Bouvet ASA

The role of the administrative, management and supervisory bodies

Reference: pages 30-32 (GOV-1 Composition and role of governing bodies; G1-GOV-1).

Composition (page 30). At the end of 2025 the board had five shareholder-elected members: 0 executive, 5 non-executive, 2 women (40%), 3 men (60%), 100% independent. "The CEO is not a board member. Bouvet ASA has no employees. Consequently, there were no employee representatives on the board of directors." The management body counts 7 members, 2 women (28.6%) and 5 men (71.4%).

Committees (page 30). The audit committee conducts "independent supervision of the company's financial reporting, sustainability reporting, auditing, internal controls and overall risk management"; the remuneration committee advises on matters "relevant to the S-16 area".

Responsibility (page 30). Board: overall strategic responsibility for sustainability. Audit committee: independent monitoring of sustainability reporting. CEO: ultimate responsibility for compliance. CCO: compilation and reporting, and the Transparency Act. Head of HR: Code of Conduct and the climate accounts.

Expertise (page 31). "Two board members have sustainability expertise, acquired through training and other appointments."

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

Reference: page 33.

"Bouvet's board of directors monitors group management's compliance with good business practices, as well as applicable rules and regulations and the group's Code of Conduct. The board supervises the group's strategies, risk management and sustainability work through regular reporting and discussion of relevant matters" (page 33).

"Further, sustainability is firmly on the meeting agendas of the board of directors and the audit committee. The board monitors sustainability targets through regular reporting on key indicators."

Topics addressed in the reporting period (page 33). "During the reporting period, the board and the audit committee considered topics such as climate and energy (ESRS E1), ethical business practices, employee development (S1) and business conduct (G1)."

The annual refresh of the double materiality assessment involves regional managers, managers of group functions and other stakeholders, and the identified IROs "relate to areas which are already part of the organisation", so ownership, line-management support and implementation sit inside existing information structures and decision-making bodies (page 33). Monitoring of sustainability targets runs through a common reporting solution for the group's sales and management functions.

Integration of sustainability-related performance in incentive schemes

Reference: pages 33-34 (GOV-3 page 33; E1-GOV-3 page 34).

Bouvet remunerates "based on groupwide performance criteria designed to promote cooperation across the organisation". CEO and senior management receive "a fixed basic salary and a variable component in the form of profit-sharing. While the scheme does not include a fixed percentage linked directly to sustainability, the financial targets cover topics that, according to the double materiality assessment, are also material to sustainability" (page 33). The scheme is approved annually by the board.

Datapoints disclosed. "Percentage of variable remuneration dependent on sustainability-related targets and (or) impacts: 0" (page 33). "Percentage of remuneration linked to climate considerations: 0" (page 34).

Climate (E1-GOV-3, page 34). "Bouvet has not linked its incentive schemes to climate factors. This is because the group has no individual bonus schemes at management level." And: "Since Bouvet does not have an incentive scheme linked to greenhouse gas emissions, climate-related factors are not assessed for the purposes of the bonus scheme." The group adds that while it "does not evaluate management by reference to reductions in greenhouse gas emissions, it is continuously focused on potential improvements." This is a clear nil return rather than an omission.

Statement on due diligence

Reference: page 34.

Bouvet presents the GOV-4 mapping table of the five core elements of due diligence against the paragraphs of the statement (page 34):

• (a) Embedding due diligence in governance, strategy and business model: "See page 35 ESRS 2 -SBM1: Strategy, business model and value chain"
• (b) Engaging with affected stakeholders in all key steps: "See page 37 ESRS 2 - SBM2: Interests and views of stakeholders"
• (c) Identifying and assessing adverse impacts: "See page 39 ESRS 2 - SBM3: Material impacts, risks and opportunities and their interaction with strategy and business model"
• (d) Taking action to address those adverse impacts: "See page 62 ESRS E1 and page 72 ESRS S1"
• (e) Tracking the effectiveness of these efforts: "Ses page 62 ESRS E1 and page 72 ESRS S1"

The underlying process is set out under IRO-1: due diligence follows the OECD Guidelines for Multinational Enterprises on Responsible Business Conduct, forms the basis for the statement under the Norwegian Transparency Act, and runs as a five-step cycle of embedding, identifying and assessing, acting, monitoring and communicating, with cooperation on remediation and compensation where relevant (page 42).

