BW Offshore

The Board of Directors (the Board) consists of five non-executive directors, 80 percent of whom are independent. Employee representation is not included within the board structure.

The Board is responsible for overseeing BW Offshore's sustainability strategy, risk management, and governance of impacts, risks, and opportunities (IROs).

Board of Directors

Andreas Sohmen-Pao (Chair): Andreas Sohmen-Pao leads BW Offshore's board with extensive experience in the maritime and offshore energy sectors, gained through his role as Chairman of BW Group and its affiliates. He brings a strategic focus on global maritime innovation and the energy transition, with a special emphasis on markets in Asia and Europe.

Rebekka Glasser Herlofsen (Director): With over 25 years in shipping and finance, Rebekka Glasser Herlofsen has served on the management teams of several major Norwegian maritime companies and currently holds board roles with organisations across Scandinavia and Northern Europe. Her financial and governance expertise bolsters BW Offshore's operational resilience in these markets, particularly in regulatory and risk management areas essential for sustaining growth.

Maarten R. Scholten (Director): Maarten R. Scholten offers in-depth legal and operational experience in the upstream oil and gas sector, having served as General Counsel at TotalEnergies. His expertise spans Europe and Africa, where he has been instrumental in navigating complex regulatory frameworks and high-risk environments.

René Kofod-Olsen (Director): René Kofod-Olsen's background in shipping and logistics includes senior roles with Maersk across the Middle East, Africa, and Asia. He has directed significant operational expansions within these regions, giving him a nuanced understanding of emerging market dynamics and regulatory complexities.

Kees van Seventer (Director): Kees van Seventer brings to the board expertise in infrastructure, LNG, and energy transition, drawn from his tenure at the Port of Rotterdam and Royal Vopak. With a focus on Europe and the Middle East, van Seventer has spearheaded energy transition projects that align with BW Offshore's ambitions in sustainable energy solutions.

Board Competencies and Expertise

BW Offshore integrates sustainability expertise into its governance framework by assessing, developing, and applying competencies across its administrative, management, and supervisory bodies. The Board prioritises sector-specific insights and training to promote informed oversight of sustainability-related impacts, risks, and opportunities.

The Board collectively offers expertise in environmental risk management, regulatory compliance, and social governance. Individual members contribute specialised knowledge in emissions management, circular economy principles, resource efficiency, and health, safety, and environmental (HSE) standards critical to FPSO operations.

Board Committees and Their Mandates

Audit Committee: Chaired by Rebekka Glasser Herlofsen, the Audit Committee has oversight of financial reporting, internal audit, compliance, internal controls, and risk management. It reviews sustainability matters, including double materiality assessments, and advises the Board on climate-related risks and ESG policies.

Technical and Commercial Committee: Chaired by Maarten R. Scholten, this committee manages commercial and technical risks related to FPSO operations. It evaluates technology innovations, tender activities, technical risk frameworks, project execution and asset operations management.

Compensation Committee: Chaired by Andreas Sohmen-Pao, the Compensation Committee aligns executive remuneration with strategic objectives, including sustainability and long-term performance.

BW Offshore's governance structure is designed to integrate oversight of IROs within our strategic decision-making and daily operational management. The Board assumes ultimate responsibility for supervising our approach to sustainability, risk management, and operational resilience. This responsibility is governed through dedicated board committees and a structured oversight framework.

The Chief Executive Officer (CEO) leads Senior Management and is responsible for executing BW Offshore's strategic priorities and embedding sustainability and risk management into daily operations. Senior Management meets regularly to assess progress on material IROs and maintains oversight through structured reporting to the Board and Audit Committee.

Dedicated control procedures, such as regular internal audits, third-party evaluations, and compliance checks, are integrated into our internal management process. These controls support continuous improvement of sustainability-related priorities.

Governance bodies are regularly informed of sustainability matters through structured reporting frameworks managed by the Audit Committee. The Audit Committee provides the Board with quarterly updates on sustainability-related matters.

Oversight Over Material Sustainability Matters

Our Board meets at least on a quarterly basis and covers a wide range of material sustainability matters throughout the year.

Quarterly: • Health, Safety and Environment (HSE) statistics • Compliance-related topics • Fleet-wide environmental performance • New business opportunities • Financial matters • Claims and litigations against the company

Bi-annually: • Corporate strategy

Annually: • Remuneration guideline and strategy • Corporate Risk Register • Annual Report • Sustainability Statement • Organisation and competencies review • Compliance and governance, including reviewing terms of reference for board committees • Emerging climate-related regulations • Cyber Security • Review of remuneration process

Other topics related to material sustainability matters are discussed by the Board as required and in cooperation with management.

BW Offshore's incentive schemes focus on sustainability by prioritising safety as a core operational value. The Compensation Committee annually reviews and approves the structure of sustainability-linked incentives, which are tied to health, safety, environment, and quality (HSEQ) performance metrics. If a serious HSEQ incident occurs, the Variable Compensation Scheme (VCS) is reduced to zero for the respective calendar year.

Further details on incentive structures and governance are available in the Corporate Governance Report.

Our due diligence process integrates sustainability-related considerations into operational and functional processes.

Core Elements of Due Diligence

Our Business Model

BW Offshore creates value for our customers by providing two primary types of services related to floating, production, storage and offloading (FPSO) assets: (1) engineering, procurement, construction and installation (EPCI) and (2) lease and operate.

We are a trusted partner for clients seeking to outsource technical competence to engineer, build and operate complex floating offshore production assets. With our existing operational network, we offer synergies that are difficult for a client to replicate on a stand-alone basis.

In a lease and operate arrangement, we take full responsibility for engineering, operating, maintaining, upgrading and/or modifying a production asset as requested by the client in a lease arrangement. BW Offshore provides clients with advantages through well-established infrastructure, manning pools, and supply chain networks. In addition, BW Offshore has extensive experience in regulatory requirements, technical maintenance, and lifecycle cost management.

BW Offshore's customer base includes global oil and gas (O&G) majors and national oil companies seeking reliable offshore production capacity. Current FPSO operations span the UK, U.S. Gulf of Mexico, and Gabon. Our newbuild FPSO, BW Opal, will commence operations in Australia this year. Meanwhile, potential new projects are being targeted in the main O&G producing regions of the Americas, North Sea, West Africa and Asia-Pacific.

Parallel to the FPSO segment, we are exploring opportunities related to our core offshore engineering capabilities, with the goal of transitioning to a low-carbon and renewable energy services company. In 2024, no new products or services were added; Looking towards 2030, BW Offshore is pursuing defined potential energy-transition segments and will make capital investments and develop those that become commercially attractive as technologies, markets, regulations, and government incentives evolve.

Our Strategy

Preparing for a sustainable future is a priority for BW Offshore. In 2020, we revised our corporate strategy to address the increased risk of reduced access to or higher cost of capital for O&G companies. Our 2020 strategy also addressed opportunities to expand into low emissions business.

Our strategy is built on three pillars: extracting maximum value from the conventional business and existing fleet, expanding the core floating production business through investments in new offshore energy infrastructure, and strengthening our position in offshore renewable energy.

As climate change drives shifts in the energy landscape, we see emerging opportunities to diversify our asset portfolio, including energy transition fuels such as floating liquid natural gas plants and renewable technologies.

Strategic Priorities

1. Growing the core floating production business through new offshore energy infrastructure projects
2. Building a substantial and growing position in offshore renewable energy infrastructure
3. Extracting maximum value from the conventional FPSO fleet

Employee Headcount by Region

To support our operations, BW Offshore maintains a global workforce of 1128 strategically allocated resources across our primary operational regions:

• Asia-Pacific: 479 • Europe: 336 • West Africa: 149 • Americas: 133

This regional workforce distribution enables efficient, localised support across BW Offshore's key markets.

Revenue by Sector and Activity

This sector-specific revenue table is consolidated to comply with IFRS 8 Operating Segments, where applicable, and reflects BW Offshore's integration of traditional energy services with our strategic entry into renewable sectors, which advances our sustainability goals.

Sustainability-Related Goals

BW Offshore is committed to sustainability across our offerings, customer engagement, and geographic reach and focuses on:

• Emissions Reductions: Continuous improvement of operational efficiencies and reduction of Scope 3 emissions through collaboration with clients. • Renewable Energy Integration: Scaling BW Ideol's floating wind technology to capitalise on clean energy markets. • Responsible Business Conduct: Promoting responsible business conduct through stakeholder engagement across geographies, particularly in high-impact regions.

We regularly evaluate operational efficiencies, environmental impacts, and the potential for emission reduction in both existing and prospective markets.

Main challenges include navigating regulatory requirements, capital allocation to high-return, low-emission projects, and balancing investment in FPSOs with growth in floating wind. We describe relevant projects throughout this report.

Interests and views of stakeholders

Identified key stakeholder groups

BW Offshore has identified the following key stakeholder groups:

• Own Workforce: Employees across all operational regions
• Suppliers: Value chain partners and vendors
• Customers: Clients utilizing FPSO and offshore wind solutions
• Lenders, investors, analysts and other financial markets participants: Prospective and existing stakeholders
• Regulatory bodies: Authorities setting compliance requirements

BW Offshore also distinguishes between affected stakeholders (those impacted by the business) and users of sustainability information (investors, lenders, analysts).

Engagement methods and frequency

Key concerns and views raised

Stakeholder engagement captured expectations on sustainability impacts, risks, and opportunities. The company states that "stakeholder insights inform materiality assessments, we address concerns and adapt approaches, as needed."

Specific feedback received:

• The company "recently strengthened labour standards in our supply chain and expanded environmental monitoring in response to stakeholder feedback."
• The 2023 double materiality assessment incorporated direct consultation with affected stakeholders, including nine external stakeholders (five affected stakeholders and four users of sustainability statements) comprising clients, vendors, financial institutions, and employee representatives.

Integration into strategy and business model

BW Offshore integrates stakeholder views through multiple mechanisms:

Strategy Journey Initiative (2024): BW Offshore initiated an internal 'Strategy Journey' involving a cross-section of the organisation in a bottom-up review of strategy. The overarching goal is to "create a more holistic understanding of BW Offshore's strategy, broaden discourse on strategic priorities, and for teams to document functions' that support delivering strategy objectives." By year-end 2024, 23% of the organisation had participated in the Strategy Journey.

