BW Offshore

Governance roles

Reference: pages 41-43, 108; board composition datapoints pages 42, 95; corporate governance deviations page 23.

The Board of Directors "holds overall responsibility for overseeing BW Offshore's sustainability strategy, risk management, and the governance of material sustainability-related impacts, risks, and opportunities" (page 41). The governance chart on page 41 runs Board of Directors - Audit Committee - Senior Management Team - Sustainability Committee - Sustainability Department / Finance Department / Organisation. The CEO "leads Senior Management and is responsible for executing strategic priorities and embedding sustainability and risk management into our daily operations" (page 41).

Composition (page 42): the Board "comprises five non-executive members, 80 per cent of whom are independent. Employee representation is not currently included in the Board structure." Board gender balance is 20 per cent female / 80 per cent male, unchanged since 2022 (page 95). The Corporate Governance Report records a deviation from the Norwegian Code of Practice on this point: "The composition of the Board does not meet the recommended gender guidelines of the Code" (page 23).

Committees (page 43): three Board committees - Audit Committee (sustainability reporting, double materiality assessments and sustainability-related risk management), Technical and Commercial Committee and Compensation Committee. The Audit Committee "currently comprised of two members. Both members are independent, possess over twenty-five years of industry experience" (page 108).

Expertise (page 42): "Board members bring sector-specific knowledge in environmental risk, regulatory compliance, and social governance, with individual expertise spanning emissions management, circular economy, and health, safety and environmental standards relevant to FPSO operations. External training and expert input are used to strengthen sustainability competence where needed."

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

Reference: pages 42-43; Speak Up reporting page 109.

"Governance bodies are regularly informed of sustainability matters, including targets, through structured reporting frameworks managed by the Audit Committee. The Audit Committee provides the Board with quarterly updates on sustainability-related matters" (page 42). Senior Management "tracks sustainability performance and evolving materiality through overseeing different functions and uses relevant information in strategic decision-making" (page 42).

Page 43 sets out the cadence explicitly under "Oversight over material sustainability matters" - the Board "meets at least on a quarterly basis":

• Quarterly: Health, Safety and Environment statistics; fleet-wide environmental performance; new business opportunities; financial matters; claims and litigations against the company.
• Bi-annually: corporate strategy; compliance-related topics.
• 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; internal control.

"Other topics related to material sustainability matters are discussed by the Board as required and in cooperation with management" (page 43). Separately, "Anonymised statistics for reported concerns are provided to the Audit Committee on a quarterly basis" (page 109), and the Audit Committee "conducts an annual review of internal control processes related to sustainability disclosures" (page 44).

Integration of sustainability-related performance in incentive schemes

Reference: page 43; further detail cross-referred to the Corporate Governance Report, page 29.

"BW Offshore's incentive schemes continue to embed sustainability at their core, with a strong emphasis on safety as a fundamental operational value" (page 43).

• "The Compensation Committee conducts an annual review and approval of the structure of sustainability-linked incentives, which remain directly tied to performance metrics in health, safety, environment, and quality" (page 43).
• "In the event of a serious incident, the Variable Compensation Scheme is set to zero for the relevant calendar year" (page 43).
• The Compensation Committee "Aligns executive incentives with long-term sustainability goals" (page 43).

What is not disclosed: no percentage of variable remuneration linked to sustainability or climate performance is given, and no GHG-emission-linked element is identified. The disclosure names HSEQ performance as the sustainability metric and does not quantify the weighting, so the ESRS datapoint on the share of remuneration recognised in the current period that is linked to climate considerations is not answered.

Statement on due diligence

Reference: page 44. Appendix page 118 maps "ESRS 2 GOV-4 Statement on due diligence paragraph 30" to page 44.

Page 44 carries the required mapping table, "Core elements of Due Diligence", with each element flagged as relating to people and/or environment and cross-referenced to page numbers:

The narrative adds that "Our due diligence process integrates sustainability-related considerations into governance, strategy, and operations, addressing environmental and social impacts across our value chain" (page 44).

Risk management and internal controls over sustainability reporting

Reference: page 44. This is new relative to FY2024, where the site records GOV-5 as omitted.

BW Offshore is candid that the control framework is incomplete: "While formalised internal controls specific to sustainability reporting are still under development, we continue to benchmark global best practices and aim to integrate these into our broader risk management framework" (page 44).

Risks identified: "Key risks under consideration include data completeness, estimation uncertainty, and value chain data collection challenges." Mitigations: "formal review cycles, data validation checks and enhanced internal documentation requirements. A structured risk assessment methodology and mitigation approach is being developed as part of our continuous improvement efforts" (page 44).

Integration with enterprise risk management: "Sustainability-related risks are integrated into our Enterprise Risk Management system, which is aligned with ISO 9001 and the ISM Code. These risks are assessed using the same structured methodology as other enterprise risks, and are reviewed quarterly by function heads and at least annually by Senior Management and the Board" (page 44).

Reporting to governance bodies: "The Audit Committee plays a central role in overseeing sustainability reporting. It receives regular updates on material sustainability matters and conducts an annual review of internal control processes related to sustainability disclosures" (page 44). No internal audit of the sustainability statement and no statement on the findings of control testing are disclosed.

Strategy, business model and value chain

Reference: pages 8-14, incorporated by reference into the statement (page 38: "Disclosure requirement incorporated by reference - SBM-1 page 8"). Key figures page 3.

Business model (page 8): "BW Offshore operates an asset-based, project-driven business focused on delivering floating production solutions to the offshore energy sector. Our core activities include engineering, procurement, construction, installation, owning, leasing, and operation of Floating Production Storage and Offloading (FPSO) assets."

Scale (pages 3-4): operating revenues USD 509.5 million, EBITDA USD 240.1 million, total assets USD 4,281.0 million, backlog USD 2.2 billion, 890 employees, 4 assets in operation plus 1 in lay-up, average 61,600 boe per day, commercial uptime 99.7, 41 FPSO and FSO projects delivered over 40 years.

Sector exposure (page 10): "In the reporting period, 100 per cent of BW Offshore's revenue was generated from the oil and gas sector, specifically through the operation and leasing of FPSO assets." The oil and gas value chain diagram on page 10 places BW Offshore activities in development, FPSO construction, FPSO operation, decommissioning and recycling, and redeployment.

Value chain (page 8): "Our value chain spans upstream and downstream activities... our contribution is concentrated in the development and operation phases, extending to field abandonment and FPSO redeployment or recycling."

Transition segments (page 11): "Floating Transition Solutions" covers floating desalination (through BW Elara), gas-to-power, ammonia and floating offshore wind through BW Ideol (68 per cent owned, page 53). "BW Offshore aims to add one or two transition-related business segments by 2030." A separate floating desalination value chain is mapped on page 14.

Interests and views of stakeholders

Reference: page 15, incorporated by reference into the statement (page 38).

"Stakeholder engagement is embedded in BW Offshore's strategic processes. Structured internal and external engagement captures stakeholder perspectives, including expectations related to sustainability impacts, risks, and opportunities, which are analysed and integrated into our strategy. Engagement outcomes inform our corporate strategy, risk management, double materiality assessment and related initiatives" (page 15).

The stakeholder table on page 15 names five groups with methods, purpose and outcomes:

"The 2025 strategy review included bottom-up input from employees, clients, partners, and other stakeholders. Their views informed both the reaffirmation of the FPSO strategy and the refinement of our transition ambitions" (page 15). Page 41 is cross-referred for how Senior Management, the Board and its committees are informed about stakeholder views.

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

Reference: page 50 (consolidated material IRO table), with topic-level SBM-3 at pages 60, 69, 73, 80, 86, 93, 98, 102, 108 and 113.

The consolidated table on page 50, "Material impacts, risks and opportunities", lists every material IRO by topic, marking each as negative impact, positive impact, financial opportunity or financial risk, and tagging its position in the value chain (upstream / own operations / downstream) and time horizon (short / medium / long term). 39 IRO rows are listed.

Environment (14 rows). Climate change (9): Scope 1, Scope 2 and Scope 3 emissions; energy consumption; access to and cost of capital; and four floating transition opportunities - desalination, CCS, gas-to-power and ammonia. Pollution to air and water (3): pollution of air - non-GHG; pollution of water - major hydrocarbon spills; pollution of water - planned discharge. Waste (2): waste; hazardous waste.

Social (20 rows). Health and safety (4): safety - offshore workers; safety - onshore workers; training and skills development; occupational safety incidents - acute. Working conditions (6): professional development; talent attraction and retention; organisational culture; collective bargaining; social protections; offshore work-life balance and well-being. Fair treatment of workers (3): gender pay gaps; unequal treatment and unconscious bias; workplace violence and harassment. Workers in the value chain (4): working conditions in the value chain; workplace violence and harassment; child labour in value chain; forced labour in value chain. Local communities (3): local community impacts as result of accidents; indigenous rights; indigenous communities' activism.

Governance (5 rows). Business conduct (3): treatment of Speak Up reporters; supplier payment terms and practices; corruption and bribery. Digital and cyber security, an entity-specific topic (2): worker privacy; cyber security breaches.

Strategic interaction is drawn out in the topical chapters - for example "Climate change also presents a financial risk for our company, particularly in relation to access to and cost of capital" (page 60).

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

Reference: pages 45-47.

Scope. "The DMA covers the same scope of consolidation as our financial statements, including subsidiaries and joint ventures. However, when assessing adverse impacts, the focus has been placed on BW Offshore's core FPSO business" (page 45). In 2025 the assessment was narrowed: "we updated the DMA to align with our current context, focusing solely on our current operating activities, excluding construction projects" (page 45). Floating wind subsidiaries "are included in scope but are not prioritised when assessing impacts, as they are not yet in full operation."

Method (page 47). "Impact materiality has been assessed based on severity and likelihood of occurrence. Severity has been determined using scale, scope, and irremediability for negative impacts, and scale and scope for positive impacts. For human rights-related impacts, severity has been prioritised over likelihood." "Financial materiality has been assessed based on financial magnitude and likelihood of occurrence, aligned with corporate risk management framework where applicable." IROs were "identified and assessed on a detailed sub-sub-topic level and then consolidated into broader topics". Where only some IROs within a topic were material, "the average score of the material IROs determined the topic's level of materiality".

Process and governance (pages 46-47). Five stages: initial assessment, internal and external stakeholder engagement, calibration of assessment based on stakeholder engagement, validation of findings by Senior Management, approval by Audit Committee. "The 2025 DMA process has been led by the Sustainability team, with support from internal subject matter experts... Final validation was conducted by Senior Management, and the Audit Committee has reviewed and approved the results."