Risk management and internal controls over sustainability reporting

Reference: page 35.

"Management gives high priority to having robust risk management and internal control procedures in place for topics identified by the double materiality assessment. This includes topics such as climate and the environment, social conditions and information security throughout the group's value chain" (page 35).

Controls. Bouvet "is certified according to ISO 9001, 14001, 27001 and 45001, and conducts annual internal and external audits to ensure that procedures and control processes are functioning as intended." Suppliers are assessed for possible human rights violations at contract signature under the Transparency Act, and "internal controls are carried out quarterly by an administrative body composed of representatives from shared group functions" (page 35).

Primary risks. "Risks identified in the double materiality assessment have been evaluated by reference to internal controls and been deemed to be adequately addressed by these." "The most important metrics are employee wellbeing and development, as well as information security." The group also applies guidance from the Norwegian National Security Authority (NSM) (page 35).

Monitoring. Annual risk assessments and internal controls, including client and employee survey results, are reported to the board; controls safeguard "the quality, completeness and consistency of supporting data" (page 35).

Strategy, business model and value chain

Reference: pages 35-37.

Business model. "Bouvet is a Scandinavian consultancy firm which helps companies develop effective, user-oriented solutions in the service areas of technology, advisory services and design." "The company made no material changes to its business model in 2025" (page 35).

Scale (page 35). 2,367 permanent employees (Norway 2,308, Sweden 59); total revenue MNOK 3,912.3.

Markets (page 36). Revenue by sector for Jan-Dec 2025: oil, gas and renewables 40.1%; power supply 19.8%; public administration and defence 19.1%; service provision 6.3%; transport 3.9%; industrial 3.1%; information and communications 2.5%; retail 2.5%; health and social 1.3%.

"Bouvet does not market any prohibited products or services, and has no activities in the fossil energy extraction, arms, chemicals or tobacco industries" (page 36).

Value chain (page 36). "Bouvet's value chain is knowledge-based and creates value through people, collaboration and technology." Input: employee expertise and continuous professional development. Activities: inter-disciplinary consulting, technology development and design. Output: digital solutions and services. "Bouvet only uses sub-contractors from countries in which the group operates."

Strategic platform (page 36). Vision "Lead the way and build the society of the future"; long-term goals "Best workplace", "client-focused" and "long-term success"; four sustainability focus areas.

Interests and views of stakeholders

Reference: pages 37-38.

"Bouvet has maintained ongoing dialogues with internal and external stakeholders for several years in order to understand their sustainability-related expectations and perspectives." Dialogues "include both formal processes and day-to-day interactions such as assignment-related meetings, tendering processes and client and employee discussions" (page 37).

Groups and engagement (pages 37-38). Employees (performance reviews, employee surveys, employee representatives involved in line with DMA findings); potential new employees; clients (satisfaction surveys, quotation requests, dialogue on the DMA); suppliers (quarterly assessments); partners (half-yearly assessments); interest organisations (industry networks, sponsorship of GoForIt under TEK Norway); shareholders (board and owner dialogues on the DMA); and "Other stakeholders (authorities, society and the financial sector)".

Use (page 38). "The insights gained from stakeholder dialogues are used actively to update and validate the group's double materiality assessment, which is the basis for setting priorities and deciding sustainability-related measures." "These dialogues have confirmed that Bouvet's strategic platform and business model reflect market needs."

No frequency of board-level reporting on stakeholder views is quantified.

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

Reference: pages 39-41. The DMA table on page 39 lists ten material IROs across three topics.

Climate change (ESRS E1) - four adverse impacts: Scope 1 actual emissions from own operations; Scope 2 actual emissions from purchased energy (own operations); Scope 3 indirect supply chain emissions (upstream); Scope 3 indirect emissions from client projects (downstream).

Own workforce (ESRS S1) - five positive impacts in own operations: working conditions (i) safe and secure work, (ii) working hours, (vii) work-life balance; equal treatment and opportunities for all (i) gender equality and equal pay for work of equal value, (ii) training and skills development.

Business conduct (ESRS G1) - one positive impact in own operations: corporate structure and guidelines on business conduct.