Governance integration: As described in GOV-1 and GOV-2, Senior Management, the Board, and its committees are informed about stakeholder views on material impacts. "Stakeholder engagement is central to aligning BW Offshore's strategy, business model, and sustainability objectives."

Materiality assessment: "A description of stakeholder engagement within the double materiality assessment is provided in IRO-1 (page 41)." The 2024 revalidation built on the 2023 DMA, which incorporated direct consultation with affected stakeholders.

Future initiatives: The company plans to establish "an annual stakeholder forum to raise awareness, promote dialogue, and align expectations."

Distinction between affected stakeholders and users of sustainability information

BW Offshore explicitly distinguishes between:

• Affected stakeholders: Those impacted by the business (e.g., own workforce, suppliers, communities)
• Users of sustainability statements: Investors, lenders, analysts, and other financial market participants

In the 2023 assessment, the company engaged "five affected stakeholders and four users of sustainability statements" to provide broad and representative input into the materiality assessment.

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

Overview

BW Offshore's materiality assessment has identified key environmental, social, and governance topics that present significant impacts, risks, and opportunities (IROs) across our operations and value chain.

The table on page 48 categorises these IROs by ESRS standards and specifies their location — upstream, own operations, or downstream — and relevance over short (less than 1 year), medium (1-5 years), and long-term (more than 5 years) horizons. Further insights into each IRO are provided in relevant chapters.

BW Offshore's strategy demonstrates resilience in the management of our material impacts, risks, and opportunities through robust governance frameworks, preventive controls, and stakeholder engagement. Periodic scenario analysis, internal risk assessments, and alignment with international standards, like ISO 14001 and ISO 45001, reinforce our approach. The resilience analysis incorporates short-, medium-, and long-term horizons; qualitative assessments confirm the adaptability of operational procedures and investment strategies to mitigate identified IROs.

There are no applicable significant changes to material impacts, risks, or opportunities from prior reporting periods. All material impacts, risks, and opportunities disclosed in this statement are aligned with ESRS Disclosure Requirements. No additional entity-specific disclosures are included.

Full List of Material IROs

Environmental

Social

Governance

Linkage between IROs and Strategy / Business Model

Climate-related risks and business model resilience:

BW Offshore's material climate-related risks include transition risks affecting access to capital and physical risks from chronic hazards. Transition risk potentially arises as global capital allocation shifts towards renewables, which increases financing costs and limits investment in offshore production facilities. Transition risk inevitably affects BW Offshore's business model, which relies on owning, leasing, and operating offshore O&G assets. Physical climate risks, particularly extreme heat, affect construction yards in Southeast Asia and operational assets in regions such as Australia, where rising temperatures could disrupt work schedules and require adaptive measures.

Climate changes also create increased risk of severe and/or more frequent storms in operating locations such as the Gulf of Mexico and the North Sea.

Scope 1 and 2 Emissions:

BW Offshore's Scope 1 emissions result in an actual negative impact from combustion processes on offshore assets under our direct control (when not operating under service agreements) and from directly contracted third-party vessels' emissions. These emissions are concentrated within BW Offshore's own activities and are directly linked to our strategy and business model, which involves offshore production activities requiring energy-intensive processes.

Scope 3 Emissions:

BW Offshore's Scope 3 emissions are an actual impact in our upstream and downstream value chains, with sources including emissions from steel production for FPSO construction and maintenance, air transportation for employee travel, and emissions generated during offshore operations under services agreements. The business model's reliance on energy-intensive steel and offshore hydrocarbon processing directly links these emissions to our operational strategy.

Pollution impacts:

Operating in the O&G sector, actual and potential pollution is an inherent consequence of BW Offshore's activities. Planned effluent discharges, particularly produced water, constitute an actual negative impact concentrated within BW Offshore's own operations. These impacts are directly linked to BW Offshore's business model, which requires continuous effluent treatment and discharge within regulatory limits.

Circular economy:

Recycling and reusing steel from FPSOs constitutes an actual positive impact concentrated in BW Offshore's downstream value chain, specifically during decommissioning and recycling activities. This impact originates from BW Offshore's ambition to embed circular economy principles into our asset lifecycle management.

Social impacts on own workforce:

Potential negative impact on mental health, well-being, and work-life balance occurs primarily within BW Offshore's offshore operations, where employees undertake rotational work patterns on FPSOs. These challenges are directly linked to our strategy of managing continuous production on offshore facilities.

Potential negative impacts of employee redundancy are concentrated within BW Offshore's own operations. Redundancy is directly linked to BW Offshore aligning our business with evolving market demands and operational priorities. Our business transformation involves jobs that may no longer align with business needs.

Supply chain labour risks:

Supply chain workers in BW Offshore's upstream and downstream value chain are susceptible to discriminatory practices, low wages, and excessive working hours. Our reliance on indirect workers connects us to these impacts through our procurement practices and selection criteria and processes.

Interaction with Business Operations

Current and anticipated effects:

The current and anticipated effects of Scope 1 and 2 emissions on BW Offshore's business model include increasing regulatory pressures, heightened stakeholder scrutiny, and potential reputational risks.

The impacts of Scope 3 emissions require strategic adjustments to mitigate. Current efforts include phasing out routine flaring, applying Best Available Techniques (BAT) for energy efficiency during asset upgrades, and using AI-driven analytics to monitor and reduce emissions.

HFC emissions currently pose a challenge due to their high GWP, which intensifies our overall emissions profile and exposes us to increased regulatory and reputational risks. Regulations restricting the use of certain HFCs in key jurisdictions, effective from 2024, necessitate a gradual transition to alternatives.

Non-GHG emissions from our assets affect operational efficiency and compliance with air quality standards.

The current and anticipated effects of planned effluent discharges in BW Offshore's business model and strategy are centred on compliance obligations and operational integrity.

Impacts of redundancies on BW Offshore include potential reputational risks, reduced employee morale, and loss of institutional knowledge.

Pay disparities affecting women may undermine workforce morale, retention, and our reputation as an equitable employer.

Incidents of unequal treatment or unconscious bias can affect employee morale, productivity, and retention and lead to increased turnover, reduced engagement, and reputational risks for BW Offshore.

Professional development contributes positively to BW Offshore's ability to attract, retain, and engage employees.

The effects of poor working conditions in our supply chain pose potential risks to BW Offshore's reputation, stakeholder relationships, and long-term supply chain resilience.

Forced labour in the supply chain poses reputational, operational, and regulatory risks to BW Offshore.

Resilience to Identified IROs

Climate resilience and scenario analysis:

BW Offshore assesses the resilience of our strategy and business model through scenario analysis with leveraging external frameworks, such as the IEA Net Zero, IEA STEPS, and DNV Energy Transition Outlook. Our analyses evaluate financial and operational risks under varying climate pathways and assess implications for asset lifespans, capital costs, and long-term sustainability.

While BW Offshore's business remains viable across multiple transition scenarios, proactive adjustments—such as diversifying into lower-carbon energy production and adapting FPSO designs for enhanced efficiency—will be crucial for maintaining competitiveness and securing financing. The scenario analysis supports strategic decisions and informs capital allocation and investment planning to balance risk exposure with emerging opportunities in the evolving energy landscape.

Climate scenario overview:

Operational resilience measures:

BW Offshore mitigates work-related accident impacts and risks through a structured approach embedded in our Management System. 100% of our own workforce is covered by or Health and Safety Management System. Key measures include HSSE awareness campaigns, safety inductions, and a Stop Work Policy that empowers personnel to halt unsafe operations.

To address HFC emissions, BW Offshore's transition strategy includes upgrading refrigeration and fire suppression systems to low-GWP alternatives in accordance with regulatory schedules.

BW Offshore has phased out older units from our fleet as part of broader asset management efforts, which contributes to reducing our non-GHG emissions.

We monitor high-risk suppliers through assessments and stakeholder engagements. High-risk contractors, such as shipyards and module fabricators, are subject to periodic audits to identify and mitigate risks.

Financial and strategic adaptations:

Over the medium- to long-term, BW Offshore acknowledges that our strategy may need to adapt to align with the global energy transition. Potential adjustments include diversification of our portfolio to include renewable energy solutions and continued evaluation of opportunities within carbon capture, utilisation, and storage (CCUS) and floating wind infrastructure.

To mitigate impacts of employee redundancy, we have implemented measures, such as re-skilling and upskilling programmes, particularly for engineering roles that can be adapted to new business areas. Internal recruitment is preferred for available open roles, and transparent communication with affected employees is core to our approach.

To mitigate pay gap effects, we are implementing a targeted approach to improve representation in higher-paid roles. This includes career development initiatives, internal mobility programmes, and transparent promotion pathways to ensure women have equitable access to leadership positions.

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

Overview of the Double Materiality Assessment Process

BW Offshore's process to identify, assess, and prioritise impacts, risks and opportunities (IROs) is anchored in a structured, five-step framework aimed at robust, double materiality-based decision-making that aligns closely with operational and strategic priorities. This approach integrates insights from internal subject matter experts and external stakeholders to anchor the results in relation to both regulatory compliance and practical relevance.

Methodology and Digital Materiality Assessment Tool

In conducting the double materiality assessment (DMA), BW Offshore leveraged a purpose-built Digital Materiality Assessment Tool (the "DMA Tool"), designed to capture, assess, and document IROs across BW Offshore's business areas. This tool replaces the previous Excel-based approach used in prior years and delivers enhanced data accuracy, traceability, and auditability in line with audit requirements and stakeholder expectations.

The DMA Tool standardises scoring across two core criteria: impact materiality (externalities on society and the environment) and financial materiality (financial risks and opportunities directly affecting the business). Each IRO is scored using a framework to account for both quantitative and qualitative factors.

Impact Materiality Assessment

Impacts on society and the environment are assessed based on:

• Scale
• Scope
• Irremediability

Each parameter uses a fixed scoring scale from 1 to 5. The tool allows for the prioritisation of actual and potential impacts by calculating an average severity score. For high-severity impacts, thresholds are aligned to ESRS 1.