Non-material topics explained (page 47). Water: seawater use for FPSO cooling and discharge of heated water, "local, temporary and well-regulated". Biodiversity: habitat disturbance during installation, noise and pollution, "limited in scale and scope".

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

Reference: page 37 (General Disclosures index), pages 49, 59, 68, 72, 79, 85, 92, 97, 101, 107 and 112 (per-chapter indexes), pages 118-123 (EU-legislation datapoint appendix). This is new relative to FY2024, where the site records IRO-2 as omitted.

The content index is distributed, not consolidated. Each chapter opens with a "Material disclosure requirements" table giving the DR code, its title and a page number, plus a second block for "Material disclosure requirements included in other chapters". Page 37 covers ESRS 2 (BP-1, BP-2 p.38; GOV-1, GOV-2 p.41; GOV-3 p.43; GOV-4, GOV-5 p.44; IRO-1 p.45; IRO-2 p.49; SBM-3 p.50; SBM-1 p.8; SBM-2 p.15). The topical indexes are: E1 page 59, E2 page 68, E5 page 72, S1 pages 79, 85 and 92, S2 page 97, S3 page 101, G1 page 107, and the entity-specific cyber security topic page 112 (MDR-P, MDR-A, MDR-T, MDR-M).

Appendix (pages 118-123) is headed "List of Datapoints that Derive from Other EU Legislation - IRO-2 - Disclosure Requirements in ESRS covered by the undertaking's sustainability statement" and gives, for each SFDR / Pillar 3 / Benchmark Regulation / EU Climate Law datapoint, either a page number or one of "Not material", "Excluded due to extended phase-in period" or "N/A".

Materiality overview (page 49) is a double-materiality matrix plus an ESRS reference legend, with the footnote "S4 Consumers and end-users: assessed as not relevant due to the nature and scope of our operations."

Caveat for readers. There is no single table listing all disclosure requirements covered; establishing coverage requires reading eleven chapter indexes together with the appendix. Omitted disclosure requirements are not listed as such, so absence from the chapter indexes is the only signal that a DR was not reported.

Transition plan for climate change mitigation

Reference: pages 62-64. Appendix page 118 maps "ESRS E1-1 Transition plan to reach climate neutrality by 2050 paragraph 14" to page 62.

BW Offshore states plainly that it has no transition plan: "While BW Offshore does not yet have a formal transition plan in place due to the nature of our core business, our scenario modelling continues to inform our planning by assessing the financial implications of climate transition pathways, such as the impact on EBITDA under different energy mix projections" (page 63).

What is disclosed in its place, under "Transition Planning" (page 62), is climate scenario analysis and a set of operational decarbonisation measures:

• Decarbonisation levers named on page 64: "operational optimisation, investment in cleaner technologies, and collaboration with stakeholders to promote emission reduction technologies", Best Available Techniques applied "during asset design and upgrades", and preventative maintenance plus rapid leak repair for hydrofluorocarbons in closed gas systems.
• ABATE class notation (DNV), "which evaluates installations across key emission sources, such as power generation, flaring, venting, leakages, and carbon capture, to identify and implement greenhouse gas abatement measures" and "requires a robust energy and emissions management system aligned with ISO 50001 standards". BW Catcher achieved ABATE certification in November 2025; BW Opal is being pursued (page 64).
• Strategic ambition "to mature one or two transition-related business segments by 2030" (page 64).

Not disclosed: no GHG reduction target - "While we do not have clear emissions reduction targets in place, we do have targets related to ABATE and to enhance availability and quality of data" (page 64); no CapEx or OpEx allocated to the actions; no locked-in emissions assessment (the word "locked" does not appear in the report); no statement of approval of a plan by the administrative, management or supervisory bodies. Appendix page 119 marks "ESRS E1-1 Undertakings excluded from Paris-aligned Benchmarks paragraph 16 (g)" as "Not material".

Identification of climate-related risks and scenario analysis

Back-filled from the E1 Transition Planning subsection and ESRS 2 IRO-1, where this content is disclosed in the FY2025 report (pages 47, 62-63). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Classification of risks as physical or transition is explicit (page 63):

• "Physical risks are identified using high-emission climate scenarios (e.g., NGFS RCP 8.5, IPCC AR6) which assesses exposure to acute (e.g., cyclones, heatwaves, coastal flooding) and chronic (e.g., rising sea levels, ocean acidification, temperature variability) climate hazards across FPSO operations and construction yards."
• "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."

Scenarios used (page 62): "scenario-based stress testing of our core business under multiple climate scenarios, including IEA Net Zero, IEA STEPS, NGFS, and DNV Energy Transition Outlook. The IEA Net Zero scenario is used to assess the potential impact on BW Offshore, when aligning with the Paris Agreement. DNV's Energy Transition Outlook and the NGFS Orderly scenarios are used as base case scenarios, representing what we believe is the most likely way forward."

Scope and horizons (pages 47, 62): the analysis covers "FPSO operations and construction yards", runs over "short-, medium-, and long-term horizons", and assesses "implications for asset lifespans, capital costs, and financial performance, including potential impacts on EBITDA and stranded assets". Time horizons are "aligned with our internal risk management assessment... and in accordance with IFRS (related to short-term)", and physical risk "has been considered both on a global and local basis" (page 47).

Assumptions and update (page 63): "In the past year, updated scenario forecasts, such as the DNV Energy Transition Outlook... are aligning closely with IEA STEPS. This indicates less transition risk for BW Offshore in the next decade, but higher physical climate risk."

Gap: no global average temperature projection is stated for any scenario, so ESRS E1-2 paragraph 17(a)(iii) is not answered.

Resilience in relation to climate change

Back-filled from the E1 Transition Planning subsection, which carries the company's resilience statement in the FY2025 report (pages 62-63). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

The analysis and its result (page 62): "BW Offshore assesses the resilience of our strategy and business model through climate scenario analysis, using external frameworks... The scenarios cover a range of climate pathways and inform our evaluation of physical and transition risks over short-, medium-, and long-term horizons."

The conclusion is stated with a qualification: "Our business remains viable across multiple scenarios, but maintaining competitiveness will likely require proactive adjustments. These include diversifying into low-carbon energy production, electrifying FPSOs, and investing in carbon capture and offshore floating wind" (page 62).

Scenario-specific implications (page 63): "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, floating wind, and electrification of FPSO operations."

Uncertainty (page 62): "We recognise that our resilience analysis involves uncertainties, particularly regarding future policy developments, technology adoption timelines, and the severity of climate-related risks. To address these uncertainties, we apply a range of climate scenarios."

Capacity to adapt (pages 62-64): "Scenario analysis supports capital allocation and investment planning, helping us balance risk exposure with emerging opportunities" (page 62). "These considerations are integrated into our strategic planning and investment decisions, reflected in our approach to diversify into low-carbon solutions" (page 63). The disclosed adaptive levers are the four floating transition segments and the ambition "to mature one or two transition-related business segments by 2030" (page 64).

Physical exposure acknowledged (page 62): "FPSO operations could be impacted by changing offshore weather patterns, while construction yards and supply chains may be affected by location-specific conditions such as heatwaves and flooding."

No quantified financial resilience analysis, and no asset-level adaptation plan, is disclosed.

Policies related to climate change mitigation and adaptation

Reference: page 61 (listed in the E1 chapter index, page 59, as E1-2 at page 61).

BW Offshore does not operate a standalone climate policy. Climate is covered by the Environmental Policy: "The Environmental Policy applies globally and is overseen by our CEO. It is available to all personnel through our Management System and is displayed in offices and onboard all our FPSOs. The policy outlines commitments to improving environmental performance, minimising impacts, and managing risks responsibly" (page 61).

Policy content (page 61): "It further emphasises the importance of stakeholder collaboration, applying Best Available Techniques, and identifying opportunities for continuous improvement in environmental management to limit or reduce emissions. In addition, the policy commits us to promote environmental awareness among employees, monitoring performance through established controls and practices, and regularly reporting on environmental matters to support transparency and continuous learning."

Supporting instruments (page 61):

• Environmental Reporting Guideline - "defines roles and responsibilities for environmental data management, facilitates timely and transparent data collection, and outlines methodologies for calculations and estimations... establishes clear processes for managing data quality and integrity".
• ISO 14001:2015 certified Environmental Management System, "integrated through the Operational Integrity Management Standard. This integration enables a holistic approach to risk management, and that environmental considerations are embedded into all aspects of our operations."

Reader caveat: the policy is an environmental policy covering emissions, pollution and waste together. No separate climate change adaptation policy is identified, and the policy is not linked to a stated mitigation target.

Actions and resources in relation to climate change policies

Reference: pages 64-65.

Decarbonisation measures (page 64): "We have measures in place to manage and mitigate our environmental impact responsibly. This includes adoption of various decarbonisation levers to address our environmental footprint, including operational optimisation, investment in cleaner technologies, and collaboration with stakeholders to promote emission reduction technologies."

• Hydrofluorocarbons: "we have preventative maintenance routines and processes in place for rapid repairs of leaks in closed gas systems" - material because HFCs "have a global warming potential more than 100 times greater than CO2" (page 60).
• Design stage: "we aim to incorporate emission reduction and energy efficiency measures in the earliest stages of asset development by applying Best Available Techniques during asset design and upgrades."
• ABATE notation: "BW Offshore successfully achieved ABATE certification for BW Catcher in November 2025... Building on this achievement, we are actively pursuing ABATE notation for BW Opal."
• Approvals in Principle for transition concepts, which "may play a role in strengthening BW Offshore's access to capital by signalling credibility and readiness to investors and financial institutions."

BW Opal case study (page 65): "BW Opal is engineered to emit around 15 per cent less greenhouse gases compared to traditional FPSO systems, corresponding to an estimated to 2.3 million tonnes less CO2 emissions over its operating life. This lower emissions profile is enabled by advanced design features such as a closed flare system that minimises open flaring, a hydrocarbon cargo tank blanket system with vapour recovery to reduce VOC emissions, and Combined Cycle Gas Turbine system with waste heat recovery that can cut energy consumption up to 66 per cent compared to industry standards." A thermal oxidiser and dual vapour recovery units are also installed.

Resources: no CapEx or OpEx amounts are attached to any of these actions, and no climate capital allocation is identified in the EU Taxonomy disclosure, where "The CAPEX is mainly related to investments in BW Opal for the Barossa project and is therefore non-eligible for the EU Taxonomy" (page 54).

Targets related to climate change mitigation and adaptation

Reference: page 64. Appendix page 119 maps "ESRS E1-4 GHG emission reduction targets paragraph 34" to page 64.

There is no GHG reduction target. "While we do not have clear emissions reduction targets in place, we do have targets related to ABATE and to enhance availability and quality of data" (page 64).

