting in locked-in emissions.

Strategy and Response:

• LSG has set Science Based Targets to reduce Scope 1, 2, and 3 emissions by 46% by 2030, using 2019 as the base year, with a long-term ambition to achieve climate neutrality by 2050.
• AUSS plans to begin work on establishing climate transition plan in 2025 and will start the work on setting Science Based Targets (SBTs) for the Group in 2025.
• Group-wide initiatives include electrification of aquaculture operations, certified soy in fish feed, sustainable fish feed development, operational energy efficiency improvements, and transportation efficiency measures.

Resilience: AUSS's business model demonstrates resilience through diversification across fish farming, fisheries, and primary and secondary fish processing, as well as geographical diversification. A notable example is the increased earnings for the fishmeal and fish oil segment when Austral experienced negative financial results due to a strong El Niño in Peru in 2023.

AUSS main strategy for mitigating risk related to volatility in cash flow is to maintain a strong balance sheet, strong liquidity, and investment grade credit rating (BBB-rating with stable outlook at Nordic Credit Rating).

Biodiversity and Ecosystems (E4)

The portfolio companies engaged in aquaculture manage the potential impacts on biodiversity, with a particular focus on farmed fish escapes. Managing fish health and fish welfare is also key to the Group's operation.

Current Financial Effects: Escapes of farmed fish have financial implications for the portfolio companies engaged in fish farming. These include costs related to loss of fish, cost related to recapture efforts, and regulatory fines for non-compliance.

Strategy and Response: To mitigate the potential impact of fish escapes, the portfolio companies have implemented a comprehensive approach that includes both preventive measures and actions to address any escapes that may occur. This involves strict procedures, emergency preparedness plans, technical maintenance, proper use of approved equipment, and targeted training. The implementation of shielding technology in aquaculture is expected to contribute to a reduction in escape incidents, particularly those related to handling, such as delousing.

Resilience: AUSS monitors these ongoing improvements as part of its broader governance and risk management framework. The Group maintains continuous monitoring systems and emergency backup solutions, with regular employee training to strengthen operational readiness.

Fish Health and Fish Welfare (Entity Specific)

Current Financial Effects: The financial impact of lice and disease is at least twofold:

• Increased costs due to capital-intensive treatments and specialized vessels
• Lost earnings due to reduced harvest volumes.

The Group's farming results have been below expectations in recent years due to biological challenges, leading to lower harvested volumes and increased costs.

Strategy and Response: Key strategic measures include:

• Optimised genetics and production processes to ensure robust smolt and healthier fish
• Improved biosecurity and disease prevention to reduce mortality and treatment costs
• Shielded farming technologies (LSG) on designated farming sites to minimize lice pressure and handling stress.

Key Capex allocations for LSG:

• 2024: MNOK 440 for shielded technology, MNOK 200 for smolt quality, MNOK 200 for land-based industry
• 2025: MNOK 400-500 for shielded technology investments

Resilience: AUSS supports LSG in scaling up shielded farming technology on designated farming locations to improve fish welfare and reduce delousing treatments. Early results indicate a decrease in delousing frequency, and further benefits are expected as implementation progresses. Despite new operational risks, AUSS expects that reduced handling stress and improved fish health will outweigh potential drawbacks.

Social Impacts (S1, S2, S4)

The Group's operations also directly or indirectly affect people, with identified material positive and negative social impacts.

Strategy and Business Model Alignment: In alignment with AUSS's strategy and business model, workforce-focused initiatives support both employee well-being and business goals. Health and safety practices are essential for operational continuity, fair wages and working conditions promote employee retention and productivity, and diversity initiatives create an inclusive workplace where employees feel valued and supported.

Own Workforce (S1):

• AUSS's strategy prioritizes three main areas: health and safety, fair wages, and working conditions.
• Health and safety is placed at the forefront, implementing systematic HSE measures across all activities to prevent injuries and promote a safe, positive work environment.
• AUSS supports fair compensation that meets or exceeds national minimums and industry standards.
• Employment contracts are provided in languages the employees understand, reinforcing transparency and accessibility.

Value Chain Workers (S2): AUSS's business model relies on third-party suppliers, including those in higher-risk regions such as Chile and Peru. Additionally, the business model relies on upstream business partners with global supply chains, within industries such as feed production and transport. These industries involve value chain workers working in high-risk regions and businesses, such as agriculture and mining of raw materials.

Strategic choices aimed at cost efficiency and operational flexibility may lead to challenges for these workers, such as high seasonal workloads, issues with wage transparency, and variable safety standards. To mitigate these impacts, the portfolio companies actively engage with both business partners and suppliers to ensure compliance with AUSS's Supplier Code of Conduct.

Consumers and End-Users (S4): Food safety remains a priority across all operations and is fundamental to both the Group's business model and consumer trust. To maintain this trust, the portfolio companies continuously adapt and refines operations in response to consumer needs, regulatory developments, and stakeholder expectations.

Interaction with Business Model and Value Chain

The Group operates across a wide range of sectors, including fish farming, fisheries, and primary and secondary processing. The value chain includes:

Upstream:

• Supply chain workers
• Main inputs: Energy (electricity, fuel), Water, Materials (feed, nets)
• Infrastructure (wellboats, service boats, workboats, packaging)

Own Operation:

• Knowledge – own workforce, employees working on production facilities, farming sites, processing facilities and supporting administrative activities
• Operations across fishery, farming (roe hatchery, smolt, farming), and primary/secondary processing

Downstream:

• Market activities
• End users
• Whistleblowing channels

Material IROs are mapped across this value chain, with specific activities identified for each segment (Pelagic, Whitefish, and Fish Farming).

Resilience to Identified IROs

Resilience in the strategy and business model is assessed as part of AUSS ongoing risk management processes and through the double materiality assessment over the short, medium, and long term.

Key Resilience Factors:

1. Diversification: AUSS's business model demonstrates resilience through diversification across fish farming, fisheries, and primary and secondary fish processing. Geographical diversification further strengthens resilience.

2. Financial Strength: AUSS main strategy for mitigating risk related to volatility in cash flow is to maintain a strong balance sheet, strong liquidity, and investment grade credit rating. AUSS has a BBB-rating with stable outlook at Nordic Credit Rating.

3. Continuous Monitoring: The Group maintains continuous monitoring of water quality, fish health, environmental conditions, and HSE indicators, ensuring rapid response protocols are in place for unexpected events.

4. Technology Investment: Significant investments in new technology (e.g., shielding technology, energy-efficient systems) enhance resilience against biological and environmental challenges.

5. Climate Scenario Analysis: A resilience analysis was conducted in 2023 using the TCFD framework, incorporating two scenarios: RCP 8.5 (business-as-usual) and RCP 2.6 (Paris Agreement). The analysis addressed both physical and transition risks over short, medium, and long-term horizons.

Long-term Considerations: In the long term, risks such as new legislation, taxes on fossil fuels, and shifting downstream expectations may impact cost structures and revenue streams. However, due to uncertainty related to potential regulatory changes, no financial estimates are currently available. Additional climate risks related to transportation and emerging challenges in fish health are also critical considerations that could negatively impact financial performance over time.

By maintaining strong governance and supporting innovation in farming technology, AUSS aims to enhance fish welfare, improve resilience in production, and secure long-term sustainability across the Group.

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

Overview

In 2024, AUSS conducted a comprehensive double materiality assessment (DMA) to identify and prioritize the material impacts, risks, and opportunities (IROs) across the Group. This is the first time AUSS conducts a DMA. The analysis builds on previous materiality analysis which focused on impact. The DMA is based on methodology from ESRS 1 and 2, in addition to guidance from the EUs advisory team, EFRAG. AUSS build the study on internal and external expertise, together with important views from stakeholders.

The process is informed by due diligence procedures and is designed to ensure proactive identification and management of sustainability responsibilities, both in operations and through business relationships. To secure this, the process is designed to address significant activities and locations within farming and fishery, together with their respective value chains and business relationships.

Step-by-step methodology

Step 1: Scoping and understanding of own operations and value chain

The assessment began with a comprehensive mapping of AUSS's and the Group companies activities, operations, and value chains. The Group operates across a wide range of sectors, including fish farming, fisheries, and primary and secondary processing. This phase involved a structured analysis of how activities, business relationships, and geographies influence the risk of adverse impacts. High-risk areas were identified based on operational complexity, regulatory environments, and stakeholder concerns. Specific focus was placed on regions with known challenges related to labour rights, environmental vulnerabilities, and governance issues.

For example, sourcing from third-party vessels in Peru and Chile was flagged as an area requiring further due diligence caused by limited transparency on working conditions.