Financial Materiality Assessment

Financial risks and opportunities are evaluated by:

• Magnitude
• Likelihood
• Nature of the financial effect

These metrics are mapped on a 1-to-5 scale, with thresholds tailored to align with BW Offshore's enterprise risk management programme and industry-specific challenges. This alignment enables the financial materiality of sustainability-related risks to be evaluated in the context of our holistic risk landscape. Thresholds reflect industry benchmarks and regulatory standards, ensuring materiality decisions are both rigorous and relevant.

Time Horizons

ESRS-aligned time horizons are applied uniformly across IROs:

• Short term: less than 1 year
• Medium term: 1-5 years
• Long term: more than 5 years

This allows BW Offshore to consider evolving impacts and financial effects of each IRO within the context of our business and operating environment.

Five-Step Process

The 2024 revalidation process included the following stages:

1. Review Previous Assessment

The 2024 revalidation commenced with a review of the 2023 assessment. Existing IROs were mapped, and newly emergent factors were identified. Each sustainability matter was assessed for continued relevance to BW Offshore's FPSO and floating offshore wind businesses. This review informed the subsequent engagement stages.

Key activities included:

• Review of 2023 DMA
• Development of new hypotheses and identification of new topics for discussion
• Review of KPMG Gap Analysis

2. Stakeholder Engagement

The process involved semi-structured interviews with internal and external stakeholders. Engagement included:

• Internal subject matter experts
• BW Ideol representatives
• External parties

Activities included:

• Further development of topic descriptions and scoring rationale based on Gap Analysis findings
• Engagement with stakeholder representatives

The process prioritised sustainability matters most likely to present heightened risks of adverse impacts, especially within geographies and business relationships critical to BW Offshore's operations and supply chain. This assessment was informed by insights from the 2023 DMA, during which external stakeholder engagement played a key role in verifying impact materiality hypotheses.

2023 External Stakeholder Engagement: In the 2023 assessment, BW Offshore engaged nine external stakeholders, including clients, vendors, financial institutions, and employee representatives, to verify and refine IROs. Five affected stakeholders and four users of sustainability statements were interviewed to provide broad and representative input into the materiality assessment.

2024 Revalidation: The 2024 revalidation leveraged 2023 results and integrated updated perspectives from internal and external stakeholders to refine the assessment. Insights were further refined through interviews with internal stakeholders representing key areas of environmental management, cybersecurity, safety, and governance.

3. Materiality (re)Assessment

The materiality of each topic was reassessed based on stakeholder feedback, and new topics were evaluated.

Impact Assessment: BW Offshore considered both the direct impacts of our FPSOs and offshore wind activities, and consequences that may arise from our business activities and relationships, including supplier and client networks. This approach extended the scope of the DMA and required a nuanced analysis of impact dependencies across the value chain.

Negative impacts were prioritised based on severity and likelihood, while positive impacts were assessed by their scale and potential for meaningful contribution. Materiality thresholds were applied per ESRS 1 section 3.4, with particular attention to high-severity issues in human rights and environmental contexts.

Financial Risk and Opportunity Assessment: The assessment of financial risks and opportunities emphasises interconnections between operational impacts and possible financial effects. Recognising that impacts in areas such as environmental stewardship can give rise to substantial financial risks or, conversely, present opportunities, we have designed our DMA process to identify and quantify these linkages. The direct and indirect dependencies between impacts and potential financial risks and opportunities were considered to account for both the immediate and cascading consequences that can stem from the business's impact on sustainability matters.

Each identified risk and opportunity has undergone a systematic assessment for both financial magnitude and likelihood. A scoring scale from 1 to 5 was used to drive prioritisation and distinguish risks that have significant financial effects from those with more moderate anticipated outcomes. This approach helps pinpoint high-consequence scenarios within BW Offshore's unique operational and geographical footprint, enabling us to focus on industry-specific risks, such as those posed by evolving offshore regulations or technological advancements.

BW Offshore focuses on sustainability-related risks with the most significant financial consequences, and have used the DMA Tool to identify and rank gross risks. Sustainability matters that are clearly material or clearly immaterial, based on predefined criteria, have not undergone further detailed assessment. Instead, additional reviews concentrated on topics where materiality is considered less certain, to avoid key risks from being overlooked.

Opportunity Management: Opportunities are managed and assessed within the broader context of our corporate strategy to align with operational goals and long-term value creation. Identified opportunities are reviewed for their potential impact on organisational resilience and growth. Each opportunity is incorporated into BW Offshore's processes, as appropriate.

4. Validation and Documentation

Preliminary results were presented and discussed with Senior Management Team (SMT). Results were adjusted based on SMT input for formal validation. The materiality matrix was updated with each material topic.

The decision-making process included three key stages: identification, scoring, and final validation. Internal controls included engagement with subject matter experts and stakeholder representatives, enabling a process to verify that relevant sustainability matters were assessed for material IROs. Scoring of IROs followed documented guidelines and was reviewed in workshops to address instances of borderline materiality. Senior Management validated the results for consistency with our risk management programme and financial materiality, prioritised decisions within BW Offshore's risk matrix, and integrated sustainability risks within our risk management framework.

5. Audit Committee Review and Finalise DMA

The Audit Committee reviewed DMA results and identified material IROs. A final Assessment Report was developed for the Auditor.

Integration with Risk Management

BW Offshore integrates IRO insights into our risk management programme. While the DMA remains a distinct process, our findings inform Senior Management risk prioritisation discussions, reinforcing a holistic view of our risk landscape. This approach, incorporating regular updates to the Corporate Risk Register, enables Senior Management to evaluate IROs within the context of our broader risk profile and strategic direction and supports a mature and integrated approach to risk management.

Input Parameters and Data Sources

The 2024 DMA revalidation leverages a combination of internal documents, prior DMA results, and insights from updated financial and operational assessments. Key data sources include:

• 2023 Annual Report and Sustainability Statement
• Internal risk management documents
• Updated environmental, social, and governance metrics

The methodology and materiality thresholds were consistent with the 2023 process, or adjusted for subsidiary-specific factors, like BW Ideol.

Topic-Specific Assessment Approaches

Climate Change

BW Offshore integrates climate scenario analysis into our risk assessment framework to evaluate physical risks, transition risks, and opportunities over the short-, medium-, and long-term.

Different external scenarios are used to illustrate the effects of alternative pathways for climate change and the energy transition:

Scenario Overview:

Physical Risks: Physical risks are identified using high-emission climate scenarios (e.g., NGFS RCP 8.5, IPCC AR6) to assess exposure to:

• Acute hazards: cyclones, heatwaves, coastal flooding
• Chronic hazards: rising sea levels, ocean acidification, temperature variability

Transition Risks: Transition risks are assessed through Paris-aligned scenarios to evaluate potential exposure to policy shifts, market fluctuations, technology disruptions, and reputational concerns affecting business operations.

Under IEA STEPS, FPSO demand remains relatively stable, whereas IEA Net Zero suggests a gradual transition away from fossil fuel infrastructure, with increased reliance on carbon capture (CCS), floating wind, and FPSO electrification. Scenario analysis informs BW Offshore's financial planning by assessing the financial implications of climate transition pathways, such as the impact on EBITDA under different energy mix projections.

BW Offshore also identifies assets that require adaptation to maintain long-term resilience, including investments in low-emission solutions, FPSO electrification, and offshore wind power to align with a climate-neutral economy.

Pollution

The 2024 DMA includes an evaluation of pollution-related impacts, risks, and opportunities across our FPSOs, construction yards, and broader value chain. The process included utilisation of environmental data and operational performance metrics to assess actual and potential impacts from effluent discharges, hydrocarbon spills, and non-GHG emissions. Screening methodologies incorporated regulatory compliance frameworks and international standards, including ISO 14001, to prioritise material pollution risks. No consultations with affected stakeholders were conducted as part of this process.

Water and Marine Resources: We conducted a high-level screening of our operations and value chain to identify water- and marine-related impacts, risks, and opportunities. The screening focused on produced water discharges, and the potential for marine pollution during FPSO operations and decommissioning activities. This evaluation relied on water quality monitoring systems that comply with global standards, such as the World Bank's 30 ppm limit for produced water discharge and MARPOL's 15 ppm for slop water.

The assessment confirms that while discharge of effluent water is a well-regulated process in the FPSO industry, planned effluent discharges - particularly produced water - constitute an actual impact on the environment and should thus be considered material. No consultations with affected communities or stakeholders were undertaken as part of this assessment.

Biodiversity and Ecosystems

The 2024 DMA includes an evaluation of biodiversity-related impacts, dependencies, and risks associated with FPSO operations and construction yards across operational sites, upstream, and downstream activities. The assessment considered actual and potential impacts on biodiversity and ecosystems, such as habitat disruption from operational discharges and risks of invasive species during FPSO operations.

Dependencies were also evaluated, particularly regarding ecosystem services that support marine environments. Systemic risks, including cumulative impacts from marine industry activities on regional ecosystems, were also considered.

The assessment revealed that no sites are located within or near biodiversity-sensitive areas or protected habitats. Consequently, no biodiversity mitigation measures, such as those aligned with international standards like IFC Performance Standard 6 or EU Directives, were deemed necessary.

Consultations with affected communities on potential impacts to shared biological resources and ecosystems were not conducted, and no affected stakeholder input was integrated into the assessment. Nevertheless, we recognise the importance of proactively minimising biodiversity impacts through operational controls and compliance with existing environmental management frameworks.

Resource Use and Circular Economy

The 2024 DMA includes a review of resource use and circular economy considerations within our operations and value chain. This process identified material issues related to the recycling and reuse of steel during decommissioning and waste management practices onboard FPSOs.

Assessment methodologies included material flow analysis and benchmarking against industry standards. Affected stakeholder consultations were not conducted, and no additional tools or assumptions were applied to assess these impacts.

Governance & Business Conduct

BW Offshore conducts risk-based due diligence to identify and assess material impacts, risks, and opportunities related to business conduct across our operations and value chain.

The process considers criteria such as:

• Geographical location
• Activity type
• Sector
• Business partner governance maturity
• Government affiliations
• Reputation

Value Chain Mapping

BW Offshore's value chain mapping reflects our role in the oil and gas value chain, focusing on production contracting, FPSO construction, and long-term operations. Key inputs include advanced engineering expertise, bespoke contracting services, and a skilled workforce. BW Offshore provides seamless transitions from design through construction to production, ending with decommissioning and recycling.