"The materiality assessment did not reveal any material areas of risk or opportunity" (page 40), and "No material financial impacts are anticipated in these areas in the short, medium or long term" (page 41).

Changes (page 41). "The Group has not identified any material deviations from previous reporting and, consequently, no material changes related to impacts, risks and opportunities (IROs) reported for the financial year 2025."

Climate risk identification and scenario analysis is also presented under E1-2, and climate resilience under E1-3 (2025 ESRS numbering).

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

Reference: pages 42-45, with E1-IRO-1 on pages 46-47 and G1-IRO-1 on page 47.

Methodology (page 42). The process "reflects the requirements of the ESRS, the Value Chain Implementation Guidance (VCIG), the Materiality Assessment Implementation Guidance (MAIG) and the OECD Guidelines for Multinational Enterprises on Responsible Business Conduct". It surveys "the 'long list' of sustainability issues defined in ESRS 1, section AR16, to ensure completeness".

Thresholds (pages 43-44). "materiality is evaluated based on both severity and likelihood. Severity is evaluated by reference to the criteria scale, scope and irreversibility". Severity for actual adverse impacts is the average of those three on a 1-5 scale. "Where the product of the factors resulted in a total score of 20 or above, the area was automatically defined as material." For positive impacts "the irreversibility criterion is excluded".

Dependencies (page 43). "The group's primary dependencies concern its own workforce: equal treatment, equal opportunities and working conditions."

Governance (page 45). Led by the CCO with a core group of Head of HR, CISO, group adviser and internal controller; approved by group management and adopted by the board; revised annually. For 2025 the group "assessed changes that may impact the DMA, including updates to EFRAG IG 1. No material changes were identified".

Disclosure requirements in ESRS covered by the undertaking's sustainability statement

Reference: pages 48-49, with chapter content indexes on pages 29, 51, 73 and 89 and Appendix B Table 1 on pages 92-99.

"Bouvet has identified the ESRS topics and reporting requirements which are covered in the group's sustainability statement. This review also revealed which topics are immaterial to the business" (page 48).

Topics deemed irrelevant "because the group does not have its own production facilities" (page 48): pollution; water and marine resources; biodiversity and ecosystems; resource use and circular economy; workers in the value chain; affected communities; end users. Each environmental exclusion carries the same reason, for example "Bouvet does not manufacture products in its capacity as a consultancy firm, and has therefore deemed pollution irrelevant."

Further conclusions (page 49): no material adverse impact on the supply chain, none on the local community, none on end users, and "Bouvet's assessment is that it does not have a material adverse impact with respect to ESRS G1."

Appendix B (page 49). "See Table 1 in the Appendix for a tabular overview of all data points derived from other EU legislation". Table 1 runs pages 92-99, marking each datapoint with a page reference or "NOT MATERIAL".

The covered requirements are published as four per-chapter indexes, not one consolidated IRO-2 table: ESRS 2 page 29, E1 page 51, S1 page 73, G1 page 89.

Transition plan for climate change mitigation

Reference: page 62.

"Norway aims to reduce greenhouse gas emissions by 55% by 2030 and 90%-95% by 2050. Bouvet will support achievement of these objectives." The group's own target is "reducing its own greenhouse gas emissions by 55% by 2030 compared to the base year 2024, and to achieve net-zero by 2050".

No ESRS-compliant transition plan yet. "Bouvet does not currently have a dedicated transition plan for climate change adaptation pursuant to the ESRS. The group considers that its strategic platform and business model are compatible with necessary future restructuring ... in line with the Paris Agreement." The group "will in 2026 assess whether the current approach is sufficient to meet the requirements applicable to a complete transition plan pursuant to ESRS E1-1".

Emission profile. "Bouvet has no greenhouse gas emissions linked to own production. Travel, and air travel in particular, is the area in which the group generates the highest emissions."

Investment. "Bouvet currently sees no need for investment to achieve its emission targets: "its remedial measures are closely related to day-to-day operational decisions"."

Taxonomy and approval. The group "carries out taxonomy-eligible activities, but that these activities are not taxonomy-aligned", and Bouvet "is not excluded from the EU Paris-aligned Benchmark (PAB) index". "Management has approved targets and actions."

