DOF Subea

DOF Governance structure

DOF's governance structure defines accountability, roles, and control mechanism across three risk and opportunity types: Strategic, Business and Operational. The process ensures risk and opportunity is managed through-out the organisation, at the appropriate point of the business cycle, by the teams with specific expertise to identify, assess and manage the risk type.

ROLES AND RESPONSIBILITIES IN RISK AND OPPORTUNITY MANAGEMENT

STRATEGIC RISK - associated with executing strategy; framing value creation and annual improvement programme. BUSINESS RISK - associated with corporate culture; adapting global model to regional environments and customs; local legal issues; regional management. OPERATIONAL RISK - associated with operations; planning and executing marine and subsea services.

GOVERNANCE STRUCTURE

• BOARD OF DIRECTORS
• AUDIT COMMITTEE
• EXECUTIVE MANAGEMENT
• REGIONAL AND BUSINESS UNIT MANAGEMENT TEAMS
• EXECUTION TEAMS

The Board of Directors, Executive Leadership and Audit Committee maintain oversight and treatment of overall risk and opportunity, set risk appetite, to deliver improved overall performance and sustainable success.

The Board of Directors

The board comprise of Svein Harald Øygard (Chair), Erik Bergöö (Vice chair), Harald Thorstein, Christine J. Morris, Daniela Davila, Adrian Geelmuyden and Kristin H. Holth as Directors.

Svein Harald Øygard - Chair Born in 1960. Joined DOF in 2023. Mr Øygard holds a degree in Economics (Cand.Oecon) from the University of Oslo. He is a business owner and independent advisor. Svein Harald has worked within the Norwegian Ministry of Finance, including as Deputy Minister. He has had multiple senior roles at McKinsey, including senior partner, and has held the title of senior partner in Sparebank1 Markets.

Erik Bergöö - Vice Chair
Born in 1978. Erik Bergöö was appointed as Vice Chair of the Board at the extraordinary general meeting on 26 July 2024. Mr. Bergöö holds a Master of Science (M.Sc.) in Industrial Engineering and Management. He is currently the Head of Shipping and Offshore Portfolio at A.P. Møller Holding A/S.

Harald Thorstein - Board Member Born in 1979. Joined DOF in 2023. Mr. Thorstein holds a MSc in Industrial Economics and Technology Management from NTNU, with specialisation in Finance and Optimalisation. He is the founder and owner of the London based advisory company Arkwright London Ltd.

Christine Morris - Board Member Born in 1966. Joined DOF in 2023. Ms. Morris holds a BS in Mathematics and an MS in Actuarial Sciences from UCL in Belgium, and an MBA from Stanford University. She has over 25 years of broad financial experience in business consulting, capital markets, accounting and financial operations.

Daniela Davila - Board Member Born in 1970. Joined DOF in 2023. Mrs. Davila is a Brazilian lawyer, and holds a bachelor's degree in law from PUC, Rio de Janeiro, Brazil, with LLM in Corporate Law and MBA in Petroleum Business. She is a senior partner and member of the board of directors of the Brazilian law firm Vieira Rezende Advogados.

Adrian Geelmuyden - Board Member Born in 1985. Joined DOF in 2024. Mr. Geelmuyden holds a BSc in economics from the Norwegian School of Economics. He is employed as an Investment Director with Seatankers Management.

Kristin H. Holth - Board Member Born in 1956. Joined DOF in 2024. Mrs. Holth holds a Bachelor's degree in Economics and Business Administration. With extensive high-level business experience, she has previously held several Executive Vice President positions at DNB Bank ASA.

Information provided to and sustainability matters addressed by the administrative, management and supervisory bodies is integrated into DOF's governance structure through:

Enterprise Risk Management Framework DOF's Enterprise Risk Management framework captures risk and opportunity in a coordinated, ongoing process to preserve and enhance value. In the framework, prioritised risks, opportunities, and material topics flow into strategy which is realised through the annual global improvement programme.

Review and Revision Mechanisms:

• Audit Committee
• Risk and Opportunity Review
• Double-Materiality Workshop
• Financial / Scenario Planning

DOF Risk and Opportunity Register Risks, opportunities and impacts associated with pillars: People, Planet, Prosperity and Principles

Material Topics Assessment The Board maintains oversight of material sustainability topics through regular review schedules and well-practiced routines to manage risk, capture opportunities, and assess material topics to enhance decision-making at every level of the organisation.

Quarterly and Monthly Reporting Financial/Investors stakeholders receive quarterly and monthly reports and investor presentations covering:

• GHG emissions reductions and Energy management
• Human rights and Labour practices
• Employee health, safety and security
• Employee diversity, engagement & inclusion
• Business model resilience
• Physical impact of climate change
• Business ethics
• Critical incident risk management

DOF implements due diligence processes across multiple areas:

Human Rights Due Diligence DOF continues our partnership with Slave Free Alliance to review our Human Rights exposure and as a result we have robust guidelines to ensure we do our best to manage the risks present in our industry. We conducted Human Rights due diligence and compliance audits in 2024.

Value Chain Due Diligence We have governance practices to safeguard labour conditions across the value chain through:

• Supplier Code of Conduct
• Oversight of performance and contractual issues
• Audits of suppliers
• Human Rights due diligence and compliance audits

Supply Chain Management DOF promotes responsible business practices and offers partnership on strategic issues through:

• Regular communication with suppliers
• Annual workshops
• Code of Business Conduct within contract terms
• Fair procurement strategy
• Supply Chain Managers Forum

Risk Management Due Diligence Due diligence is integrated into our Enterprise Risk Management process through:

• Risk assessments with customers
• Commercial/Business Acquisition Risk Reviews
• Project Risk Registers
• HAZID/HIRAs (Hazard Identification/Hazard and Risk Assessments)

The main concern is exposure to non-compliance labour and human rights practices through the use of short-term contracts and temporary employment through manning agencies, which may weaken worker's rights.

Enterprise Risk Management in DOF

DOF's Enterprise Risk Management framework captures risk and opportunity in a coordinated, ongoing process to preserve and enhance value. The framework ensures risk and opportunity is managed through-out the organisation, at the appropriate point of the business cycle, by the teams with specific expertise to identify, assess and manage the risk type.

Risk Management Framework Structure:

Strategic Risk - associated with executing strategy; framing value creation and annual improvement programme Business Risk - associated with corporate culture; adapting global model to regional environments and customs; local legal issues; regional management
Operational Risk - associated with operations; planning and executing marine and subsea services

Governance Structure for Risk Management:

• Board of Directors - maintains oversight and treatment of overall risk and opportunity, set risk appetite
• Audit Committee - supports Board oversight
• Executive Management - implements risk management strategies
• Regional and Business Unit Management Teams - manage regional risk and opportunity registers
• Execution Teams - implement operational risk controls

Risk Information, Communication and Reporting Transparent reporting to maximise communication of risk and opportunity to all stakeholders.

Review and Revision Mechanisms:

• Audit Committee reviews
• Risk and Opportunity Review processes
• Double-Materiality Workshop
• Financial/Scenario Planning

Internal Controls

• Project Risk Registers
• HAZID/HIRAs (Hazard Identification/Hazard and Risk Assessments)
• Commercial/Business Acquisition Risk Reviews
• Ethics Helpline to capture any non-compliance issues
• Data Security measures to ensure multiple-platform integrity through technology, processes and people

Risk Register Management DOF maintains a comprehensive Risk and Opportunity Register covering risks, opportunities and impacts associated with People, Planet, Prosperity and Principles pillars.

Regular review schedules and well-practiced routines manage risk, capture opportunities, and assess material topics to enhance decision-making at every level of the organisation.

How DOF creates value for stakeholders

DOF is structured around diversified strengths, offering both marine and offshore subsea services, a global footprint, and strong local networks. In 2024 the company worked with over 130 operators, subsea engineering companies and eight wind farm developers.

Business Model Overview

DOF is a leading provider of integrated subsea and marine services to the global offshore energy market. Established in Austevoll in 1981, DOF has continued a proud tradition of delivering safe and quality services to our customers.

Value Creation Process:

Our operations rely on:

• Investment and Development decisions
• Expert Team
• Natural Resources
• Offices & operational yards
• Financial Platform
• Technology
• Engineering
• Construction fleet and subsea assets
• AHTS and PSV fleet
• Skilled and dedicated personnel
• ROVs
• Survey and Inspection capabilities
• Diving services
• PROJECT MANAGEMENT

We offer customers:

• A purpose-built fleet and knowledgeable, dedicated core crews to support safe operations
• Regionally based vessels in a global fleet to provide flexibility and capability across a wide-range of operations, water depths and environmental conditions
• End-to-end customised project delivery. A single point of access to all project resources including design and engineering, vessels and marine management

Fleet Composition:

• Annual revenue: USD 1,513 million
• Operational history: +40 years
• 6 operating continents
• >5,000 people (3,800 people offshore)
• Fleet: 65 + 4 chartered in vessels, 1 CLV, 12 high end subsea vessels, 28 AHTS + AHTS with ROV/crane, 18 owned IMR CSV + 4 chartered-in, 6 PSVs

Regional Operations:

Value Chain Integration:

DOF operates across the full offshore energy value chain from exploration through to decommissioning, serving both:

• Offshore fossil fuel value chain (ESRS sectors EEU)
• Offshore renewable energy value chain (ESRS sectors MOU)

Services across value chain stages:

• UPSTREAM: Exploration + Investigation, Site Investigation + Fabrication
• DEVELOPMENT: Construction and installation
• PRODUCTION: Operations and maintenance
• DOWNSTREAM: Distribution + Marketing, End Use
• DECOMMISSIONING: Asset removal and recycling

Strategic Value Proposition:

DOF has a unique value proposition: owned and operated vessels, integrated subsea and marine services with in-house project management and engineering capability. Our reputation for teamwork, professionalism, and high-quality assets, built over forty-four years, attracts repeat business, new clients and allows us to expand into new segments.

Mission, Vision and Core Values: "We aspire to be a trusted and leading partner delivering integrated subsea and marine services globally for a sustainable utilisation of offshore energy and other subsea resources."

Strategic Priorities:

• Sustainable finance
• Maintain ESG leadership
• Global organisation
• Expand conventional services
• Grow renewables

Outcomes and Benefits:

• Circular business practices
• A safe, diverse and inspiring, inclusive workplace
• Lasting value for investors and a long-term competitive return on the investment
• Delivering our partner agreements
• Practices to support labour conditions across the value chain
• Contributing to the energy mix required by society

Stakeholder engagement

Across all areas of DOF's value chain, we engage with internal and external parties who are important to us and who may be directly or indirectly affected by our actions. The responsibility we have to engage stakeholder groups is not something we take lightly, and their valued input informs our decision-making processes and operations.