The two climate targets disclosed are process targets, presented in the 2026 Targets table on page 64:

The Scope 3 mapping target follows an acknowledged prior-period error: "In the 2024 Annual Report, we stated that all relevant scope 3 categories had been included in our emission inventory. Following further review and methodological improvements during 2025, we have identified that some relevant categories were not fully captured. This year, we have enhanced the granularity of our scope 3 reporting and are progressing toward complete mapping and reporting of all relevant categories for 2026" (page 39).

What ESRS E1-4 asks for and does not get: no base year, no 2030 or 2050 absolute or intensity reduction percentage, no scope-by-scope target, no decarbonisation-lever contribution, and no science-based validation. The company's own framing is that its core business makes a formal plan premature (page 63). Adaptation targets are likewise absent; the pollution chapter records the same position for its domain - "We currently do not have any measurable targets related to reducing pollution" (page 70).

Energy consumption and mix

Reference: page 67; accounting policy page 77. Appendix page 119 maps the E1-5 paragraph 37, paragraph 38 and paragraphs 40-43 datapoints to page 67.

"BW Offshore operates exclusively within high climate impact sectors, and as such we report energy intensity as the ratio of total energy consumption to total net revenue" (page 77).

Mix: fossil share 99.15 per cent (2024: 90.61), renewables 0.76 per cent (0.75), nuclear 0.09 per cent (8.64).

Intensity: energy consumption from activities in high climate impact sectors 150.48 MWh per MUSD revenue (2024: 11.25) - a thirteen-fold rise driven by BW Opal's mobilisation and commissioning.

Offshore energy consumption is reported separately at 4,505.30 TJ (2024: 4,273.39) and flared gas at 6,551.11 mmscf (899.60) (page 66). Fuel-based energy consumption "covers crude oil and petroleum products used by FPSOs under construction, FPSOs in lay-up and third-party towing vessels, including heavy fuel oil, marine diesel oil and marine gas oil. The renewable/fossil split for purchased electricity is based on national grid averages" (page 77).

Gross Scopes 1, 2, 3 and total GHG emissions

Reference: page 66; accounting policies pages 76-77. Appendix page 119 maps E1-6 paragraph 44 and paragraphs 53-55 to page 66.

Intensities (page 66): 26.30 kg CO2e per boe produced (2024: 13.32); Scope 1 and 2 10.19 tCO2e per MUSD revenue; Scope 3 1,481.19; total 1,491.38.

Scope 3 breakdown (page 66): FPSOs under contract 746.35, crew rotation travel 3.37, corporate travel 3.42, fuel consumption from yard activities 0.20, WTT emissions 1.25. Categories reported are 3.2 capital goods, 3.3 fuel- and energy-related activities, 3.6 business travel, 3.7 employee commuting and 3.13 downstream leased assets (pages 76-77). "Approximately 90 per cent of our scope 3 emissions are calculated using primary data" (page 77).

Drivers (page 66): Scope 1 rose because "the BW Opal mobilised from the Singapore shipyard to its on-field location in Australia, consuming 1,480 tonnes of Low Sulphur Marine Gas Oil across three deep-sea tug vessels". Scope 2 fell 75 per cent "as yard construction activities were completed in May 2025". Scope 3 "increased in 2025 due to BW Opal commissioning activities and expanded FPSO service operations".

Boundary and limitation (page 76): "Emissions indicators follow the GHG Protocol's operational control approach. Assets not currently under contract are included in scope 1, while assets on service contracts and client-owned assets operated by BW Offshore are included in scope 3." "We have not yet conducted a full mapping of all relevant scope 3 categories." Biogenic CO2 is not material and no Energy Attribute Certificates are purchased.

Policies related to pollution

Reference: page 69 (listed in the E2 chapter index, page 68, as E2-1 at page 69).

"Our Environmental Policy is embedded within our ISO 14001 certified Environmental Management System and is implemented through established processes and procedures. Pollution management forms a core part of this policy and is operationalized through our Environmental Management System" (page 69). The policy "outlines commitments to minimising pollution to air and water and managing our risks responsibly. Furthermore, the policy emphasises the importance of stakeholder collaboration to reduce emissions and discharges, and identifying opportunities for continuous improvement in pollution prevention and environmental management" (page 69).

Operating procedures (page 69):

• "Incident reporting, spill management, and emergency response are governed by a combination of overarching procedures and asset-specific plans. We apply a company-wide Incident Reporting Procedure that outlines responsibilities, classification, and notification requirements for incidents, supported by a digital system for registration and follow-up."
• "each FPSO maintains a vessel-specific Shipboard Oil Pollution Emergency Plan, developed in accordance with MARPOL and International Convention on Oil Pollution Preparedness, Response and Co-operation conventions. These plans, which are approved by DNV, define immediate actions, reporting protocols, and coordination mechanisms with authorities."

Scope of the policy in practice. The material pollution sub-topics are air pollution (non-GHG) and water pollution, the latter split into major hydrocarbon spills and planned discharge (page 50). Produced water is identified as the main planned discharge and "contains hydrocarbons, heavy metals, naturally occurring radioactive materials, and residual chemicals" (page 69). No substances-of-concern or microplastics policy is disclosed, consistent with those sub-topics not being material.

Actions and resources related to pollution

Reference: page 70.

Air (page 70): "In 2025, we advanced several initiatives to reduce non-GHG air pollutants, particularly on BW Catcher and BW Opal. Further, BW Catcher successfully achieved ABATE class notification in November, reflecting the vessel's original design features that incorporate effective emission management measures. Similarly, BW Opal's design integrates advanced emission control technologies, including vapor recovery systems and thermal oxidisers, which further reduce the release of non-GHG pollutants." "Operational assets now use app-based analytics to benchmark and monitor air quality, and to support proactive emissions management."

Water (page 70): "Water discharges are monitored using onboard oil-in-water analysers. If the oil levels exceed limits, the discharges are redirected to slop tanks for further treatment until permissible discharge limits are met." "BW Catcher is designed to reinject produced water as part of its standard operations. Produced water reinjection is a key environmental management measure to aid production from the field, minimising discharges to sea."

Spill prevention and response (page 70): "advanced engineering, strict maintenance routines, robust operational controls and continual emergency preparedness". Procedural controls include "permit-to-work systems, regular hazard identification, and operability studies". "All FPSOs are equipped with double-hulled storage tanks, and cathodic protection systems to minimise material wear and prevent leaks." BW Opal adds "advanced fire and gas detection systems, automated emergency shutdown systems, and spill containment barriers", with fire suppression and water deluge systems. "Our emergency response framework is structured through tiered response teams offshore and at each office", supported by "comprehensive oil spill response plans, which include agreements with external and regional response organisations" and, "To prevent and respond to pollution incidents, we conduct annual spill drills and emergency preparedness exercises."

"In 2025, technical reviews led to improved monitoring and review of corrosion management systems" (page 70). No monetary resources are attached to these actions.

Targets related to pollution

Reference: page 70.

There are no pollution targets, and the company says so in the terms ESRS permits under the minimum disclosure requirement for targets:

"We currently do not have any measurable targets related to reducing pollution, however, we are managing pollution to air and water through operational controls and continuous improvement initiatives, aligned with applicable international standards such as MARPOL and the World Bank guidelines. Stakeholder engagement, including input from operational teams and external advisors, supports ongoing evaluation of future targets" (page 70).

Effectiveness is tracked instead against external limits rather than internal targets. Produced water discharges are measured against "the World Bank Group guideline limit of 30 ppm oil in water content", with a fleet-wide average of 10.9 ppm in 2025 (page 71), and overboard spills are measured against "the 100-litre MARPOL threshold for significant spills" (page 71). Asset-level performance is benchmarked through the DNV ABATE notation, which BW Catcher obtained in November 2025 (page 70).

The position mirrors the company's stance on climate targets - "we do not have clear emissions reduction targets in place" (page 64) - and on waste - "we do not have specific targets to achieve a defined percentage reduction in waste" (page 73).

Pollution of air, water and soil

Reference: page 71. Appendix page 120 maps "ESRS E2-4 Amount of each pollutant listed in Annex II of the E-PRTR Regulation... paragraph 28" to page 71.

Scope limitation, stated by the company (page 71): "BW Offshore does not track all pollutants listed in Annex II of Regulation (EC) No 166/2006. The table discloses all identified pollutants that exceed the threshold value specified in the Annex."

Narrative (page 71): "Non-GHG emissions remained largely stable year-on-year... while the outlier was a rise in nmVOC emissions, driven predominantly by BW Opal's commissioning activities requiring significant auxiliary diesel combustion and increased fugitive venting during the Barossa field startup." Produced water re-injection represented "approximately 85 per cent of total produced water volumes", and discharges "remained in compliance with the World Bank Group guideline limit of 30 ppm".

"No major pollution incidents were recorded in 2025." The 81 litres comprised "In July, a 20 litre diesel overflow... on BW Opal" and "In September, a 61 litre crude spray from hawser hydraulic failure... on BW Catcher". "Each case triggered root cause analysis, corrective actions, and follow-up verification to prevent recurrence." No soil pollution is reported, consistent with offshore operations.

Policies related to resource use and circular economy

Reference: page 73 (listed in the E5 "Waste" chapter index, page 72, as E5-1 at page 73).

"Waste management is covered in our Environmental Policy and is operationalised through our Environmental Management System and our Environmental Reporting Guideline" (page 73). "The Environmental Policy outlines our commitment to minimising environmental impacts, including reducing waste materials and preventing release of hazardous substances during ship recycling" (page 73).

Asset-level instruments (page 73): "each of our FPSOs has a specific Waste Management Plan, defining procedures for waste segregation, tracking and disposal in accordance with MARPOL Annex V and ISO 14001 standards."

Scope of control stated by the company (page 73): "On our FPSOs, we maintain direct control over waste generation and management until it is transferred over to licensed disposal contractors... Although the final disposal of waste depends on third-party handlers, we retain indirect control by enforcing supplier and yard compliance with our waste management policies." "During project execution, waste generated at shipyards is managed by contracted yards, which are audited by BW Offshore to verify collection, processing, storage, and discharge."

Why the topic is material (page 73): "The waste generated by our organisation includes packaging materials for new equipment, consumables such as flushing chemicals, obsolete equipment designated for scrap, and general waste." Hazardous waste "including chemicals, oily water, paints, coatings, and solvents, can have significant negative impacts if not handled properly, as it may be toxic to marine life and ecological systems."

The E5 topic is material through its waste sub-topic only; resource inflows are not addressed by the policy.

Actions and resources related to resource use and circular economy

Reference: pages 73-74.

