DNO ASA

Reference: page 20.

The Board of Directors has seven members, three of whom are women (43 percent). The Group's largest shareholder, Bijan Mossavar-Rahmani, serves as Executive Chairman; all other members are independent (86 percent). There are no employee-elected representatives on the Board or its five advisory committees: Audit and Risk (two women, one man), HSEC (one woman, one man), Finance and Investment (two men), Nomination (three men) and Remuneration (two men).

Senior management has nine members (six men, 67 percent; three women, 33 percent), responsible for the overall conduct of DNO's business, including managing material IROs. The Kurdistan and North Sea business units each have a dedicated General Manager/Managing Director.

Reference: page 20.

Corporate and operational risks are reported to the Board quarterly through the HSEC and Audit and Risk committees. HSEC oversees environmental performance; Audit and Risk covers regulatory/financial compliance and sustainability reporting. Topics discussed during 2025 included "GHG, water and biodiversity related data," including the GHG emissions management policy, emissions-reduction projects, verification methodologies and regulatory developments.

During 2025, the Audit and Risk committee "supervised the work associated with DNO's Double Materiality Assessment (DMA)." The external auditor's limited assurance activities are described in the assurance statement.

Reference: page 21.

Remuneration guidelines for senior personnel were approved by the AGM in May 2023. Environmental performance, including GHG/climate topics, is evaluated as part of the annual appraisal and bonus process for the General Managers of both business units, with roughly five percent of their bonus tied to this. The Chief Supply Chain Officer has performance targets tied to climate-related supplier engagement.

"As environmental performance is included in an overall judgement, the percentage of variable remuneration due to sustainability factors cannot be specified." DNO has no other sustainability-linked incentive schemes.

Reference: page 21; Appendix 1, page 44.

"The mapping of the sustainability statement to the due diligence process is included in Appendix 1." Appendix 1 maps the five core elements of due diligence to specific sections of the statement: embedding due diligence in governance/strategy (GOV-2, GOV-3, SBM-3); engaging with stakeholders (SBM-2, IRO-1, and the own-workforce/value-chain-worker/affected-community engagement sections); identifying and assessing adverse impacts (IRO-1, SBM-3); taking action (the topical Actions sections and Corruption and bribery); and tracking effectiveness (Actions related to own workforce, Equal treatment, Adequate wages, Health/safety/security).

Reference: page 21.

Risk management and internal controls follow "a structured approach to sustainability reporting, with quarterly updates provided to the HSEC and Audit and Risk committees." Key risks identified: data completeness and accuracy, and alignment with the reporting framework.

2025 focus areas: "ensuring a consistent interpretation of the ESRS requirements with our peers and the wider industry," preparing for announced regulatory changes, and integrating the newly acquired Sval Energi business into the sustainability statement.

Reference: page 21.

DNO's vision is to remain "a leading, growth-oriented oil and gas exploration and production group," with ESG priorities spanning talent, governance, HSSE leadership and minimizing GHG emissions in operated and partner-operated assets. FY2025 revenue was USD 1,474 million (gas USD 577m, oil USD 802m); DNO has no EU Taxonomy-aligned revenue.

Workforce: 1,159 employees (67 at Oslo HQ, 1,092 across Dubai, Erbil and Stavanger operations). Value chain: upstream raw materials and drilling/processing equipment; own operations consume energy, water and land onshore and offshore; downstream is sale and distribution of oil and gas to end customers.

Reference: page 22.

Key stakeholders: shareholders and other investors (DNO has "some 16,000 shareholders" as a 54-year-old public company), authorities, suppliers, license partners, banks, insurance companies, employees and local communities. Engagement occurs through organized group meetings plus "formal correspondence as well as informal contact with stakeholders... on an almost daily basis."

"The main concerns of the stakeholders are business performance and compliance with regulations." No amendments to strategy resulting from this engagement are described.

Reference: pages 21-22.

The DMA identified material IROs across E1, E2, E4, E5, S1, S2, S3 and G1 (E3 water and S4 consumers are not material). The IRO table lists, among others: actual negative GHG-emission impacts in own operations and the value chain (E1); produced-water discharge and acute-discharge risk (E2); exploration-drilling exposure in biodiversity-sensitive areas (E4); resource in/outflows from construction and decommissioning (E5); workforce injury and gender-disparity impacts (S1); value-chain-worker injury risk (S2); positive and negative community impacts in Kurdistan plus an employment opportunity (S3); and supplier/whistleblower/corruption compliance risks (G1).