Stakeholder Engagement Framework:

Stakeholder Expectations:

Our Workforce: Meaningful work, equitable treatment and compensation, inclusivity, and ample development prospects for everyone

Value Chain Workers: Responsible business practices, and partnership on strategic issues to uphold adequate working conditions, secure employment, and fair wages through our supply chain

Customers: DOF to anticipate and deliver a vessel fleet and subsea services that prioritise responsible practices, meet operational requirements and complement supply chains from an ESG perspective

Suppliers: DOF to promote responsible business practices and offer partnership on strategic issues

Financial/Investors: DOF is expected to implement strategies, plans, and actions aimed at mitigating short- and long-term risks to the business model. They seek proactive measures to safeguard against potential threats and ensure sustained financial stability

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

DOF's Sustainability related Goals and Strategic Response:

Environment:

• Main Challenges: DOF's ability to reduce GHG emissions and meet stricter climate related regulations. DOF's business model must increasingly offer valued low-carbon solutions and support customers' decarbonisation targets. New opportunities regarding natural resources offshore other than oil and gas are key drivers for future organisation. Vessel overhauls and ship breaking contribute to generation of general and hazardous waste.
• Goals: Employ a Circular Economy approach to progress Decarbonisation roadmap. Energy management through digitalisation to optimise efficiency. Employee engagement to build knowledgeable culture and protect Ecosystem Health. Participate in industry forums for energy efficient solutions.
• ESRS Response: E1 Climate Change, E2 Pollution, E5 Circular Economy

Social - Own Workforce:

• Main Challenges: Occupational health, safety and security hazards are inherent in DOF's operations. Challenges encompass occupational illness, credible security threats or serious accident events. Developing, attracting, and retaining personnel with skills for new markets and growing assets is essential. Overcoming perceived barriers to inclusion and diversity in a male-dominant industry.
• Goals: Promote strong health and safety culture and robust safety system. Enhance DOF's diversity, inclusion and equitable working environment. Future Skills - Training and development. Continuity management through strategic succession planning. Continual review of remuneration.
• ESRS Response: S1 Own Workforce

Social - Value Chain:

• Main Challenges: Ensuring adequate working conditions, secure employment, and fair wages in the supply chain. Our geographical footprint exposes DOF to potential compliance issues across fundamental industry labour standards (ILO, MLC, UN Guiding Principles on Human Rights, Modern Slavery Act, Transparency Act). Main concern is exposure to non-compliance through short-term contracts and temporary employment through manning agencies.
• Goals: Control human rights exposure across value chain.
• ESRS Response: S2 Workers in the Value Chain

Governance:

• Main Challenges: Regulatory frameworks continue to evolve with increasing emphasis on sustainability and corporate responsibility. DOF's geographic footprint exposes the Group to various compliance risk sources relating to evolving and inconsistent legislative conditions across jurisdictions, including Tax, Taxonomies, ESG disclosures and Labour laws.
• Goals: Ensure robust tools and control mechanisms to support safe, legal and ethical decision making. Enterprise Risk Management process maintain compliance. Ethics Helpline to capture non-compliance issues. Data Security to ensure integrity and protect business information.
• ESRS Response: G1 Business Conduct

Integration with Business Model:

These material topics are integrated into DOF's strategic priorities:

1. Sustainable finance - addressing climate change and ESG requirements
2. Maintain ESG leadership - managing all material sustainability topics
3. Global organisation - ensuring consistent governance across regions
4. Expand conventional services - leveraging expertise while managing impacts
5. Grow renewables - capitalizing on energy transition opportunities

Risk and Opportunity Management:

Material topics flow into strategy through DOF's Enterprise Risk Management framework, which captures risk and opportunity in a coordinated process. Prioritised risks, opportunities, and material topics are realised through the annual global improvement programme.

Business Model Resilience:

DOF is positioning the organisation to become a segment leader in the renewables market, specifically Floating Offshore Wind (FOW) field development, while maintaining leadership in conventional energy services. This dual approach addresses both transition risks and opportunities in the evolving energy landscape.

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

Double Materiality Assessment Process:

Aligned with the CSRD framework, we have strengthened our double materiality assessment to identify the most critical sustainability topics for DOF. This assessment considers societal, environmental, and financial impacts.

DOF Double-Materiality Topics Scope: All sustainability matters affected by, or that affect, DOF.

Materiality Framework:

IMPACT MATERIALITY - Environmental and social impacts of DOF's activities FINANCIAL MATERIALITY - Sustainability matters that affect DOF's financial performance MATERIAL FROM BOTH PERSPECTIVES - Topics meeting both impact and financial materiality criteria

Enterprise Risk Management Integration:

DOF's Enterprise Risk Management framework captures risk and opportunity in a coordinated, ongoing process. The framework ensures material topics are identified and assessed at the appropriate point of the business cycle by teams with specific expertise.

Risk and Opportunity Register: DOF maintains a comprehensive Risk and Opportunity Register covering:

• Risks, opportunities and impacts associated with pillars: People, Planet, Prosperity and Principles
• Strategic Risk (associated with executing strategy)
• Business Risk (associated with corporate culture and regional adaptation)
• Operational Risk (associated with marine and subsea operations)

Assessment Methods:

Review and Revision Mechanisms:

• Audit Committee reviews
• Risk and Opportunity Review processes
• Double-Materiality Workshop
• Financial/Scenario Planning

Stakeholder Input Integration: Material topics are informed by stakeholder engagement across:

• Our own workforce through employee surveys and townhalls
• Customers through contract reviews and operational meetings
• Value chain workers through union negotiations and surveys
• Suppliers through regular communication and audits
• Investors through quarterly reporting and continuous dialogue

Governance Oversight: The Board of Directors, Executive Leadership and Audit Committee maintain oversight of the materiality assessment process and treatment of overall risk and opportunity to deliver improved overall performance and sustainable success.

Continuous Assessment: Regular review schedules and well-practiced routines manage risk, capture opportunities, and assess material topics to enhance decision-making at every level of the organisation.

Regional Risk Assessment: Regional and Business Unit Management Teams maintain regional risk and opportunity registers to capture location-specific material topics across DOF's global operations in:

• Atlantic region
• Asia-Pacific region
• North America region
• South America region

Project-Level Assessment: Execution teams implement:

• Project Risk Registers
• HAZID/HIRAs (Hazard Identification/Hazard and Risk Assessments)
• Commercial/Business Acquisition Risk Reviews

The insights gained from this assessment have enhanced our ability to track and report on material sustainability topics, highlighting key focus areas such as climate change, pollution prevention, resource efficiency, workforce conditions, and anti-corruption.

Based on DOF's materiality assessment, the following ESRS disclosure requirements are covered in the sustainability statement:

ESRS 2 – General Disclosures:

• All general disclosure requirements are covered as they apply to all undertakings

Environmental Standards:

• E1 Climate Change - Material topic covering GHG emissions, energy management, transition risks and opportunities
• E2 Pollution - Material topic covering air, water and soil pollution from operations
• E5 Resource Use and Circular Economy - Material topic covering waste management and circular business practices

Social Standards:

• S1 Own Workforce - Material topic covering employee safety, health, diversity, training and working conditions
• S2 Workers in the Value Chain - Material topic covering supply chain labour conditions and human rights

Governance Standards:

• G1 Business Conduct - Material topic covering business ethics, anti-corruption and governance practices

Topics Assessed as Not Material:

Based on DOF's double materiality assessment, the following topics were not identified as material for DOF's operations:

• E3 Water and Marine Resources - While DOF operates marine vessels, water consumption and marine resource impacts were not assessed as material
• E4 Biodiversity and Ecosystems - Biodiversity impacts were not identified as material through the assessment process
• S3 Affected Communities - Direct impacts on local communities were not assessed as material
• S4 Consumers and End-Users - DOF operates in B2B markets and direct consumer impacts were not material

Disclosure Coverage:

A detailed overview of our progress on material topics is available in the Sustainability Statement, which, together with this report, forms an integral part of this year's Management Report. The sustainability statement aligns with the EU Corporate Sustainability Reporting Directive (CSRD), reinforcing our commitment to transparency and accountability in non-financial reporting.

Assurance: In line with CSRD requirements, our sustainability statement is subject to limited assurance by an independent auditor, enhancing the integrity of our ESG-related data.

DOF is positioning the organisation to become a segment leader in the renewables market, specifically Floating Offshore Wind (FOW) field development, as part of our transition plan for climate change mitigation.

Transition Strategy:

DOF's business model must increasingly offer valued low-carbon solutions and support customers' decarbonisation targets. New opportunities regarding natural resources offshore other than oil and gas are key drivers for our future organisation and utilisation of our competence and assets.

Renewable Energy Growth: Our renewable energy organisation builds the structure, capability, and future assets incrementally to meet increasing demand in this segment. Transferable skills and assets were key in delivering fast-track cable solutions projects to international energy operators for offshore wind farms.

Decarbonisation Approach: Employ a Circular Economy (CE) approach to progress Decarbonisation roadmap to meet the Group's emissions reduction ambition.

Energy Management: Harness technology to digitalise operations, optimise energy efficiency and reduce consumption.

Industry Collaboration: Participate in industry forums to develop energy efficient and alternative fuel solutions.

Dual Market Strategy: DOF maintains leadership in conventional energy services while expanding into renewable energy, addressing both transition risks and opportunities in the evolving energy landscape.

Longer term outlook: I am confident the offshore floating wind market will provide additional opportunities to expand our backlog. Our focus will be to keep our people safe and deliver value to our stakeholders.

Employee Engagement: Build a knowledgeable culture, motivated to change behaviours, promote advocacy and protect Ecosystem Health.

Policies related to climate change mitigation and adaptation

DOF has disclosed one named policy that addresses climate change mitigation and adaptation:

Environment Impact Policy

Purpose:
To manage environmental aspects of DOF's operations and in the value chain.

Scope:
All onshore and offshore worksites and all individuals present on our sites.