The value chain illustration depicts the allocation of emission responsibilities. Our clients manage upstream and downstream emissions (Scope 3), and BW Offshore addresses direct Scope 1 and 2 emissions associated with operations. BW Offshore activities span from seismic and drilling through development decision, production contracting, FPSO construction, and FPSO operation, to decommissioning (including recycling of oil and gas materials).

Frequency of Review

The DMA was conducted in 2023 and revalidated in 2024. There are no applicable significant changes to material impacts, risks, or opportunities from prior reporting periods.

Transition plan for climate change mitigation

Strategic context

Preparing for a sustainable future is a priority for BW Offshore. In 2020, we revised our corporate strategy to address the increased risk of reduced access to or higher cost of capital for O&G companies. Our 2020 strategy also addressed opportunities to expand into low emissions business.

Our strategy is built on three pillars: extracting maximum value from the conventional business and existing fleet, expanding the core floating production business through investments in new offshore energy infrastructure, and strengthening our position in offshore renewable energy.

In 2023, we established a new Strategic Development function led by our Chief Strategy Officer (CSO), which is responsible for driving progress across all three strategic pillars, including our New Ventures & Technology and Offshore Floating Wind segments. Positioning the Sustainability department within Strategic Development reflects our belief that strategy and sustainability are intrinsically linked.

Transition plan status

At present, we do not have a firm transition plan in place to achieve net-zero or carbon neutrality. Our current emissions, in large part, are dictated by our stakeholders and their ambitions to reduce emissions. Collaboration and joint initiatives among industry stakeholders will drive change in the O&G industry.

While we do not yet have a firm net-zero or carbon-neutral transition plan, we continue to actively engage with industry stakeholders to drive collective emissions reductions and technological innovation. BW Offshore will develop a transition plan depending on our strategic direction.

Alignment with energy transition scenarios

In 2024, BW Offshore initiated the development of an energy transition scenario model. The model sets a range of potential future states of global energy mix via three published outlook scenarios: DNV Energy Transition Outlook 2024, IEA Net Zero 2024, and IEA STEPS 2024 (read more on page 43). The model further assesses current strategic plans against various scenario-driven risk and opportunity sets and links potential business lines with perceived energy transition pathways.

Fleet divestment and emission reduction

In 2024, we completed our fleet divestment programme by retiring legacy assets with high-carbon footprints. These divestments contributed to a reduction in our overall CO2 emissions. The divestment programme was completed with the decommissioning of FPSO Petroleo Nautipa in January 2024.

As a result of our fleet divestment programme, in 2024 we achieved 93.3% reduction of Scope 1 emissions, and 63.1% reduction of Scope 3 emissions compared to 2023. However, anticipated emissions are expected to increase in 2025 with BW Opal commencing operations.

Key decarbonization levers

By providing current and potential clients with innovative technical solutions, we can increase asset energy efficiency, reduce emissions, and operate in a manner that is better for the environment. We are implementing and proposing technologies to lower emissions on newbuild FPSOs by applying combined-cycle gas turbines, carbon-capture technology, as well as other energy efficiency solutions and continuously work with our clients to tailor solutions that fit their needs and support them in reaching their emission reduction goals.

We have adopted various decarbonisation levers to address our environmental footprint, including operational optimisation, investment in cleaner technologies, and collaboration with stakeholders to promote sustainable practices.

Our flagship FPSO BW Opal was designed to achieve emission reduction through application of the latest power generation technologies of combined cycle gas turbines (CCGT) with waste heat recovery. BW Opal's design has been optimised to reduce fuel, flare, and vent (FFV) emissions and to enable the possibility of future export of reservoir CO2 to a CCS project.

Recognising that emissions reduction relies on collaboration across the value chain, BW Offshore is working with clients and industry partners to develop joint initiatives and explore decarbonisation technologies. We also are evaluating alternatives to existing refrigerants.

Investment in renewable energy

Since 2021, BW Offshore has invested USD 80 million in BW Ideol, a floating offshore wind technology and project co-development business. BW Ideol benefits from BW Offshore's extensive experience in offshore construction projects, supporting the development of market-leading renewable technology capabilities.

Future sustainability governance

During 2025, Senior Management will consider a sustainability roadmap that includes the creation of sustainability ambassadors to promote our sustainability ambitions across the organisation.

BW Offshore is assessing additional adaptation actions and their associated timelines to develop increased in our operations. These evaluations will consider resource availability and long-term financial implications of future projects.

We will incorporate updates on access to sustainable financing and transition strategies into our ongoing efforts to strengthen our alignment with climate goals.

Policies related to climate change mitigation and adaptation

BW Offshore has not yet established a dedicated climate change policy. The company is currently evaluating whether to formalise a climate or sustainability policy to address broader climate-related objectives and align with stakeholder expectations and regulatory obligations.

Environmental Policy

Key content and principles: BW Offshore integrates environmental management into its Environmental Management System, which systematically identifies, assesses, controls, monitors, and continuously improves processes. The Environmental Policy addresses core material environmental matters, including:

• Energy efficiency
• Promotion of emission reduction
• Best available techniques

However, some climate-specific mitigation and adaptation areas are currently under review.

Certification and standards: The Environmental Management System is independently certified by ABS to the globally recognised best practice ISO 14001:2015 Environmental Management Standard.

Governance: The Environmental Policy is overseen by the Chief Executive Officer.

Scope: The policy applies globally.

Public availability: The Environmental Policy is available to all personnel through the BW Offshore Management System and is prominently displayed in offices and onboard FPSOs.

Development and launch: In 2024, after consulting with internal stakeholders in Projects, Asset Operations, Supply Chain, Business Development, and Engineering, BW Offshore launched its Environmental Policy and Environmental Reporting Guideline.

Future development: During 2025, Senior Management will consider a sustainability roadmap that includes the creation of sustainability ambassadors to promote sustainability ambitions across the organisation.

Actions and resources in relation to climate change policies

BW Offshore operates assets under contracts with oilfield operators, which limits direct control over GHG emissions generated by these units. Due to this operational structure, BW Offshore has not yet established specific, measurable emission reduction targets. However, the company remains committed to environmental sustainability through initiatives aligned with its Environmental Policy.

Fleet Divestment Programme

Action: Retirement of legacy assets with high-carbon footprints

Scope: Own operations

Time horizon: Completed in January 2024 with the decommissioning of FPSO Petroleo Nautipa

What it does: The fleet divestment programme retired legacy assets with high-carbon footprints, demonstrating strategic focus on transitioning to a more sustainable operational model.

Expected outcomes:

• Achieved 93.3% reduction of Scope 1 emissions compared to 2023
• Achieved 63.1% reduction of Scope 3 emissions compared to 2023
• Significant reduction in CO2 emissions

Link to policy: Aligns with the Environmental Policy, which underpins efforts to reduce emissions and minimise environmental impact

Regulatory Compliance Initiatives

Actions include:

• Compliance with 2024 Flare Consent limits for BW Catcher
• Feasibility studies to transition to lower Global Warming Potential (GWP) refrigerants on BW Adolo and BW Pioneer

Scope: Own operations

FPSO BW Opal - Cleaner Technology Investment

Action: Design and implementation of emission reduction technologies on flagship FPSO BW Opal

Scope: Own operations

What it does: Application of latest power generation technologies including:

• Combined cycle gas turbines (CCGT) with waste heat recovery
• Optimised design to reduce fuel, flare, and vent (FFV) emissions
• Enable possibility of future export of reservoir CO2 to a CCS project

Time horizon: BW Opal expected to commence operations in 2025

Expected outcomes: Anticipated emissions increase in 2025 with BW Opal commencing operations (noting this represents new capacity with cleaner technology)

Decarbonisation Levers

Actions adopted:

• Operational optimisation
• Investment in cleaner technologies
• Collaboration with stakeholders to promote sustainable practices

Scope: Own operations and value chain collaboration

Value Chain Collaboration

Action: Working with clients and industry partners to develop joint initiatives and explore decarbonisation technologies

Scope: Upstream and downstream value chain

What it does: Recognising that emissions reduction relies on collaboration across the value chain, BW Offshore is engaging with clients and industry partners

Specific activities:

• Evaluating alternatives to existing refrigerants
• Developing joint initiatives for emissions reduction
• Exploring decarbonisation technologies

Electrification of O&G Installations (Power-to-Platform)

Context: Electrifying O&G installations through a power-to-platform concept presents opportunity to advance global energy transition goals and meet client demands for emissions reduction

Action: Leveraging expertise in offshore operations and renewable energy to deliver value proposition focused on emissions reduction

Scope: Own operations and downstream (client installations)

Time horizon: Pilot projects and expansion activities planned (no specific dates provided)

Resources: Developed capabilities through joint ventures involving BW Ideol

Planned actions: Developing pilot projects and expanding carbon capture or other renewable technologies to lower emissions from production processes

Geographic focus: Particularly relevant in Europe, where regulatory and market conditions strongly favour decarbonisation initiatives

Note: ENOVA grant announced January 2025 was smaller than industry expectations and was not awarded to BW Offshore (placed second), triggering reevaluation of commercial viability of floating wind power-to-platform concept

Clean Energy Production Through Windfarms (BW Ideol)

Context: Floating wind presents material opportunity for BW Ideol over the long term, concentrated within own operations

Action: Low-emission energy production through floating wind solutions

Scope: Own operations

Time horizon: Long term; large-scale commercial wind farm developments (e.g., SCOTWIND UK) expected to reach commercial operation dates in the next decade

What it does: BW Ideol's floating wind solutions positioned to support transition to clean energy by offering scalable and affordable alternatives

Impact on business: Significantly affects BW Offshore's business model, strategy, and decision-making; offers pathways to diversify revenue streams with potential to support sustainable business throughout energy transition

Resources: Developed capabilities in the floating wind sector through joint ventures

Monitoring and Evaluation

Action: Continuous monitoring of environmental policies and actions effectiveness

What it does: Data collected through daily operational reports and analysed quarterly, enabling evaluation of ongoing performance and adaptation of initiatives as required

Future Planning

Action: Assessment of additional adaptation actions and timelines

Time horizon: Under evaluation; Senior Management will consider sustainability roadmap during 2025

What it does: Evaluations will consider resource availability and long-term financial implications of future projects; includes creation of sustainability ambassadors to promote sustainability ambitions across the organisation

Resources: Non-financial resources allocated include sustainability ambassadors (planned for 2025)

Targets related to climate change mitigation and adaptation

BW Offshore has not established specific, measurable emission reduction targets.