Identification of climate-related risks and scenario analysis

Back-filled from ESRS 2 E1-IRO-1 (pages 46-47) and E1-SBM-3 (page 63), where this content is disclosed in the FY2025 report. This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Risk identification. "The double materiality assessment has not identified any material, climate-related physical or transition risks for Bouvet" (page 63). "Bouvet has not identified any material climate-related risks in the short, medium or long term" (page 46). The DMA's four E1 entries are all adverse impacts (page 39).

Methodology (page 46). The process "is owned by group management, with the CCO in direct charge, and is integrated into annual risk assessments"; assessing "how assets and services may be exposed and sensitive to climate-related risks" is "based on the group's strategic platform and history".

Scenarios (pages 46-47). Three were developed, with "particular emphasis on high-emission scenarios": "Sustainability - the green path"; "The middle way - business as usual"; "Regional rivalry - the bumpy road: high emissions and severe physical consequences, including in Norway". "The scenarios cover both transitional and physical risks" and "did not reveal any critical climate-related assumptions with an impact on the group's financial statements".

Gap. No named reference scenario (no SSP, RCP or IEA pathway), no temperature projection, no date for the analysis.

Resilience in relation to climate change

Back-filled from ESRS 2 SBM-3 "Strategic resilience" (page 41) and E1-SBM-3 (page 63), where this content is disclosed in the FY2025 report. This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Results (page 63). "The assessment examined the group's strategy and governance structures, whose compact decision-making processes and low bureaucracy permit rapid adaptation of services in response to market needs and regulatory changes. Physical climate change is expected to have limited direct impact on Bouvet's business."

Strategy and business model (page 63). "The strategic platform and business model have been structured as a framework based on Beyond Budgeting principles ... This approach has proven robust thus far." "While the group currently sees no need to amend its strategy or its business model based on climate-related factors, it will revisit this conclusion in the event of external changes that impact the group."

Capacity to adapt (pages 41, 47). "Bouvet's strategy and business model are designed for agility and adaptability. The regional structure enables the group to respond quickly to altered impacts, risks and opportunities", and "business plans are updated annually" (page 41).

Gap. No analysis is labelled an ESRS resilience analysis, no financial resilience is quantified, and areas of uncertainty are not discussed.

Policies related to climate change mitigation and adaptation

Reference: page 63.

"Greenhouse gas emissions constitute Bouvet's most material climate-related impacts. The group's climate and environmental policy contains measures to reduce emissions and describes the group's environmental and climate impacts and its commitments and strategic priorities related to purchasing, energy consumption, waste management and transport."

Content and scope. The policy sits in the environmental management system, which "sets out guidelines, procedures and roles related to the implementation and monitoring of environmental efforts", covering instructions for environmental managers, internal audits, "Guidelines for supplier assessments, including risk assessment" and due diligence. "The policy mainly applies to the company's own operations" but "is also designed to help exert positive influence on both suppliers and clients".

Accountability. "Responsibility for implementing the environmental system rests with the Head of HR and the quality manager. Regional managers are responsible for ongoing monitoring. The environmental agents in the group's environmental network are responsible for local implementation in their regions."

Availability. Implementation sits within the ISO 14001-certified system and the Eco-Lighthouse framework; "The climate and environmental policy is available on bouvet.no/om-bouvet/miljo."

No separate climate adaptation policy is identified.

Actions and resources in relation to climate change policies

Reference: pages 64-66. Five actions are tabulated against the MDR-A datapoints.

Scope 2 (pages 64-65). (1) Increase the share of renewable energy sources: "Renewable energy sources are demanded when new premises are leased", with cooperation with lessors and requirements on "modern energy-consumption control systems". (2) Reduce energy consumption at individual offices: "As at 31 December 2025, the group was renting 15 office premises - 14 in Norway and one in Sweden." Result: "The climate accounts show a drop in energy consumption per employee from 2024 to 2025." Both sit upstream, and "Cooperation with lessors is a prerequisite".

Scope 3 (pages 65-66). (3) 4+ years operating life for employee PCs/Macs: "As at 31 December 2025, the total operating life of the Group's computers was 3.26 years, representing a positive increase compared with the previous year." Equipment not bought by employees "is recycled, either completely or as parts". (4) 3+ years for mobile telephones: "the average operating life of mobile phones was 2.98 years". (5) Reduced and greener travel: quarterly climate accounts to the regions; "emissions linked to business travel decreased by 2.7 per cent from 2024 to 2025."