Governance:
Accountable: CEO

Key content / principles:

• Climate change is understood as a significant environmental impact and risk that must be managed through the business management system
• Climate change adaptation and mitigation considerations are integrated into operational planning and risk assessment
• Fuel consumption and emissions are continuously monitored and optimised, even under challenging operational conditions such as harsh weather and longer voyages
• Assess and control the environmental impact of operations, benchmark fuel efficiency performance and monitor GHG emissions across the value chain
• Apply pollution prevention measures, focusing on emissions such as air pollution known to be detrimental to the environment
• Actively monitor and communicate performance to the industry and community
• Compliance with GHG-related regulations and industry best practices extends to Scope 3 emissions
• Environmental performance is continuously monitored and reviewed, ensuring alignment with evolving climate regulations, industry benchmarks and stakeholder requirements
• Consideration for environmental improvements is prioritised in new-build projects, supporting the adoption of lower-emission technologies and alternative fuels

Public availability:
BMS, SEEMP, Website, All DOF Worksites

Certification:
ISO 14001

Related policy documents:
CoBC (Code of Business Conduct), Garbage Management Plan

Monitoring implementation:
In line with ISO 14001 compliance. Environmental performance is continuously monitored and reviewed. The policy commits to actively monitoring and communicating performance to the industry and community, with transparent reporting within annual reporting mechanisms.

Actions and resources in relation to climate change policies

DOF's decarbonisation roadmap consists of five main decarbonisation levers ("measures"), evaluated per vessel based on type, operations, and operational area.

1. Optimizing operations with digital fleet and client support

Description: Focus on speed management and logistics, reducing non-ECO speed transit. 41 vessels connected at the end of 2024. Expected to be integrated with digital fleet by end of 2025.

Scope: Fleet-wide operational optimisation

Resources: Opex for 2024: USD 199,331

Expected outcomes: Estimated 2.5% emission reduction potential operating without having or acting on these insights

Status: Ongoing

Policy link: Environmental Impact Policy (ensuring environmental management in operational planning, assessing and controlling environmental impacts, monitoring environmental performance, considering environmental improvement areas)

2. Enhanced ship energy efficiency management programme (SEEMP)

Description: A long list of operational and technical improvement measures identified by operational teams and vessels, most being low-cost items. To be followed up as part of vessels' mandatory SEEMP with enhanced focus. Introduction of dedicated Opex funds allocated to cover the cost of energy efficiency measures, ensuring adequate funding without compromising other critical budget areas.

Scope: Fleet-wide energy efficiency improvements

Time horizon: Medium-term (part of vessels' annual budgets and Opex; currently not a significant part of vessels' total Opex)

Expected outcomes: Estimated 1.5% emission reduction potential compared to current state

Status: Ongoing; pending finalisation of emission reduction targets and climate transition plan

Policy link: Environmental Impact Policy (ensuring environmental management in operational planning, assessing and controlling environmental impacts, monitoring environmental performance, considering environmental improvement areas)

3. Biofouling management: antifouling products and robotic cleaning

Description: Invest in better antifouling products and robotic cleaning to reduce drag and fuel use.

Scope: Fleet-wide hull maintenance and efficiency

Time horizon: Short-term implementation for hull cleaning; medium- to long-term for advanced technologies

Resources: No specific Opex/Capex outside dry-docking programmes

Expected outcomes: Estimated 2.5% emission reduction potential compared to current state

Status: Ongoing

Policy link: Environmental Impact Policy (assessing and controlling environmental impacts, ensuring environmental management in operational planning)

4. Battery and hybrid system integration

Description: Focus on dynamic positioning (DP) vessels. Systems expected to reduce fuel consumption and emissions by optimizing engine loads and allowing fewer engines to be used during operations. Subsea and construction vessels, which spend substantial time in DP mode, prioritized for battery system implementation.

Scope: Selected vessels within the fleet (15 priority vessels identified)

Time horizon: Long-term investment; medium-term implementation after approval

Resources: No current Opex/Capex allocated; no committed projects yet

Expected outcomes: Estimated 11-13% fuel/emission reduction potential

Status: Identified 15 priority vessels

Policy link: Environmental Impact Policy (assessing and controlling environmental impacts, ensuring environmental management in operational planning)

5. Biofuel adoption

Description: Some vessels capable of running on HVO. Evaluated case-by-case.

Scope: Selected vessels within fleet (to be determined based on commercial and technical feasibility)

Time horizon: Medium- to long-term solution

Resources: No current Opex/Capex allocated

Expected outcomes: Estimated 5-10% reduction (up to 90% with full HVO use)

Status: Under evaluation

Policy link: Environmental Impact Policy (assessing and controlling environmental impacts, ensuring environmental management in operational planning)

Integration with vessel impairment testing

Analysis of measures necessary to achieve DOF decarbonisation ambitions has been used as basis for the impairment test for vessels. Potential implementation of battery systems together with other measures such as minor efficiency upgrades, digital tools, and hull cleaning, are the key elements taken into account in the impairment model for vessels.

Management within Global Improvement Programme

Decarbonisation activities are controlled and managed in the Global Improvement Programme, with progress continuing in 2024. The Board, Executive Management and EVP Sustainability conduct an annual review of the Global Improvement Programme, agree priorities for the next strategic period, and set targets related to material IROs. Progress is monitored through a quarterly review process.

Targets related to climate change mitigation and adaptation

DOF does not currently have climate change mitigation and adaptation targets that can be presented in a transition plan using absolute emission reduction in line with the Paris Agreement.

Current Ambition

Overall ambition in DOF's decarbonisation roadmap: "40% energy efficiency by 2030, compared to 2008"

• Target metric: Energy efficiency improvement
• Target value: 40% improvement
• Target year: 2030
• Baseline year: 2008
• Target type: Intensity-based (energy efficiency)
• Scope: Not specified
• Science-based/Validation: Not specified as science-based or externally validated
• Progress to date: Not reported

Limitations and Future Plans

The company acknowledges that this ambition "does not offer easy comparability or progress tracking." Work is underway to define CO2e-based targets to align with this ambition in order to report on the targets and work in line with the ESRS requirements. The company's intention is to conclude on these targets during 2025.

Action-Level Estimated Impacts

While not formal targets, the company has identified estimated emission reduction potentials from specific actions:

• Optimizing operations with digital fleet: ~2.5% emission reduction potential
• Enhanced ship energy efficiency management programme (SEEMP): ~1.5% emission reduction potential
• Biofouling management: ~2.5% emission reduction potential
• Battery and hybrid system integration (15 priority vessels): 11-13% fuel/emission reduction potential

Energy consumption and mix

E1-5 Energy consumption and mix

DOF's primary source of energy consumption is marine gas oil (MGO) on board vessels. The conversion factor used is DEFRA for the respective years 2022, 2023, 2024. As DOF has not purchased any Renewable Energy Certificates (RECs), purchased electricity, heat, steam and cooling is allocated within fossil sources.

Note: Line 2, Fuel consumption from crude oil and petroleum products (MWh) for 2022 and 2023 has been recalculated according to new scope boundaries (see E1-6 for further details).

Energy intensity

DOF's activities have been evaluated to be related to NACE sections B (Mining and Quarrying), F (Construction) and H (Transportation and Storage). These sections are high climate impact sectors. Thus, the energy intensity is based on the Group's total energy consumption and total net revenue.

Gross Scopes 1, 2, 3 and Total GHG emissions

Scope 1 GHG emissions

Methodology: Scope 1 emissions are calculated by multiplying fuel consumption from vessels with an internationally recognised emission factor. The emissions have not been validated by an external body other than the assurance provider. Scope 1 emissions originate from combustion of Marine Gas Oil (MGO) on board vessels where DOF has operational and/or financial control.

Scope boundary change: DOF previously reported according to GHG Protocol with operational control to determine if a vessel's emissions are accounted in Scope 1 or Scope 3. With ESRS requirements, emissions are accounted in Scope 1 based on operational control and/or ownership. Thus, a large part of DOF's Scope 3 emissions have changed to Scope 1 compared to previous years. For consistent comparability, 2023 emissions have been reallocated according to the 2024 methodology. All vessels where DOF has operational and/or financial control are now allocated in Scope 1. In addition, six vessels owned by Joint Venture (DOFCON Brasil AS) are now allocated in Scope 3 category 15 Investments by JV ownership share (50%).

Scope 2 GHG emissions

Methodology: Scope 2 emissions are calculated by multiplying consumption of purchased electricity, district heating/cooling, or heat natural gas, by internationally recognised emission factors. The emissions have not been validated by an external body other than the assurance provider. Scope 2 emissions originate from purchased electricity, heating and cooling for offices/workshops, and vessel shore power.

Scope 3 GHG emissions

Scope 3 calculation methodology and boundaries:

Categories determined not material:

• Category 7 (Employee commuting): The majority of DOF's workforce are offshore and the travel emissions are included in category 6.
• Category 8 (Upstream leased assets): Third-party vessels leased by DOF are reported in Scope 1 due to DOF's operational control of the vessel.
• Category 9 (Downstream transportation): Any transportation performed by DOF's vessels is included in Scope 1 emissions.
• Categories 10, 11, 12 (Processing, use, and end-of-life of sold products): DOF does not sell products.
• Category 13 (Downstream leased assets): Due to the ownership of vessels that DOF lease out, they are reported in Scope 1.
• Category 14 (Franchises): DOF does not have franchises.

Spend-based methodology: Some Scope 3 categories were calculated using spend-based methods, facilitated by Ignite Procurement's carbon accounting module, which utilizes Climatiq for emission factor data. All transactional data for 2024 was matched to EXIOBASE 3 emission factors and adjusted for inflation and currency fluctuations by Climatiq. This methodology was applied to Categories 1 (purchased goods and services), 2 (capital goods), and, in part, Category 4 (upstream transportation and distribution). To enhance accuracy, taxes, trade margins, and freight costs were excluded from expenditure calculations to align with EXIOBASE's basic price model.

Total GHG emissions

GHG intensity based on net revenue

Note on intensity: The activities performed by DOF have been evaluated to be related to NACE sections B (Mining and Quarrying), F (construction) and section H (transportation and storage). These sections are high climate impact sectors. Thus, the energy intensity is based on the Group's total energy consumption and total net revenue.

Biogenic CO₂ emissions

Not disclosed separately.

Regulated emissions (EU ETS)

0% of Scope 1 GHG emissions from regulated emissions trading schemes (2023: 0%, 2024: 0%).

Emission factors used

DEFRA (2024) for Marine gas oil (MGO) (includes gases CO₂, CH₄, N₂O). IEA (2024), AIB (2024), Green-e (2024), DCCEEW (2024) for electricity by region. Ecoinvent 3.11 for residual waste incinerated. DEFRA (2024) for WTT emissions and heat natural gas. Detailed emission factor sources are provided in the report by Scope and item.