Step 2: Stakeholder engagement

Key stakeholders—including customers, suppliers, employees, regulators, NGO, and community representatives—were identified and engaged as part of the process. Stakeholder input was gathered through a combination of surveys and interviews conducted in 2024, supplemented by insights from prior materiality assessments carried out by the Group's largest subsidiary, LSG. As part of this engagement, stakeholders were asked to provide insights on heightened risks associated with business relationships and geographic exposure, ensuring that stakeholder perspectives helped validate and refine the identification of adverse impacts. Stakeholders were asked to prioritize and evaluate significant sustainability topics, providing critical input to the DMA process. This phase ensured that the assessment aligned with both societal and financial expectations.

Step 3: Identification of impacts, risks and opportunities

In this step, relevant IROs were identified by analysing potential impacts on both the environment and society ("inside-out") as well as financial risks and opportunities from external factors ("outside-in"). This comprehensive identification process was informed by input from stakeholder engagement, industry expertise, and desktop research.

Environmental, social, and governmental impacts: The effects were assessed to determine whether they were actual or potential and whether they were positive or negative.

Financial risks and opportunities: These were evaluated by identifying the ESG-related risks the Group might face, considering the connection of the identified impacts, dependencies, potential outcomes, and how these could affect operations, customers, employees, and financial performance.

The identification of IRO involves assessing climate change, particularly the Group's GHG emissions. In 2024, AUSS conducted a climate risk and scenario analysis using the TCFD framework. Two scenarios were used in the study: business as usual (4-degree increase) and in line with the Paris Agreement (1.5-degree increase). The assessment includes both physical and transitional risks and opportunities over the short, medium, and long term, considering potential impacts on the Group's assets, including fishing vessels, fish farming, and processing facilities.

The Group has conducted mapping and assessments of impacts and dependencies on biodiversity and ecosystems, including ecosystem services, systemic risks, and transitional and physical risks and opportunities within the value chain. Transition risks were assessed based on potential regulatory developments, stakeholder expectations, and evolving market conditions related to biodiversity protection.

To ensure a structured and quantifiable risk evaluation, the assessment framework applied severity, likelihood, and financial consequence scoring. Spatial analyses were conducted to assess the proximity of the Group's operations to biodiversity-sensitive areas, and screening was performed against UNESCO-listed sites to identify potential operational overlaps. Water stress analysis was carried out using the UN water stress map to evaluate dependencies on freshwater resources within the value chain.

The Group has some activities in or near bio sensitive areas. In the event of an escape or suspected escape, fish farmers are legally required to report the incident immediately to the Norwegian Directorate of Fisheries.

The Group has not conducted direct consultations with affected communities regarding sustainability assessments of shared biological resources and ecosystems for this reporting period. However, findings from previous stakeholder analysis have been used as a basis for this year's double materiality assessment.

The identification process was carried out at both company level and Group level, ensuring a comprehensive overview of material IROs across the organisation.

Step 4: Evaluate

To assess the materiality of the IROs, all IROs were evaluated based on defined criteria to ensure a consistent and objective assessment. The scoring was performed based on consolidated IROs at Group level.

Impact Materiality: Actual negative impacts were assessed based on severity, while potential impacts were assessed on both severity and likelihood. Severity was determined by the scale, scope, and irremediability nature of the impacts. For human rights impacts, severity took precedence over likelihood. Positive impacts were evaluated based on their scale and scope, with potential impacts also factoring in likelihood. The scoring of scale, scope and irremediability (severity) was conducted on a scale from 1-5, with 5 indicating the highest possible negative- or positive impact. A lower score indicates lower environmental or social impact, and a higher score indicates high environmental or social impact.

Financial Materiality: Risks and opportunities were assessed based on their likelihood and financial consequences, with a scoring system tied to financial figures, including EBITDA. The scoring of financial consequences was conducted on a scale from 1-5, were score 5 will indicate the most material financial consequences.

The scoring of likelihood was conducted on a scale from 1-5, with 5 being the highest likelihood for both impact materiality and financial materiality.

Time Horizons: The assessment included short-term (reporting year), medium-term (1-5 years), and long-term (beyond 5 years) perspectives of the impact, risk or opportunity.

Where in the value chain the IROs originated—whether in own operations, upstream, or downstream—was also evaluated. The results were categorized and prioritized.

The scoring of severity, likelihood and consequence was conducted on a scale from 1-5.

Step 5: Thresholds and material topics

Thresholds for determining material IROs were established to focus on the most critical topics and IROs. For impact materiality, a threshold score of 3 was applied across the Group, ensuring consistency in identifying significant IROs. For financial materiality, the scoring system considered both the likelihood and magnitude of financial effects, with threshold score 3 established to distinguish high-priority risks and opportunities.

The final list of material IROs was reviewed by the AUSS management team, including the Audit and ESG Committee and the Board, to ensure alignment with governance priorities and stakeholder expectations. Input from group leaders and reference groups helped refine and validate the final assessment. The double materiality process, identifying and assessing IROs, is included in the overall management process and will be updated on a yearly basis.

Inputs to the assessment

• Sector benchmarks and ESRS guidance: The DMA is based on methodology from ESRS 1 and 2, in addition to guidance from EFRAG. Industry expertise and desktop research informed the identification of IROs.
• Internal experts: Input from group leaders, reference groups, and the AUSS management team, including the Audit and ESG Committee and the Board.
• External consultants: AUSS build the study on internal and external expertise.
• Stakeholder consultation: Stakeholder input was gathered through a combination of surveys and interviews conducted in 2024, supplemented by insights from prior materiality assessments carried out by LSG. Stakeholders included customers, suppliers, employees, regulators, NGO, and community representatives.
• Value chain mapping: The assessment began with a comprehensive mapping of AUSS's and the Group companies activities, operations, and value chains. The process is designed to address significant activities and locations within farming and fishery, together with their respective value chains and business relationships.

Scoring criteria

Impact materiality:

• Severity: Determined by scale, scope, and irremediability. Scored on a scale from 1-5, with 5 indicating the highest possible negative or positive impact.
• Likelihood: For potential impacts. Scored on a scale from 1-5, with 5 being the highest likelihood.
• Human rights impacts: Severity took precedence over likelihood.
• Positive impacts: Evaluated based on scale and scope, with potential impacts also factoring in likelihood.

Financial materiality:

• Likelihood: Scored on a scale from 1-5, with 5 being the highest likelihood.
• Financial consequences: Scored on a scale from 1-5, with score 5 indicating the most material financial consequences. Scoring system tied to financial figures, including EBITDA.

Threshold for materiality

For impact materiality, a threshold score of 3 was applied across the Group. For financial materiality, threshold score 3 was established to distinguish high-priority risks and opportunities.

Frequency / when last reviewed

This is the first time AUSS conducts a DMA, conducted in 2024. The double materiality process, identifying and assessing IROs, is included in the overall management process and will be updated on a yearly basis.

Use of value chain mapping in the process

The assessment began with a comprehensive mapping of AUSS's and the Group companies activities, operations, and value chains. The Group operates across a wide range of sectors, including fish farming, fisheries, and primary and secondary processing. This phase involved a structured analysis of how activities, business relationships, and geographies influence the risk of adverse impacts. The process is designed to address significant activities and locations within farming and fishery, together with their respective value chains and business relationships.

The identification process was carried out at both company level and Group level, ensuring a comprehensive overview of material IROs across the organisation. Where in the value chain the IROs originated—whether in own operations, upstream, or downstream—was also evaluated.

Transition plan for climate change mitigation

Scope and coverage

As a holding company, the impact on climate change mitigation primarily arises from the activities and strategies of the portfolio companies and not from AUSS itself. While AUSS do not yet have a finalized transition plan for the Group, LSG (largest company in the Group) has set emissions reduction targets and developed a transition plan. LSG is the only company in the Group with formalised targets.

Target years and milestones

LSG has committed to a Science Based Target to reduce Scope 1, 2, and 3 emissions by 46% by 2030, using 2019 as the base year. Their long-term ambition remains to achieve climate neutrality by 2050.

LSG has achieved an approximate 4.7% reduction in GHG emissions (Scope 1, 2, and 3) compared to 2019 levels. In 2024, LSG updated its 2019 baseline as part of its CSRD reporting, resulting in adjustments to the reported reduction figures.

The Group has also set challenging targets within ESG, including reducing greenhouse gas emissions by 46% by 2030. A number of measures with long lead times have been implemented. The Group is concentrating in particular on solutions within transport and fish feed.

SBTi validation and Paris alignment

As part of the CSRD reporting the Science Based Targets will be reviewed in 2025, and may be subject to change.

AUSS will start the work on setting Science Based Targets (SBTs) for the Group in 2025, which will guide long-term climate strategies. These targets will serve as the foundation for a strategy aligned with global climate goals, including the Paris Agreement's 1.5°C target.