"In 2025, our material ESG risks and opportunities have not materially affected our financial position... DNO has not allocated any financial resources to the strategy over the short, medium or long term.

Reference: pages 22-23.

Four-phase methodology: (1) Understand context - value-chain activities mapped; (2) Identify actual/potential IROs; (3) Assess - scored via an ERM-based 1-5 matrix (effect x scale x irreversibility x likelihood; severity weighted higher than likelihood for human-rights impacts); (4) Decide - materiality threshold set by matrix, approved by senior management and the Audit and Risk committee.

Topic add-ons: climate uses a quarterly Risk Assessment Matrix plus IEA WEO scenario sensitivity (Net Zero 2050, Stated Policies, Current Policies); biodiversity follows the Biodiversity Management Policy and found no sites in UNESCO World Heritage Sites or protected areas, though exploration drilling occurred in/near high-biodiversity-value areas on the NCS.

Reference: page 24; Appendix 3 (pp.20-24) and Appendix 2 (pp.44-46).

"Based on the results of the DMA, DNO assessed the materiality of information to determine which disclosure requirements under the ESRS were relevant... First, we included the mandatory disclosure requirements related to policies, actions and targets for all material ESRS topics. Second, we reviewed the list of disclosure requirements and assessed which ones referred to relevant elements in our material IROs. If we found no such information, we marked the disclosure requirement as not relevant."

Appendix 3 lists the DRs covered with page references (the source for this file's statuses). Appendix 2 cross-references individual datapoints to SFDR/Pillar 3/Benchmark Regulation/EU Climate Law, each tagged Material or Immaterial, and flags several E1-9 physical/transition-risk datapoints: "DNO will not report on this in 2025 as it is a phase-in requirement.

Reference: page 25.

"Given the nature of the industry, we do not have a net zero by 2050 transition plan and currently we have no plans for adopting such a plan." The majority of GHG impact is Scope 3 use-of-sold-products emissions, which DNO considers "incompatible with a transition to a carbon-neutral economy" and "beyond DNO's direct control." DNO instead argues its production and emissions "are expected to be near zero by 2050, as the vast majority of the Group's licenses... will have expired by then."

A resilience/scenario exercise using IEA WEO scenarios quantifies exposure: the Net Zero by 2050 scenario would cut 2025 net profit by USD 1,005.0 million; Stated Policies by USD 195.3 million; Current Policies would increase profit by USD 83.0 million.

Reference: Back-filled from ESRS 2 IRO-1 and E1-1, where this content is disclosed in the FY2025 report (pages 23, 25). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Physical risk is assessed within DNO's quarterly group-wide risk process over short- (<1yr), medium- (1-5yr) and long-term (5-30yr) horizons, using IEA World Energy Outlook scenarios "as a reference framework." Transition risk is assessed over a medium-to-long-term horizon using the IEA's Net Zero Emissions by 2050, Stated Policies and Current Policies scenarios, incorporating potential carbon pricing in Kurdistan and carbon-tax/ETS exposure in the North Sea. Oil and gas price paths for 2035/2050 are sourced from the IEA (2024 real terms) and interpolated to 2025 prices; resulting profit impacts are quantified under E1-1.

Reference: Back-filled from ESRS 2 IRO-1 and E1-1, where this content is disclosed in the FY2025 report (pages 23, 25). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

"DNO has carried out a resilience assessment based on the IEA's WEO scenarios, Net Zero Emissions by 2050, Stated Policies and Current Policies, to test the robustness of the Group's financial performance under alternative long term commodity price trajectories." This is a financial-profitability sensitivity analysis rather than a full ESRS-defined resilience analysis; DNO states it "will consider conducting a more detailed resilience analysis during 2026.

Reference: page 26.

Underpinned by the HSSE policy and an ISO 14001-based environmental management system, plus a corporate GHG emissions policy requiring every business unit "to identify emissions reduction projects... and to include GHG impacts/reductions in investment proposals." The policy "is designed to be a high-level guiding document and does not specifically address each IRO in detail"; the Managing Director is accountable Group-wide.

DNO is a signatory to OGCI's Aiming for Zero Methane Emissions Initiative (near-zero methane from operated assets by 2030, no-routine-venting policy) and reports annually to CDP, receiving a B rating for the seventh consecutive year (2024 reporting year).