Waste management actions (page 73): "We have implemented comprehensive waste management plans across our assets, offices, and projects. These plans outline procedures for segregation, tracking, and disposal of waste in alignment with MARPOL Annex V... Furthermore, we have established internal controls including processes for regular audits." "Across our assets, BW Offshore promotes responsible waste management through source-level segregation and enforcing strict compliance with established garbage protocols. These efforts are supported by dedicated facilities, structured disposal systems, and continuous engagement."

Targeted measures (page 73): "On BW Opal, additional measures have been introduced due to the significant contractor activity and high volumes of consumables, making it a priority area for waste reduction. We require contractors and project participants to minimise single-use plastics and packaging waste, as these materials are particularly challenging to manage offshore."

Ship recycling (page 74): "In 2025, this was demonstrated through the completion of the recycling of FPSO Petroleo Nautipa, conducted by approved recycling facilities and in accordance with the Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships. A third-party representative and a BW Offshore representative, supported by regular oversight visits from BW Offshore managers, monitored the process on-site for compliance with environmental and safety regulations and adherence to the approved recycling plan. Our recycling procedure is designed to maximise material recovery and minimise hazardous waste generation."

Effectiveness caveat, stated by the company (page 73): "While these initiatives are expected to reduce overall waste generation, their full impact on total waste figures is still being assessed and will be reported as data becomes available." No monetary resources are attached to the actions.

Targets related to resource use and circular economy

Reference: page 73.

There is no quantified waste or circularity target, and the company states this under the minimum disclosure requirement for targets:

"While we do not have specific targets to achieve a defined percentage reduction in waste, we have implemented several initiatives aimed at reducing overall waste generation and minimising impact from our activities" (page 73).

Effectiveness is tracked through metrics rather than targets: "We monitor performance regularly using both qualitative and quantitative waste metrics to track progress and identify improvement areas" (page 73), reported as the waste indicator tables on page 75. The company also records the limit of that tracking - "their full impact on total waste figures is still being assessed and will be reported as data becomes available" (page 73).

Compliance benchmarks stand in for internal targets: MARPOL Annex V and ISO 14001 for waste handling (page 73), and the Hong Kong International Convention for ship recycling (page 74). The only quantified movement disclosed for 2025 is outturn rather than target - "BW Offshore reduced total waste generation by 40 per cent compared to 2024" and "achieved a ~35 per cent diversion rate" (page 75).

The position is consistent across the environmental chapters: no GHG reduction target (page 64) and no pollution target (page 70).

Resource outflows

Reference: page 75; accounting policy page 77. Appendix page 121 maps "ESRS E5-5 Non-recycled waste paragraph 37 (d)" and "ESRS E5-5 Hazardous waste and radioactive waste paragraph 39" to page 75.

BW Offshore answers E5-5 through its waste limb. The resource outflow of the business is the asset itself at end of life, handled through ship recycling rather than through products.

"In 2025, BW Offshore reduced total waste generation by 40 per cent compared to 2024, driven by completion of yard construction work, operational efficiencies and the absence of major decommissioning activities. Total waste diverted from disposal improved year-on-year as we in 2025 achieved a ~35 per cent diversion rate with non-hazardous recycling up 16 per cent and hazardous waste recovery increasing due to enhanced offshore oil and sludge processing" (page 75).

End-of-life outflow (page 74): the recycling of FPSO Petroleo Nautipa completed in 2025 at approved facilities under the Hong Kong Convention, with a procedure "designed to maximise material recovery and minimise hazardous waste generation".

Not disclosed: the products-and-materials limb of E5-5 - expected durability, reusability, repairability, recyclability and recycled content of products - is not addressed. BW Offshore leases and operates FPSOs rather than selling products, and the report does not restate that limb as a nil return. Reporting boundary excludes office waste (page 77).

Waste

Reference: page 75 (waste indicator tables); accounting policy page 77; prior-period restatement pages 38-39.

Waste diverted from disposal, tonnes:

Waste directed to disposal, tonnes:

"Disposal volumes decreased significantly from 2024. This includes a 90 per cent reduction in hazardous waste disposed at landfills... Furthermore, non-hazardous incineration was 377.5 tonnes (previously 0 tonnes), reflecting increased regional waste-to-energy solutions" (page 75).

Boundary (page 77): "We report waste for all operating assets, as well as yard activities under our operational control. Waste generated in offices is not included. Onboard FPSOs, waste is segregated and logged daily. Skip weights and contents are recorded before back-loading. Third-party waste handlers contracted by BW Offshore or our partners provide monthly reports by treatment route."

Prior-period error corrected (page 38): "In the 2024 Sustainability Statement, historical waste data for 2023 and 2022 was incorrectly presented", and one 2024 line item, "Hazardous waste diverted due to other recovery operations", was excluded. "Updated historical data has been fully corrected and restated on page 75."

Policies related to own workforce

Reference: pages 80, 86, 93, 99. Appendix page 121 maps S1-1 human rights policy commitments (paragraph 20) to page 99, ILO due diligence policies (paragraph 21) to page 86, and the workplace accident prevention policy (paragraph 23) to page 80; "processes and measures for preventing trafficking in human beings' paragraph 22" is marked "Not material".

Health and safety (page 80): "BW Offshore has implemented two key policies to manage health, safety and wellbeing matters of our personnel." The Safety First Policy "defines a set of shared commitments that guides how safety is embedded into daily operations", and the Stop Work Policy "provides all personnel with permission and responsibility to stop any action they think is unsafe". Both "apply across our business activities and to all employees and contractors, and are endorsed by the CEO, who is ultimately accountable for policy implementation", and are operationalised through the Operational Integrity Management Standard. The Management System is "certified under the ISM Code, ISO 9001, ISO 14001 and ISO 45001" (page 81).

Working conditions (page 86): the framework comprises the Code of Ethics and Business Conduct, the Human Rights and Decent Working Conditions Policy ("Implementation of these policies is overseen by the Head of Corporate Integrity"), the People and Culture Policy (implementation overseen by the People and Culture function), the Occupational Health Management Standard ("requirements for risk assessments, health surveillance, and fitness-for-work evaluations") and the Mental Health and Wellness Guideline. "The UN Guiding Principles on Business and Human Rights, the ILO Declaration on Fundamental Principles and Rights at Work, and the OECD Guidelines for Multinational Enterprises inform BW Offshore's approach to human rights and fair employment."

Fair treatment (page 93): policies "prohibit all forms of unlawful discrimination, including but not limited to race, social or economic status, age, sex, gender identity, sexual orientation, marital or parental status, religion, political beliefs, and disability." The Diversity, Equity and Inclusion Statement was "updated and signed by the Chief Executive Officer" in 2025, "reinforcing leadership accountability". The Human Rights and Decent Working Conditions Policy "prohibits forced labour, child labour, modern slavery, and human trafficking" (page 99).

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

Reference: page 87, with safety committees at page 81 and the stakeholder table at page 15.

"We gather 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. Regular culture assessments provide valuable insights into the current organisational climate and help identify areas for improvement" (page 87).

Formal channels (page 87): "While we do not have an established Global Framework Agreement, we have a collective bargaining agreement in place for Australia, and maintain strong collaboration with unions, as well as structured engagement with workers' representatives through Working Environment Committees and Offshore Safety Committees. These committees meet quarterly and serve as formal channels for dialogue and collaboration on matters related to human and labour rights, workplace safety, and employee development."

At asset level, "all operating offshore assets have a safety committee which meets monthly to bring together worker representatives and management to discuss occupational health and safety topics" (page 81). Safety leadership visits "connect senior leaders with employees across different levels of the organisation" (page 81).

Grievance route (page 87): "Employees and other stakeholders can report breaches of law or corporate policies, including human or labour rights violations, through the confidential Speak Up Channel."

Effectiveness (page 87): "We regularly assess the effectiveness of our workforce engagement through internal company surveys and track the completion rate of performance dialogues using internal systems." The biannual Culture Survey was conducted in 2025.

No senior executive is named as accountable for workforce engagement, and no perspective of particularly vulnerable workforce groups is separately described.

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

Reference: page 109 (cross-referred from the working conditions chapter index, page 85). Appendix page 121 maps "ESRS S1-3 grievance/complaints handling mechanisms paragraph 32 (c)" to page 109.

Channels (page 109): "BW Offshore provides multiple methods for reporting concerns about unethical or unlawful behaviour or breaches of company policies. The Speak Up Channel, one reporting option, is a third-party hosted platform available to both internal and external stakeholders where reporters may submit concerns anonymously if desired." "In addition to the Speak Up Channel, staff may report concerns directly to line managers, People & Culture or Legal departments, the Head of Corporate Integrity, or through a dedicated email address."

2025 change (page 109): "In November 2025, BW Offshore enhanced the Speak Up Channel with a mobile application and voice-recorded reporting, which improve accessibility for all stakeholders."

Handling (page 109): "Each concern is reviewed independently and objectively, in accordance with applicable laws and recognised best practices, including fair hearing principles... Investigations are carried out independently of any individuals or management chains implicated in the reported concern. Anonymised statistics for reported concerns are provided to the Audit Committee on a quarterly basis." "The Head of Corporate Integrity assigns investigators based on the nature of the concern and relevant expertise, and external experts such as forensic accountants or legal professionals may be engaged when needed. Reporters receive updates throughout the review process and at its conclusion."

Non-retaliation (page 109): "BW Offshore prohibits retaliation against anyone who raises a concern in good faith or participates in a review process, which we reinforce through townhalls and via other internal communications. As with any other concern, allegations of retaliation are investigated independently and monitored by the Head of Corporate Integrity, with oversight by the Audit Committee."

Remediation (page 109): "If BW Offshore were to identify that we had caused or contributed to an adverse impact, we would initiate a remediation process... We would assess effectiveness of remedial action through follow-up engagement, when possible." No figure is given for workforce awareness of, or trust in, the channel.

Taking action on material impacts on own workforce

Reference: pages 81-82 (health and safety), 87-88 (working conditions), 93-94 (fair treatment).

Health and safety (pages 81-82). Four systems were introduced or extended in 2025:

• A digital Control of Work system, "a structured framework that governs how work is planned, authorised, and executed... has been successfully deployed on two operating assets during 2025. Full implementation across all assets is planned for 2026."
• A digital barrier management tool, integrated with Control of Work, providing "real time visibility of barrier health and performance... The new tool has been successfully implemented on one operating asset in 2025, with full deployment across all assets planned for 2026."
• An Integrated Risk Management project "to consolidate risk data from multiple sources, standardise assessment, and enable real time monitoring", scheduled for full implementation in 2026.
• A Competence Management System, "a digital platform that centralises competency requirements, tracks individual qualifications, and supports targeted development plans", targeted for completion in 2026.