Rationale for Absence of Targets

As stated in the disclosure:

"BW Offshore operates our assets under contracts with oilfield operators, which limits our direct control over the GHG emissions generated by these units. Due to this operational structure, BW Offshore has not yet established specific, measurable emission reduction targets."

Commitment to Environmental Sustainability

While no quantified targets are set, the company commits to:

• Environmental sustainability through initiatives aligned with the Environmental Policy
• Compliance with regulatory frameworks, such as the 2024 Flare Consent limits for BW Catcher
• Feasibility studies to transition to lower Global Warming Potential (GWP) refrigerants on BW Adolo and BW Pioneer

Performance Context (Not a Target)

In 2024, as a result of the fleet divestment programme:

• 93.3% reduction of Scope 1 emissions compared to 2023
• 63.1% reduction of Scope 3 emissions compared to 2023

Note: The company acknowledges that emissions are expected to increase in 2025 with BW Opal commencing operations.

Energy consumption and mix

BW Offshore reports energy consumption and mix metrics in accordance with ESRS E1-5 (now E1-7 under updated nomenclature). The company operates within a high climate impact sector and reports energy intensity based on total energy consumed in relation to total net revenue.

Energy consumption and mix (2024)

Share of energy consumed per category (2024)

Energy intensity (2024)

Scope and methodology: Total energy consumption was 6,828 MWh with an energy intensity of 11.25 MWh per million USD revenue. The reporting covers BW Offshore's operational activities as a high climate impact sector undertaking. Energy consumption offshore in 2024 was 4,273 TJ (Note 23). The decrease in total energy consumption compared to prior years reflects the completion of the fleet divestment programme, with legacy assets retired (FPSO Petroleo Nautipa decommissioned in January 2024).

Gross Scopes 1, 2, 3 and Total GHG emissions

BW Offshore disclosed GHG emissions for 2024, 2023, and 2022. The company reports emissions in thousands of tonnes CO₂ equivalent (tCO₂eq). The methodology is aligned with the GHG Protocol. Scope 1 and 2 emissions are based on operational control; Scope 3 includes categories 3 (Fuel-and energy-related activities), 6 (Business travel), and 13 (Downstream leased assets).

Emission Indicators

Note: Declared under overall Scope 3 CO₂ equivalent emissions.

Emission Intensity

Scope 2: Location-based vs Market-based

BW Offshore reports Scope 2 emissions using the location-based methodology only. Market-based data is not available due to lack of market-based data for operations. The 1.6 thousand tonnes CO₂ eq for 2024 is location-based, calculated using IEA emissions factors per the GHG Protocol Scope 2 Guidance. GWP rates are from the IPCC 5th Assessment Report.

Scope 3 Breakdown by Category

BW Offshore's Scope 3 emissions encompass multiple sources. ~90% are calculated using primary data. The disclosure covers:

• Category 3 (Fuel-and energy-related activities not included in Scope 1 or 2): FPSO operations under service agreements (combustion, fugitive, and vented emissions). Calculated using daily fuel consumption data from vessel reports, applying API and UK Oil and Gas Guidelines methodologies.
• Category 6 (Business travel): Air travel emissions reported monthly by BW Offshore's designated travel provider (6.9 thousand tonnes in 2024).
• Category 13 (Downstream leased assets): Emissions from FPSOs under client operational control. Estimated using IPCC and Oil and Gas UK Environmental Emissions Monitoring System factors for the maritime industry.

Project construction activities emissions are calculated from monthly HSSE reports from yard owners. HFC consumption is calculated from procurement records using IPCC GWP factors.

Methodology and Consolidation

• Consolidation approach: Operational control. Covers all subsidiaries and joint ventures under operational control; unconsolidated subsidiaries excluded.
• GWP rates: IPCC 5th Assessment Report.
• Scope 1: Combustion emissions from offshore assets not under service agreements and third-party vessels directly contracted by BW Offshore. Estimated using IPCC emissions factors.
• Scope 2: Location-based only, using IEA emissions factors.
• Scope 3: Categories 3, 6, and 13. No additional categories excluded. Upstream emissions (steel production, yard construction) and downstream operational emissions (FPSO operations under client control) included.
• Reporting boundary: No changes in reporting year; year-on-year comparability ensured.
• No offsets or internal carbon pricing applied.
• Biogenic CO₂: BW Offshore does not generate material biogenic CO₂ emissions.

Flaring

Reporting Error – Prior Period

Scope 2 correction: 2023 electricity consumption data for the Houston office was inaccurate (building-wide vs. office-specific). Updated historical data is provided in emission factor and energy consumption tables (page 64).

Energy Consumption (Context for Emissions)

Total energy consumption for 2024 was 6,828 MWh with an intensity of 11.25 MWh/million USD revenue. 90.6% from fossil sources, 8.6% renewable, 0.8% nuclear.

Policies related to own workforce

BW Offshore has established a comprehensive framework of policies related to its own workforce, covering health and safety, human rights and fair employment, and equal treatment and opportunities.

Safety First Policy

Policy description:
Outlines BW Offshore's commitment to prioritise safety and sets out the key requirements necessary for achieving this commitment.

Scope:

• Applies across business activities to all employees and contractors

Approval and oversight:

• Endorsed by the CEO, who is ultimately accountable for policy implementation

Implementation and monitoring:

• The Operational Integrity (OI) Management Standard outlines the activities and actions necessary to fulfil the policy commitments
• The Management System is certified under ISM Code, ISO 9001, ISO 14001 and ISO 45001
• Applies to all employees, contractors and visitors working at locations controlled by BW Offshore
• Available on the company's intranet
• Internal stakeholders and end-users are consulted during policy development and updates
• All employees can give feedback through the Management System
• Policy owners consider feedback during periodic reviews

Training:
Onboarding process creates awareness through mandatory e-learning courses tailored to distinct roles; refresher training conducted as needed and in accordance with industry best practices

Stop Work Policy

Policy description:
Provides all personnel the explicit authority to stop any action they think is unsafe and/or they are unsure about and to initiate a process to define and clarify their concerns without any repercussions.

Scope:

• Applies across business activities to all employees and contractors

Approval and oversight:

• Endorsed by the CEO, who is ultimately accountable for policy implementation

Code of Ethics and Business Conduct

Policy description:
Sets forth BW Offshore's commitment to preventing and mitigating adverse human rights impacts, both within own operations and across the value chain. Sets expectations for ethical conduct and responsible business practices.

Scope:

• Applies to BW Offshore, subsidiaries, and those working for or on behalf of these entities

Implementation and oversight:

• Implemented under the lead of the Head of Corporate Integrity

Link to international standards:

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

Human Rights and Decent Working Conditions Policy

Policy description:
BW Offshore is committed to respecting human rights and providing decent working conditions. Prohibits forced labour, child labour, modern slavery, and human trafficking and outlines expectations for business partners.

Scope:

• Applies to BW Offshore, subsidiaries, and those working for or on behalf of these entities

Implementation and oversight:

• Implemented under the lead of the Head of Corporate Integrity

Link to international standards:

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

Monitoring:

• Human rights due diligence conducted through human rights assessment to identify possible risks within operations and across value chain
• Training: All personnel receive human rights awareness training
• Reporting and Transparency: Annual statement published in compliance with Norwegian Transparency Act and UK Modern Slavery Act, approved by Board of Directors
• Grievance Mechanisms: Employees and stakeholders can report breaches through confidential SpeakUp Channel
• Monitoring adherence through tracking cases raised through internal reporting mechanisms, site visits, and audits of suppliers

Human Capital Policy

Policy description:
Reinforces BW Offshore's commitment to being an employer of choice by fostering a respectful and rewarding workplace.

Scope:

• Applies to all BW Offshore employees

Implementation and oversight:

• Managed and implemented by the Human Capital (HC) function, which sets processes and procedures

Diversity, Inclusion and Equity Policy Statement

Policy description:
Underscores BW Offshore's commitment to cultivating a diverse and inclusive workplace where all employees, regardless of background, can contribute meaningfully. Promotes respect, cultural awareness, and collaboration across the organisation.

Scope:

• Applies to both employees and non-employees

Approval and oversight:

• Statement signed by the CEO
• Implementation overseen by the HC function

Policy development:

• Internal stakeholders and employees consulted in policy development
• All employees encouraged to provide feedback
• Policies reviewed regularly; policy owners consider feedback during review process

Commitment:
Strictly prohibits any form of unlawful discrimination, including but not limited to race, social or economic status, age, natal sex, sex characteristics, sex reassignment, sexual orientation, personal presentation, marital or civil partnership status, family structure, pregnancy or parental status, religion, political beliefs, disability, or any other status protected by applicable laws.

Career Development and Promotion Policy

Policy description:
Establishes a framework to consistently and fairly manage career development and promotions across BW Offshore. Promotes diversity, equity, and inclusion and provides fair opportunities for all employees. Promotions and development plans avoid disparities based on factors such as disabilities, pregnancies, or family situations.

Scope:

• Applies to all permanent employees

Implementation and oversight:

• Implemented by the HC function

Taking action on material impacts on own workforce

BW Offshore has not yet established measurable outcome-related targets for health and safety in line with ESRS requirements. However, the company actively tracks performance against its Safety-First Policy, which underlines that safety is at the core of everything they do. BW Offshore is committed to achieving zero harm by learning from incidents within operations and across the industry. The ambition is to consistently enhance safety and performance and avoid any incidents or harm to people.