Key decarbonization levers and initiatives

Although a group-wide transition plan is not yet in place, all portfolio companies within the fish farming segment are implementing measures to reduce GHG emissions and support climate change mitigation at the group level.

Current group-wide initiatives include:

• Electrification of Aquaculture Operations: Implementing energy-efficient systems across all fish farming operation to lower emissions from production activities.
• Certified Soy in Fish Feed: Ensuring that the Group use responsibly sourced soy in fish feed to minimize environmental impact.

Key initiatives undertaken by the Group's companies in 2024:

FISH FARMING

• Sustainable Fish Feed: Developing feed with low-carbon ingredients, utilizing residual raw materials, and exploring new technologies to reduce Scope 3 emissions.
• Operational Energy Efficiency: Investing in hybridization of farming fleets, expanding remote operations, and increasing the use of shore power to lower emissions.
• Transportation Efficiency: Reducing transportation weight, optimizing logistics, and participating in innovation projects to develop alternatives to fossil fuels.
  • Reduction of approximately 0.1% of the Group's total Scope 1 emissions is expected.

WHITEFISH

• Energy Efficiency: Implementing fuel-efficient engines and adopting technologies such as float trawling to reduce fuel consumption and seabed impact.
  • Reduction of approximately 0.2% of the Group's total Scope 1 emissions is expected.

PELAGIC

• Energy Efficiency: Installing energy-saving technologies such as heat pumps to reduce overall energy demand.
• Fuel change: Change to fuel with lower emissions.
  • Reduction of approximately 0.6% of the Group's total Scope 1 emissions is expected.

CapEx and investment commitments

LSG is investing in new technology as part of a broader plan to improve fish health, biosecurity and earnings, by implementing innovations in farming operations. In 2024, LSG invested NOK 400-500 million in new shielding technology. An additional NOK 400-500 million investment in shielded technology is planned for 2025.

The majority of the Group's activity is currently not encompassed by the Taxonomy Regulation, and thus the Group's CapEx plan is presently not aligned with the requirements set for CapEx plans in the EU Taxonomy.

Locked-in emissions and stranded assets

The Group operate fishing vessels, used for catching whitefish and pelagic species. The fishing vessels are key contributors to the Group's Scope 1 GHG emissions. Service vessels also contribute to the overall emissions and are considered in the assessment of potential locked-in emissions. The fishing vessels have a lifespan of 10–50 years, with limited potential for significant emission reductions during their remaining operational life, resulting in locked-in emissions. In 2024 59% of the Group's emissions comes from fishing vessels.

The Group are actively exploring measures to reduce emissions, including upgrading to more efficient engines and implementing other energy-saving initiatives. AUSS, as an active owner, acknowledges the transition risks posed by these emissions and is committed to managing them as part of the climate strategy going forward.

Transition plan timeline and next steps

While the work on developing a formal transition plan has not yet started, the aim is to complete it within two years from initiation.

AUSS aims to establish a group-wide transition plan beginning in 2025, based on Science Based Targets and lessons learned from the portfolio companies initiatives.

AUSS will in the following year work closely with the Group's companies in order to be able to set SBT at Group level going forward.

Climate scenario analysis and resilience

A resilience analysis was conducted in 2023, building on climate risk and scenario analysis using the TCFD framework. The analysis involved workshops with key internal stakeholders across all portfolio companies and scenario studies covering on Chile, Peru, and Norway. This analysis integrates both upstream and downstream risks into AUSS's DMA process.

The resilience analysis incorporated two scenarios:

• RCP 8.5 (business-as-usual): Focusing on significant physical risks such as extreme weather, changing ocean conditions, and sea level rise.
• RCP 2.6 (Paris Agreement): Addressing transition risks, including regulatory changes (e.g., carbon pricing), market shifts, and technological advancements.

The RCP 8.5 scenario emphasizes high physical risks, including severe climate hazards, while the RCP 2.6 scenario aligns with a 1.5°C pathway, focusing on regulatory and market shifts. These scenarios were selected for their alignment with IPCC and state-of-the-art climate science, ensuring a robust evaluation of possible risks and uncertainties. The main assumption of the RCP 2.6 scenario is that global emissions reached their peak in 2020 and that they are currently rapidly declining.

Key assumptions include a gradual transition to low-carbon operations, advancements in renewable energy and vessel technologies, and growing demand for sustainable seafood products. The analysis considers short-term (reporting year), medium-term (2030), and long-term (2050) horizons, aligned with strategic and financial planning.

Results of the analysis:

Physical Risks:

• Extreme weather events (e.g., El Niño, storms, flooding) and changing fish stock migration patterns impact operational efficiency and supply chain reliability.
• Chronic risks, such as ocean acidification and warming, pose long-term threats to fish availability and aquaculture production.

Transition Risks:

• Increasing carbon taxation and stricter regulations on packaging and feed could lead to higher operational costs.
• Stricter customer sustainability requirements may limit market access for non-certified products.

Opportunities:

• Adoption of energy-efficient technologies and renewable energy in operations.
• Increased market demand for certified, low-carbon seafood products.

Uncertainties in the study include regulatory timelines, technological feasibility, and market adaptability. These uncertainties may affect the resilience of specific assets and business activities, particularly in relation to operational sites, supply chain dependencies, and energy-intensive processes. The full assessment of how these risks influence the Group's strategy, investment decisions, and planned mitigation actions has not yet been completed, but this will be further integrated into the transition plan going forward.

AUSS demonstrates resilience through ongoing efforts by the portfolio companies to explore the potential for upgrading engines and implementing energy-saving measures in their operation. Remaining uncertainties, such as the pace of regulatory changes and the technological feasibility of retrofitting trawlers, will be considered in the AUSS's strategic planning. This approach ensures adaptability over the short, medium, and long term, supporting alignment with global climate goals, including the Paris Agreement.

Carbon credits and removals

Not disclosed.

Progress monitoring and governance

The portfolio companies monitor and report on their GHG emissions. AUSS reports are consolidated at the Group level on a quarterly basis, providing oversight and insights into ongoing progress.

Progress is tracked quarterly through consolidated reports from the portfolio companies, which include climate and energy indicators.

Policies related to climate change mitigation and adaptation

Climate and energy consumption policy

Scope and application:

• Applies to the portfolio companies, employees, and contracted labour
• Provides the framework for managing the Group's climate related impact effectively

Governance and approval:

• The policy is approved by the board
• The CEO at AUSS has the overall responsibility for the policy
• Top management in each company is responsible for ensuring compliance with this policy

Key content and principles:

• As a holding company, AUSS encourages its portfolio companies to set targets for reducing GHG emissions and to actively implement energy-efficient solutions and technologies that run on renewable energy
• These efforts focus on climate change mitigation, addressing negative impacts such as GHG emissions and energy use
• The policy emphasizes climate change adaptation, requiring portfolio companies to regularly map climate-related risks and carry out assessments and analyses

Public availability:

• The policy is publicly available on AUSS's website

Policy development and stakeholder engagement:

• In developing the policy, AUSS has engaged with the portfolio companies and industry experts
• Through ongoing dialogue and feedback, AUSS ensures that the policy addresses the ecological, social, and economic concerns of all stakeholders involved

Implementation monitoring:

• Progress is tracked quarterly through consolidated reports from the portfolio companies, which include climate and energy indicators

Limitations:

• The policy does not address financial risk requirement of blending biofuel into conventional fuel and higher taxes on fossil fuels and new EU legislation

Actions and resources in relation to climate change policies

Scope 3 Screening

Action description: In 2024 AUSS conducted a screening of the Group's value chain emissions. The screening was based on 2023 data. Data was estimated using internal record, where 90% of the data was third party audited, and industry benchmarks. Other factors, such as significant events during the year, changes in fixed assets, and stakeholder dialogues, were also considered.

Outcomes: The result of the screening shows the Group's material categories and set the reporting foundation in the reporting year.

Scope: Value chain (Scope 3 emissions)

Time horizon: Completed in 2024

Resources: Not quantified. Reference is made to page 57 for more information regarding AUSS's financial capacity.

Transition to Science Based Targets (SBTs)

Action description: The Group has identified and initiated actions aimed at climate change mitigation and adaptation. Efforts include transitioning to set Science Based Targets (SBTs) aligned with the Paris Agreement's 1.5°C target. See chapter E1-1 Transition plan for more information regarding action taken.

Scope: Own operations and portfolio companies

Time horizon: Targets to be set at Group level in 2025. LSG has set their SBT in 2021 aiming to reduce their total emissions by 46% by 2030 and climate neutral by 2050 compared to 2019 level.