Supporting measures: mandatory onboarding sessions and e-learning, unit-specific inductions, major accident awareness training conducted across all worksites since 2024, a safety observation card system reviewed by managers, and the We LEAD Recognition Programme - the fourth We LEAD Day was held in October 2025 on the theme "Simplification" (page 82).

Working conditions (pages 87-88). The Human Capital function "was strategically restructured and renamed People & Culture"; a new performance management framework was launched; Wellbeing Month ran in October; "BW Offshore has implemented a new Employee Assistance Programme vendor, which offers 24/7 support in 22 languages"; and MentorMatch, a group-wide mentoring programme with peer and reverse mentoring, was launched alongside the Young Talent Programme and the Explorer and Voyager leadership programmes.

Fair treatment (pages 93-94). "To support fair pay and living wages, we review employee wages, pay scales, and union agreements annually, applying a minimum living wage for direct hires in each location". A Job Grading System and a Leadership Framework are in development for 2026, and partnerships continue with POWERS and United Women Singapore.

Targets related to own workforce

Reference: page 82 (health and safety), 94 (fair treatment); framing at page 42.

"In 2025, BW Offshore has set measurable, outcome-oriented or timebound targets related to certain key sustainability-areas, which are described throughout the report in relevant chapters" (page 42). Two of the three own-workforce chapters carry a target table; the working conditions chapter does not.

Health and safety 2026 targets (page 82):

Fair treatment 2026 targets (page 94):

Effectiveness tracking in the absence of targets. The company commits to "zero harm" (page 81) but sets no quantified injury-rate target. Working conditions effectiveness is tracked rather than targeted: "We regularly assess the effectiveness of our workforce engagement through internal company surveys and track the completion rate of performance dialogues" (page 87), and the new Leadership Framework's effectiveness "will be monitored through annual employee engagement surveys" (page 94). No diversity or gender-representation target is disclosed, and none of the targets was set with workforce involvement that the report describes.

Characteristics of the undertaking's employees

Reference: pages 89-90; accounting policy page 104.

Headcount at year end: 890 (2024: 1,128; 2023: 1,189; 2022: 1,733) (page 95).

By contract type and gender (page 89):

2024 comparatives: onshore 620 (487 permanent, 133 temporary), offshore 508 (453 permanent, 55 temporary). "Non-guaranteed hours employees" are reported as "nr" throughout; the accounting policy explains they "constitute less than 1 per cent of our workforce and are not reported on separately" (page 104).

By region (page 89): onshore - Africa 5, Americas 19, APAC 278, EMEA 172; offshore - Americas 119, APAC 127, EMEA 156, Global 14. "Employees classified as 'Global' are typically offshore roving employees supporting the entire fleet and thus have no fixed work location" (page 104).

By country (page 90): Singapore 238, UK 195, Australia 167, USA 135, Norway 126, Gabon 5, Brazil 3, UAE 3, France 2, Netherlands 2, Global 14.

Turnover (page 90): onshore leavers 122, rate 29.02 per cent (2024: 12.49); offshore leavers 138, rate 33.41 per cent (2024: 9.83). "The 2025 turnover reflects the handover of BW Adolo operations to BW Energy and the global right sizing process linked to the completion of yard activities for BW Opal and our new strategic direction... When excluding the impact of these processes, underlying turnover for 2025 was 8.33 per cent onshore and 7.5 per cent offshore."

Boundary (page 104): "Employees refer to direct hires (permanent and temporary full- and part-time staff), and consultants (whose work is directly controlled by BW Offshore) working at yards, in offices and offshore."

Characteristics of non-employee workers

Reference: page 89 (the working conditions chapter index, page 85, lists "S1-7 Characteristics of non-employee workers in the undertaking's own workforce" at page 89); accounting policy page 104.

BW Offshore lists S1-7 as a material disclosure requirement, but what it presents is a boundary definition and a partial nil return rather than a headcount breakdown.

Boundary (page 104): "Employees refer to direct hires (permanent and temporary full- and part-time staff), and consultants (whose work is directly controlled by BW Offshore) working at yards, in offices and offshore. Contractors refer to anyone employed by contractors or sub-contractors (where BW Offshore does not have direct control)." "Workforce composition is calculated as the total number of employees at year end, and includes all permanent and temporary employees (direct hire and third party consultants)."

So third-party consultants under BW Offshore's direction are folded into the employee tables on page 89 rather than reported separately, while contractors outside its control are treated as value chain workers under S2.

Non-guaranteed hours (pages 89, 104): every "Non-guaranteed hours employees" cell in the workforce tables reads "nr", explained as "Non-guaranteed hours employees constitute less than 1 per cent of our workforce and are not reported on separately".

What is missing. ESRS S1-7 asks for the number of non-employee workers split between self-employed people and people provided by undertakings primarily engaged in employment activities. No such split, headcount or FTE is given, and no methodology for estimating it is described. Elsewhere the statement shows that non-employees are within scope of the safety system: the ISO 45001 certified Management System "applies to all employees, contractors and visitors working at locations controlled by BW Offshore" (page 81), contractor exposure hours and contractor injury data are reported separately under S1-14 (page 83), with contractor exposure hours of 0 in 2025 against 0.95 million in 2024, and suppliers' workers on BW Offshore sites have access to the Safety Observation System and Speak Up Channel (page 99).

Collective bargaining coverage and social dialogue

Reference: page 91; accounting policy page 105; related narrative page 87.

Page 91 presents a "Collective Bargaining Agreement and Social Dialogue" table with coverage bands (0-19%, 20-39%, 40-59%, 60-79%, 80-100%) against three rows: Collective bargaining coverage - Employees in the EEA, naming Norway; Collective bargaining coverage - Employees outside the EEA, naming Singapore, UK and USA; and Social dialogue - workplace representation (EEA only), naming Australia and Norway.

Scope rule (page 105): "Collective bargaining coverage is calculated for EEA and non-EEA countries with more than 50 employees, representing more than 10 per cent of total employees. Social Dialogue is reported as percentage of workplace representation within EEA countries, when number of employees is higher than 50, and constitutes more than 10 per cent of total employees."

Narrative (page 87): "While we do not have an established Global Framework Agreement, we have a collective bargaining agreement in place for Australia, and maintain strong collaboration with unions, as well as structured engagement with workers' representatives through Working Environment Committees and Offshore Safety Committees."

Reader caveats. First, the presentation is a banded matrix rather than a stated percentage, so the coverage rate for any individual country cannot be read off the table as a number. Second, the social dialogue row is labelled "EEA only" yet lists Australia alongside Norway, which sits awkwardly with the stated scope rule. Third, the five countries named across the table (Norway, Singapore, UK, USA, Australia) are the five where BW Offshore has 50 or more employees (page 90), so the disclosure covers the whole of the material workforce even though it does not total to a single group-wide coverage percentage.

Diversity metrics

Reference: pages 95-96.

Gender balance (page 95):

Total workforce 2025: male 718, female 172, other 0, not reported 0, total 890. Senior Management comprises six people; the Board five.

Age distribution (page 95), reported for permanent and temporary direct hires:

"Age data for third party consultants is not collected due to data-protection limitations" (page 105), and the 2024 age figures were restated after a methodology change that "excludes third-party consultants" (page 38).

By country (page 96): female share of onshore employees - Singapore 34.87 per cent, UK 28.21, Australia 27.50, USA 31.25, Norway 32.54. Female share of offshore employees - UK 5.77 per cent, Australia 3.15, Singapore 0, USA 0. Reported for "countries where BW Offshore has 50 or more employees representing at least 10 per cent of total number of employees".

The company frames the imbalance directly: "In an industry where technical and leadership positions have long been male-dominated, we recognise that gender-based pay disparities and unconscious bias are not just legacy issues but a current challenge" (page 93).

Social protection

Reference: page 91 (listed in the working conditions chapter index, page 85, as S1-11 at page 91).

"All employees across our operating countries are covered by social protection systems that provide access to healthcare and income support during major life events such as sickness, employment injury and acquired disability, and retirement" (page 91).

Two gaps are disclosed against the ESRS list of major life events:

• Unemployment. "Unemployment protection applies to all employees except in Singapore, where no public unemployment insurance scheme exists. Although we do not operate a formal company unemployment benefit in this location, direct hire employees affected by downsizing have historically received support from the company" (page 91). Singapore is BW Offshore's largest country by headcount, with 238 employees (page 90), which makes the exception material rather than marginal.
• Parental leave. "Parental leave protection is available to all employees. In the United States, federal regulations do not mandate paid parental leave; however, BW Offshore provides paid leave at the company's discretion for direct hire employees, and there is no known instance in which this entitlement has been withheld" (page 91). The USA accounts for 135 employees (page 90).

"With these exceptions noted, employees are protected through public schemes, company-provided benefits or a combination of both, resulting in comprehensive coverage across major life events" (page 91).

Social protections is one of the material working-conditions IROs (page 50), and the chapter explains why: "Social protection is particularly relevant for working conditions in offshore roles where elevated safety risks and diverse national systems may affect access to benefits related to sickness, injury, or disability coverage. These variations underscore the importance of comprehensive insurance and health-related coverage across our workforce" (page 86). No count of employees not covered is given for either exception.

Training and skills development metrics

Reference: page 91; accounting policy page 105.

Performance dialogue completion (page 91):

"Improving the completion rate for Performance Dialogues was a key focus area for BW Offshore in 2025. With the introduction of a new performance review platform and process and active follow up with leaders and employees, the completion rate reached 79 per cent, up from 41.9 per cent in 2024" (page 91).

Average hours spent on training (page 91):

Method (page 105): performance dialogues are "the share of permanent employees who completed a performance dialogue during the reporting year out of the number of permanent employees who were assigned one. A new platform was implemented in September 2025, and all permanent employees at this time were assigned performance dialogues." Offshore training hours combine e-learning and external courses, with "E-learning hours... estimated at 45 minutes per completed course". Onshore and offshore hours are calculated on different bases, so the two are not directly comparable.

Health and safety metrics

Reference: pages 83-84; accounting policy page 104. Appendix pages 121-122 map "ESRS S1-14 Number of fatalities and number and rate of work-related accidents paragraph 88 (b) and (c)" and "Number of days lost to injuries, accidents, fatalities or illness paragraph 88 (e)" to page 83.

Coverage (page 81): the Management System is "certified under the ISM Code, ISO 9001, ISO 14001 and ISO 45001", and "applies to all employees, contractors and visitors working at locations controlled by BW Offshore".