Reference: page 26.

Since 2020 the Tawke license has run Kurdistan's first associated-gas capture and injection facilities, avoiding CO2e from flaring. In 2025 a waste-heat-recovery project at Tawke's central processing facility cut diesel-fired heating, saving "around 1.5 million liters of diesel annually" and "cutting CO2e emissions by roughly 4,000 tonnes," with further demulfisier-use reductions expected.

North Sea action centers on electrification via power-from-shore: DNO spent USD 5.5 million in 2025 on the Fenja license power-from-shore project (operational 2027). DNO also maintains Tawke's Leak Detection and Repair program and membership of Norway's SINTEF-coordinated LowEmission research center.

Reference: page 27.

DNO's only quantified ambition is an emission-intensity target for operated fields' Scope 1+2: "below the average of the global upstream industry." 2025 actual: 13.7 kgCO2e/boe, ahead of OGCI's 12-company commitment of 17 kgCO2e/boe by 2025 (from a 2017 baseline of 23).

"DNO does not have a target for reducing its absolute GHG emissions." Separately, a near-zero-methane-by-2030 ambition applies Group-wide. DNO states plainly: "DNO GHG reduction targets do not meet the requirements of ESRS for science-based targets and are not compatible with limiting global warming to 1.5 degrees Celsius.

Reference: page 27.

Total energy consumption 2025: 1,591,242 MWh - 98.6% fossil (natural gas 1,169,638 MWh; crude oil/petroleum products 361,897 MWh), 0.8% renewable (13,112 MWh, including 21 MWh self-generated solar at Tawke) and 0.6% nuclear-factor purchased electricity. Energy intensity was 1,079.5 MWh per USD million net revenue, up from 889.2 in 2024.

"All of the total energy consumption is from activities in high climate impact sectors." Fossil consumption more than doubled year-on-year, driven by the Sval Energi acquisition.

Reference: page 28.

Scope 1 (equity share): 537,130 tCO2e (2024: 358,860). Scope 2 market-based: 27,924 tCO2e. Scope 3: 17,254,110 tCO2e, dominated by Use of sold products (15,568,832t) and Processing of sold products (1,323,662t). Total GHG (market-based): 17,819,164 tCO2e (2024: 13,130,608), GHG intensity 12.1 tCO2e per USD thousand net revenue (down from 19.7).

The year-on-year rise reflects the Sval Energi acquisition, consolidated from 1 June 2025. 2024 is the base year, "the first year of reporting under ESRS"; DNO has no absolute-emissions milestones against which to track this base year.

Reference: page 28.

"DNO did not have any GHG removal or mitigation projects financed through carbon credits in 2025." This sits directly alongside the internal-carbon-pricing discussion on the same page and follows the Scopes 1-3 GHG emissions and intensity tables (E1-6), which report no reliance on removals or offsets to reach the Group's reported emissions figures.

Reference: page 29.

Underpinned by the HSSE policy and ISO 14001-based environmental management system, plus a Crisis Management and Emergency Response Policy and a Corporate Major Accident Prevention Policy covering incident prevention and spill/accident response.

"While DNO does not maintain specific group-level policies focused solely on mitigating air, water and soil pollution, tailored procedures at the business unit level are in place to minimize environmental pollutants and remediate any incidents of pollution.

Reference: page 29.

The Tawke gas-capture/injection project (also an E1 action) displaces diesel generators, cutting local SOx/NOx and noise. Routine flaring has been "prohibited for over 50 years" in Norway; UK regulation "strongly encourages" avoiding unnecessary flaring. All North Sea activity runs under environmental permits, impact assessments and public-hearing consultation.

DNO applies Best Available Techniques (BAT), including chemical-substitution assessments before each operation. Where feasible, produced water is reinjected subsurface; otherwise discharge is regulated to an average oil content of no more than 30 mg/liter per month, monitored daily or continuously, with broader pollutant analysis twice a year.

Reference: page 29.

"DNO is committed to minimizing the environmental impacts of its operations, including pollution and is considering ESRS-aligned targets suited to the Group's specific operations and asset portfolio." No quantified pollution target is yet in place.

Reference: page 29.

Pollution to air, 2025 (equity share): NOx 2,600t, SOx 1,310t, NMVOC 792t, PM 69t - all up on 2024, "mainly due to the acquisition of Sval Energi and the resulting higher production in the North Sea."