Resources. "No investment in connection with the measures" (page 64); "No investments linked to this measure. The task is being performed by existing roles within the group" (page 66).

Targets related to climate change mitigation and adaptation

Reference: pages 67-69.

Targets (page 67). "The overarching target ... comprises two milestones: reducing Bouvet's own emissions by 55% by 2030 (relative to the base year 2024), and achieving net-zero by 2050." "The group has therefore defined its target based on emissions per employee in line with Norway's commitments under the Paris Agreement."

Summary table, emissions per employee in tCO2eq (page 69). Scope 3: 2.11 (2024) to 1.16 (2030) to 0 (2050). Scope 2: 0.07 (2024) to 0.04 (2030) to 0 (2050).

Science-based status (page 68). The same table states both that the target "is based on recognised scientific evidence and is intended to help limit global warming to 1.5°C" and, under "Targets based on scientific evidence", that "Bouvet has not adopted scientific targets." The two are not reconciled, and no SBTi validation is claimed.

Levers (page 69). "Lower Scope 2 emissions will be achieved through energy efficiency and increased use of renewable energy." "Lower Scope 3 emissions will be achieved through reduced travel and fewer purchases of equipment."

Results (page 68). "Bouvet's total Scope 3 emissions are increasing due to the group's growth in terms of both staff numbers and office locations. In addition, improved methods mean that more emissions are being identified." Energy consumption fell.

No Scope 1 target and no adaptation target are set.

Gross Scopes 1, 2, 3 and Total GHG emissions

Reference: pages 70-71. Figures are 2024 (base year) then 2025, with the stated change.

Emissions in tCO2eq (page 70). Scope 1: 0.9 then 0.4, -55.6%. Location-based Scope 2: 154.2 then 153.5, -0.5%. Market-based Scope 2: 1,871.6 then 1,305.3, -30.3%. Total Scope 3: 4,969.7 then 5,101.1, +2.6%, comprising category 1 goods and services 4,165.0 then 4,321.0, category 3 fuel- and energy-related 70.8 then 65.4, category 5 waste 1.7 then 2.1 and category 6 business travel 732.2 then 712.6. Total location-based: 5,124.8 then 5,255.0, +2.5%. Total market-based: 6,276.0 then 6,406.0, +2.1%. Per employee: location-based 2.17 then 2.23; market-based 2.66 then 2.71. Intensity: 1.3 tCO2eq/MNOK location-based and 1.6 market-based in both years.

Boundary (page 70). Coverage is "waste and business travel in own operations, production emissions and transmission losses linked to fuel, electricity, district heating and district cooling, as well as purchases of goods and services (Scope 3, category 1)". "Other Scope 3 categories have not been included in the reporting."

Restatement (pages 70-71). "Scope 3 category 1 has also been included for the 2024 financial year, and the base year has been changed from 2022 to 2024."

Data quality (page 29). "For Scope 3 in 2025, no primary data was used, and the calculations are entirely based on estimated data and generic emission factors."

Policies related to own workforce

Reference: page 74, cited by Appendix B Table 1 for all four S1-1 datapoints (pages 96-97).

"Bouvet has introduced several policies that apply to its own employees, as well as contractors, partners and sub-contractors. These include: strategic platform; working environment policy (Eco-Lighthouse and ISO 45001 certified); Code of Conduct; Supplier Code of Conduct (applicable to both suppliers and contracted staff)."

Coverage. The policies "cover material impact areas such as: working conditions and occupational health and safety; equal treatment and diversity; skills development and career development". Per the DMA, Bouvet "has a material positive impact on employees through its provision of a safe workplace, work-life balance, gender equality, fair pay and good development opportunities".

Discrimination. The Code of Conduct "states that discrimination and harassment are prohibited, and that active measures must be taken if such conduct is observed", covering "all grounds of discrimination under Norwegian law".

International instruments. "Bouvet respects human and labour rights protected by Norwegian law, the UN Universal Declaration of Human Rights and ILO conventions."