Key Safety Initiatives for 2024-2025

Integrated Risk Management

• Focuses on enhancing the quality of risk management at both operational and enterprise levels
• Goal: Enable more effective and transparent risk management and provide senior leadership with a comprehensive view of overall risk profile
• Aims to embed risk assessments seamlessly into daily work processes

Competence Management System

• Enhances the competence management process to align job roles and safety-critical tasks with necessary competencies
• Addresses non-technical skills such as communication, leadership, and teamwork
• Provides a holistic approach to competence management

Management System

• Improving the Management System and core documents
• Provides users with an effective tool for safe and efficient work

Control of Work

• Developing and implementing an industry leading digital Control of Work solution
• Aims to enhance the quality and consistency in how the permit to work process is applied

Barrier Management

• Introducing a fully integrated digital barrier management tool linked to the electronic control of work system
• Will strengthen ability to identify, monitor, and manage critical safety barriers effectively

Leadership Development for Offshore Supervisors

• Strengthening leadership capabilities among offshore supervisors to enhance safety culture and leadership
• Focuses on equipping leaders with the skills necessary to guide their teams effectively

Resources Allocated

BW Offshore allocates key resources and invests in training programmes, health and wellness initiatives, and support services to effectively manage material health and safety-related impacts and risks. An HSSE Manager is assigned to support each project and operating asset.

Confidential internal budget and resource costs are excluded from this statement.

Safety Training and Awareness

BW Offshore maintains a comprehensive training matrix for each operating Asset, including:

• Industry safety and certification training
• Emergency response training
• Hazard management and risk assessment
• Safety systems and processes
• Occupational health training
• Specialised activities training

Major Accident Awareness Training:

• Comprehensive and periodic training designed to enhance awareness of major accident risks
• In 2024, 152 people attended major accident awareness training
• Feedback is surveyed from each participant to track training effectiveness
• Annual programme review with all facilitators to identify improvement areas

Onboarding Process includes:

• HSE induction: All new personnel complete a detailed HSE induction covering company policies, management system, and HSSE expectations
• Unit-specific inductions: Offshore personnel attend unit-specific induction tailored to hazards, HSSE requirements, and emergency procedures

Working Conditions Actions

Improving Mental Health and Wellbeing

• Mental health and wellbeing programme accessible to all employees
• Proactive, data-driven approach analysing workforce data such as absenteeism and turnover rates
• Employee assistance programmes offer short-term counselling for personal or work-related challenges across all locations
• Family-related leave provided to all employees
• October designated as Wellbeing Month with activities, workshops, and webinars in collaboration with BW Group affiliates
• Recordings of seminars made available on intranet

Future Initiatives (2025):

• Expand mental health initiatives as part of Wellbeing Month
• Conduct a culture survey to gather insights on safety performance and culture maturity
• Employee engagement survey
• Metrics to evaluate mental health support services
• Data analytics to measure effectiveness and uptake

Training to Upskill and Re-skill

• Employees made redundant receive financial compensation linked to years of service
• In Singapore, the Shipbuilding and Marine Engineering Employees' Union may negotiate additional support (lump sum training grant)
• Targeted training initiatives to equip employees to adapt to industry changes
• E-learning modules include post-training tests to measure knowledge retention
• Dedicated training code in time registration system tracks participation and time spent

Professional Development Actions

Explorer Programme

• 6-month modular programme designed specifically for people leaders
• Provides opportunity to understand personal leadership styles and their impact on teams
• Enhances leadership capabilities

Voyager Programme

• Designed for high-potential employees preparing for leadership roles
• Strengthens BW Offshore's leadership pipeline
• Includes advanced training, strategic projects, and leadership development
• Participants receive personalised development plans, executive mentorship, and opportunities to lead projects

Young Talent Programme

• Attracts and develops young professionals through training, mentorship, and hands-on experience
• Participants receive tailored development plans, challenging project assignments, and collaboration with experienced professionals
• Builds a skilled talent pipeline for BW Offshore's future

Performance Management

• Annual performance and development dialogues cover past performance, future objectives, development plans, employee aspirations, and opportunities for improvement

Equal Treatment and Opportunities Actions

Ensuring Fair Remuneration

• Annual review of employee wages, pay scales and union agreements
• Minimum living wage applied for direct hires in each operating location
• Living wage calculations account for taxes, social security contributions, and costs for housing, food, and essential goods
• Merit-based framework for total compensation
• Ratio of basic salary between women and men monitored annually

Career Development and Promotion

• Career Development and Promotion Policy promotes diversity, equity, and inclusion
• Provides fair opportunities for all employees
• Promotions and development plans avoid disparities based on disabilities, pregnancies, or family situations

Governance and Oversight

The Human Capital (HC) function oversees effective processes to protect the interests of BW Offshore and employees.

Targets related to own workforce

Health and Safety

BW Offshore has not yet established measurable outcome-related targets for health and safety, in line with ESRS requirements.

However, the company actively tracks performance against its Safety-First Policy and is committed to achieving zero harm by learning from incidents within operations and across the industry. The ambition is to consistently enhance safety and performance and avoid any incidents or harm to people.

Safety observation target:

• Target: One safety observation card per person per week (two cards per person per week in some contexts)
• Type: Process/activity target
• Scope: Offshore facilities and operations

Working Conditions

BW Offshore does not currently have measurable outcome-oriented targets for working conditions in line with ESRS requirements, but is committed to continuously improving management of material impacts in alignment with relevant policies.

Equal Treatment and Opportunities

BW Offshore does not have measurable outcome-oriented targets on equal treatment, in line with ESRS requirements.

However, BW Offshore is committed to improving gender balance in the graduate programme by increasing the representation of women in historically male-dominated O&G roles.

Monitoring approach:

• Annual review of gender representation in recruitment
• Headcount analysis
• Annual presentation to Senior Management on programme outcomes, including gender-related trends

Characteristics of the undertaking's employees

Total Headcount and FTE

Total Workforce:

• 2024: 1,128 employees
• 2023: 1,189 employees

Average number of employees:

• 2024: 1,216
• 2023: 1,521

Headcount by Gender

Gender Balance in Total Workforce:

Gender Balance in Board of Directors:

Gender Balance in Senior Management:

Headcount by Region

Employee Headcount by Region (Total: 1,128):

• Asia-Pacific: 479
• Europe: 336
• West Africa: 149
• Americas: 133

Onshore Workforce by Region:

Offshore Workforce by Region:

Gender Balance in Total Workforce per Region:

Headcount by Employment Contract Type

Onshore:

• Permanent Onshore Personnel: 487
• Direct Hire Contract Onshore Personnel: 108
• 3rd Party Consultant Onshore Personnel: 25
• Resource Onshore Personnel: 1
• Consultant Onshore no hours: 4

Offshore:

• Permanent EXPAT Offshore Personnel: 245
• Direct Hire Contract EXPAT Offshore Personnel: 23
• 3rd Party Consultant EXPAT Offshore Personnel: 6
• Permanent NATIONAL Offshore Personnel: 208
• Direct Hire Contract NATIONAL Offshore Personnel: 3
• 3rd Party Consultant NATIONAL Offshore Personnel: 23

Age Distribution

Age Distribution in Onshore Workforce:

Age Distribution in Offshore Workforce:

Employee Turnover

Not disclosed in a separate metric. The company reports year-end headcount decreased from 1,189 (2023) to 1,128 (2024).

New Hires

Not disclosed.

Methodology Notes

• Personnel statistics are based on year-end headcount from December 2024
• The most common type of non-permanent personnel are contract and consultant staff hired for a time-specific period
• Offshore "other" is a group of employees not designated to a specific work location who work globally
• Non-guaranteed hours employees are less than 1% of workforce and not separately reported
• Part-time staff is not separately reported; total number of part-time staff is less than 1% of total workforce
• Headcount numbers are based on year-end statistics derived from HR systems; the company was transitioning from one system to a new system during the reporting period
• 100% of own workforce is covered by Health and Safety Management System

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

Offshore Non-Employee Workforce

Onshore Non-Employee Workforce

Methodology Notes

• The personnel statistics are based on the year-end headcount from December 2024.
• The most common type of non-permanent personnel are contract and consultant staff hired in for a time specific period. Contract personnel have direct contracts with the company, while consultants are employed via third-party agreements.
• Offshore, other is a group of employees that are not designated to a specific work location and work globally.
• Headcount numbers are based on year-end statistics derived from HR systems. BW Offshore is currently in transition from one system to a new system and used the new system to quality check data from the old system.

Total Non-Employee Workforce Summary

Offshore non-employees: 55 workers (23 direct hire contracts + 6 3rd party EXPAT consultants + 3 direct hire NATIONAL + 23 3rd party NATIONAL consultants)

Onshore non-employees: 138 workers (108 direct hire contracts + 25 3rd party consultants + 1 resource personnel + 4 consultants with no hours)

Total non-employees in own workforce: 193 workers

Collective bargaining coverage and social dialogue

BW Offshore's Human Rights and Decent Working Conditions policy states that employees have the right to free association and collective bargaining. Union engagement occurs at a frequency described in the applicable Collective Bargaining Agreement (CBA). Out-of-cycle meetings take place as and when required by either party. CBAs are put in place mutually between the employer and the employees.

Worker representation structures

Working Environment Committee (WEC)

In Norway and Singapore, Working Environment Committees are in place to advocate on behalf of onshore workers for a secure, safe, and healthy work environment. The WEC meets quarterly with management. The Human Capital function manages the WEC process.

Offshore Safety Committee (OSC)

All operating offshore units have an Offshore Safety Committee. There are monthly OSC meetings between worker representatives and management to discuss occupational health and HSE-related topics. The Asset Operations function manages the OSC process. The Offshore Installation Manager (OIM) is responsible for implementing the process on the respective asset.

Engagement processes

BW Offshore gathers feedback on working conditions through regular communication between worker representatives and management, as well as direct engagement with employees via mechanisms such as workforce surveys, townhalls, and performance dialogues. Union engagements follow Collective Bargaining Agreements. General Managers or Asset Managers lead respective staff engagements for areas within their remits.

Diversity metrics

Gender Balance in Board of Directors

Gender Balance in Senior Management

Gender Balance in Total Workforce

Age Distribution in Onshore Workforce

Age Distribution in Offshore Workforce

Gender Balance in Total Workforce per Region

Gender Balance in Total Workforce per Country

Gender Balance in Onshore Workforce per Region

Adequate wages

Benchmark used

BW Offshore applies a minimum living wage for direct hires in each operating location. The company states:

"We apply a minimum living wage for direct hires in each operating location. Living wage calculations account for taxes, social security contributions, and costs for housing, food, and essential goods. This methodology aligns with standards referenced by the ILO and Employment Conditions Abroad (ECA)."