Exposure hours (page 83): employee 1.30 million offshore plus 1.55 million onshore = 2.85 million (2024: 4.92; 2023: 13.77; 2022: 8.60). Contractor hours were 0 in 2025 (2024: 0.95).

Frequency rates (page 83): overall TRI 1.84 (2024: 0.88), overall LTI 0.79 (0.49), overall HPI 1.05 (0.29), overall fatality rate 0. All 2025 injuries were to employees; contractor injuries were nil.

The company explains the deterioration (page 84): "BW Offshore recorded stable safety performance in 2025, with incident numbers remaining broadly aligned with previous years. However, when measured against total exposure hours, the frequency rates for LTIs, TRIs and HPIs increased in 2025... These higher frequency rates are linked to the significant reduction in exposure hours following the completion of yard activities for the construction of BW Opal in 2025."

Ill health (page 84): "Work-related ill-health is reported in line with ESRS S1-14 (including musculoskeletal disorders). The one case reported in 2025 is also included in TRI for consistency with BW Offshore's established HSE performance reporting (based on IOGP)."

Caveats. Frequency rates are labelled "%" in the table although the accounting policy defines them as incidents per million exposure hours (page 104). And although the appendix cites page 83 for the number of days lost (paragraph 88(e)), no days-lost figure appears in the page 83 tables.

Work-life balance metrics

Reference: page 91 (cross-referred from the fair treatment of workers chapter index, page 92, which lists "S1-15 Work-life balance metrics" at page 91); accounting policy page 105.

Method and boundary (page 105): "Family-related leave is reported as the share of permanent and temporary (direct hire) onshore and offshore employees who took leave during the reporting period out of the average number of employees. Third-party consultants are excluded, as their leave is managed by their own employers."

The metric sits against a material IRO described as "offshore work-life balance and well-being" (page 50). The working conditions chapter explains the underlying exposure: "Rotational work patterns involve twelve-hour shifts, seven days a week, which, combined with long rotations and extended time away from home, can impact mental health, well-being, and personal relationships. These impacts are directly linked to BW Offshore's operational strategy and duty-holder responsibilities on FPSOs, highlighting the importance of structured rotation planning, access to occupational health services, and active monitoring of working hours and working conditions" (page 86).

Responses reported under S1-4 include Wellbeing Month each October and a new Employee Assistance Programme vendor offering "24/7 support in 22 languages" (page 87). No working-hours or overtime figure is disclosed alongside the leave metrics, and the gap between 100 per cent entitlement and 2.40 per cent take-up is not analysed.

Compensation metrics (pay gap and total compensation)

Reference: page 96; accounting policy page 105. Appendix page 122 maps "ESRS S1-16 Unadjusted gender pay gap paragraph 97 (a)" and "Excessive CEO pay ratio paragraph 97 (b)" to page 96.

Definitions (page 105): "Gender pay gap is defined as the average salary of women compared with the average salary of men (where men represent 100 per cent), including the highest-paid individual salary. The annual total remuneration ratio is calculated as the ratio of the highest-paid individual's annual remuneration to the median annual remuneration. The median remuneration is based on all permanent and temporary direct-hire employees, excluding the highest-paid individual."

Reader caveat on the pay gap. Read against the company's own definition, the 64 per cent figure is a pay ratio - women's average salary as a share of men's - not the ESRS S1-16 gap, which is the difference in average pay expressed as a percentage of male average pay. On the figures as defined, the ESRS-style gap would be the complement, and the series shows the position widening year on year under either reading (59, 63, 64). The label in the table reads "Gender pay-gap".

Company explanation (page 96): "We monitor 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. BW Offshore practices same pay for same jobs, and specifically considers gender pay-gaps for comparable positions as part of the annual remuneration review process."

The underlying material IRO is "gender pay gaps" (page 50), and the responses reported are the Job Grading System, "a systematic review of pay discrepancies... scheduled for completion in 2026", and the annual gender pay ratio review with follow-up through Heads of Function (pages 93-94).

Incidents, complaints and severe human rights impacts

Reference: page 111 (cross-referred from the fair treatment of workers chapter index, page 92); restatement at page 39. Appendix page 122 maps "ESRS S1-17 Incidents of discrimination paragraph 103 (a)" and "Nonrespect of UNGPs on Business and Human Rights and OECD Guidelines paragraph 104 (a)" to page 111.

"In 2025, BW Offshore identified no severe human rights incidents" (page 111).

Prior-period correction (page 39): "A similar correction has been made to the 2024 Speak Up data related to harassment or discrimination, as the previously reported figure did not include sexual harassment cases. This was a presentation oversight only, and corrected data is now reflected on page 111." The comparative shown for 2024 is therefore the restated figure.

Definition (page 116): "Speak Up and Grievances represent the number of cases submitted through the Speak Up Channel during the reporting period."

What is not disclosed. ESRS S1-17 also asks for the total amount of fines, penalties and compensation for damages resulting from the reported incidents, and for the number of severe human rights cases connected to the own workforce together with any fines or remediation payments. No monetary amount is given; nor is an outcome breakdown of the 26 reports - how many were substantiated, how many closed, or what remediation followed. The remediation framework itself is described qualitatively at page 109, including independent review, non-retaliation and quarterly anonymised reporting to the Audit Committee.

Policies related to value chain workers

Reference: page 99. Appendix page 122 maps S2-1 human rights policy commitments (paragraph 17), policies related to value chain workers (paragraph 18) and ILO due diligence policies (paragraph 19) to page 99, and non-respect of the UNGPs (paragraph 19) to page 111.

"BW Offshore has zero-tolerance for human trafficking, forced labour, child labour, discrimination, and harassment. Our commitment is supported by clear policies for ethical business conduct and labour practices" (page 99). Three instruments are named:

• Human Rights and Decent Working Conditions Policy - "reflects our commitment to respecting human rights and ensuring decent working conditions. The policy prohibits forced labour, child labour, modern slavery, and human trafficking, and sets out expectations for our business partners. It applies to us, our subsidiaries, and all individuals working for or on behalf of these entities."
• Supplier Code of Ethics and Business Conduct - "endorsed by the Chief Commercial Officer and demonstrates our respect for human rights and commitment to internationally recognised standards, including the Universal Declaration of Human Rights, ILO conventions, United Nations Guiding Principles on Business and Human Rights, and OECD Guidelines for Multinational Enterprises on Responsible Business Conduct." "Standard contractual terms and conditions enable BW Offshore to enforce the principles set out in the policy."
• Supplier Ethical Employment Practice Guidelines.

Expectations placed on suppliers (page 99): "We expect our suppliers to foster good employee relations, including providing mechanisms for receiving and addressing employee grievances and to support freedom of association and collective bargaining." "Suppliers are required to provide workers with avenues for raising concerns and to notify BW Offshore of situations that may create a risk of negative impacts on human rights or decent working conditions."

Public reporting (page 99): "In line with these commitments, we publish annual Board-approved statements under the Norwegian Transparency Act and UK Modern Slavery Act, outlining our human rights due diligence; these are available on our website."

No separate statement on whether the policies address human trafficking, forced labour and child labour in specific high-risk geographies is given beyond the Walk Free screening noted under S2-4.

Processes for engaging with value chain workers about impacts

Reference: page 100, with limitations stated at page 98.

Human rights assessments (page 100): "We conduct human rights assessments to identify potential adverse impacts within our operations and in our supply chain. We consider geography, regulatory frameworks, culture, and the nature of activities performed. Supplier relationships in countries with elevated risk ratings are monitored to support effective risk mitigation and continuous improvement."

Worker-level engagement (page 100): "We also perform ethical labour audits during construction phase. These audits evaluate conditions and practices at supplier sites and employer-provided accommodations and typically involve worker interviews, document reviews, and evaluation of compliance with human rights and decent work standards. Worker interviews include awareness of and trust in reporting mechanisms, working and living conditions, recruiting practices, wages, document retention, and safety."

2025 activity, including a nil return (page 100): "Site visits and audits are more frequent during the construction phase of our activities. In 2025, BW Offshore did not conduct any construction-phase ethical labour audits." "In 2025, we conducted three supplier pre-qualification site visits."

Accountability (page 100): "Following audits and site visits, we collaborate with relevant suppliers to develop appropriate improvements, when necessary. The Head of Corporate Integrity coordinates these activities and reports results to the CEO, Senior Management, and the Audit Committee of the Board of Directors."

Limitations the company states itself (page 98): "The vendor qualification process relies on supplier self-reporting and is currently limited to first-tier suppliers. For suppliers further down the supply chain, we rely on contractual flow-downs and selective audits. Visibility, therefore, is more limited. While this approach is practical and efficient, risks may go undetected." "Recognising these limitations, BW Offshore continues to assess ways to improve visibility beyond first-tier suppliers."

Engagement is mediated through suppliers and audits rather than conducted with workers' own representatives, and no credible worker-proxy organisation is named.

Processes to remediate negative impacts and channels for value chain workers to raise concerns

Reference: page 109 (cross-referred from the workers in the value chain chapter index, page 97), with access arrangements at page 99.

Access for value chain workers (page 99): "Workers employed through suppliers and contractors at BW Offshore sites, onboard FPSOs, or at operational locations also have access to our Safety Observation System and Speak Up Channel. These reporting mechanisms provide a direct line for raising concerns and sharing feedback related to safety and workplace conditions. We actively promote our reporting mechanisms across digital platforms and at working locations."

"Suppliers are required to provide workers with avenues for raising concerns and to notify BW Offshore of situations that may create a risk of negative impacts on human rights or decent working conditions" (page 99), so the channel is layered: BW Offshore's own channel for workers on its sites, and a contractual requirement for supplier-operated channels beyond them.

The channel itself (page 109): the Speak Up Channel is "a third-party hosted platform available to both internal and external stakeholders where reporters may submit concerns anonymously if desired", enhanced in November 2025 "with a mobile application and voice-recorded reporting, which improve accessibility for all stakeholders". Concerns are reviewed independently and objectively "including fair hearing principles", retaliation is prohibited, and "Anonymised statistics for reported concerns are provided to the Audit Committee on a quarterly basis".

Remediation (page 109): "If BW Offshore were to identify that we had caused or contributed to an adverse impact, we would initiate a remediation process. This would include engaging with affected individual(s) or communities, or their legitimate representatives, to understand the nature and extent of the harm and collaborating on appropriate remediation... We would assess effectiveness of remedial action through follow-up engagement, when possible."

Whether value chain workers are aware of, and trust, these channels is assessed indirectly: worker interviews during ethical labour audits cover "awareness of and trust in reporting mechanisms" (page 100). No count of value chain worker reports is given separately from the total of 26 Speak Up reports (page 111).