Physical and Transition Risk Considerations:

The Group remains vigilant in addressing geopolitical risks beyond the conflicts in Ukraine and in the Middle East. This requires heightened risk mitigation measures, reinforcing a commitment to robust enterprise risk management processes aligned with global standards.

Climate-related Business Model Resilience:

DOF's business model must increasingly offer valued low-carbon solutions and support customers' decarbonisation targets. New opportunities regarding natural resources offshore other than oil and gas are key drivers for our future organisation and utilisation of our competence and assets.

Market Transition Opportunities:

Longer term, I am confident the offshore floating wind market will provide additional opportunities to expand our backlog. DOF is positioning the organisation to become a segment leader in the renewables market, specifically Floating Offshore Wind (FOW) field development.

Energy Transition Financial Impact:

The Group's strategy covers the services we provide to our Conventional Energy and Offshore Wind industries. It is informed by our relationships with our customers and designed to meet their sustainable management requirements and build awareness of our services sustainable attributes.

Physical Climate Risks:

DOF's risk profile prioritises the decarbonisation of operations into the future, to adapt and build a resilient business model against climate change physical and transition risks.

Strategic Response:

Our strategic priorities include:

• Sustainable finance
• Maintain ESG leadership
• Expand conventional services
• Grow renewables

These priorities address both the financial opportunities from energy transition and the risks from climate change impacts on operations.

Policies related to pollution

DOF Subea discloses one policy related to pollution prevention:

Environment Impact Policy

• Purpose: Pollution prevention, waste reduction
• Scope: All onshore and offshore worksites and all individuals present on DOF sites
• Governance: CEO is accountable for the policy
• Public availability: Available in Business Management System (BMS), Ship Energy Efficiency Management Plan (SEEMP), Website, and all DOF worksites
• Related policy documents: Works in conjunction with Code of Business Conduct (CoBC) and Planet Manual
• Certification: The policy is part of DOF's ISO 14001 certified environmental management system
• Key content: The Environmental Impact Policy governs pollution prevention and environmental impact minimisation. It specifically addresses the identified impact, risk and opportunity (IRO) of "major pollution events because of spills". The Policy and adherence to ISO 14001 provides a structured approach to identify, address and monitor environmental risks such as offshore spill pollution events.
• Implementation approach: DOF's strategic approach to pollution addresses main challenges through:
  • Applying industry best practice standards and pollution prevention methodologies
  • Open stakeholder communication
  • Supporting upstream and downstream value chain waste reduction targets
• Monitoring: Information is gathered via UNISEA and incident reports to collate information on spill events, including volumes, locations and the level of containment. Pollution events are reported according to the Global Standard - Non-Conformity and Incident Management. All spill incidents are reported directly from vessels through an event flash application to relevant stakeholders. Significant incidents trigger formal investigation and reporting to regional regulators.

Actions and resources related to pollution

DOF discloses four key actions to address pollution, all integrated into its Business Management System and aligned with its Environmental Impact Policy.

1. Proactive Risk Management

Description: Prevention of pollution events through rigorous risk management practices as outlined in the Business Management System, including comprehensive project planning, risk assessments, and emergency response planning to reduce or mitigate pollution spill risks. Maintains robust emergency response framework including vessel emergency response procedures, SOPEP, Project Emergency Response Plans, and contract management standards.

Scope: Fleet-wide pollution risk management

Time horizon: Continuous, as part of Business Management System

Corresponding Policy Element:

• Ensure environmental management is given equal consideration throughout all operational planning and undertaking
• Consider all environmental incidents to be preventable and make all efforts to meet the target of zero spill to the external environment

Resources allocated: Not quantified

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2. Crew Training and Preparedness

Description: Regular crew training in shipboard pollution emergency plans (SOPEP/SMPEP), including periodic drills and simulations. SOPEP/SMPEP drills scheduled quarterly on all vessels as required by vessel Drill Matrix.

Scope: Fleet-wide crew training and emergency preparedness

Time horizon: Ongoing, continuously monitored as part of vessel assurance processes

Corresponding Policy Element:

• Ensure environmental management is given equal consideration throughout all operational planning and undertaking
• Consider all environmental incidents to be preventable and make all efforts to meet the target of zero spill to the external environment
• Apply applicable laws and regulations and where deficient apply company and industry best practice

Resources allocated: Not quantified

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3. Reducing Liability

Description: Insurance policy designed to limit liability for pollution events by focusing on specific areas of responsibility. Company only accepts liability for pollution caused by its own equipment and vessels, explicitly excluding liability for pollution from underground reservoirs, permanent installations, or uninsurable risks. Pollution liabilities passed down to vendors on a knock-for-knock basis. Indemnities for pollution reviewed against relevant insurance policy.

Scope: Across Group, unless otherwise authorised according to authority matrix

Time horizon: Ongoing, as part of Business Management System

Corresponding Policy Element:

• Apply applicable laws and regulations and where deficient apply company and industry best practice
• Assess and control the aspects and impacts of our operations upon the environment

Resources allocated: Not quantified

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4. Supply Chain Management

Description: Mechanisms in pre-qualification and tendering processes ensure upstream areas of value chain follow the same preventative and mitigation measures for pollution control. Includes desktop reviews of pre-qualification documentation, audits, onsite inspections, and monitoring based on criticality of subcontracted work scopes. During execution phases, monitoring and follow-up based on scope of work and criticality.

Scope: Upstream value chain compliance with pollution controls

Time horizon: Ongoing, as part of Business Management System (reference to ESRS S2)

Corresponding Policy Element:

• Apply applicable laws and regulations and where deficient apply company and industry best practice
• Ensure environmental management is given equal consideration throughout all operational planning and undertaking
• Assess and control the aspects and impacts of our operations upon the environment

Resources allocated: Not quantified

Targets related to pollution

Target: Minimize offshore spill pollution events

Target metric: Number of significant spills to the environment per million manhours

Target value: Less than 4 significant spills per million manhours

Ambition: Zero significant spills released to the external environment

Definition of significant spill: Any loss of secondary containment over 50 litres

Scope: Entire asset base including owned and chartered vessels (fleet-wide)

Target type: Intensity-based (per million manhours)

Baseline year: Not disclosed

Baseline value: Not disclosed

Target year: Not disclosed

Science-based / External validation: Not mentioned; targets are not based on conclusive scientific evidence (as stated)

Governance: Target has been set within the Global Improvement Program and agreed upon by the Executive Management team

Progress to date: Not disclosed

Monitoring: Information gathered via UNISEA and incident reports; spill events reported according to Global Standard - Non-Conformity and Incident Management; all spill incidents reported directly from vessels through event flash application

Related metrics tracked:

• Total volume of all spills
• Loss of secondary containment volumes (absolute metric)
• Number of significant spills per million manhours (relative metric)

Pollution of air, water and soil

DOF evaluated its direct value chain to determine its environmental impact. It concluded it does not emit pollutants exceeding the threshold values specified in Annex II of Regulation EC No 166/2006 as part of planned or foreseeable discharges. This assessment accounts for emissions and pollutants emanating from all facilities under our direct operational control.

While DOF does emit GHG pollutants from the combustion of marine diesel oil, these emissions are reported in detail within the ESRS E1 sustainability statements.

To ensure compliance with MARPOL Annexes II and III, DOF reviewed relevant compliance documents and evaluated all spill events that resulted in a breach of secondary containment. The company has determined that no Annex II pollutants were emitted in these incidents.

Spills to water

Number of significant spills (over 50 litres):

Number of significant spills (over 50 litres) per million manhours:

Spill performance volume per year (loss of secondary containment in Litres):

DOF was not subject to any fines in relation to spill pollution events.

Microplastics

Although microplastics generated in our value chain are not specifically measured, operations were assessed and concluded there are no significant sources of this pollutant.

Monitoring methodology

All discharges to the sea, whether planned or unplanned, are strictly regulated and monitored. The company uses a combination of vessel or asset flow meters, sensors, alarm systems, and CCTV systems to identify and estimate discharges. Information is gathered via UNISEA and incident reports to collate information on spill events, including volumes, locations and the level of containment. Compliance is verified periodically by class society and through internal ISM audits.

Anticipated financial effects from pollution-related impacts, risks and opportunities

DOF exercises the right, as per the ESRS Phase-in option, to begin reporting on this disclosure in the subsequent year.

Material pollution-related risk identified

DOF has identified one material pollution-related financial risk in its IROS assessment:

Financial exposure in offshore spills: A significant offshore spill event may expose DOF to financial liabilities. This is classified as a potential risk affecting direct operations, with no specific time horizon disclosed in the assessment table.

Risk management approach

While DOF has not provided quantified financial effects, the company has outlined its risk management framework:

• DOF's insurance policy is designed to limit liability for pollution events by focusing on specific areas of responsibility
• The company only accepts liability for pollution caused by its own equipment and vessels, explicitly excluding liability for pollution from underground reservoirs, permanent installations, or uninsurable risks
• Pollution liabilities are passed down to vendors on a knock-for-knock basis, ensuring that DOF is not left with uninsured risks if a vendor fails to insure for pollution
• Any indemnity for pollution must be carefully reviewed against the relevant insurance policy to ensure it provides adequate coverage
• This approach helps DOF manage potential pollution risks and claims effectively, safeguarding the company from significant financial exposure

Policies related to resource use and circular economy

DOF has disclosed one policy related to circular economy and resource use:

Environment Impact Policy

Purpose:

• Waste reduction and efficient use of natural resources
• Adherence to the waste hierarchy
• Avoid the inefficient use of natural resources
• Comply with relevant legislation

Scope:

• All onshore and offshore worksites and downstream suppliers

Governance:

• Accountable: CEO

Public availability:

• Business Management System (BMS)
• Garbage Management Plan
• Website
• All DOF Worksites

Related policy documents:

• Code of Business Conduct (CoBC)
• Planet Manual

Certification:

• ISO 14001

Implementation monitoring:

DOF employs various processes to track the effectiveness of policies related to the circular economy:

• Regular waste generation monitoring and disposal records via UNISEA
• Internal and external audits of onboard waste management practices
• Analysis of operational data to identify areas for improvement
• Tracking number of incidents related to non-compliance with the garbage management plan
• Safety observation card system
• IMO-approved garbage management plan

During the reporting period, one non-conformity was recorded related to waste management and compliance with the IMO garbage management plan. An internal catering inspection identified waste collection facilities in the kitchen and galley area were not labeled and legible as per the garbage management plan.