Health and safety. "The group systematically addresses occupational health and safety through documented procedures and defined responsibilities. Bouvet holds ISO 45001 and Eco-Lighthouse certification." No S1-14 metrics accompany it.

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

Reference: page 75.

"Bouvet strongly emphasises engagement and dialogue with its workforce as an integral part of its strategy work and the growth of the group. The management principle of 'proximity' underlines the importance of closeness, trust and effective communication between management and employees."

Structured arenas (page 75). Performance and development reviews, "Conducted annually, and followed up throughout the year"; working environment committee, "Quarterly meetings with representatives of both the employees and the group", with minutes and annual reports on the intranet; safety representatives "Established at every office location", in monthly meetings, safety inspections and non-conformance follow-up; regional and local employee representatives; a diversity and inclusion network running "lectures, workshops and knowledge-sharing arenas"; and a cooperative committee supporting the working environment committee.

Collective agreements. "Bouvet is not party to collective pay agreements, but has introduced procedures to ensure broad-based consultation and participation."

Responsibility. "Management is responsible for ensuring productive dialogue and compliance with procedures. Auditing and evaluation of collaboration arenas is part of the group's improvement efforts."

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

Reference: page 76, the page Table 1 cites for the S1-3 grievance-mechanism datapoint (page 97).

"Bouvet promotes a company culture characterised by open communication, mental safety and learning. Managers have a particular responsibility to be available, provide support and encourage feedback."

Channels (page 76). "employee appraisals and 1:1 meetings"; "working environment committee, safety representatives and employee representatives - for collective participation"; "anonymous employee surveys - conducted annually by an external party with the option of free text responses"; and a "digital whistleblowing channel for reporting censurable conditions - available on bouvet.no and includes anonymous reporting functionality".

Handling. "All whistleblowing reports are processed in accordance with established procedures, so that the principles of impartiality, confidentiality and procedural fairness are safeguarded. HR is involved in all whistleblowing cases." Where recipients are not impartial, "the company uses an external legal partner to process received reports" (page 89).

Protection. "Bouvet guarantees that employees who file whistleblowing reports responsibly will not be subjected to any form of retaliation."

Effectiveness. Employee survey results "show high employee satisfaction, high trust and strong mental safety."

Taking action on material impacts on own workforce

Reference: pages 77-79.

General measures (page 77). These include "significant managerial responsibility to ensure that individual employees are offered interesting tasks and professional development opportunities"; "salary reviews and reporting tools and management training to ensure fair salary-setting"; the diversity and inclusion network; and "continuous improvement of the working environment through cooperation forums, systematic handling of non-conformances and internal audits".

"Impact is measured by metrics such as high employee wellbeing, low staff turnover and success in attracting and retaining talent. Employee surveys are used systematically to evaluate the measures."

Resourcing. "Bouvet does not operate with dedicated budgets for these activities. Responsibility for implementation rests with senior executives" (page 77); "Bouvet has no investments linked to this measure" (page 79).

Two key measures (pages 78-79). (1) Strengthen and highlight professional support measures: skills development, in-house expertise sharing, conferences and networks. "Technical ambassadors have been/will be established in each region", and "The role of technical ambassador has been established in different regions." (2) Strengthen the employee experience: onboarding, gatherings, company trips, student projects and recruitment events, with responsibility assigned in each region.

Targets related to own workforce

Reference: pages 80-81.

Two ongoing annual targets, both measured by the employee survey (summary table, page 81): "Minimum index score for reputation in employee survey: 90" and "Minimum index score for job content in employee survey: 80".

Rationale (page 80). "The group's long-term goal is to be the best workplace. This is a relative goal which the group has pursued since its establishment. Progress towards the goal is measured through employee satisfaction ... The survey shows that the factors reputation and job content have the greatest impact on employee satisfaction."

Method (page 80). "The employee survey has been conducted annually since 2019, and is carried out by an external provider." Results run "on a scale from 10 to 100, where 100 is best. A score of more than 75 index points constitutes high goal achievement", with benchmarks "against Norwegian companies of the same size and in the same industry".

2025 results (page 81). Reputation: "a score of 88 index points, two points below target." Job content: "a score of 78 index points, two points below target." Both targets were missed by two points.