Link to targets: AUSS will work closely with the Group's companies in order to be able to set SBT at Group level going forward (see E1-4).

Portfolio Company Engagement and Targets

Action description: As a holding company, AUSS encourages its portfolio companies to set targets for reducing GHG emissions and to actively implement energy-efficient solutions and technologies that run on renewable energy. These efforts focus on climate change mitigation, addressing negative impacts such as GHG emissions and energy use.

Scope: Portfolio companies (own operations and value chain)

Quarterly Progress Tracking

Action description: Progress is tracked quarterly through consolidated reports from the portfolio companies, which include climate and energy indicators.

Scope: Group-wide monitoring

KPIs/Outcomes: Climate and energy indicators reported quarterly

Targets related to climate change mitigation and adaptation

Group-level targets

Austevoll Seafood ASA has not yet set emission reduction targets at Group level. As stated in the report: "AUSS has not yet set emission reduction targets at Group level. This work will start in 2025." The company plans to set Science Based Targets (SBTs) for the Group in 2025.

Lerøy Seafood Group (LSG) targets

LSG, the largest portfolio company in the Group, has established the following climate targets:

Progress to date (LSG):

• As of 2024, LSG has achieved an approximate 4.7% reduction in GHG emissions (Scope 1, 2, and 3) compared to 2019 levels
• In 2024, LSG updated its 2019 baseline as part of its CSRD reporting, resulting in adjustments to the reported reduction figures
• LSG's Science Based Targets will be reviewed in 2025 and may be subject to change

Health, Safety, and Environment (HSE) target

The Group has set the following target related to workforce safety:

Progress: LTI rate was 15 in both 2023 and 2024.

Energy consumption and mix

Energy consumption by source (MWh)

Energy intensity

Scope and methodology:
Marine fishing and fish farming (aquaculture) are defined as "high-climate impact sectors"; hence energy intensity per net revenue does not include any exclusions. The increase in total energy consumption in 2024 is primarily due to higher production volumes, particularly in Peru where two good fishing seasons occurred in 2024 compared to 2023 when the first season was cancelled due to El Niño and the second season quota was historically low. Fishing vessels account for 59% of the Group's Scope 1 emissions in 2024.

Gross Scopes 1, 2, 3 and Total GHG emissions

Scope 1 GHG emissions

Scope note: Scope 1 covers all direct emissions from the Group. Main contributors are diesel and marine gas oil (MGO) for vessels, and natural gas, liquefied petroleum gas (LPG), and other fossil fuels used in production facilities. Emission factors sourced from DEFRA, Norwegian Environment Agency, Linde Gas, and A-gas. In 2024, 59% of the Group's emissions come from fishing vessels.

Scope 2 GHG emissions

Scope note: Scope 2 emissions are indirect emissions from purchased electricity, district heating, and cooling consumed at operational sites. Location-based emissions calculated using average country-specific emission factors. Market-based calculations incorporate Guarantees of Origin (GOs) for renewable energy purchases where applicable and assume regular power is delivered as residual power.

Scope 3 GHG emissions

Scope 3 emissions include indirect emissions in the Group's value chain (upstream and downstream). In 2024, the Group conducted a screening of Scope 3 emissions, leading to identification of new material categories for some portfolio companies. Previously, Scope 3 data was solely from LSG. 2023 data for Category 1 (Purchased Goods and Services) updated to include other purchased goods and services beyond fish feed. Category 15 (Investments) newly included in 2024, with Pelagia (joint venture) accounting for over 97% of emissions in this category.

*Scope 3 emissions for 2023 only include LSG, as AUSS did not have a consolidated Scope 3 calculation for 2023.

**Category 15 (Investments) is a new material category for 2024.

Category-specific notes:

• Category 1: Fish feed accounts for 80% of emissions. Emissions from fish feed calculated using supplier-specific methods. Other purchased goods and services calculated using spend-based method. AUSS is not able to locate purchased cloud computing and data centre services in 2024.
• Category 2: Capital goods emissions calculated using spend-based method. Inherent uncertainties due to use of generic accounts, broad categorisation and limited data granularity.
• Category 3: Indirect emissions from production, extraction, refining, and transportation of fuels and energy. Calculated based on Well-to-Tank (WTT) data from consumption volumes in Scope 1 and 2.
• Category 4: Transport of purchased goods included in Category 1. Distance-based and fuel-based method used. Calculations based on distance from capital to capital.
• Category 5: Data on waste volumes and composition collected from portfolio companies. Calculated based on waste type specific method.
• Category 7: Average-data method using average data on commuting patterns (generic assumptions).
• Category 9: Transportation carried out by customers. Distance-based method.
• Category 10: Estimated electricity use for storage before end consumer, and third-party processing. Average-data method.
• Category 12: End-of-life for packaging, food waste, and fishmeal/fish oil. Waste-specific method.
• Category 15: Emissions from the Group's investments, calculated based on share of ownership, including Scope 1, 2, and 3 emissions. Pelagia (joint venture) accounts for over 97%.

Total GHG emissions

Note: 2024 serves as the base year for the Group's GHG emissions going forward. Emission figures are revised if updated emission factors result in a change in total emissions exceeding 5% compared to the year before.

GHG intensity per net revenue

Note: The increase is due to changes in Scope 3 emissions. In 2023, only LSG's Scope 3 emissions were reported. In 2024, Scope 3 reporting expanded to include all portfolio companies and Category 15 (Investments). Marine fishing and fish farming (aquaculture) is defined as "high-climate impact sector", hence Energy intensity per net revenue does not include any exclusions.

Methodology and consolidation approach

AUSS calculates GHG emissions in accordance with ESRS and GHG Protocol Corporate Accounting and Reporting Standard. Consolidation follows the financial control approach, ensuring consistency with financial reporting. In E1, consolidation also includes emissions from entities over which AUSS has operational control, including leased assets under IFRS 16.

Emission factors for Scope 1, 2, and 3 sourced from DEFRA, IEA, IPCC, and supplier-specific data. Reporting conducted via an IT tool. Scope 2 location-based factors reflect grid averages, while market-based calculations account for residual mixes or Guarantees of Origin. Scope 3 calculations employ supplier-specific, spend-based, distance-based, and average-data methods, depending on the category.

Regulated emissions and biogenic CO2

No information disclosed on regulated emissions under EU ETS or separate biogenic CO2 emissions for the reporting period.

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

Financial effects of physical risks

The Group has not had any significant costs in 2024 resulting from incidents that may have been caused by extreme weather. No climate-related incidents were identified in 2024 that would indicate the need to reassess the working life or residual value of the Group's fixed assets.

In terms of the Group's fishery activities (wild catches), extreme weather is first and foremost the most significant physical risk. If the weather is too extreme, the fishing vessels may not be able to fish. Should this type of situation arise during high season for the fishery concerned, the vessels may not be able to fish their quotas for individual fish species within the quota year. Such a situation would also have consequences for the processing industry onshore. With extreme weather, the onshore industry would suffer due to an insufficient supply of raw materials for the production of end products, which in turn would reduce the earnings of fishing vessels and processing facilities alike.

Extreme weather in the form of strong winds, heavy precipitation, floods, droughts and fire may damage key infrastructure. This could potentially have a major impact on the Group's operations both directly and indirectly through our supplier chain, as efficient infrastructure is important.

El Niño and La Niña occur at regular intervals. This is taken into account in the Group's impairment tests, using historical catch volumes.

Financial effects of transition risks

There were no grounds for writing down the company's intangible assets related to aquaculture and fishery rights in 2024 as a result of the impact of climate change.

Reducing emissions linked to the fishing fleet will require the development of currently unknown technology and therefore an unknown amount of capital as well. Based on current legislation, the Group has not identified any future costs that suggest the need for provisions for future obligations under IAS 37 Provisions, Contingent Liabilities and Contingent Assets.

Costs related to climate risk have not been found to have impacted the Group's impairment tests or sensitivity analyses.

The fishing vessels represent the largest share of the Group's direct CO2 emissions, and there are currently no effective alternatives to the existing propulsion systems.

Financial effects of climate-related opportunities

Salmon, trout and wild-caught fish have one of the lowest carbon footprints compared with other animal proteins. This is positive for the Group, as it is expected that consumers will increasingly demand food with a lower carbon footprint in the future. The value of the inventory has not been changed based on climate-related incidents.

Impact on accounts receivable

Historically, the Group's losses on accounts receivable and other receivables have been low. Based on the Group's business activities and customer base, it has been assessed that climate change does not impact the Group's estimated provision for bad debt beyond what is stated in Note 9.

Going concern assessment

It is hereby confirmed that climate-related risks do not significantly affect the Group's going concern assumption.