Strategic approach:

DOF's strategic approach to circular economy uses two levers:

• Industry best practice standards and pollution prevention methodologies
• Environmental improvement during projects and new buildings

Actions and resources related to circular economy

Garbage and Waste Management Plans

Description: All vessels in the fleet have a garbage management plan that prioritises waste reduction, recycling, and responsible disposal. The plan minimises waste generation, seeks to reuse materials where possible, and segregates waste streams to maximise proper processing when waste is transferred from the vessel.

Scope: Fleet-wide application of Garbage Management Plan. Project HSE Management Plans established on an ad-hoc basis related to the nature and level of Project.

Time horizon: Ongoing, as part of Business Management System

Resources allocated: Not quantified

Link to policy: Environmental Impact Policy:

• Ensure environmental management is given equal consideration throughout all operational planning and undertaking
• Assess and control the aspects and impacts of our operations upon the environment
• Apply applicable laws and regulations and where deficient apply company and industry best practice
• Reduce and restrict the production of waste products known to be detrimental to the environment
• Minimise our impact on the environment through pollution prevention, efficient use of natural resources and the reduction and recycling of waste

Expected outcomes: Vessel-specific Garbage Management Plans provide the framework for optimal waste sorting, enabling the appropriate treatment of waste streams once disembarked. Waste transfer notes are maintained to document the handover of disposal responsibilities to third-party carriers. All waste discharges are recorded in the Garbage Record Book, detailing the date, vessel position, quantity and type of waste, and its point of discharge.

Current performance (2024): Total waste generation of approximately 120,401 metric tonnes, consisting of:

• 15,337 metric tonnes hazardous waste
• 105,063 metric tonnes non-hazardous waste
• 106,398 metric tonnes discharged at sea under MARPOL Annex V
• 529 metric tonnes incinerated using MARPOL Annex VI-compliant incinerators

Targets related to circular economy

DOF has not established measurable targets for resource use and circular economy due to the operational constraints of reducing daily waste without affecting integrity.

Company Statement

As disclosed in the sustainability statement:

"DOF has not established measurable targets for resource use and circular economy due to the operational constraints of reducing daily waste without affecting integrity. Waste generation is the key impact, and additional targets will be assessed when shipbuilding or asset decommissioning activities occur."

Approach Instead of Targets

While no quantified targets are set, DOF employs various processes to track the effectiveness of policies related to the circular economy and actions related to controlling circular economy impacts, risks, and opportunities, including:

• Regular waste generation monitoring and disposal records via UNISEA
• Internal and external audits of onboard waste management practices
• Analysis of operational data to identify areas for improvement
• Tracking incidents related to non-compliance with the garbage management plan
• Safety observation card system

Environmental Ambition

The Environmental Impact Policy states the ambition to:

• Adhere to the waste hierarchy
• Avoid the inefficient use of natural resources
• Comply with relevant legislation

Note: The company indicates that additional targets will be assessed when shipbuilding or asset decommissioning activities occur.

Circular Economy Financial Considerations:

Vessel overhauls and ship breaking contribute to the generation of general and hazardous waste, which represents both a cost and an opportunity for circular business practices.

Circular Business Practices:

DOF aims to employ a Circular Economy (CE) approach as part of our decarbonisation roadmap to meet the Group's emissions reduction ambition. This includes:

• Optimising vessel lifecycle management
• Implementing waste reduction strategies
• Exploring opportunities for material reuse and recycling
• Participating in industry forums to develop more sustainable solutions

Strategic Integration:

Circular business practices are integrated into our strategic priorities and represent one of the key outcomes and benefits we deliver to stakeholders, alongside:

• A safe, diverse and inspiring, inclusive workplace
• Lasting value for investors and long-term competitive return on investment
• Delivering our partner agreements
• Practices to support labour conditions across the value chain
• Contributing to the energy mix required by society

Resource Efficiency Focus:

The insights gained from our materiality assessment have highlighted resource efficiency as a key focus area, supporting our commitment to circular economy principles in our operations and asset management strategies.

Waste

Waste Management Approach

DOF's Environmental Impact Policy governs waste reduction and efficient use of natural resources. The policy covers all onshore and offshore worksites and downstream suppliers, with certification to ISO 14001.

The company employs a Circular Economy (CE) approach across the lifespan of assets to meet emissions reduction ambitions and minimise resource use. DOF adheres to the waste hierarchy, seeks to avoid the inefficient use of natural resources, and complies with relevant legislation.

All vessels in the fleet have a garbage management plan that prioritises waste reduction, recycling, and responsible disposal. The plan minimises waste generation, seeks to reuse materials where possible, and segregates waste streams to maximise proper processing when waste is transferred from the vessel.

Project documentation such as Health, Safety and Environmental Management Plans assist DOF with the management of project-specific wastes or managing waste streams in remote or sensitive environments.

DOF tracks the effectiveness of waste management measures by identifying the number of incidents related to non-compliance with the garbage management plan, and through the safety observation card system.

During the reporting period, one non-conformity was recorded related to waste management and compliance with the IMO garbage management plan. An internal catering inspection identified waste collection facilities in the kitchen and galley area were not labeled and legible as per the garbage management plan.

Quantitative Waste Data

E5-5 Non-recycled waste paragraph 37 (d) is listed as Material on page 66 in the disclosure index.

E5-5 Hazardous waste and radioactive waste paragraph 39 is listed as Material on page 66 in the disclosure index.

However, the actual quantitative data tables for E5-5 appear to be truncated in the provided excerpts. The content cuts off before the detailed waste metrics are presented.

Scope 3 Waste Emissions

Within Scope 3 emissions reporting:

5. Waste generated in operations

• 2023: 365 tCO2eq
• 2024: 250 tCO2eq
• Change: -31%

Methodology: Activity-based (Amount x emission factor)

Reporting boundary: Waste incinerated on own and managed vessels; waste incinerated on 3rd party vessels where DOF has operational control.

Policies related to own workforce

DOF's policies governing its own workforce are embedded in its Business Management System (BMS) and align with the UN Guiding Principles for Business and Human Rights, OECD Guidelines for Multinational Enterprises, and ILO Declaration on Fundamental Principles and Rights at Work. The company has established comprehensive policies covering working conditions, human rights, occupational health and safety, equal opportunities, and other work-related rights.

Business Management System (BMS)

Purpose: Manages all aspects of DOF's operations and value chain.

Scope: All employees, onshore and offshore worksites, and downstream suppliers.

Governance: Accountable to the CEO and the Board.

Availability: Available through BMS, website, and all DOF worksites.

Review: Annual management review process.

Alignment: UN Guiding Principles for Business and Human Rights, OECD Guidelines for Multinational Enterprises, ILO Declaration on Fundamental Principles and Rights at Work, and local legislation.

Monitoring: Mechanisms to monitor compliance with international instruments described throughout S1-1.

Equal Employment Opportunity Policy

Purpose: To support fair and equal treatment for applicants and employees, free association and collective bargaining. Ensures working hour requirements are upheld and fair compensation for all employees.

Works with: Code of Business Conduct (CoBC), Human Resources Policy, Global Standard on Recruitment Management.

Key content: Working hour requirements and timely payment of wages according to national legal standards or industry benchmarks.

Human Resources Policy

Purpose: Support employees to reach their full potential and ensure employees exemplify DOF's vision and values.

Works with: CoBC, Global Standard Recruitment Management, Equal Employment Opportunity Policy.

Key content: Compliance with local legislation.

Code of Business Conduct (CoBC)

Purpose: The blueprint for conducting business ethically and responsibly, including human rights, diversity, zero tolerance for bribery and corruption, transparency, anti-money laundering laws compliance, and protection of personal data.

Scope: All employees, onshore and offshore worksites, value chain workers, and downstream suppliers.

Governance: Accountable to the CEO and the Board.

Availability: BMS, website, all DOF worksites.

Review: Annual management review process.

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

Business Integrity and Ethics Policy

Purpose: Outlines core values, business conduct and behaviours expected in DOF companies and employees to protect and build DOF's reputation.

Scope: All employees, business units and operations.

Governance: Accountable to the CEO and the Board.

Availability: BMS, website, all DOF worksites.

Review: Annual management review process.

Alignment: UN Guiding Principles for Business and Human Rights and OECD Guidelines for Multinational Enterprises.

Transparency Act Statement

Purpose: Promote DOF's respect for fundamental human rights and decent working conditions across operations and ensure the general public access to information regarding how adverse impacts on fundamental human rights and decent working conditions are addressed.

Scope: All employees, onshore and offshore worksites, value chain workers, and downstream suppliers.

Governance: Approved by the Board.

Availability: BMS, website, all DOF worksites.

Review: Annual management review process to meet June 30th update deadline in accordance with §5 in "Åpenhetsloven".

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

UK Modern Slavery Statement

Purpose: To respect and protect human rights, prohibit all acts of modern slavery, including use of forced and child labour.

Scope: All employees, onshore and offshore worksites, value chain workers, and downstream suppliers.

Governance: Approved by the CEO and the Board.

Availability: BMS, website, all DOF worksites.

Review: Annual management review process.

Alignment: The full human rights/anti-slavery policy suite, UN Guiding Principles for Business and Human Rights, OECD Guidelines for Multinational Enterprises, and ILO Declaration on Fundamental Principles and Rights at Work.

Health, Safety and Working Environment Policy

Purpose: To manage a safe and healthy working environment.

Scope: All onshore and offshore worksites and all individuals present on DOF sites.

Governance: Accountable to the CEO.

Availability: BMS, website, all DOF worksites, Occupational Health and Safety e-learning module.

Works with: CoBC, Supplier Code of Conduct (SCoC), Security Policy.

Certification: ISO 45001 and BMS under ISO 45001:2018.

Security Policy

Purpose: To manage safety and protect personnel, physical assets, and intellectual property.

Scope: All onshore and offshore worksites and all individuals present on DOF sites.

Governance: Accountable to the CEO.

Availability: BMS, website, all DOF worksites.

Works with: CoBC, SCoC.

Workplace Harassment Policy

Purpose: Supports a zero-tolerance policy for any form of harassment in the workplace.

Scope: All employees, onshore and offshore worksites, value chain workers.

Governance: Accountable to the CEO and the Board.

Availability: BMS, website, all DOF worksites.

Works with: CoBC, Dignity & Respect guide, Equal Employment Opportunities policy.