Involvement (pages 80-81). "Targets and measures are defined for each unit in cooperation with the unit's employees ... The targets are also agreed with employee representatives."

No numerical target is set for pay gap, turnover, training or health and safety.

Characteristics of the undertaking's employees

Reference: pages 82-83.

Headcount at 31 December (page 82). Total 2,379 in 2025 and 2,370 in 2024; women 768 (2025) and 753 (2024); men 1,611 (2025) and 1,617 (2024). By contract type in 2025: permanent 2,367; temporary 3; hourly 9; permanent full-time 2,313; part-time 66, being "Employees who have chosen to work part-time for welfare-related reasons". By country in 2025: Norway 2,320, Sweden 59. "Average number of employees across the reporting period: 2,366" in 2025 and 2,363 in 2024.

Turnover. "Bouvet does not publish staff turnover figures as these are not included in the group's stock-market reports" (page 82). This is an explicit withholding, and it sits awkwardly beside S1-4 and S1-5, which both cite low staff turnover as the measure of whether the workforce measures work (pages 77-79).

Employment practice (page 82). "As a general principle, Bouvet only has permanent employees in full-time positions ... A small number (nine) of on-call temps are used to cover certain absences in business support functions."

Gender basis (page 83). "Bouvet only registers the legal gender of its employees, and therefore only uses the ratio between women and men for reporting purposes."

Non-employees (page 83). "In 2025, 7.8% of revenues were generated by hired-in consultants, a decrease from 8.5% in the previous year."

Training and skills development metrics

Reference: page 83.

Datapoint (page 83). "Percentage of employees that participated in regular performance and career development reviews": 72.33% in 2025 and 72.25% in 2024; women 66.27% in 2025 (67.92% in 2024) and men 75.20% in 2025 (74.24% in 2024).

Process. "Annual appraisals are an important tool in dialogue between managers and employees. During an appraisal, structured feedback is provided and development goals and measures are set." "All employees must have at least one appraisal every year. The various units within the group conduct appraisals at different times."

Data quality caveats, disclosed by the company. "Underreporting is likely because appraisals may have been conducted without the tool being fully utilised. There may also be mismatches between time periods ... Employees on leave do not usually have an appraisal until they are back at work. On average, women take longer periods of leave than men, which affects the average number of appraisals conducted among women."

Gap. Average training hours per employee, by gender, is not reported. Training and skills development is one of the five material S1 positive impacts (page 39) and is addressed through the S1-4 actions (pages 78-79), but the appraisal participation rate is the only quantified metric.

Work-life balance metrics

Reference: page 84.

Datapoints (page 84). "Percentage of employees entitled to take family-related leave": 100 in both 2025 and 2024. "Percentage of entitled employees that took family-related leave": 8.14 in 2025 and 7.71 in 2024, split women 13.63 in 2025 (11.02 in 2024) and men 5.54 in 2025 (6.19 in 2024).

Basis. "The calculation of family-related leave is based on the number of permanent employees. The use of temporary employees comprises cover for staff on leave" (page 84).

Commentary. "The scope for employees to stay at home and prioritise their family in connection with childbirth is an important element in a positive work-life balance. The reported data show the number of employees who were absent from work in 2025 due to taking paid or unpaid parental leave under the Working Environment Act."

Entitlements. "All employees have rights under the National Insurance Act. In addition, all permanent employees are entitled to coverage of a large part of the difference between national insurance benefits and actual pay" (page 84).

Work-life balance is one of the five material S1 positive impacts, recorded as working conditions sub-topic (vii) in own operations (page 39), and the group states that it "adapts working hours and work locations to meet individual employee needs, and projects are planned and estimated based on normal working hours" (page 73).

Compensation metrics (pay gap and total compensation)

Reference: page 85, the page Table 1 cites for both the unadjusted gender pay gap and the excessive CEO pay ratio datapoints (pages 96-97).

Gender pay gap (page 85). Total pay gap between women and men: 5.47% in 2025 against 4.85% in 2024, so the gap widened. By employee function in 2025, with 2024 in brackets: consultants 5.48% (4.60%); business support 5.96% (5.00%); management 5.57% (7.84%). "Remuneration difference between women and men, expressed as the difference in % between the average hourly rates paid to women and men. The average for women is lower than the average for men in all three categories."