Pollution to sea (produced-water discharge, E-PRTR Annex II substances): e.g. cadmium 129 kg/year (equity share) against a 5 kg/year E-PRTR reporting threshold; arsenic 9 kg/year against the same 5 kg/year threshold. Discharge oil content is kept to ≤30 mg/liter monthly average per the regulatory permit regime described under E2-2.

Reference: page 30 (indexed as "MDR E4: Minimum disclosure requirements biodiversity and ecosystems"; DNO's own index consolidates E4's policy/action/target coverage under this single MDR line rather than the individual 2023 ESRS codes).

"Both the HSSE and Biodiversity Management Policies clearly state DNO's commitment to prevent pollution and minimize the impact of our operations on the environment and biodiversity." DNO "prohibits operations in UNESCO World Heritage Sites" and "aims to avoid new developments in, or in proximity to, protected areas," with extra assessment/minimization/reporting care where operations touch Key Biodiversity Areas or Particularly Valuable and Sensitive Areas (SVOs) on the NCS. The Managing Director is accountable to the Board; business-unit General Managers implement.

Reference: page 30 (indexed as "MDR E4").

"None of our operations in 2025 were in proximity of WHS or protected areas." DNO drilled the exploration well Page within the Inner Shoal SVO (sand-eel spawning habitat): environmental-risk and oil-spill-contingency analyses were performed, drilling was timed to avoid the spawning season, and drill cuttings were collected for onshore treatment rather than seabed disposal.

A habitat survey during the Kjøttkake exploration campaign identified Isidella lofotensis (bamboo coral, "near threatened" on the Norwegian Red List); findings were submitted to the Norwegian Environment Agency's Visual Database.

Reference: page 30 (indexed as "MDR E4").

"DNO has not established measurable biodiversity-related targets." Effectiveness is instead tracked through "regular environmental monitoring as part of a joint industry program," comparing oil-contaminated area and benthos-fauna changes to baseline data around North Sea installations. Results to date: "the total oil-contaminated areas have significantly decreased over the years," with "no indication [of] significant negative impacts on the benthic fauna" at most field-specific stations versus baseline.

Reference: page 31.

"At present, DNO does not have a dedicated group policy specifically addressing resource use or the circular economy," nor policies on reducing virgin-resource consumption or increasing renewable-resource use, though the HSSE policy addresses minimizing environmental impact generally and a Kurdistan business-unit Waste Management Procedure governs waste streams "from generation point to its final disposal."

DNO "strives to follow the waste hierarchy" (prevent, re-use, recycle, recover, disposal), applying MARPOL 73/78 Annexes and local regulation.

Reference: page 31.

Decommissioning and reuse projects: Vale (operated - USD 14 million spent in 2025 installing rig anchors for the 2026 plugging and abandonment campaign) and Heimdal (partner-operated), both targeting ">95 percent" recycling; the Marulk field plans to reuse a Christmas tree and subsea flow module from a previously producing field. In the UK, DNO oversees onshore dismantling/recycling of the Schooner and Ketch gas platforms. In Kurdistan, equipment reuse dates back to Tawke's first (second-hand) processing facility nearly twenty years ago.

Reference: page 31.

"DNO is working to strengthen its understanding and management of resource inflows and outflows across its operations. While we have not yet adopted specific targets or related metrics in these areas, we are exploring ways to establish measurable goals to enhance our resource management practices.

Reference: page 32.

Resource inflow 2025: material use (steel and cement, spend-based estimate) of 31,904 tonnes (2024: 44,031 tonnes); secondary reused or recycled components 39 tonnes, 0.1 percent of the total. Steel and cement are "deemed to be the most important of the raw materials used in DNO's assets," mainly for facility/well construction (wellhead casing and tubing) and well-site infrastructure.

Reference: page 32.

Decommissioning recycling (Vale/Heimdal, >95 percent target) is the main positive resource outflow. Waste outflow 2025: total waste generated 10,709 tonnes (9,405 hazardous + 1,304 non-hazardous; 2024: 9,163 tonnes); total recovered 648 tonnes; total non-recovered 10,061 tonnes (94 percent, up from 70 percent in 2024). "The majority of waste generated in DNO operations over the last couple of years relates to decommissioning activities and drilling operations," with drill cuttings the main hazardous stream.