The benchmark is based on an internal methodology that references ILO standards and Employment Conditions Abroad (ECA), accounting for:

• Taxes
• Social security contributions
• Housing costs
• Food costs
• Essential goods

Coverage

The disclosure does not provide specific percentage coverage of the workforce assessed against the living wage benchmark or what proportion was found to earn at or above it.

Geographic scope

The living wage applies to "each operating location" globally for direct hires. No specific countries or exclusions are disclosed.

Targets and commitments

No forward-looking targets or commitments regarding living wage coverage are disclosed.

Methodology details

• Frequency: Employee wages, pay scales, and union agreements are reviewed annually
• Assessment approach: Living wage calculations account for taxes, social security contributions, and costs for housing, food, and essential goods
• Alignment: Methodology aligns with ILO standards and Employment Conditions Abroad (ECA)
• Contractors: Not explicitly addressed for own workforce; however, separate supply chain initiatives exist (living wage programme created in 2021 for high-risk suppliers)

Additional information

BW Offshore uses a merit-based framework for total compensation. The ratio of basic salary between women and men for permanent employees is monitored as part of the annual remuneration process.

In the materiality assessment, S1-10 Adequate wages is marked as "Not material" in the disclosure table.

Social protection

BW Offshore has assessed ESRS S1-11 (Social Protection) as not material and has omitted disclosure of this data requirement.

No metrics on percentage of employees covered by social protection against loss of income from major life events (sickness, unemployment, employment injury, parental leave, retirement) have been disclosed.

Persons with disabilities

BW Offshore has assessed ESRS S1-12 (Persons with disabilities) as not material and therefore omits disclosure of metrics related to the percentage of employees with disabilities.

No quantitative data on employees with disabilities is provided in the sustainability statement.

Training and skills development metrics

Performance Dialogues (completion rate)

Time Spent on Training (average hours per employee)

Notes:

• Training activities are registered by time recording in IFS for onshore employees, capturing external courses.
• External courses for offshore employees (such as BOSIET, HUET etc.) are also included in the training overview.
• Performance review data captures all permanent onshore personnel employed before 31 December 2024.
• Offshore data pertains to employees on permanent rotation (both permanent and fixed-term contracts on a permanent rotation onboard the units) and 3rd party nationals employed before 31 December 2024.

Health and safety metrics

Coverage of health and safety management system

100% of BW Offshore's own workforce is covered by the Health and Safety Management System. This includes all employees and contractors at locations controlled by BW Offshore. The Management System is certified under ISO 45001, ISM Code, ISO 9001, and ISO 14001.

Health and safety performance metrics (2022–2024)

Methodology notes

Frequency rates: All rates calculated per 1 million exposure hours.

Exposure hours calculation:

• Offshore employees: 12 hours per day for each Person Onboard (POB) based on unit's average POB
• Onshore employees: Average working hours of permanent employees and direct hires, plus hours for contract hires working on projects
• Onshore contractors: Exposure hours from shipyard contractors and subcontractors involved in BW Offshore projects

Definitions:

• Lost Time Injury (LTI): A fatality or lost work day case
• Total Recordable Injury (TRI): The sum of fatalities, lost work day cases, restricted work day cases and medical treatment cases
• High Potential Incident (HPI): An incident that could have realistically resulted in one or more fatalities, but the actual consequence is of lesser severity
• Occupational Illness: Any abnormal condition or disorder caused by prolonged or repeated exposure to environmental factors associated with employment

Onshore absence: In 2024, onshore absence due to sickness was 2.3% of total hours worked by employees (2.1% in 2023).

Work-life balance metrics

Family-related leave

Methodology notes

• All employees under direct contract with BW Offshore are entitled to family-related leave. It is the employer's responsibility to provide leave in accordance with applicable regulations; thus, family-related leave for third-party consultants is managed by their respective employers.
• Family-related leave metrics are recorded for onshore personnel. Due to the nature of offshore rotation-work, family-related leave is not tracked for offshore employees. No female employees offshore have requested maternity leave.
• Data is unavailable for operations in Nigeria.

Compensation metrics (ESRS S1-16)

Pay gap

BW Offshore discloses a gender pay gap metric for 2024, 2023, and 2022:

²Pay-gap is defined as the average salary of women vs. the average salary of men (where the salary of men is 100%).

The company reports a 6.78% gender pay-gap improvement in 2024 compared to 2023 as a key performance indicator.

Remuneration ratio

BW Offshore discloses the annual total remuneration ratio:

¹The annual total remuneration ratio is calculated from the highest paid individual to the median annual total remuneration for all employees (excluding the highest-paid individual).

Methodology

Scope and consolidation:

• The data has been compiled from the company personnel system and includes remuneration data for permanent employees and employees on timebound contracts (direct hire contract employees).
• The countries of employment are Singapore, Norway, the United Kingdom, the United States, Australia, Brazil, France, Gabon, Netherlands, and the United Arab Emirates.
• Annual gross salaries (including fixed allowances) have been converted from local currency to USD using the exchange rate from OANDA.com on 31 December 2024.

Pay gap methodology: BW Offshore monitors the ratio of basic salary and remuneration of women to men for permanent employees. Due to the over-representation of female workers in certain job types and levels, often with lower market value than positions where male workers are overrepresented, the average salary of women is lower than the average salary of men.

The company notes: "The pay gap refers to the difference in average gross hourly earnings between men and women, rather than unequal pay for equal work."

Remuneration ratio methodology: The ratio is calculated from the highest paid individual to the median annual total remuneration for all employees (excluding the highest-paid individual).

Incidents, complaints and severe human rights impacts

BW Offshore states that S1-17 (Incidents of discrimination) is not material to the company's operations.

No quantitative data on incidents of discrimination, harassment, severe human rights impacts, fines, sanctions, or complaint status is disclosed in the sustainability statement.

Related policies and mechanisms

The company has established:

• SpeakUp Channel: A confidential grievance mechanism available to employees and external stakeholders for reporting breaches of law or corporate policies, including human or labour rights violations. Reports may be submitted anonymously via web or telephone in all operational languages.

• Corporate Integrity function: Reviews all reports to the SpeakUp Channel and conducts investigations when needed. Investigation outcomes may include disciplinary or remedial actions, policy or procedure changes, communication, or training.

• Prohibition of retaliation: Retaliation against reporters is strictly prohibited.

• Monitoring: BW Offshore monitors adherence to human and labour rights by tracking cases raised through internal reporting mechanisms, site visits, and audits of suppliers.

Supplier-related human rights issues

While no metrics are disclosed under S1-17 for own workforce, the company acknowledges human rights risks in the value chain, particularly:

• Forced labour in the supply chain: Identified as a potential negative impact concentrated upstream, particularly within FPSO construction
• Harassment and discrimination risks: Acknowledged among third-party contractors, with gaps noted in monitoring the full extent of harassment risks among contractors and their sub-suppliers

High-risk contractors, including shipyards and module fabricators, are subject to audits that include worker interviews about awareness and availability of local reporting mechanisms.

Policies related to consumers and end-users

BW Offshore has not identified any material impacts, risks and opportunities (IROs) related to consumers and end-users.

As stated in the company's materiality assessment and omitted disclosures table, ESRS S4 (Consumers and end-users) has been assessed as not material. Consequently, the company has omitted ESRS S4-1 through S4-5, including disclosure requirements for policies related to consumers and end-users.

No specific policies related to consumers and end-users are disclosed.

Taking action on material impacts on consumers

Not disclosed.

BW Offshore has not identified any material impacts, risks and opportunities (IROs) related to consumers and end-users, and therefore omits ESRS S4-1 through S4-5, including S4-4 (Taking action on material impacts on consumers and end-users).

Business conduct policies and corporate culture

BW Offshore has implemented a comprehensive framework of policies and governance documents to support ethical business conduct and corporate culture, aligned with the UN Guiding Principles on Business and Human Rights, ILO Declaration on Fundamental Principles and Rights at Work, and OECD Guidelines for Multinational Enterprises.

Code of Ethics and Business Conduct

Scope: Applies globally to all employees, board members, officers, temporary staff, and representatives of BW Offshore, including joint ventures where BW Offshore has majority interest. Also extends to legal agents, consultants, contractors, intermediaries, and other parties acting on behalf of BW Offshore.

Governance: Implementation overseen by the Head of Corporate Integrity. The Code is signed by the CEO. Supplemented by the Code of Ethics and Business Conduct Guidelines and additional policies and procedures accessible on the internal Management System. Oversight provided by the Board of Directors and Audit Committee.

Key content/principles: Foundational governance document establishing minimum standards for business conduct and fundamental expectations of fair dealing, honesty, and integrity. Covers:

• Anti-bribery and corruption
• Competition
• Money laundering
• Insider trading
• Health, safety, and environment
• Trade compliance
• Confidentiality
• Communications
• Data protection and information security
• Accurate records
• Conflicts of interests
• Expressions of concern
• Living wage
• Governance
• Human rights and fair employment practices
• Respect for individuals

Public availability: Available on the company website www.bwoffshore.com

International standards: Reflects commitment to respect individuals, uphold human rights, and maintain fair and ethical employment practices. Aligned with the Universal Declaration of Human Rights, ILO conventions, United Nations Guiding Principles on Business and Human Rights, and OECD Guidelines for Multinational Enterprises.

Monitoring: Annual performance dialogues provide feedback on compliance. Biennial survey on leadership behaviours. Head of Corporate Integrity monitors trends in SpeakUp reports and investigation outcomes, sharing insights with the Audit Committee and Senior Management quarterly. Internal Audit conducts regular reviews of expense claims. Annual conflict of interest questionnaire required for all staff.

Supplier Code of Ethics and Business Conduct

Scope: Applies to BW Offshore's business partners, suppliers, agents, and other third parties (collectively "suppliers").

Governance: Approved by the Head of Supply Chain. Owned by the Senior Manager - Business Process Management. Principles enforced through standard contractual terms and conditions.