Total remuneration ratio (page 85). 5.82 in 2025 and 5.85 in 2024, showing "the difference between the total remuneration received by the highest-paid employee and the median total annual remuneration received by all other employees".

Basis (page 85). "The calculations are based on quantitative data extracted from Bouvet's own systems, and include all permanent employees as at year-end 2025. In the case of part-time employees, basic salary and fixed supplements are recalculated to reflect a full-time position. A full-time position corresponds to 1,950 hours per year. Temporary positions are not included."

Incidents, complaints and severe human rights impacts

Reference: page 86, the page Table 1 cites for the incidents-of-discrimination and non-respect-of-UNGPs datapoints (page 97).

Datapoints, 2025 then 2024 (page 86). Reported incidents of discrimination: 0 then 3. Complaints filed through channels for people in own workforce to raise concerns: 2 then 3. Fines, penalties and compensation arising from reported incidents and complaints: NOK 0 in both years. Severe human rights incidents connected to own workforce: 0 in both. "Incidents involving breaches of the UN Guiding Principles on Business and Human Rights, the ILO Declaration on Fundamental Principles and Rights at Work or the OECD Guidelines for Multinational Enterprises": 0 in both. Other incidents: 0 in both. Fines for severe human rights incidents: NOK 0 in both.

Commentary (page 86). "No human rights violations involving Bouvet employees have been identified." "The reported cases have been processed and closed." "None of the reported cases have resulted in fines, penalties or compensation payments." "The number of whistleblowing cases is an indicator of the group's success in creating a safe and inclusive working environment."

Basis. The data "equate to the number of cases reported in 2025 through whistleblowing channels established pursuant to section 2A of the Working Environment Act".

Business conduct policies and corporate culture

Reference: pages 89-91; Table 1 cites page 89 for the whistleblower-protection datapoint (page 98).

Policy framework (page 89). Bouvet lists over twenty instruments, including "Bouvet's strategic platform; Bouvet Code of Conduct; Supplier Code of Conduct; Whistleblowing; Authorisation structure; Safety instructions; Disciplinary process; Principles for purchasing and cooperation with suppliers; Evaluation of suppliers and sub-suppliers".

Corporate culture (page 89). "Bouvet has a positive impact on its stakeholders and society in general by ensuring that its business operations comply with applicable laws, regulations and relevant quality, environmental, safety and working environment standards."

Accountability (page 89). "Bouvet's senior management is responsible for operationalising the group's sustainability and business ethics guidelines", which "are reviewed annually as part of Bouvet's internal controls and management reviews".

Whistleblower protection (pages 89-90). Reports may go to a superior, another manager, a safety or employee representative, or "via Bouvet's electronic whistleblowing mechanism on bouvet.no", anonymously if desired. "In cases where the persons who receive such reports are not impartial, the company uses an external legal partner to process received reports."

Training (pages 90-91). "Necessary training has been provided to all managers by an external partner."

Targets related to business conduct

Back-filled from the business conduct chapter (pages 89-91), where targets are addressed as part of the MDR-T/GDR-T minimum disclosure requirements rather than as a numbered disclosure requirement. G1-3 became a standalone DR only in the 2025/2026 ESRS, and this statement was prepared under the 2023 ESRS.

Bouvet discloses no measurable outcome-oriented business conduct target. The G1 chapter sets none, and the Governance chapter content index lists only G1-1 (page 89). The only quantified targets in the statement sit under S1-5 (page 81) and E1-4 (page 69).

Consistent with MDR-T's other limb, effectiveness is tracked in the absence of a target. Three annual review cycles are described: "The guidelines are reviewed annually as part of Bouvet's internal controls and management reviews, and are updated as necessary to ensure that they remain relevant and compliant with current regulations and best practice" (page 89); whistleblowing procedures are "reviewed annually as part of internal controls and HR processes to ensure that they function as intended" (page 89); and "The handling of corruption and bribery cases is reviewed annually as part of the group's internal controls and audits to ensure compliance and continuous improvement" (page 90).

Outcome data appears under S1-17 rather than G1: 2 whistleblowing complaints in 2025 against 3 in 2024, 0 discrimination incidents against 3, and NOK 0 in fines (page 86).