Reference: page 32.

2025 waste data (equity share): hazardous 9,405 tonnes, non-hazardous 1,304 tonnes, total generated 10,709 tonnes (2024: 9,163 tonnes). Recovered: 355 tonnes hazardous + 293 tonnes non-hazardous = 648 tonnes. Non-recovered: 9,050 tonnes hazardous + 1,011 tonnes non-hazardous = 10,061 tonnes, i.e. 94 percent non-recycled (2024: 70 percent). "Drill cuttings represent the majority of the hazardous waste generated. In Kurdistan, these are stored onsite for periodic remediation, while in the North Sea they are sent to shore for treatment and disposal.

Reference: page 33.

Policies: the Code of Conduct (core values First, Fair, Firm; two of its six principles address safety and respect), the HSSE policy, the Diversity and Inclusion policy and the Major Accident Prevention policy. Human-rights commitments draw on the UN Global Compact, reinforced by an annual OECD-Guidelines-based assessment of DNO's own operations and value chain. The Managing Director is accountable for the Code of Conduct and HSSE policy Group-wide; the Diversity and Inclusion and Major Accident Prevention policies are implemented by management at all levels.

Reference: page 34.

Direct engagement through line management is "the most important channel," with the Chief Human Resources and Corporate Services Officer holding functional responsibility. In Norway, Working Environment Committees (required under the Working Environment Act, normally quarterly) and an agreement with trade union Tekna provide structured engagement; elsewhere DNO runs town halls, sessions with elected employee representatives (including an employee-elected safety representative) and employee-satisfaction surveys. Effectiveness "is assessed through... employee satisfaction surveys and the analysis of trends in reporting of concerns.

Reference: page 34.

"The general procedure for providing remedy is not set out in a formalized process... remedy is determined on a case-by-case basis." Employees raise concerns via line management, HR or a compliance officer, or through a confidential/anonymous whistleblowing channel that only the Head of Compliance can access; status is reported to the Managing Director quarterly and the Audit and Risk committee biannually.

Risk assessment, validated by the DMA, identified elevated injury risk for field workers and a risk that "female workers may feel isolated in a male-dominated environment.

Reference: page 34.

Actions focus on "formalizing policies and procedures covering all operational activities," with employee-survey feedback and the occupational health and safety management system surfacing areas needing change. "The policies and processes that DNO have in place... ensure the Group's own practices do not cause or contribute to material negative impacts on the workforce." HR (diversity/inclusion, training, performance) and business-unit HSSE staff carry this out as part of running costs.

Reference: page 34.

"The ambitions within each material area are set out below and these are primarily based on absolute ambitions, such as the ambition of zero serious health and safety incidents each year, rather than measures of progress from a base line." DNO frames its workforce commitments as standing absolute ambitions (health and safety, equal treatment, adequate wages) rather than numeric reduction targets against a baseline.

Reference: page 35.

Headcount 1,159 (2024: 1,070; +8 percent, mainly the Sval Energi acquisition), spanning 49 nationalities (2024: 39). Gender: male 989 (85 percent), female 170 (15 percent). By country: Norway 293, Kurdistan region of Iraq 795, UAE 67, UK 2, other 2. Permanent employees 1,058; temporary employees 101 (mostly international contractors and specialist consultants in the Middle East). By region: Middle East 864, North Sea 238, Corporate (Oslo) 57. Turnover was 4 percent (39 leavers; 2024: 5 percent, 55 leavers).

Reference: page 38.

Women were 15 percent of the total workforce (2024: 14 percent) and 33 percent of managerial, administrative and non-field roles (unchanged). The Board had three of seven members (43 percent) women and senior management three of nine (33 percent). By age band: under 30 = 11 percent (2024: 15), 30-50 = 72 percent (66), over 50 = 17 percent (19).

Reference: page 35.

"DNO aims to provide competitive wages to all our employees... Regular market assessments are conducted to ensure we are offering competitive wages to employees in each of the regions in which we operate." Employees are grouped by the Group's job ladder "to ensure fair compensation practices," and DNO states it ensures "all of our employees are paid an adequate wage that aligns with applicable benchmarks for their location." No quantified living-wage benchmark or gap figure is given.

Reference: DNO's own index lists S1-13 at page 38; substantive training content sits earlier, at pages 33-34.