Policies related to own workforce

AUSS has established four policies that address the Group's material impacts related to the workforce, supporting the commitment to human rights and decent working conditions. These policies provide the framework for managing the Group's responsibilities effectively and fostering a safe, fair, and supportive work environment.

Human Rights and Decent Work Conditions Policy

Scope: All employees, directors, officers, hired personnel, consultants and representatives, as well as any person conducting work on behalf of or otherwise representing AUSS globally. The Group expects suppliers and business partners in the upstream and downstream value chain to conduct themselves in line with this policy.

Key content:

• Adequate Wages: Salaries must at minimum comply with national minimum wage laws or industry standards and be sufficient to cover basic needs. Disciplinary deductions from salary are not permitted. Employees are entitled to an employment contract in a language they understand.
• Gender equality in management positions: All forms of discrimination and harassment, including discrimination based on sex, are strictly prohibited. The Group has committed to positive action for vulnerable groups and has implemented procedures to prevent, mitigate, and address discrimination. Special protections are in place to prevent harassment, discrimination and inequal treatment of vulnerable groups, specifically women, ensuring an inclusive work environment that prevents gender inequality in management positions.
• Freedom of association: All employees shall have freedom of association and be free to engage in collective wage bargaining and union organisations, without exceptions. The portfolio companies shall have a dialogue with employee representatives and cooperate with both employees and trade unions and shall not discriminate against trade union representatives or prevent them from performing their duties.

Governance: The policy is approved by the board. The CEO at AUSS has the overall responsibility for the policy. Top management in each portfolio company is responsible for ensuring compliance with this policy.

Public availability: The policy is publicly available on AUSS' web site.

International standards: AUSS and its portfolio companies upholds strong human rights commitments, guided by international standards such as the UN Guiding Principles on Business and Human Rights, the ILO Declaration on Fundamental Principles and Rights at Work, and the OECD Guidelines for Multinational Enterprises. AUSS's policies are aligned with these international standards and focus on respecting labour rights, engaging with the workforce, and providing remedies for any human rights impacts, and specifically address issues such as human trafficking, forced or compulsory labour, and child labour.

Monitoring: Monitoring of policy adherence is performed on a quarterly basis, with reports from each portfolio company consolidated at Group level. These reports include health and safety indicators, as well as equality measures. In the event of identified human rights impacts, processes are in place to provide appropriate remedies. This includes corrective actions, compensation where applicable, and measures to prevent recurrence.

Health and Safety Policy

Scope: The policy applies to the Group's employees and contract labour, with particular emphasis on high-risk roles at sea and in processing facilities.

Key content: The policy outlines the commitment to a zero-injury goal by enforcing rigorous safety standards, conducting regular risk assessments, and providing comprehensive safety training.

Governance: The policy is approved by the board. The CEO at AUSS has the overall responsibility for the policy. Each portfolio company's management holds responsibility for compliance, supported by designated HSE personnel who oversee daily implementation.

Public availability: The policy is publicly available on AUSS' web site.

International standards: The Health and Safety Policy is aligned with international standards and prevailing national HSE regulations and laws.

Monitoring: Regular audits and monitoring performed by the portfolio companies ensure that health and safety practices are continuously improved.

Diversity and Inclusion Policy

Scope: All Group employees.

Key content: The policy emphasizes the positive impact of diversity and inclusion on the Group, with a focus on empowering employees and equal opportunities, such as promoting gender equality in management positions. The general objectives include enhancing diversity across all levels of the organization, eliminating discrimination, supporting flexible work arrangements to improve employee well-being and promoting the basis for equal opportunities. AUSS is committed to ensuring equal employment opportunities and rights for all the Group's employees and encourages the formation of "Gender Equality and Diversity Committees" to promote a corporate culture of equality and respect.

Governance: The policy is approved by the board. The CEO at AUSS has the overall responsibility for the policy. Top management in each portfolio company is responsible for ensuring compliance with this policy.

Public availability: The policy is publicly available on AUSS' web site.

Monitoring: The Policy includes procedures for reporting and evaluation diversity and inclusion indicators, including the detection and prevention of discrimination.

Whistleblowing Policy

Scope: All employees, as well as external parties.

Key content: The Whistleblowing policy is an integral part of the commitment to ensuring a safe and transparent environment where employees can report concerns without fear of retaliation. This policy provides employees with a secure, confidential channel to report issues related to the identified material impacts, such as non-compliance with HSE regulations, discrimination and concerns related to diversity and equality, ethical concerns, or other serious matters.

Governance: The policy is approved by the board. The CEO at AUSS has the overall responsibility for the policy. Top management in each portfolio company is responsible for ensuring that all employees have information about and access to the channel.

Public availability: The policy is publicly available on AUSS' web site.

Monitoring: Each report is carefully documented and followed up. Number of cases and status is collected by the management team within each portfolio company, with quarterly oversight by AUSS to ensure that issues are addressed promptly and effectively. The Group's policies are designed to protect the anonymity of individuals who report concerns.

Taking action on material impacts on own workforce

Austevoll Seafood has implemented actions to address material impacts related to the workforce within the Group. The need for actions is identified through ongoing monitoring of work environment, working conditions (including HSE), and compensation of own workforce. This includes both monitoring of KPIs and engaging with own workforce and their representatives.

Health and Safety Actions

What it does: Portfolio companies have conducted regular safety training, risk assessments, logging of near-miss accidents, and audits to help reduce accident risks, particularly for employees in high-risk environments.

Scope: Globally applicable across the Group's operations and involves all employees.

Expected outcomes: Reduced workplace accidents, enhanced employee safety and a proactive safety culture.

Link to policy: These procedures inform the need for further actions in response to the impact, and support the achievement of the HSE policy.

Resources allocated (non-financial): Dedicated HSE resource is responsible for monitoring, assessing, and reporting on progress to ensure effectiveness in HSE-related initiatives. Dedicated teams oversee these initiatives. Quarterly compliance reports are followed up by AUSS.

Segment-specific implementation:

• In the pelagic segment in Peru, HSE management is internationally certified under ISO 45001. The segment follows national regulatory frameworks and conducts continuous training, medical surveillance, and safety programs to protect workers and contractors.
• Structured management involvement in HSE work and strengthened reporting mechanisms implemented to improve safety culture.

Remediation: For all HSE-related incidents in 2024, portfolio companies took actions to provide support and remedy for those affected, including financial compensation, time off, and social support where applicable.

KPIs: Accidents, near miss (incidents that could have resulted in injury or damage), and sick leave are reported and followed up quarterly through a compliance report.

Adequate Wages

What it does: Policies ensure fair wages that meet or exceed industry standards, supporting financial stability for employees.

Scope: The positive impact identified relates to operations in Peru and Chile. Globally applicable across the Group's operations and involves all employees.

Expected outcomes: Enhanced employee financial well-being as well as securing adequate and fair wages for employees in Peru and Chile. Adequate wages improve the standard of living for employees and their families, enabling them to access better housing, education, and healthcare. This can lead to greater social stability, reduced poverty, and enhanced well-being within the community.

Link to policy: These procedures inform the need for further actions in response to the Group's impact, and support the achievement of the Human Rights and Decent Work Conditions Policy.

Key actions performed for 2024 and on an ongoing basis:

• Two-monthly review of salaries for operation in Chile: The personal manager every two months reviews the correct application of the local salary policy. In case of identified salary gaps, the salaries are adjusted. This ensures adequate fair compensation for all employees.

• Participations in local salary initiatives in Peru: Monitored by a third-party consultant, ensuring that the local salary policies are upheld, and all employees receive an adequate and fair compensation for the work they perform.

Resources allocated (non-financial): Dedicated teams oversee these initiatives. Quarterly compliance report is followed up by AUSS.

KPIs: A new KPI for wages has been introduced and will be followed up annually in compliance with ESRS S1-10, contributing to fair and equitable pay practices.

Gender Equality in Management Position

No specific actions initiated related to this impact in 2024. The work with promoting gender equality in management positions is an integrated part of the Group's diversity- and equality work, implemented through the policies. AUSS has not set Group level targets, but LSG has set a goal of minimum 40% gender representation in management position by 2030.

Freedom of Association

No specific actions initiated related to this impact in 2024. The work with promoting freedom of association is supported at all times as stated in AUSS policy. This right is ensured through compliance reporting, where the portfolio company report the number of employees who are organized.

Effectiveness Monitoring

The effectiveness of these actions is monitored through:

• Incident reports
• Employee satisfaction surveys
• Key performance indicators (KPIs)
• Quarterly compliance reports
• Diversity metrics monitored annually in the compliance report to meet reporting requirements and improve transparency

Regular assessments, including reviews of these KPIs, allow the Group to refine practices and improve workforce outcomes and a safe work environment in a structured and measurable way.