Information Technology and GDPR Compliance Standard

Purpose: Uphold General Data Protection Regulations (GDPR) and other legislative requirements such as Lei Geral de Proteção de Dados (LGPD) in Brazil.

Scope: All employees, business units and operations.

Governance: Accountable to DOF Group Executive Management.

Availability: BMS.

Works with: CoBC, SCoC, the International Ship and Port Facilities Security Code (ISPS), Recruitment Management Standard.

Grievance Mechanisms

DOF operates a comprehensive grievance procedure through its ethics helpline operated by a third party, aligned with the UN Guiding Principles on Business and Human Rights effectiveness criteria. The system allows anonymous or identified reporting and is accessible through the portal, management systems, website, and onboard vessels. The company has a non-retaliation policy protecting reporters. Alternative channels include supervisors, senior staff, HR managers, legal department, employee representatives, unions, and work environment committees. A dedicated channel for human rights violations is referenced in the Transparency Act statement.

Monitoring and Implementation

DOF monitors policy implementation through:

• Annual management review processes
• ISO 45001 certification audits (yearly interim and three-yearly recertification by DNV)
• Ethics helpline compliance reports
• Employee engagement surveys (2024 survey showed 91/100 awareness of reporting channels and 87/100 trust in reporting mechanisms)
• Global Improvement Programme tracking
• Power BI reporting dashboards
• Quarterly performance reports
• Entity-specific occupational health and safety targets
• Work environment committee yearly reports

Engagement Channels with Own Workforce:

DOF engages with employees and contractors through multiple channels:

• Annual Employee satisfaction surveys - Regular assessment of employee experience and engagement
• Regular Townhall meetings - Direct communication forums with management
• Organisational development workshops - Collaborative development sessions
• Performance Appraisals - Individual feedback and development planning
• Intranet/DOF portal - Digital communication platform
• Ethics Helpline - Channel for reporting concerns
• Union negotiations - Formal worker representation processes
• Surveys and feedback sessions - Regular feedback collection
• Training and capacity-building programmes - Skills development initiatives

2024 Engagement Initiatives:

• Employee engagement survey - Comprehensive workforce assessment
• HR Employee Survey improvement plans - Action plans based on survey results
• Diversity and inclusion committee and plan - Structured approach to D&I
• Workplace safety environment focus - Enhanced safety culture initiatives
• Offshore Leader's Conference Safety workshop - Leadership development in safety
• Dignity and respect in the workplace guide - Behavioral guidance and standards

Worker Representatives:

DOF engages with workers through:

• Union negotiations
• Other worker representatives
• Formal consultation processes

Key Engagement Topics:

• Safety, security, health and wellbeing
• Business model resilience and emissions management
• Sustainable finance
• Business ethics and compliance
• Employee wellbeing, experience and engagement
• Equality and diversity
• Training and development

Speak Up Culture:

Following 2023 industry and company surveys related to harassment, we identified a need to strengthen our "Speak Up" and "Stop Work" culture and rolled-out DOF's "Dignity & Respect" campaign focused on identifying, managing, and reporting harassment in the workplace. The campaigns ran throughout 2024 and will continue into 2025.

Safe Working Environment:

Creating a safe working environment is a continuous undertaking. Safety means protecting and empowering our employees and contractors to stop unsafe or inappropriate actions, to report any breach of law or any violation of the DOF Group's policies, or other legal or ethical concerns, without fear of intimidation or reprisal.

Ethics Helpline and Grievance Mechanisms:

DOF provides an Ethics Helpline to capture any non-compliance issues and enable workers to raise concerns without fear of intimidation or reprisal.

Speak Up and Stop Work Culture:

Safety means protecting and empowering our employees and contractors to:

• Stop unsafe or inappropriate actions
• Report any breach of law or any violation of the DOF Group's policies
• Report other legal or ethical concerns
• All without fear of intimidation or reprisal

Dignity & Respect Campaign:

Following 2023 industry and company surveys related to harassment, we identified a need to strengthen our "Speak Up" and "Stop Work" culture and rolled-out DOF's "Dignity & Respect" campaign focused on identifying, managing, and reporting harassment in the workplace. The campaigns ran throughout 2024 and will continue into 2025.

Code of Business Conduct:

DOF maintains a comprehensive Code of Business Conduct that provides guidance on:

• Legal and ethical standards
• Reporting mechanisms
• Protection against retaliation
• Procedures for addressing violations

Remediation Processes:

DOF has established processes to:

• Investigate reported concerns
• Take appropriate corrective action
• Provide remediation where negative impacts are identified
• Ensure protection for workers who raise concerns

Training and Awareness:

The Group implements:

• Training programmes on workers' rights
• Awareness campaigns on available channels
• Regular communication about grievance procedures
• Leadership development on handling concerns appropriately

Continuous Improvement:

DOF continuously reviews and strengthens its grievance mechanisms based on:

• Employee feedback
• Industry best practices
• Regulatory requirements
• Incident learning and analysis

Safety Performance and Actions:

In 2024, safety performance showed a negative trend. However, campaigns to address the trend were rolled out globally. Our focus has been on reinforcing safety leadership, culture, and capability, and our actions continue into 2025 as we target increased leading indicator levels for a measurable improvement in safety culture.

Our highest priority is the safety and well-being of our people. The Group remains dedicated to enhancing safety and environmental performance across worksites worldwide.

Safety Culture Strengthening:

• Dignity & Respect Campaign - Rolled out globally focusing on identifying, managing, and reporting harassment in the workplace (campaigns ran throughout 2024 and continue into 2025)
• Speak Up and Stop Work Culture - Strengthened to enable workers to report concerns without fear
• Safety Leadership - Enhanced focus on leadership capabilities and culture
• Leading Indicators - Targeting increased levels for measurable safety culture improvement

Incident-Free Organisation Goal:

We Aim To Be An Incident-Free Organisation - This remains our overarching safety objective with comprehensive programmes to achieve this goal.

People Development and Retention:

Attracting, developing, and retaining the right people is imperative in maintaining our competitive edge. The key to DOF's success remains unchanged - our people.

2024 Workforce Initiatives:

• Employee engagement survey - Comprehensive assessment of workforce satisfaction
• HR Employee Survey improvement plans - Action plans based on survey findings
• Diversity and inclusion committee and plan - Structured approach to enhance workplace diversity
• Workplace safety environment focus - Enhanced safety culture development
• Offshore Leader's Conference Safety workshop - Leadership development in safety management

Integration and Collaboration:

As we expanded our workforce by 25% with 1,200 new colleagues through the DOF Denmark acquisition, our focus is on providing a safe, inclusive, and healthy, collaborative working environment to cement the success of upscaling the Group.

Skills Development:

Developing, attracting, and retaining personnel with the skills and availability to support new markets, growing assets and operational commitments is essential to the achievement of DOF's strategic ambition. This includes overcoming perceived or actual barriers to inclusion and diversity in a male-dominant industry.

Health and Wellbeing:

The Group maintains comprehensive programmes addressing:

• Occupational health and safety hazards inherent in operations
• Security threats and risk mitigation
• Employee wellbeing and support systems
• Work-life balance considerations

Effectiveness Monitoring:

The effectiveness of our actions is monitored through:

• Safety performance indicators and leading indicators
• Employee satisfaction surveys
• Incident reporting and analysis
• Regular review of improvement programmes
• Feedback from workforce engagement activities

Targets related to own workforce

Health and Safety Targets

DOF has established global HSEQ targets to manage material impacts and risks related to occupational health and safety:

Nature of targets: These are absolute targets (number of incidents) and intensity-based targets (per million man-hours or per 200,000 man-hours).

Scope: All employees and non-employees on vessels and worksites covered by the ISO 45001 certified Occupational Health and Safety management system.

Progress: By end-of-year 2024, DOF was above some health and safety targets, including lost time injuries, recordable and first-aid cases. The company introduced a new target "Serious Incident Frequency" for 2025.

Diversity and Inclusion Target

Nature of target: Intensity-based (percentage representation)

Scope: Onshore workforce only (professionals and managers)

Origin: Target announced in 2021, initiated by stakeholders and as a result of commitment to the "Fifty-fifty" programme.

Monitoring: Evaluated by end of each reporting year, monitored throughout the year by Power BI reports, and reported in quarterly reports.

Other Work-Related Rights

DOF has not established any measurable or time-bound outcome-oriented targets to evaluate the effectiveness of activities connected to:

• Working Conditions (S1-5, page 83)
• Other work-related rights (data privacy) (S1-5, page 95)

Effectiveness is tracked through feedback from employees, employee surveys, retention and turnover analysis, external benchmarking reports and industry standards (for working conditions), and monitoring data breaches and training completion rates (for data privacy).

DOF Group Workforce Composition (End of 2024):

Total Employees: 5,440 people

• Increase of 25% compared to 2023 due to DOF Denmark acquisition (1,200 new colleagues)
• 3,800 people offshore
• >5,000 people total workforce including contractors

Regional Distribution:

Workforce Growth:

With 1,200 new colleagues from the DOF Denmark acquisition, the total headcount increased by 25% compared to 2023. At the end of 2024, there were 5,440 people in the Group.

Operational Structure:

DOF operates with both onshore and offshore personnel:

• Onshore employees - Supporting project management, engineering, commercial, and administrative functions
• Offshore employees - Operating vessels and conducting subsea operations
• Contractors - Additional specialized personnel as needed for projects

Global Footprint:

DOF operates across 6 continents with a globally distributed workforce supporting operations in conventional energy and offshore wind industries.

Integration Success:

The integration of 1,200 new colleagues represents one of the most exciting expansions in DOF's history, combining the knowledge, experience, and professionalism of two highly regarded teams in the offshore energy sector.

Non-Employee Workers:

DOF utilizes non-employee workers including:

• Contractors - Specialized personnel for specific projects and operations
• Temporary workers - Through manning agencies for operational flexibility

Manning Agency Considerations:

The main concern identified in our risk assessment is exposure to non-compliance labour and human rights practices through the use of short-term contracts and temporary employment through manning agencies, which may weaken worker's rights.