Taking action on material impacts on value chain workers

Reference: pages 98, 100, 110-111. Appendix page 122 maps "ESRS S2-4 Human rights issues and incidents connected to its upstream and downstream value chain paragraph 36" to page 111.

Where the risk sits (page 98): "Our supply chain relies heavily on labour provided through suppliers, contractors, and service providers, and we have a particular focus in sectors such as construction, maintenance, and offshore operations." "Forced labour concerns are of most concern in FPSO construction, module fabrication, and integration yards. Common indicators include document retention, wage withholding, debt bondage, and restrictions on movement."

Actions (pages 98, 100, 110):

• Risk-based vendor qualification: "Higher-risk suppliers undergo enhanced scrutiny during vendor qualification, including targeted questionnaires and, where appropriate, site visits and audits" (page 98). The process "assesses whether the prospective supplier meets baseline requirements related to governance, ethics, and labour practices" and includes restricted party screening; "we do not engage external parties if the compliance risk is deemed too high and cannot be effectively mitigated" (page 110).
• Fatigue controls: "To mitigate these impacts, we have implemented measures to minimise and monitor fatigue, including introducing maximum working hours and mandatory rest days" (page 98).
• Monitoring for violence and harassment: "We continuously monitor for this risk through site visits, Speak Up reports, and other feedback methods" (page 98).
• Geographic screening: "As of today, BW Offshore does not operate in countries classified by Walk Free as highest risk for modern slavery but remains alert to potential indirect involvement through our extended supply chain" (page 98).

Outcome metrics (page 111): new vendors assessed 129 (2024: 154); re-assessed vendors 221 (235); total vendors assessed 350 (389); "Direct vendors screened for social criteria" 100 per cent (100); vendors with valid compliance assessment 1,020 (3,836). "In 2025, BW Offshore identified no severe human rights incidents."

No construction-phase ethical labour audits were carried out in 2025 (page 100), and the sharp fall in vendors holding a valid compliance assessment is not explained.

Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities

Reference: page 99.

There are no value chain worker targets, stated under the minimum disclosure requirement for targets:

"While we do not currently have measurable targets for workers in the supply chain, we are committed to actively preventing and mitigating potential adverse impacts on workers across our supply chain. Our approach is grounded in proactive engagement, supplier assessments, and continuous monitoring" (page 99).

Effectiveness is tracked through process metrics instead of outcome targets (page 111): vendors assessed in the year (350, of which 129 new and 221 re-assessed), the share of direct vendors screened for social criteria (100 per cent), and vendors holding a valid compliance assessment (1,020). The governance route is reporting of audit and site-visit results by the Head of Corporate Integrity "to the CEO, Senior Management, and the Audit Committee of the Board of Directors" (page 100).

Forward-looking commitments are framed as intentions rather than targets: "BW Offshore continues to assess ways to improve visibility beyond first-tier suppliers, and we explore opportunities to strengthen supplier engagement throughout our extended supply chain" (page 98). No date, baseline or measurable level is attached, and the report does not describe value chain workers or their representatives being involved in setting any target.

Policies related to affected communities

Reference: page 102. S3 is material for the first time in FY2025; the site records it as not material for FY2024. Appendix pages 122-123 map "ESRS S3-1 Human rights policy commitments paragraph 16" to page 99 and "non-respect of UNGPs on Business and Human Rights, ILO principles or and OECD guidelines paragraph 17" to page 111.

Commitments (page 102): "We are committed to the principles of the OECD Guidelines for Multinational Enterprises on Responsible Business Conduct, OECD Due Diligence Guidance for Responsible Business Conduct, and UN Global Compact. Through our ongoing efforts, we strive to cease, prevent, or mitigate adverse negative impacts."

Instruments (page 102):

• Human Rights and Decent Working Conditions Policy - "outlines our commitments to support local communities and indigenous peoples' rights, to limit negative impacts on people, the environment, and the communities in which we operate, and to carefully consider the impact our activities may have."
• First Nations Inclusion Policy - "defines how we engage with First Nations communities in Australia and is designed to foster cultural respect, awareness, and inclusivity and maximise local recruitment and procurement from First Nations communities." It "is overseen by the local Asset Manager and People & Culture Manager, and is aligned with our Diversity, Equity & Inclusion Statement".
• Code of Ethics and Business Conduct - "sets expectations for responsible and ethical business conduct and practices, including stakeholder engagement and transparency."
• Supplier Code of Ethics and Business Conduct - "sets minimum standards for how our vendors conduct business with us and others."

Why the topic became material (page 102): "While our FPSOs typically are located at a considerable distance from shore, oil and gas developments can affect communities, particularly those coastal areas closest to or supporting our operations." "Although the likelihood of a serious hazardous incident, such as a hydrocarbon leak, is considered low due to our robust barriers, such an incident could directly impact coastal communities and have significant consequences, particularly for those reliant on fishing or tourism."

The policies do not state an explicit commitment on free, prior and informed consent by BW Offshore itself; that obligation is placed with clients as concession holders (page 102).

Processes for engaging with affected communities about impacts

Reference: page 102, with emergency-preparedness engagement at page 70 and the grievance route at page 103.

The company discloses the absence of a global process (page 102): "BW Offshore does not have a formalised global process for engaging directly with affected communities. Rather, we consider the particular needs and requirements of specific locations and adopt appropriate strategies, like developing a First Nations Inclusion Policy and a phased First Nations Engagement Plan for Australia's Northern Territory."

Free, prior and informed consent is placed with clients (page 102): "As a service provider to the oil and gas industry, our clients, as concession holders, lead processes related to Free, Prior and Informed Consent. We rely on our clients to fulfil these obligations, and we aim to operate in a way that avoids actions that could undermine these obligations."

What engagement does exist (pages 70, 102-103):

• The First Nations Engagement Plan "outlines how we plan to engage with First Nations communities, including timelines and modes of interaction, and is designed to foster inclusivity and equal opportunities" (page 103).
• "Emergency preparedness processes including engagement plans with local authorities and communities, for operational assets are longstanding" (page 102), with the underlying framework described at page 70.
• Indirect engagement through rights disputes: "We also recognise the importance of and respect indigenous rights and cultural heritage... Throughout any process, we listen to the perspectives of local communities and seek solutions that are mutually agreeable" (page 102).
• "Local communities and indigenous peoples may raise concerns via our Speak Up Channel, described on page 109" (page 103).

No senior executive is identified as accountable for community engagement beyond the local Asset Manager and People & Culture Manager who oversee the First Nations Inclusion Policy, and the report does not describe how the effectiveness of community engagement is assessed.

Processes to remediate negative impacts and channels for affected communities to raise concerns

Reference: page 109 (cross-referred from the local communities chapter index, page 101), with the community access point at page 103.

Channel (pages 103, 109): "Local communities and indigenous peoples may raise concerns via our Speak Up Channel, described on page 109" (page 103). The Speak Up Channel is "a third-party hosted platform available to both internal and external stakeholders where reporters may submit concerns anonymously if desired" (page 109), and in November 2025 it was "enhanced... with a mobile application and voice-recorded reporting, which improve accessibility for all stakeholders". Key governance documents are published on the website, which "also provides contact information and guidelines on how to raise grievances or concerns, to provide transparency and accessibility for all stakeholders" (page 108).

Handling (page 109): "Each concern is reviewed independently and objectively, in accordance with applicable laws and recognised best practices, including fair hearing principles." "Investigations are carried out independently of any individuals or management chains implicated in the reported concern. Anonymised statistics for reported concerns are provided to the Audit Committee on a quarterly basis." Retaliation is prohibited and allegations of retaliation are "investigated independently and monitored by the Head of Corporate Integrity, with oversight by the Audit Committee".

Remediation, with communities named explicitly (page 109): "If BW Offshore were to identify that we had caused or contributed to an adverse impact, we would initiate a remediation process. This would include engaging with affected individual(s) or communities, or their legitimate representatives, to understand the nature and extent of the harm and collaborating on appropriate remediation... We would assess effectiveness of remedial action through follow-up engagement, when possible."

No count of community grievances received is reported separately from the 26 total Speak Up reports (page 111), and no assessment of community awareness of the channel is given.

Taking action on material impacts on affected communities

Reference: pages 102-103; related pollution preparedness pages 69-70. Appendix page 123 maps "ESRS S3-4 Human rights issues and incidents paragraph 36" to page 111.

Material impacts being managed (page 50): local community impacts as a result of accidents, indigenous rights, and indigenous communities' activism.

Actions in Australia's Northern Territory (pages 102-103): "In 2025, operations commenced on the BW Opal, located offshore Darwin, Northern Territory, Australia. We are developing specific actions related to local community engagement and indigenous peoples' rights." The two instruments are the First Nations Inclusion Policy, "designed to foster cultural respect, awareness, and inclusivity and maximise local recruitment and procurement from First Nations communities", and a phased First Nations Engagement Plan.

"We prioritise local recruitment and procurement opportunities with local and indigenous peoples-owned businesses. This approach supports local economic development and helps to build enduring partnerships within the community. We regularly monitor our workforce composition for indigenous representation and local recruitment ratio" (page 103). "Through these initiatives, we aim to contribute positively to local capacity-building, support sustainable economic participation, and uphold the rights and interests of indigenous and local communities wherever we operate."

Accident prevention as community protection (pages 69-70, 102): the risk of a hydrocarbon spill reaching "coastal communities and have significant consequences, particularly for those reliant on fishing or tourism" is managed through the spill prevention and response framework - double-hulled tanks, oil-in-water monitoring, vessel-specific Shipboard Oil Pollution Emergency Plans approved by DNV, tiered response teams, agreements with external and regional response organisations, and annual spill drills. "Emergency preparedness processes including engagement plans with local authorities and communities, for operational assets are longstanding" (page 102).

No resources are quantified for these actions, no indigenous representation or local recruitment figure is published despite the stated monitoring, and the actions in the Northern Territory are described as still being developed.

Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities

Reference: page 103.

The disclosure is an explicit nil return: "BW Offshore has not set any time-bound or outcome-oriented targets concerning affected communities during the reporting period" (page 103).

Effectiveness is tracked instead. "We regularly monitor our workforce composition for indigenous representation and local recruitment ratio" (page 103), though neither figure is published for 2025. The First Nations Engagement Plan "outlines how we plan to engage with First Nations communities, including timelines and modes of interaction" (page 103), giving a phased schedule rather than an outcome target, and the company states that it is "developing specific actions related to local community engagement and indigenous peoples' rights" following the start of BW Opal operations offshore Darwin (page 102).