Insights gained from the remediation process are used to improve policies and practices, fostering a safer and supportive work environment.

Targets related to own workforce

Health, Safety, and Environment (HSE) Target

Target metric: Zero fatalities within workforce

Target value: 0 fatalities

Target year: Annual (maintain zero-fatality rate annually)

Baseline year: 2020

Baseline value (LTI): 17

Performance metric: Lost Time Incident rate (LTI) - measured as number of employees injured at work and work-related accidents, including fatalities, divided by total number of working hours multiplied by million hours worked

Scope: 100% hired own employees

Target type: Absolute target (zero fatalities)

Validation: Internal target, aligned with AUSS HSE policy

Progress to date:

• 2023: LTI = 15
• 2024: LTI = 15

Gender Equality in Management (LSG only)

Target metric: Gender representation in management positions

Target value: Minimum 40% gender representation

Target year: 2030

Scope: LSG (Lerøy Seafood Group - one of the portfolio companies in the salmon and trout farming segment)

Note: AUSS has not set Group level targets for gender equality; this is a portfolio company-specific target.

Adequate Wages

The Group maintains wages above minimum wage standards in respective countries through regular wage assessments and adjustments. However, no specific quantified target, target year, or baseline is disclosed for this ambition.

Characteristics of the undertaking's employees

Total headcount and breakdown

As of year-end 2024, the Group had just over 8,500 employees in permanent and temporary positions, including 1,000 contract workers. Of this total number, 33% were women and 67% men. At year-end 2023, the Group had just under 8,500 employees in permanent and temporary positions, and the gender balance was 35% women and 65% men.

The total number of full-time equivalents in the Group in 2024 was 7,320, of whom 1,917 were in South America. The corresponding figures for 2023 were 7,022 full-time equivalents with 1,667 in South America.

Headcount by gender, country, employment contract type, and employment type

Table 1: Number of employees by gender (headcount)

Table 2: Employees in countries with at least 10% of total number of employees

*Included as a portfolio company, despite having less than 10% of total employees

Table 3: Number of employees by employment type (headcount)

Employee turnover

In 2024, the Group had an employee turnover of 751.

Methodology note: The headcount represents the number of employees with employment status 'active' at the end of the reporting period. It includes the employment types: permanent, temporary and non-guaranteed employees. The employees are divided by gender and country.

Turnover includes both voluntary and involuntary leavers. The number covers all permanent employees who have left the organisation during the reporting period. The number does not include temporary employees with an end date in their contract and employees with non-guaranteed hours.

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

Number of non-employee workers

Methodology

Accounting principle S1-6

The headcount represents the number of employees with employment status 'active' at the end of the reporting period. It includes the employment types: permanent, temporary and non-guaranteed employees. The employees are divided by gender and country.

Context

The sustainability statement references workers in the value chain who are not part of the Group's own workforce, including:

• Workers on third-party fishing vessels in Chile and Peru (artisanal and seasonal fishing industries)
• Contract workers doing work on the Group's sites, onshore and at sea
• Upstream value chain workers in high-risk regions and industries (agriculture, mining, feed production, transport)

However, specific headcount or FTE figures for these non-employee workers are not disclosed in the S1-7 context. The Group states that "value chain workers include those working on the Group's sites but not part of the Group's own workforce" and mentions actions to "protect workers and contractors" in Peru's HSE management system, but quantitative breakdowns by contractor type, agency workers, or self-employed are not provided.

The only quantitative metric disclosed is the 609 "non-guaranteed employees" shown in the S1-6 table, which appears to represent a category of employment within the own workforce rather than external contractors or agency workers.

Collective bargaining coverage and social dialogue

Collective bargaining coverage and social dialogue by country

The table below shows collective bargaining coverage and social dialogue in countries where the undertaking has at least 50 employees representing at least 10% of its total number of employees.

*Chile included as a portfolio company, despite having less than 10% of total employees

Percentage of total employees covered by collective bargaining agreements

Employees that have a collective bargaining agreement divided by total number of employees per country representing at least 10% of total number.

Employees covered by workers' representatives

The total percentage of employees covered by workers' representatives split by country level due to different legislation across the Group. Figures are only given for countries where the undertaking has at least 50 employees representing at least 10% of its total number of employees.

Countries covered:

• Norway (EEA): 60-79% collective bargaining coverage; 60-79% workplace representation
• Peru (Non-EEA): 20-39% collective bargaining coverage
• Chile (Non-EEA): 80-100% collective bargaining coverage

Diversity metrics

Gender distribution at management level

Employee age groups

Accounting principles

Gender distribution, top management (headcount): The number of employees at top management includes the Group's executive management.

Gender distribution, managers with personnel responsibilities (headcount): The number includes all managers with personnel responsibilities in the Group.

Gender distribution, all employees (headcount): The number includes all employees in the Group.

Employee age groups (headcount): The age groups are calculated at the end of the reporting period and include all headcounts. The age groups are 0-29, 30-50 and 51+ years.

Adequate wages

Benchmark used: Minimum wage only (national legislation and industry standards)

Austevoll Seafood discloses that all employees are paid above minimum wages. The company references national minimum wage provisions and industry standards as the baseline for adequate wages, with no mention of living wage benchmarks.

Coverage: 100% of own workforce (figures do not include apprentices)

Geographic scope: Global operations, with specific disclosure for:

• Norway: NOK 32,422 per month (minimum wage for production workers in fish processing industry, based on 37.5-hour work week; source: Arbeidstilsynet)
• Chile: CLP 500,000 per month (source: Chilean Law No. 21,578)
• Peru: PEN 1,130 per month (source: Living wage benchmarks - Wage Indicator Foundation)

Methodology: The company states that "adequate wages are determined based on national legislation, industry benchmarks, and internationally recognized methodologies." Despite referencing the Wage Indicator Foundation for Peru, the disclosure emphasizes minimum wage compliance rather than living wage assessment.

Policy commitment: The Human Rights and Decent Work Conditions Policy requires that "salaries at a minimum comply with national minimum wage laws or industry standards and are always sufficient to cover basic needs." The policy states that "salaries paid to employees as a minimum shall comply with the national provisions regarding minimum wage or the industry standard and shall always be sufficient to cover basic needs."

Actions for South American operations:

• Chile: Two-monthly review of salaries where the personal manager reviews correct application of local salary policy. Salary gaps are adjusted when identified to ensure adequate fair compensation.
• Peru: Participation in local salary initiatives monitored by third-party consultant to ensure local salary policies are upheld and all employees receive adequate and fair compensation.

Positive impact: For operations in South America, the company identifies adequate wages as an actual positive impact, noting that "in these communities fair pay is not guaranteed, and this has a significant impact on the standard of living for employees and their families, enabling them to access better housing, education, and healthcare."

Targets: The Group has consistently maintained wages above minimum wage standards and "remains dedicated to upholding this standard through regular wage assessments and adjustments." A new KPI for wages monitoring has been introduced and will be followed up annually in compliance with ESRS S1-10. No specific percentage targets or timelines disclosed.

Disclosure note: The company states "These figures have not been previously disclosed" regarding adequate wages metrics.

Social protection

Coverage disclosure

Austevoll Seafood's sustainability statement does not disclose specific percentages of employees covered by social protection against loss of income from major life events (sickness, unemployment, employment injury, parental leave, retirement).

Partial information available

The report mentions that "The Group's activities in Norway are affiliated with various company health service providers" but does not quantify the percentage of workforce covered or specify whether coverage is through public schemes, private schemes, or both.

The report states that employees exist across multiple countries (Norway, South America including Peru and Chile, and Europe through Pelagia), but does not provide country-specific breakdowns of social protection coverage.

Sick leave data

While not a direct measure of social protection coverage, the report provides:

• Group sick leave in 2024: 5.2% (2023: 5.6%)
• Parent company (Austevoll Seafood ASA) sick leave: 0% in both 2024 and 2023 (3 employees)

This data reflects sick leave rates but does not indicate the percentage of employees covered by sickness benefits or other social protections.

Health and safety metrics

The legal requirements for health and safety management vary depending on the country of operation, but the management system applies to all employees (100%).

Coverage

100% of employees are covered by the Group's health and safety management system.

Methodology

Lost Time injuries (LTI): number of injuries with absence divided by the number of working hours and multiplied by a factor of 1,000,000.

Injury with absence is defined as a work-related personal injury resulting in absence beyond the day the injury occurred.

Work-related injuries are sudden or unexpected injuries that occur while carrying out tasks at work. Any fatalities are included in the frequency, counted as injury with absence.

The Group has a target of zero fatalities within its workforce, with a baseline LTI of 17 from 2020.

Compensation metrics

Pay gap

Not disclosed.

Remuneration ratio

Not disclosed.