Key content/principles: Demonstrates respect for human rights and commitment to ethical practices. Establishes minimum expectations for labour practices, including:

• Bribery and corruption
• Competition
• Money laundering
• Insider trading
• Health, safety, and environment
• Trade compliance
• Confidentiality
• Communications
• Data protection and information security
• Accurate records
• Conflicts of interests
• Expressions of concern
• Living wage
• Governance
• Zero tolerance for human trafficking, forced labour, child labour, discrimination, and harassment
• Prohibition of discrimination and maintaining employment environment free from harassment or abuse

Public availability: Available on the company website www.bwoffshore.com

International standards: Aligned with Universal Declaration of Human Rights, ILO conventions, United Nations Guiding Principles on Business and Human Rights, and OECD Guidelines for Multinational Enterprises.

Monitoring: High-risk contractors, including shipyards and module fabricators, subject to periodic audits to identify and mitigate risks. Supplier Vendor Qualification Process includes questionnaires, site visits, and audits. Ongoing due diligence including ethical labour audits and risk mapping. Suppliers required to notify BW Offshore of situations that may create high likelihood of negative impacts on human rights or decent working conditions.

Supplier Ethical Employment Practice Guidelines

Scope: Applies to suppliers and other third parties.

Key content/principles: Establishes expectations for ethical labour practices across the value chain.

Public availability: Available on the company website www.bwoffshore.com

Monitoring: Part of the due diligence process for suppliers, including site visits and ethical labour audits.

Human Rights and Decent Working Conditions Policy

Scope: Applies to both employees and non-employees. Covers BW Offshore's own operations and value chain.

Governance: Implementation overseen by the Head of Corporate Integrity. Statement signed by the CEO. Policy reviewed regularly with feedback considered during review process.

Key content/principles:

• Commitment to respecting human rights and providing decent working conditions
• Prohibits forced labour, child labour, modern slavery, and human trafficking
• Outlines expectations for ethical conduct and responsible business practices
• Zero-tolerance stance on workplace misconduct, including harassment, violence, and discrimination
• States that BW Offshore employees have the right to free association and collective bargaining
• Commitment to preventing and mitigating adverse human rights impacts within own operations and across value chain

International standards: Informed by UN Guiding Principles on Business and Human Rights, ILO Declaration on Fundamental Principles and Rights at Work, and OECD Guidelines for Multinational Enterprises.

Monitoring: BW Offshore monitors adherence to human and labour rights by tracking cases raised through internal reporting mechanisms, site visits, and audits of suppliers. Human rights assessment conducted to identify possible human rights risks within operations and value chain. Annual statement published in compliance with Norwegian Transparency Act and UK Modern Slavery Act, approved by Board of Directors.

Human Capital Policy

Scope: Applies to both permanent and temporary employees. The policy applies to all BW Offshore employees.

Governance: Implementation and processes overseen by the Human Capital (HC) function. Policy reviewed regularly.

Key content/principles:

• BW Offshore's aspiration to be an attractive employer with a rewarding workplace
• Expectation of mutual respect for individual employees and for the company throughout employment
• Provides equal opportunities regardless of gender, nationality, ethnicity, or other characteristics
• Recognises both permanent and temporary employees as integral to company's success
• Mandates fair treatment at all stages of employment
• Commitment to being an employer of choice by fostering a respectful and rewarding workplace

Monitoring: HR function manages implementation and sets processes and procedures.

Diversity, Inclusion and Equity Policy Statement

Scope: Applies to all employees.

Governance: Implementation overseen by the Human Capital function. Policy reviewed regularly with internal stakeholders and employees consulted.

Key content/principles:

• Commitment to cultivating a diverse and inclusive workplace
• Equal opportunities for all employees regardless of background
• Promotes diversity, equity, and inclusion across the organisation
• Strictly prohibits any form of unlawful discrimination including based on race, colour, nationality, ethnic or national origin, social or economic status, age, sex, sex characteristics, sex reassignment, sexual orientation, personal presentation, marital or civil partnership status, family structure, pregnancy or parental status, religion, political beliefs, disability, or any other protected status

Monitoring: Policy owners consider feedback during regular review process.

Career Development and Promotion Policy

Scope: Applies to all permanent employees.

Governance: Implemented by the HC function.

Key content/principles:

• Establishes framework to consistently and fairly manage career development and promotions across BW Offshore
• Promotes diversity, equity, and inclusion
• Provides fair opportunities for all employees
• Promotions and development plans avoid disparities based on factors such as disabilities, pregnancies, or family situations

Monitoring: Annual review of gender representation in recruitment, headcount analysis, and annual presentation to Senior Management on programme outcomes including gender-related trends.

Corporate Culture Framework: We LEAD with Integrity

Key content/principles: Core values framework encompassing:

• Leverage the Team: Trust each other, recognise strength as a team, embrace diversity and collective competencies
• Excellence: Strive to do everything to the best of abilities, seek continuous improvement, see sharing of failure as strength and learning opportunity
• Accountability: Care about work and people, take ownership to ensure positive outcomes for stakeholders
• Development: Actively seek learning opportunities, inspire individual growth, continuously seek feedback
• Integrity: Foundation of all values

Supported by eight leadership behaviours: trust, care, openness, learning, feedback, speaking up, teamwork, and addressing dilemmas.

Monitoring: Biennial all-staff survey measures maturity of leadership behaviours. Annual We LEAD Recognition Programme recognises and rewards positive behaviours. Annual We LEAD Day celebrates achievements and holds engagement sessions.

Anti-Retaliation Policies

Key content/principles: Prohibits retaliation against anyone who raises a concern in good faith.

Monitoring: Allegations of retaliation investigated and monitored by Corporate Integrity with oversight by Audit Committee. Communicated through town halls, posters, internal communications, and intranet.

Prevention and detection of corruption and bribery

BW Offshore is committed to maintaining the highest standards of integrity and ethical conduct across its operations. The company has implemented policies, processes, and training to address corruption and bribery challenges.

Code of Conduct

Scope:

• All new staff are required to complete e-learning within 30 days of joining the organisation, which includes modules on corruption, modern slavery, conflicts of interest, and other relevant topics
• Annual refresher courses are mandatory for onshore workers
• BW Offshore's Senior Management and Board also complete the Code e-learning
• Specialised anti-bribery and corruption training is provided to personnel in high-risk functions, such as business development, procurement, and other at-risk roles

Key content and principles:

• The Code includes modules on corruption, modern slavery, conflicts of interest, and topics including Data Breach, Managing Personal Data and Data Protection Laws, Anti-Trust/Competition, Money Laundering, Sanctions and Embargoes, Insider Trading, and Preventing Modern Slavery
• Guidelines for the giving and receiving of gifts, hospitality, and charitable donations
• Staff are required to complete an annual conflict of interest questionnaire and disclose conflicts as they arise
• Internal Audit conducts regular reviews of expense claims

Public availability:

• Anti-corruption and anti-bribery policies are available on the internal Management System
• Corporate Integrity maintains an Intranet site with programme information
• Updates and new policies are announced through intranet articles, town halls, posters, and leadership communications

Monitoring implementation:

• Internal Audit conducts regular reviews of expense claims
• The SpeakUp Channel provides personnel and external parties with a confidential platform to report potential bribery or corruption
• Reported concerns are reviewed confidentially by the Head of Corporate Integrity, and independent investigators are assigned, as necessary, to conduct fact-finding
• The Audit Committee receives regular updates from the Head of Corporate Integrity on SpeakUp statistics, including reports related to corruption or bribery, including anonymised findings of internal investigations and any recommended actions taken
• This provides transparency and senior oversight of reported incidents and their resolutions

Anti-Bribery and Corruption (ABC) Training Programme

Scope:

• 100% of functions identified as at-risk for corruption and bribery
• All new joiners complete the Code e-learning, which includes an ABC module, within their first 30 days
• Onshore staff retake the module annually
• Dedicated ABC module for higher-risk staff, including Senior Management, commercial, and procurement departments

Key actions:

• Conducting ethical labour audits
• Maintaining controls on gifts, hospitality and charitable contributions
• Providing anti-bribery and corruption training
• Conducting risk-based due diligence on third-parties
• Commitment to continuously improving processes to meet emerging challenges, with a focus on addressing both direct and indirect impacts in operations and value chain

Incidents of corruption or bribery

Confirmed incidents

In 2024, BW Offshore received 33 reports through the SpeakUp Channel. Of these, there were 5 reports related to harassment or discrimination, and none related to corruption.

Convictions and fines

In 2024, BW Offshore reported no convictions for violations of anti-corruption and anti-bribery laws, and no fines were issued for such violations.

Governance indicators (2022-2024)

Investigation and speak-up procedures

SpeakUp Channel: BW Offshore provides a third-party-hosted confidential reporting platform (SpeakUp Channel) available to both internal and external stakeholders. Reports may be submitted anonymously at the reporter's choice via web or telephone, with language support in all operating locations.

Multiple reporting channels: Personnel may also report concerns directly to line managers, Human Capital, or the Legal department.

Anti-retaliation protections: BW Offshore prohibits retaliation against anyone who raises a concern in good faith. Reports are handled confidentially and monitored by the Head of Corporate Integrity.

Investigation process: All reports to the SpeakUp Channel are reviewed by Corporate Integrity. Investigations are conducted independently by appropriate internal or external investigators based on the concern's nature. No individual implicated in an allegation participates in the investigation process. Investigations into allegations of corruption and bribery are conducted independently of the management chain involved.

Oversight: The Audit Committee receives quarterly updates from the Head of Corporate Integrity on SpeakUp statistics, including anonymised findings of internal investigations and recommended actions.

Training: All new staff must complete mandatory Code of Ethics e-learning (including anti-bribery and corruption modules) within 30 days of joining. Onshore staff retake the module annually. Specialized ABC training is provided to higher-risk personnel in Senior Management, commercial, and procurement departments. Training coverage is 100% of functions identified as at-risk for corruption and bribery.

Payment practices

BW Offshore has assessed ESRS G1-6 (Payment practices) as not material and has omitted disclosure of this requirement.

No metrics on average payment time, contractual payment terms, late payments, or prompt payment code participation are disclosed.