This mirrors the company's position across its topical chapters: no emissions reduction target (page 64), no pollution target (page 70), no waste reduction target (page 73), and no value chain worker target (page 99). Only health and safety, fair treatment of workers, climate process measures and cyber security carry target tables, all with 2026 horizons (pages 64, 82, 94, 114).

Business conduct policies and corporate culture

Reference: pages 108-109. Appendix page 123 maps "ESRS G1-1 Protection of whistle-blowers paragraph 10 (d)" to page 109 and marks "ESRS G1-1 United Nations Convention against Corruption paragraph 10 (b)" as "N/A".

The Code (page 108): "Our Code of Ethics and Business Conduct (the Code) is a foundational governance document. The Code applies to BW Offshore personnel and board members and establishes our minimum standards for business conduct and expectations of fair dealing, honesty, and integrity. The Code of Ethics and Business Conduct Guidelines and additional policies and procedures supplement the Code." "Key governance documents, including the Code, are publicly accessible on our website. The website also provides contact information and guidelines on how to raise grievances or concerns, to provide transparency and accessibility for all stakeholders."

Governance of conduct (page 108): "BW Offshore has well-developed corporate governance that incorporates principles of the current version of the Norwegian Code of Practice for Corporate Governance." The Audit Committee "has oversight of our internal controls, risk management, internal and external audit activities, legal and regulatory compliance, governance, and annual reporting", and is "currently comprised of two members. Both members are independent, possess over twenty-five years of industry experience".

Corporate culture (pages 108-109): "The CEO and senior leaders implement our policies and promote accountability throughout the organisation. We circulate regular communications and conduct targeted, risk-based training to reinforce awareness of our policies" (page 108).

Whistleblower protection (page 109): "BW Offshore prohibits retaliation against anyone who raises a concern in good faith or participates in a review process, which we reinforce through townhalls and via other internal communications. As with any other concern, allegations of retaliation are investigated independently and monitored by the Head of Corporate Integrity, with oversight by the Audit Committee." Memberships (page 109): "BW Offshore is a member of Building Responsibly, TRACE, and the Maritime Anticorruption Network." No animal welfare or training-programme coverage percentage for board members is disclosed.

Management of relationships with suppliers

Reference: page 110, with vendor qualification detail at page 100. This is new relative to FY2024, where the site records G1-2 as omitted.

Supplier risk management (page 110): "We actively manage risks in our supply chain through our vendor qualification process (page 100), during which prospective suppliers complete a questionnaire covering governance, ethics, and labour practices. This process also considers social and environmental criteria, including human rights, working conditions, and environmental performance. We also conduct restricted party screening and do not engage external parties if the compliance risk is deemed too high and cannot be effectively mitigated."

The process is risk-tiered: "The process includes a questionnaire and, for the highest risk, key suppliers, pre-qualification site visits. In 2025, we conducted three supplier pre-qualification site visits" (page 100).

Payment practices towards vulnerable suppliers (page 110): "Additionally, we aim to be a fair and reliable business partner to our suppliers by maintaining transparent payment practices. BW Offshore applies a consistent process for all suppliers, regardless of size. Our standard payment term is forty-five days after invoice receipt unless other payment terms have been agreed. BW Offshore processes a payment upon receipt of the invoice, other required documentation, and necessary internal approvals. Our payment process is clearly outlined in our standard Terms and Conditions, which form part of the Purchase Order or Contract shared with suppliers."

Why the relationship matters (page 108): "Given the substantial value of our contracts, timely and fair payment practices are essential, especially for smaller suppliers who depend on our payments to maintain liquidity, meet payroll obligations, and provide stable employment for their workforces... we recognise that our practices most affect suppliers with limited bargaining power and a high dependency on our payments."

Metrics (page 111): 350 vendors assessed in 2025 (129 new, 221 re-assessed), 100 per cent of direct vendors screened for social criteria, 1,020 vendors with a valid compliance assessment at year end (2024: 3,836 - a fall the report does not explain).

Prevention and detection of corruption and bribery

Reference: page 109. Appendix page 123 maps "ESRS G1-4 Standards of anti-corruption and anti-bribery paragraph 24 (b)" to page 109.

The programme (page 109): "BW Offshore maintains a compliance programme designed to prevent, detect, and respond to incidents of corruption and bribery. Our programme includes guidelines on disclosing conflicts of interest and the giving and receiving of gifts, hospitality, and charitable donations. We monitor compliance with our internal controls through, for example, regular audits of expense claims."

Where the risk sits (page 108): "Corruption may occur at any level, but procurement, business development, and interactions with government entities present particular opportunities for corrupt conduct."

Independence of investigation (page 109): "Each concern is reviewed independently and objectively, in accordance with applicable laws and recognised best practices, including fair hearing principles. Investigations are initiated when necessary and are conducted promptly, fairly, and in accordance with established procedures. Investigations are carried out independently of any individuals or management chains implicated in the reported concern. Anonymised statistics for reported concerns are provided to the Audit Committee on a quarterly basis." "The Head of Corporate Integrity assigns investigators based on the nature of the concern and relevant expertise, and external experts such as forensic accountants or legal professionals may be engaged when needed."

Training (page 109): "The training includes an annual Code refresher for onshore workers. In addition, staff are assigned topic-specific e-learning on a role- and risk-based approach on subjects including antibribery and corruption, conflicts of interest, and modern slavery." "Personnel in higher-risk functions, such as business development, procurement, and Senior Management, receive supplemental anti-corruption training through a dedicated anti-bribery and corruption course." Training metrics (page 111): new joiners assigned 18, completion rate 77.78 per cent; at-risk-function individuals assigned 52, completion 65.38 per cent; managers assigned 16, completion 75.00 per cent; Code of Ethics and Business Conduct training completion for onshore employees 77.60 per cent. No function-by-function coverage of the whole at-risk population, and no board-level training figure, is given.

Targets related to business conduct

Back-filled from the Business Conduct chapter, where targets are addressed as part of the MDR-T minimum disclosure requirement rather than as a numbered disclosure requirement. G1-3 became a standalone targets DR only in the 2025/2026 ESRS; this statement was prepared under the 2023 ESRS.

No business conduct target is stated. The Business Conduct chapter index lists SBM-3, GOV-1, G1-1, G1-2, G1-3, G1-4, G1-6 and four cross-referred social DRs, and no MDR-T row (page 107). The chapter's "ACTIONS AND TARGETS" section (page 109) describes the compliance programme and training calendar without setting a target. The company's general framing is that "In 2025, BW Offshore has set measurable, outcome-oriented or timebound targets related to certain key sustainability-areas, which are described throughout the report in relevant chapters" (page 42) - business conduct is not one of them.

Effectiveness is tracked in the absence of a target, which is MDR-T's other limb:

• Compliance monitoring: "We monitor compliance with our internal controls through, for example, regular audits of expense claims" (page 109).
• Training completion tracked and reported (page 111): new joiners 77.78 per cent; at-risk functions 65.38 per cent; managers 75.00 per cent; Code of Ethics training for onshore employees 77.60 per cent.
• Quarterly governance reporting: "Anonymised statistics for reported concerns are provided to the Audit Committee on a quarterly basis" (page 109).
• Outcome metrics (page 111): 0 convictions for violations of anti-corruption and anti-bribery laws and USD 0 in fines (unchanged since 2022); 0 Speak Up reports related to corruption; 26 total Speak Up reports.
• Supplier-side tracking (page 111): 350 vendors assessed, 100 per cent of direct vendors screened for social criteria.
• Payment practices tracked against the standard term: average 39 days from invoice receipt to payment and 71 per cent of invoices paid within agreed terms, against a standard term of 45 days (pages 110-111).

The only target table anywhere in the Governance section belongs to the entity-specific cyber security topic: "Complete gap analysis towards ISO 27001 certification - Gap analysis completed - In progress" (page 114).

Incidents of corruption or bribery

Reference: page 111. Appendix page 123 maps "ESRS G1-4 Fines for violation of anti-corruption and anti-bribery laws paragraph 24 (a)" to page 111.

Definition (page 116): "Incidents of corruption and bribery represent the number of legal convictions issued during the reporting year for breaches of anti-corruption or anti-bribery laws, as well as the total monetary value of related fines."

This is a nil return on a narrow definition, and readers should note what the definition excludes. ESRS G1-4 asks for the number of convictions and the amount of fines for violation of anti-corruption and anti-bribery laws, and also for the total number and nature of confirmed incidents of corruption or bribery, confirmed incidents where own workers were dismissed or disciplined, and confirmed incidents relating to contracts with business partners that were terminated or not renewed. BW Offshore reports only the convictions-and-fines limb; the confirmed-incidents limb is not separately reported, although the zero Speak Up reports related to corruption in each of the last four years (page 111) is the nearest proxy the statement provides.

The actions behind the figure are the compliance programme, expense-claim audits, role- and risk-based training with supplemental anti-bribery training for business development, procurement and Senior Management, and independent investigation of concerns with quarterly anonymised reporting to the Audit Committee (page 109). The company also discloses that the likelihood of corruption "is generally considered low in the countries where we have a presence" while "industry-wide risks persist" (page 108).

Payment practices

Reference: page 111, with the standard terms at page 110.

2025 performance (page 111): "In 2025, the average time from invoice receipt to payment was 39 days, and 71 per cent of invoices were paid within the agreed terms. Out of the 29 per cent remaining invoices not paid within the agreed term, 40 per cent of the invoices pertain to project invoices with strict documentation requirements. During the reporting period, 0 legal proceedings for late payments were commenced."

Standard terms (page 110): "BW Offshore applies a consistent process for all suppliers, regardless of size. Our standard payment term is forty-five days after invoice receipt unless other payment terms have been agreed. BW Offshore processes a payment upon receipt of the invoice, other required documentation, and necessary internal approvals. Our payment process is clearly outlined in our standard Terms and Conditions, which form part of the Purchase Order or Contract shared with suppliers."

So the average of 39 days sits inside the 45-day standard term, and the company attributes most of the late tail to documentation requirements on project invoices rather than to payment policy.

Why this is a material IRO (page 108): "Business conduct also extends to the way we engage with our suppliers, where we play a pivotal role in shaping relationships. Given the substantial value of our contracts, timely and fair payment practices are essential, especially for smaller suppliers who depend on our payments to maintain liquidity, meet payroll obligations, and provide stable employment for their workforces. While all suppliers are subject to the same payment process unless otherwise specified by contract, we recognise that our practices most affect suppliers with limited bargaining power and a high dependency on our payments." "Supplier payment terms and practices" is listed among the material business conduct IROs (page 50).

ESRS G1-6 also asks for an explanation of standard payment terms by main supplier category where these differ; BW Offshore states a single standard term applying regardless of supplier size, which answers the requirement by stating that no such differentiation exists.