Methodology

The company reports that it is phasing in ESRS S1-16 under ESRS 1 Appendix C. The sustainability statement explicitly notes: "Only ESRS data points identified as material under the double materiality assessment and mandatory under the ESRS are reported. Voluntary and phase-in requirements according to the ESRS are not included in the report."

The excerpts provide detailed remuneration information for the CEO, CFO, and Board members for 2024 and 2023, including salary, bonuses, pension costs, and board fees. However, no gender pay gap percentage or CEO-to-median remuneration ratio is disclosed in accordance with ESRS S1-16 requirements.

Incidents, complaints and severe human rights impacts

Accounting principle

AUSS reviews quarterly whistleblowing cases from the Group. For GDPR compliance, all data on employee cases are anonymous. All cases are investigated by a compliance team in each portfolio company.

Whistleblowing cases - 2024

The majority of cases related to non-compliance with the Group's policies and the Code of Conduct.

Fines and sanctions

In the reporting period, the undertaking has not been subject to any fines, penalties, or compensation for damages related to incidents of discrimination or harassment. Therefore, no reconciliation with the financial statements is necessary.

Business conduct policies and corporate culture

Austevoll Seafood ASA (AUSS) has established a comprehensive framework of policies to govern business conduct and promote a strong ethical corporate culture across the Group and its portfolio companies.

Code of Conduct

Policy name: Code of Conduct

Scope: Applies to AUSS and the portfolio companies (the Group) and all Group employees. The Code of Conduct is also used as a basis when collaboration with suppliers and business partners are entered.

Governance:

• Approved by the Board of Directors
• CEO at AUSS has the overall responsibility for the policy
• Top management in each portfolio company is responsible for ensuring compliance
• Company management is responsible for ensuring compliance with the regulations

Key content/principles: The Code of Conduct reflects the values represented by the Company and guides Group employees to make use of the correct principles for business conduct. It addresses:

• Fundamental human rights
• Respect for society and the environment
• Responsibility for ethical conduct
• Impartiality
• Conflict of interest
• Political activity
• Entertaining customers
• Processing information and duty of confidentiality
• Relationships with business partners
• Corruption
• Whistleblowing
• Bribes

Each Group employee is individually responsible for practicing the ethical guidelines. The Company has prepared an Ethics Test for employees which will help them to make the right decisions whenever needed.

Public availability: Publicly available on AUSS's website (auss.no)

International standards alignment: The Code of Conduct is aligned with:

• UN Guiding Principles on Business and Human Rights (UNGPs)
• ILO Declaration on Fundamental Principles and Rights at Work
• OECD Guidelines for Multinational Enterprises
• UN Convention against Corruption
• Norwegian Transparency Act

Monitoring and implementation:

• AUSS has established a Governance model
• Quarterly compliance reports to the Board including key KPIs such as accidents, regulatory non-compliance, whistleblowing and complaints received
• Reports presented to the Board by the Audit and ESG committee
• Management undertakes appropriate follow-up actions if reports indicate specific circumstances beyond expectations
• A wide range of additional policies provide detailed guidance and requirements related to business conduct principles
• Whistleblowing system established for anonymous reporting via third-party company
• In the event of nonconformities, measures shall be implemented to improve the situation
• No deviations from the Code of Practice reported

Policy for Supply Chain Management

Policy name: Policy for Supply Chain Management

Scope: Applies to all suppliers, contractors, and partners involved in the Group's upstream and downstream value chain, covering all regions where the Group operates.

Governance:

• Approved by the Board of Directors
• CEO at AUSS has the overall responsibility
• Top management in each portfolio company is responsible for ensuring compliance
• AUSS's suppliers are obliged to familiarize themselves with and follow this policy

Key content/principles: The policy addresses:

• Ethical, sustainable, and efficient practices throughout the supply chain
• Mitigating negative impacts by respecting labour and human rights
• Decent working conditions and well-being
• Engaging with workers and providing remedies for human rights impacts
• Preventing human trafficking, forced or compulsory labour, and child labour
• Fair working hours, adequate wages, and health and safety standards
• Impartiality, transparency, and non-discriminatory practices in procurement
• Preventing conflicts of interest

Public availability: Publicly available on AUSS's website

International standards alignment:

• UN Guiding Principles on Business and Human Rights
• ILO Declaration on Fundamental Principles and Rights at Work
• OECD Guidelines for Multinational Enterprises

Monitoring and implementation:

• Regular dialogue with suppliers through surveys, audits, site visits, collaboration meetings, and operational reviews
• Supplier audits conducted on a rolling basis, with annual reviews to verify compliance
• Supplier self-assessments introduced for high-risk suppliers
• Due diligence assessments conducted annually
• Quarterly compliance reporting to AUSS

Supplier Code of Conduct

Policy name: Supplier Code of Conduct

Scope: Applies to all suppliers and business partners in the upstream and downstream value chain.

Governance:

• Top management in each portfolio company is responsible for ensuring compliance

Key content/principles: Sets clear expectations for:

• Fair working hours
• Adequate wages
• Health and safety standards
• Ethical sourcing practices

Public availability: Information about the whistleblowing channel is included in the supplier code of conduct

International standards alignment: Aligned with AUSS's commitments under international human rights frameworks

Monitoring and implementation:

• Portfolio companies maintain regular dialogue with suppliers
• Compliance monitored through supplier assessments and audits

Human Rights and Decent Work Conditions Policy

Policy name: Human Rights and Decent Work Conditions Policy

Scope: Applies to the Group's own workforce, including all employees, directors, officers, hired personnel, consultants and representatives, as well as any person conducting work on behalf of or otherwise representing AUSS globally. Also expected to be upheld by suppliers and business partners in the upstream and downstream value chain.

Governance:

• Approved by the Board of Directors
• CEO at AUSS has the overall responsibility
• Top management in each portfolio company is responsible for ensuring compliance

Key content/principles:

• Adequate wages: Salaries must at minimum comply with national minimum wage laws or industry standards and be sufficient to cover basic needs; disciplinary deductions not permitted
• Gender equality in management positions: Prohibition of all forms of discrimination and harassment; commitment to positive action for vulnerable groups; special protections to prevent harassment and inequal treatment of women
• Freedom of association: All employees have freedom of association and are free to engage in collective wage bargaining and union organizations; dialogue with employee representatives; no discrimination against trade union representatives
• Working hours and overtime: Compensation in accordance with national legislation and international conventions
• Employment contracts: All workers entitled to employment contract in a language they understand

Public availability: Publicly available on AUSS's website

International standards alignment:

• UN Guiding Principles on Business and Human Rights
• ILO Declaration on Fundamental Principles and Rights at Work
• OECD Guidelines for Multinational Enterprises

Monitoring and implementation:

• Quarterly reporting from portfolio companies consolidated at Group level
• Reports include equality measures
• Processes in place to provide appropriate remedies for human rights impacts
• Corrective actions, compensation where applicable, and measures to prevent recurrence

Health and Safety Policy

Policy name: Health and Safety Policy

Scope: Applies to the Group's employees and contract labour, with particular emphasis on high-risk roles at sea and in processing facilities.

Governance:

• Approved by the Board of Directors
• CEO at AUSS has the overall responsibility
• Each portfolio company's management holds responsibility for compliance, supported by designated HSE personnel who oversee daily implementation

Key content/principles:

• Commitment to a zero-injury goal
• Enforcing rigorous safety standards
• Conducting regular risk assessments
• Providing comprehensive safety training
• Preventing and minimizing accidents and damage to health

Public availability: Publicly available on AUSS's website

International standards alignment: Aligned with international standards and prevailing national HSE regulations and laws

Monitoring and implementation:

• Regular audits and monitoring by portfolio companies
• Quarterly compliance reports to AUSS including accidents, near miss incidents, and sick leave
• Health and safety practices continuously improved based on monitoring results
• In 2024, approximately 5,200 employees in the Group conducted HSE training
• Within the pelagic segment in Peru, HSE management is internationally certified under ISO 45001

Diversity and Inclusion Policy

Policy name: Diversity and Inclusion Policy

Scope: Applies to all Group employees.

Governance:

• Approved by the Board of Directors
• CEO at AUSS has the overall responsibility
• Top management in each portfolio company is responsible for ensuring compliance

Key content/principles:

• Emphasizes positive impact of diversity and inclusion on the Group
• Focus on empowering employees and equal opportunities
• Promoting gender equality in management positions (LSG has set a goal of minimum 40% gender representation in management positions by 2030)
• Enhancing diversity across all levels of the organization
• Eliminating discrimination
• Supporting flexible work arrangements to improve employee well-being
• Promoting basis for equal opportunities
• Encouraging formation of "Gender Equality and Diversity Committees" to promote corporate culture of equality and respect

Public availability: Publicly available on AUSS's website

International standards alignment: Aligned with commitments to equal employment opportunities and rights

Monitoring and implementation:

• Procedures for reporting and evaluation of diversity and inclusion indicators
• Detection and prevention of discrimination
• Diversity metrics monitored annually in compliance reports

Whistleblowing Policy

Policy name: Whistleblowing Policy

Scope: Applies to all Group employees and also available to external parties, value chain workers, and other affected stakeholders.