Contractor Management:

DOF engages with contractors through:

• DOF Code of Business Conduct application
• Safety protocols and training
• Performance management systems
• Ethics Helpline access for reporting concerns

Value Chain Worker Protection:

DOF implements governance practices to safeguard labour conditions across the value chain, including for non-employee workers through:

• Human Rights due diligence and compliance audits
• Supplier Code of Conduct implementation
• Regular oversight of performance and contractual issues
• Governance and ethical business practices requirements

Integration Approach:

Non-employee workers are integrated into DOF's safety and compliance culture through:

• Safety training and orientation
• Code of Business Conduct awareness
• Access to grievance mechanisms
• Health and safety protection equivalent to employees

Regulatory Compliance:

DOF ensures compliance with fundamental industry labour standards for all workers including:

• ILO standards
• MLC (Maritime Labour Convention)
• UN Guiding Principles on Human Rights
• Modern Slavery Act requirements
• Transparency Act compliance

Union Engagement and Social Dialogue:

DOF engages with workforce representatives through:

• Union negotiations - Formal collective bargaining processes
• Worker representatives - Engagement with other forms of worker representation
• Social dialogue - Regular communication on working conditions and policies

Norwegian Context:

As a Norway-headquartered company with significant Norwegian operations, DOF operates within the Norwegian model of industrial relations which emphasizes:

• Strong collective bargaining traditions
• Cooperative labor-management relationships
• High levels of union organization
• Social dialogue as a key component of workplace governance

Global Operations:

Across DOF's global operations in multiple regions (Atlantic, Asia-Pacific, North America, South America), the company respects local labor laws and practices regarding:

• Collective bargaining rights
• Freedom of association
• Worker representation
• Social dialogue mechanisms

Stakeholder Engagement:

Union negotiations and worker representative engagement are formal channels identified in DOF's stakeholder engagement framework, addressing key topics including:

• Safety, Health, Security and wellbeing
• Code of business Conduct compliance
• Due diligence processes

Norwegian Shipowners Association:

DOF participates in industry-level social dialogue through membership in the Norwegian Shipowners Association, where representatives serve on the board of directors, facilitating industry-wide labor relations and standards.

2024 Initiatives:

As part of strengthening worker voice and representation, DOF implemented:

• Enhanced "Speak Up" culture initiatives
• Dignity & Respect campaigns
• Improved grievance mechanisms
• Strengthened worker consultation processes

Diversity and Inclusion Initiatives:

DOF has implemented comprehensive diversity and inclusion measures in 2024:

• Diversity and inclusion committee and plan - Structured governance approach to enhance workplace diversity
• Dignity and respect in the workplace guide - Comprehensive guidance on creating inclusive working environment

Industry Context:

DOF operates in a traditionally male-dominant industry and has identified the need for "overcoming perceived or actual barriers to inclusion and diversity in a male-dominant industry" as a key challenge.

2024 Focus Areas:

Dignity & Respect Campaign: Following 2023 industry and company surveys related to harassment, DOF identified a need to strengthen workplace culture and rolled-out DOF's "Dignity & Respect" campaign focused on:

• Identifying, managing, and reporting harassment in the workplace
• Campaigns ran throughout 2024 and will continue into 2025
• Creating safe, inclusive working environment

Global Workforce Integration:

With the addition of 1,200 new colleagues through the DOF Denmark acquisition (25% workforce increase), DOF focused on:

• Providing a safe, inclusive, and healthy, collaborative working environment
• Combining knowledge, experience and professionalism of two diverse teams
• Cementing success of upscaling the Group through inclusion

Strategic Goals:

DOF's sustainability goals include:

• Enhance DOF's diversity, inclusion and equitable working environment performance
• Create meaningful work, equitable treatment and compensation, inclusivity, and ample development prospects for everyone
• Build a safe, diverse and inspiring, inclusive workplace

Stakeholder Expectations:

Our workforce expects meaningful work, equitable treatment and compensation, inclusivity, and ample development prospects for everyone.

Management Structure:

Diversity considerations are reflected in DOF's leadership structure, with representation across different backgrounds and expertise areas in both Board composition and management team.

Adequate wages

S1-10 Adequate Wages

All employees receive a fair and adequate wage. The company has conducted a comprehensive mapping exercise, examining the minimum and living wages in the countries where we operate. This ensures that the wages provided are above these thresholds.

Benchmark Used

DOF worked together with Slave Free Alliance to produce a report with information on minimum and living wage benchmarks in all countries where DOF has operations and employees. This report is used as a tool to verify that all employees are paid an adequate wage.

The company states: "Since these numbers fluctuate and are dynamic in many areas of the world, it is important to continue to map what is considered a living and minimum wage to be confident that we offer fair wage accreditation for our own employees going forward."

Coverage

The living and minimum wage mapping exercise covers all countries of operations associated with Own Workforce. Status for 2024: Complete for 2024.

The report verified that wages provided are above minimum and living wage thresholds in countries where DOF operates.

Methodology Details

Position grading and mapping: DOF uses the Korn Ferry job evaluation system for ranking positions logically and fairly. Korn Ferry operates with four employee groups to cover various reference levels: Staff, Managers/Seasoned Professionals, and Senior Managers/Executives. External salary benchmark reports are used during salary settlements to ensure fair and market-adjusted pay. The company has an annual review of all eligible salary placements in connection with yearly salary settlements.

Frequency: Annual review during salary settlements; living/minimum wage mapping completed for 2024 with recognition that benchmarks are dynamic and require ongoing monitoring.

Policy Framework

Equal Employment Opportunity Policy states DOF will:

• Pay wages in-full and on time using national legal standards or industry benchmarks as a minimum requirement

Human Resources Policy incorporates compliance with local legislation.

Value Chain Extension

DOF made paying workers a living wage a contractual requirement in terms and conditions for all direct suppliers in Q4 2024. The company states: "In 2025, we will explore ways we can achieve this for sub-contractors and indirect suppliers."

The company has not measured the outcome of this action in 2024, as implementation of the contractual requirement was updated in Q4 2024.

Targets

For suppliers: DOF's ambition is to collaborate with Factline to enhance vendor evaluation questionnaires by including questions regarding minimum wages and overtime pay. "In the years to come we aim to set target for our direct suppliers to pay their workers a living wage and implement a system for validating based upon the supplier's self-assessment and audits."

No specific time-bound targets disclosed for own workforce (already meeting threshold) or for suppliers.

Social protection

This disclosure has been omitted under the year one phase-in allowance permitted by ESRS.

No metrics or information on social protection coverage have been disclosed for the 2024 reporting period.

Training and Skills Development:

DOF maintains comprehensive training and development programmes addressing multiple aspects of workforce capability:

Strategic Priority - Future Skills:

• Future Skills - Training and development identified as a key sustainability goal
• Developing, attracting, and retaining personnel with the skills and availability to support new markets, growing assets and operational commitments

2024 Training Initiatives:

• HR Policy & training programmes - Systematic approach to employee development
• Organisational development workshops - Collaborative skill building sessions
• Performance Appraisals - Individual development planning and feedback
• Training and capacity-building programmes - Structured skill enhancement
• Offshore Leader's Conference Safety workshop - Leadership development focused on safety management

Skills for Energy Transition:

As DOF expands into renewable energy markets:

• Transferable skills and assets were key in delivering fast-track cable solutions projects for offshore wind farms
• Training programmes to support transition from conventional to renewable energy operations
• Development of capabilities for Floating Offshore Wind (FOW) operations

Safety Training:

Comprehensive safety training addressing:

• Safety leadership, culture, and capability development
• Dignity & Respect workplace training
• "Speak Up" and "Stop Work" culture reinforcement
• Incident prevention and response training

Global Integration Training:

With 1,200 new colleagues from DOF Denmark acquisition:

• Integration training programmes
• Cultural alignment workshops
• Combined knowledge sharing between teams
• Collaborative working environment development

Professional Development:

• Continuity management: strategic succession planning - Leadership development and career progression
• Ample development prospects for everyone - Comprehensive career development opportunities
• Skills development across technical, leadership, and safety competencies

Industry-Specific Training:

• Maritime and offshore industry certifications
• Subsea operations technical training
• Project management capabilities
• Engineering and technical skills development
• Compliance and regulatory training

Employee Engagement in Development:

• Employee engagement survey to identify development needs
• HR Employee Survey improvement plans based on feedback
• Individual and collective development planning
• Regular assessment of training effectiveness

Health and safety metrics

Workers covered by health and safety management system

All workers on vessels and worksites are covered by the Occupational Health and Safety management system. This includes both employees and workers who are not employees. The business management system is audited yearly and recertified every three years by DNV to the ISO 45001 standard.

Health and safety performance

TRIR = Total Recordable Injury Rate (equivalent to LTI, RWC, MTC per million man-hours)

Additional metrics tracked (from internal targets)

Disclosure note

Under ESRS S1-14, DOF disclosed information on coverage, fatalities and recordable work-related accidents/injury rates. The company noted partial use of year-one phase-in allowance, specifically omitting: cases of work-related ill-health and data on number of days lost to injuries, accidents, fatalities and work-related ill health. There were no fatalities due to work-related injuries and work-related ill health in 2024. The increase in incidents during 2024 was attributed to routine and high-frequency activities, with mitigating actions planned for 2025.

Compensation metrics

Pay gap

In the year, the average wage of a female employee was approximately 81.7% of the average male employee's remuneration across all employees. This was calculated based on the average total annual remuneration of all women employees and all male employees (including base salary, overtime allowance, and bonus payments).

DOF has not adjusted the ratio for purchasing power differences between countries. Neither have we included information regarding how objective factors such as type of work and country of employment may influence the gender pay gap.

Remuneration ratio

The total remuneration of the highest paid individual was 18.9 times the median total remuneration for the company.

Incidents and Human Rights Impact Management:

2024 Safety Incident Trend: In 2024, safety performance showed a negative trend. However, campaigns to address the trend were rolled out globally with continued focus into 2025.