No quantified training-hours metric (e.g. average hours per employee) is provided. Qualitative references: mandatory Code of Conduct training in the onboarding program for all new employees (page 33); leader training "to ensure discrimination is prevented" and that employees "are treated fairly and evaluated objectively" under the Diversity and Inclusion policy (page 33); and HR-team responsibility for "training and performance management" (page 34).

Reference: page 37.

Work-Related Accident Rate (TRIF) was 1.18 per million hours in 2025 (2024: 1.06) - employees 0 (2024: 0.49), contractors 2.88 (2024: 1.73) - above the IOGP 2024 industry average of 0.81. There were 5 work-related accidents (0 employees, 5 contractors, all Medical Treatment Cases; 2024: 4, of which 1 employee). Zero fatalities among employees or other workers in 2025 or 2024. Exposure hours totaled 4,232 thousand. In July 2025, drone strikes disrupted Tawke/Peshkabir operations with no casualties; mitigation was coordinated with the Kurdistan Regional Government.

Reference: page 38.

Gender pay gap: -76.3 percent (2024: -71.9 percent) - under DNO's own definition, "the difference of average pay levels between female and male employees, expressed as percentage of the average pay level of male employees," meaning average female pay exceeded average male pay by this margin. Annual total remuneration ratio: 20.1 (2024: 22.1) - the highest annual salary among permanent workers divided by the median.

Reference: page 37.

Incidents of discrimination (including harassment): zero in 2025 (2024: 3, all harassment, none escalated to the OECD National Contact Point). Complaints via the concerns-raising channel: 35 (2024: 32). "In 2025, DNO did not receive concerns on human rights violations and/or incidents in relation to our own workforce, nor did we incur any fines, penalties or compensation for human rights related issues.

Reference: page 39.

The Business Partner Code of Conduct applies to all suppliers and customers, requiring alignment with DNO's environmental/safety standards and internationally recognized employment practices (prevention of modern slavery and child labor, anti-discrimination, freedom of association, decent hours and living wages). Risk-based supplier assessment considers service type, geography, incident history, contract size and location; higher-risk suppliers face documented-policy review, preventive/mitigating measures and, where needed, audits. The Head of Compliance is accountable. "DNO did not identify any actual adverse impacts on human rights and decent working conditions in 2025 related to our value chain.

Reference: page 39.

At operated sites, value-chain workers are held to the same HSSE standard as employees, reinforced with Code of Conduct flyers; a pre-contract risk assessment includes dialogue with higher-risk suppliers, and audits are conducted against the Business Partner Code of Conduct. "Apart from this, DNO does not currently have in place any formalized processes to engage with value chain workers, but the Group is assessing whether any measures should be implemented." North Sea partner-operated sites are engaged through joint-venture governance and direct operator contact.

Reference: page 39.

Value-chain workers raise concerns via the same confidential channel described under Business conduct, signposted through the Code of Conduct on DNO's website. "DNO is currently exploring ways to ensure the effectiveness of the channel and assess awareness and trust in using it to raise concerns." Remedy for impacts DNO has caused or contributed to is determined case-by-case.

Reference: page 39.

A group-wide supplier risk-assessment system runs ahead of, and periodically after, contract signing across "nearly 1,000 suppliers worldwide." Higher-risk suppliers receive preventive/mitigating measures and corrective action where necessary. Kurdistan's contractor-vehicle IVMS rollout (shared with the own-workforce safety program) extends driving-behavior monitoring to contractors. "Concerning our suppliers, we aim to implement improved risk assessment tools to better visualize our supply chain risks, including but not limited to supplier employee wages.

Reference: page 39.

"DNO does not have any ESRS defined targets or metrics that are considered relevant to workers in the value chain as this area is managed through ongoing operational processes." This follows directly from the Actions section (S2-4) on the same page, which describes the group-wide supplier risk-assessment system as the operational process in question, run continuously rather than tracked against a numeric target or baseline.

Reference: page 40.

A Land Acquisition and Compensation procedure governs engagement with private landowners in Kurdistan when acquiring or leasing land, including a land-return risk assessment before handback, and a CSR projects procedure identifies community-benefit projects. Both mandate a local committee's involvement in decisions, "ensuring community voices are heard and fair compensation is provided," though neither explicitly references indigenous peoples or the UNGPs. "There have been no reported cases of breaches of the UN Guiding Principles... the ILO Declaration... or the OECD Guidelines... that involve affected communities during the year.