Governance:

• Approved by the Board of Directors
• CEO at AUSS has the overall responsibility
• Top management in each portfolio company is responsible for ensuring that all employees have information about and access to the channel

Key content/principles:

• Provides employees and external parties with a secure, confidential channel to report issues
• Covers non-compliance with HSE regulations, discrimination, concerns related to diversity and equality, ethical concerns, or other serious matters
• Protection of anonymity of individuals who report concerns
• Protection against retaliation for whistleblowers
• Independent and confidential reporting

Public availability:

• Publicly available on AUSS's website and portfolio company websites
• Notices displayed at operation sites
• Information provided in supplier code of conduct

International standards alignment: Fully compliant with Directive (EU) 2019/1937

Monitoring and implementation:

• Established system for anonymous whistleblowing via third-party company
• Each report carefully documented and followed up
• Cases reviewed by whistleblowing committee based on nature of report
• Number of cases and status collected by management team within each portfolio company
• Quarterly oversight by AUSS to ensure issues addressed promptly and effectively
• Consolidated quarterly report presented to management and the Audit and ESG Committee
• Trust and effectiveness monitored through number of concerns raised
• Open dialogue, workshops, training sessions and campaigns promoting use of channels conducted on ongoing basis
• In 2024, 56 whistleblowing cases reported, of which 23 were confirmed

Food Safety Policy

Policy name: Food Safety Policy

Scope: Applies to the Group's operations and the upstream and downstream value chain globally, including the Group's employees and contract labour.

Governance:

• Approved by the Board of Directors
• CEO at AUSS has the overall responsibility
• Top management in each portfolio company is responsible for ensuring compliance
• Quality teams within portfolio companies manage implementation under oversight of Head of Quality & Compliance

Key content/principles:

• Prioritizing food safety
• Appointing personnel with relevant expertise
• Ensuring responsible supplier chains through systematic audits and follow-ups
• Risk management based on HACCP principles to address biological, chemical, and physical hazards
• Preventing contamination throughout production processes including slaughtering/harvesting
• Ensuring accurate product labelling with correct information on ingredients, allergens, and usage instructions

Public availability: Publicly available on AUSS's website

International standards alignment:

• Mandates compliance with global standards such as Global Food Safety Initiative (GFSI)
• HACCP
• Local food safety regulations

Monitoring and implementation:

• Regular testing for contaminants and microbiological risks
• Many products are certified
• Central and local emergency preparedness groups established for product withdrawals
• All product recalls and withdrawals recorded in portfolio company quality systems
• Statistics monitored centrally across the Group
• Quarterly consolidation of food safety data at Group level
• Product recall procedures with mandatory root cause analysis and corrective action plans
• In 2024, 7 product recalls performed totaling 8,769 kg finished product

Anti-Corruption and Anti-Bribery Policies

Policy name: Code of Conduct and anti-corruption (anti-corruption and anti-bribery provisions)

Scope: Applies to AUSS and all portfolio companies globally, all Group employees, and expected to be upheld by suppliers and business partners.

Governance:

• Approved by the Board of Directors
• CEO at AUSS has the overall responsibility
• Top management in each portfolio company is responsible for ensuring compliance

Key content/principles:

• Zero-tolerance approach to corruption and bribery
• Functions such as procurement, supplier management, and sales identified as highest risk
• Leadership accountability and targeted training programs
• Ethical training provided through e-learning
• Sound business practices and ethics in procurement processes

Public availability: Publicly available on AUSS's website

International standards alignment:

• Fully aligned with United Nations Convention against Corruption
• OECD principles for taxation

Monitoring and implementation:

• Regular risk assessments
• Mandatory employee declarations
• Whistleblowing system for employees, suppliers, and other stakeholders
• Allegations or incidents investigated by independent team separate from management chain
• Findings and outcomes reported quarterly to AUSS and presented to Audit and ESG Committee and Board of Directors
• Portfolio companies report quarterly through compliance reporting
• At AUSS administration, new hires required to read policies and Code of Conduct as part of onboarding and confirm acknowledgment
• Members of administrative, management, and supervisory bodies required to familiarize themselves with policies
• E-learning modules for employees (sales department must complete comprehensive version - 100% in 2024)
• No convictions or fines for violations in reporting period

Remuneration Policies

Sustainability-related considerations are currently not included in the remuneration policies for the Board of Directors, management, or supervisory bodies.

Prevention and detection of corruption and bribery

Code of Conduct and anti-corruption

Approval and oversight:

• Approved by the Board of Directors
• The CEO at AUSS has overall responsibility for the policy
• Top management in each portfolio company is responsible for ensuring compliance

Public availability:

• Publicly available on AUSS's website

Alignment with international standards:

• Fully aligned with the United Nations Convention against Corruption

Key content and principles:

• Defines standards for ethical behaviour, anti-corruption, and anti-bribery
• Zero-tolerance approach to corruption and bribery
• Functions such as procurement, supplier management, and sales are identified as being at highest risk for corruption and bribery due to exposure to third-party interactions and high-value transactions

Prevention and detection mechanisms:

• Regular risk assessments conducted by portfolio companies
• Mandatory employee declarations
• Whistleblowing system available for employees, suppliers, and other stakeholders
• Whistleblower system compliant with Directive (EU) 2019/1937
• All cases investigated promptly, independently, and objectively by an independent team separate from the management chain involved in the matter
• Investigations ensure confidential reporting for internal and external stakeholders

Communication and training:

• Communicated to all employees and key suppliers through various channels
• New hires at AUSS administration required to read policies and Code of Conduct as part of onboarding and confirm acknowledgment
• Members of administrative, management, and supervisory bodies required to familiarize themselves with policies during onboarding
• E-learning modules provided to employees and contractors covering Code of Conduct and policies (including anti-corruption and business ethics)
• Information shared via physical postings in office spaces and other accessible communication channels
• Functions at risk (sales department at AUSS) must complete a more comprehensive training course (100% completion in 2024)
• Leadership workshop and reinforcement of ethical guidelines planned for Peru portfolio company in 2025

Monitoring and reporting:

• Regular audits and risk assessments conducted by portfolio companies to monitor compliance and strengthen policy enforcement
• Portfolio companies report quarterly to AUSS through compliance reporting
• Consolidated report presented to the AUSS Audit and ESG Committee and Board of Directors
• Findings and outcomes of investigations reported quarterly to AUSS and presented to the Audit and ESG Committee and Board of Directors
• Ensures necessary actions are taken promptly and transparently to address identified issues and implement corrective measures

Incidents of corruption or bribery

Confirmed incidents

In the reporting period 2024, there were zero confirmed incidents of corruption or bribery across the Group.

Convictions and fines

In the reporting period, there were zero convictions or fines imposed on AUSS or its portfolio companies for violations of anti-corruption and anti-bribery laws.

Disciplinary actions

The number of confirmed incidents in which own workers were dismissed or disciplined for corruption or bribery-related incidents: 0

Contracts terminated

The number of confirmed incidents relating to contracts with business partners that were terminated or not renewed due to violations related to corruption or bribery: 0

Investigation and speak-up procedures

To prevent and detect corruption and bribery, the portfolio companies perform regular risk assessments, mandatory employee declarations, and operate a whistleblowing system available for employees, suppliers, and other stakeholders.

Allegations or incidents are investigated by an independent team, ensuring that the investigators are separate from the management chain involved in the matter. Findings and outcomes of investigations are reported quarterly to AUSS and presented to the AUSS Audit and ESG Committee and the Board of Directors. This ensures that necessary actions are taken promptly and transparently to address identified issues and implement corrective measures where needed.

The whistleblower system ensures that internal and external stakeholders can report concerns confidentially, with all cases investigated promptly, independently, and objectively. These procedures are fully compliant with Directive (EU) 2019/1937.

The Group operates with a zero-tolerance approach to corruption and bribery. Training is provided to employees and contractors through e-learning and covers Code of Conduct and policies (including anti-corruption and business ethics) and transparency act. The function at risk is defined as the sales department; in AUSS they must complete a more comprehensive version of the course (100% in 2024).

During the reporting year, any whistleblowing breach of anti-corruption and anti-bribery procedures were investigated thoroughly by the portfolio company independent compliance team.

Summary table (2024)