Reference: page 41.

Engagement centers on discussions with local leaders and authorities near the Tawke and Baeshiqa field areas, with frequency "depend[ing] on the need" rather than a fixed interval; the Country Manager Kurdistan leads it, though local leaders can also initiate contact via the CSR manager. "Based on the long history of consistent engagement and follow-up" (over 20 years), communities "have developed confidence in using this channel." In the North Sea, fisheries and other stakeholders engage through public consultation on discharge permits and field-development impact assessments.

Reference: page 41.

Landowner compensation for Kurdistan land use follows "local laws and government guidelines"; land is remediated before being returned to its owner, aligned to community and authority input. Concerns can be raised through authorities, local leaders or DNO's local CSR manager. In the North Sea, decommissioning and site restoration are governed by national Petroleum Acts and the OSPAR Convention (15 governments and the EU), which accounts for fishing-industry interests.

Reference: page 41.

Over 20 years, DNO's Kurdistan CSR function has funded infrastructure, agriculture, health and education projects, alongside prioritizing local recruitment and local suppliers. Actions on the negative land-use impact run case-by-case: "DNO does not currently have other specific actions planned as the Group deems the processes and procedures currently in place to be sufficient measures to mitigate and remediate any negative impacts identified.

Reference: page 41.

"DNO does not have any ESRS defined targets or metrics that are considered relevant to affected communities as this is considered a continuous process." Effectiveness is instead assessed "through continuous dialogue with local leaders and authorities" and observed community improvements.

Reference: page 41.

The Code of Conduct sets six principles: comply with laws and regulations; ensure a safe working environment; treat everyone with respect; act in DNO's best interest; ensure financial integrity; and take responsibility. Corporate governance is based on the Norwegian Code of Practice for Corporate Governance, the Articles of Association and the Public Limited Liability Companies Act. The Managing Director is accountable for implementation; the Head of Compliance monitors and verifies it. Breaches "will lead to disciplinary action"; the Code is publicly available on DNO's website.

Reference: page 42.

Procurement is managed "fairly and with transparency," under a supplier-conduct policy with "regular audits and assessments to monitor compliance." Due diligence runs both at contract signing and periodically thereafter, and environmental/social criteria are built into supplier selection. On payment timeliness: "Ensuring that our suppliers get paid in a timely manner is important to DNO... There are currently no legal proceedings against DNO related to late payments.

Reference: page 42.

A zero-tolerance bribery/corruption stance (Code of Conduct principle one) is backed by a dedicated anti-corruption policy, interactive training, business-hospitality approval and conflict-of-interest registration tools on the "My DNO Compliance" intranet. All staff take mandatory Code of Conduct training (covering anti-corruption, bribery and whistleblowing) every second year; supply chain and HR, identified as at-risk functions, receive additional face-to-face training, and "in 2025, all management personnel within these at-risk functions successfully completed the required training." A confidential whistleblowing channel feeds the Head of Compliance, with outcomes reported quarterly to the Managing Director and biannually to the Audit and Risk committee.

Reference: pages 42-43 (part of MDR-T/GDR-T disclosures; G1-3 Targets is a standalone DR only from the 2025/2026 ESRS - this FY2025 report was prepared under the 2023 ESRS).

"DNO has not set any targets in relation to its governance as the Group is focused on building a strong foundation through policies and processes. DNO has as an ambition to maintain zero material breaches related to business conduct." In the absence of a numeric target, effectiveness is tracked through quarterly reporting to the Managing Director and biannual reporting to the Audit and Risk committee on whistleblowing and investigation outcomes, and through the anti-corruption metrics table (35 tips received in 2025, two corruption-related, zero confirmed incidents).

Reference: pages 42-43.

During 2025, DNO's compliance team "received 35 tips on potential Code of Conduct violations via the confidential channel for reporting, of which two were related to suspicions of corruption or bribery... none of the tips resulted in substantiated cases of corruption or bribery." The reported metrics table shows zero confirmed incidents, dismissals, disciplinary actions, contract terminations, public legal cases, convictions or fines for anti-corruption/anti-bribery violations in both 2025 and 2024.

Reference: page 42.

"Ensuring that our suppliers get paid in a timely manner is important to DNO. Payment terms differ between jurisdictions and the maximum number of days until the due date is sometimes also a matter of negotiation. There are currently no legal proceedings against DNO related to late payments.