Incident Response and Learning:

• Global campaigns rolled out to address negative safety trends
• Leading indicator levels targeting for measurable improvement in safety culture
• Continuous improvement approach to incident prevention
• Focus on safety leadership, culture, and capability reinforcement

Harassment and Workplace Issues:

Following 2023 industry and company surveys related to harassment, DOF identified areas for improvement and implemented:

• Dignity & Respect campaign focused on identifying, managing, and reporting harassment in the workplace
• Campaigns ran throughout 2024 and will continue into 2025
• Strengthened "Speak Up" and "Stop Work" culture

Grievance and Reporting Mechanisms:

• Ethics Helpline to capture any non-compliance issues
• Protection from retaliation - employees and contractors can report concerns without fear of intimidation or reprisal
• Mechanisms to report any breach of law or violation of DOF Group policies
• Other legal or ethical concerns reporting channels

Human Rights Due Diligence:

• Partnership with Slave Free Alliance to review Human Rights exposure
• Robust guidelines to manage risks present in the industry
• Human Rights due diligence and compliance audits conducted in 2024

Severe Impact Prevention:

DOF addresses the risk of serious accident events affecting multiple personnel through:

• Comprehensive safety management systems
• Risk assessment and mitigation processes
• Emergency response procedures
• Continuous monitoring and improvement

Supply Chain Incidents:

Recognition of exposure to non-compliance labour and human rights practices through the use of short-term contracts and temporary employment through manning agencies with active management through:

• Enhanced due diligence processes
• Supplier auditing and monitoring
• Contractual safeguards
• Regular compliance reviews

Incident Documentation and Response:

• Systematic incident reporting and investigation
• Root cause analysis and corrective action planning
• Learning sharing across global operations
• Regular review of incident patterns and trends
• Integration of lessons learned into safety programmes

Human Rights Compliance:

Compliance with fundamental standards including:

• ILO standards
• MLC (Maritime Labour Convention)
• UN Guiding Principles on Human Rights
• Modern Slavery Act
• Transparency Act

Policies related to value chain workers

DOF has identified material impacts related to workers in the value chain, including risks of child and forced labour, labour conditions, and occupational health and safety. The company addresses these through the following policies:

Supplier Code of Conduct

• Purpose: To manage supplier obligations to comply with international human rights standards and national laws regarding child and forced labour, working hours, wages and benefits, and non-discrimination.
• Scope: The entire supply chain. All new suppliers must commit to the code as a pre-requisite for transacting business with DOF. Suppliers are required to share the code with subcontractors and other business associates who provide goods and services outlined in the main contract.
• Accountability: CEO
• Review: Periodically, within management review process
• Availability: Business Management System (BMS), Website, All DOF Worksites. Integrated into purchase agreements with suppliers.
• Alignment with international frameworks:
  • International Bill of Human Rights
  • International Labour Organization (ILO) conventions
  • UN Guiding Principles on Business and Human Rights
• Related policy documents: Code of Business Conduct, Supply Chain Management Manual
• Monitoring and implementation:
  • All suppliers subject to self-assessment undertaken through partner Factlines
  • Supplier audits conducted
  • Risk-based assessment built upon the 10 principles of UN Global Compact
  • Updates and information regarding the SCoC readily available to global value chain workers and suppliers via online platforms and portals
  • Supplier engagement monitored through platforms; non-compliance with mandatory training addressed as part of ongoing supplier management
  • 2,289 vendors evaluated since 2019; 492 evaluations performed in 2024
  • In 2024, paying workers a living wage became a contractual requirement in terms and conditions for all direct suppliers

Supply Chain Management Manual

• Purpose: Outlines engagement responsibilities, including vessel officer involvement and supplier feedback loops.
• Scope: The supply chain
• Accountability: CEO
• Review: Periodically, within management review process
• Availability: BMS, Website, All DOF Worksites
• Related policy documents: Code of Business Conduct, Supplier Code of Conduct

Health, Safety and Working Environment Policy

• Scope: Applies to DOF value chain, including contractors
• Key content:
  • Implement and maintain OHSAS 18001 / ISO 45001 compliant Health and Safety Systems
  • Ensure Health and Safety systems are provided and maintained, considering the continued need to protect personnel, assets and the environment
  • Encourage all personnel to use products and technical solutions with the least impact to their health and environment
• Monitoring: DOF provides contractors with a training portal giving access to e-learning modules to improve awareness and knowledge of DOF procedures. Ambition for all clients and contractors to conduct vessel induction video before vessel sails and conduct DOF permit to work within two weeks of joining the vessel. 3,214 DOF e-learn modules completed by value chain workers in 2024 covering Occupational Health and Safety, permit to work, management of change and the Code of Business Conduct.

Due Diligence Approach

DOF is committed to perform human rights due diligence. The company's approach is communicated in its Transparency Act statement, Modern Slavery Act statement, Code of Business Conduct, and Supplier Code of Conduct. The company states: "DOF Group ASA and all its subsidiaries adhere to the same guide-lines, procedures, and governing documents regarding human rights, and our due diligence assessments are based up on the common risks identified in our unified Supply Chain Management system or any incidents reported through our grievance mechanisms."

DOF has not been found in breach of labour law or human rights, and there have been no cases or allegations brought forward through OECD National Contact Point or Business and Human Rights Resource Centre. During the reporting year there were no cases of breaches of the UN Guiding Principles of Business and Human Rights.

Grievance Mechanisms

The Ethics Helpline is publicly available, and reports may be made through the website or telephone numbers available 24/7 in various languages. The database allows communication with the reporter in an anonymous and secure way. Reporters are protected by DOF's non-retaliation policy.

Training and Communication

The company communicates effectively to protect value chain workers and suppliers in high-risk areas, including regular training sessions for employees involved in procurement and supply chain management. Training sessions outline expectations for conduct and ensure participants understand the impacts, risks and opportunities associated with labour practices, human rights, health and safety, the environment, and bribery and corruption within the value chain. Training materials are accessible in English and Portuguese, DOF's two business languages.

Value Chain Worker Engagement:

DOF engages with value chain workers through multiple channels addressing their working conditions and rights:

Engagement Channels:

• Union negotiations - Formal engagement with worker representatives in the supply chain
• Via other worker representatives - Alternative forms of worker representation
• Surveys and feedback sessions - Regular assessment of worker conditions and concerns
• Training and capacity-building programmes - Skills development and awareness building
• Supplier audits and oversight - Direct engagement during compliance assessments

Supplier Engagement Framework:

• Regular communication with suppliers on labour practices
• Annual workshop sessions with suppliers
• Code of Business Conduct within contract terms - Contractual requirements for supplier engagement with workers
• Oversight of performance and contractual issues - Monitoring of supplier worker practices
• Supply Chain Managers Forum - Platform for addressing worker-related issues

Key Engagement Topics:

• Safety, Health, Security and wellbeing of value chain workers
• Code of business Conduct compliance and awareness
• Due diligence processes and requirements
• Human rights and Labour practices standards
• Waste and hazardous materials management affecting worker safety

2024 Engagement Initiatives:

• Governance practices to safeguard labour conditions across the value chain
• Human Rights due diligence and compliance audits including value chain worker consultation
• Supplier Code of Conduct implementation with worker protection requirements
• Fair procurement strategy considering worker welfare

Stakeholder Expectations Management:

Value chain workers expect responsible business practices, and partnership on strategic issues to uphold adequate working conditions, secure employment, and fair wages through our supply chain.

Challenges in Engagement:

DOF recognizes challenges in engaging value chain workers due to:

• Geographical footprint spanning multiple jurisdictions with varying labour laws
• Complex supply chains across global operations
• Short-term contracts and temporary employment through manning agencies which may weaken worker representation
• Varying local practices in worker engagement across regions

Compliance Framework:

Engagement processes ensure compliance with:

• ILO fundamental labour standards
• UN Guiding Principles on Human Rights
• Modern Slavery Act requirements
• Transparency Act obligations
• MLC (Maritime Labour Convention) standards

DOF's engagement approach aims to control human rights exposure across value chain while maintaining productive relationships with suppliers and ensuring worker welfare throughout the supply chain.

Value Chain Worker Grievance Mechanisms:

DOF provides channels for value chain workers to raise concerns through our supply chain management framework:

Supplier-Based Grievance Channels:

• Code of Business Conduct within contract terms - Contractual requirements for suppliers to establish worker grievance mechanisms
• Oversight of performance and contractual issues - Monitoring and addressing worker concerns through supplier management
• Regular communication with suppliers including worker welfare discussions
• Audits of suppliers including assessment of worker grievance systems

Direct Reporting Channels:

• Ethics Helpline access extended to value chain workers for reporting concerns
• Human Rights due diligence and compliance audits processes include worker consultation
• Surveys and feedback sessions providing direct channels for worker input

Training and Awareness:

• Training and capacity-building programmes including awareness of rights and grievance procedures
• Annual workshop sessions with suppliers covering worker protection mechanisms
• Supply Chain Managers Forum addressing grievance system effectiveness

Remediation Processes:

DOF implements governance practices to safeguard labour conditions across the value chain including:

• Human Rights due diligence processes to identify and address impacts
• Compliance audits to verify remediation effectiveness
• Fair procurement strategy incorporating worker protection requirements
• Supplier Code of Conduct with remediation obligations

Challenges in Remediation:

DOF recognizes significant challenges in providing effective remediation for value chain workers:

• Geographical footprint exposing DOF to potential compliance issues across fundamental industry labour standards
• Short-term contracts and temporary employment through manning agencies which may weaken worker's rights and access to remediation
• Complex supply chains across multiple jurisdictions with varying legal frameworks

Risk-Based Approach:

The main concern identified is exposure to non-compliance labour and human rights practices through the use of short-term contracts and temporary employment through manning agencies. DOF addresses this through:

• Enhanced due diligence on suppliers using temporary employment
• Stronger contractual protections for temporary workers
• Regular monitoring of manning agency practices
• Direct engagement with workers where possible

Continuous Improvement:

• Partnership with Slave Free Alliance to review Human Rights exposure and improve remediation processes
• Robust guidelines to manage risks and improve worker protection
• Regular assessment of grievance mechanism effectiveness
• Integration of lessons learned into supplier management practices

Compliance Standards:

Remediation processes align with:

• UN Guiding Principles on Human Rights
• ILO fundamental labour standards
• Modern Slavery Act requirements
• Transparency Act obligations
• MLC (Maritime Labour Convention) standards

Actions on Material Impacts for Value Chain Workers:

DOF has identified ensuring adequate working conditions, secure employment, and fair wages in the supply chain as a key material challenge requiring comprehensive action.

Material Impact Management:

Primary Challenge: Ensuring adequate working conditions, secure employment, and fair wages in the supply chain is challenging. Our geographical footprint and supply chain exposes DOF to potential compliance issues across fundamental industry labour standards (ILO, MLC, UN Guiding Principles on Human Rights, Modern Slavery Act, Transparency Act).

Main Risk: The main concern is exposure to non-compliance labour and human rights practices through the use of short-term contracts and temporary employment through manning agencies, which may weaken worker's rights.

2024 Actions Taken:

Governance and Due Diligence:

• Governance practices to safeguard labour conditions across the value chain implemented
• Human Rights due diligence and compliance audits conducted throughout 2024
• Partnership with Slave Free Alliance to review Human Rights exposure continued
• Robust guidelines developed to manage risks present in the industry

Supplier Management:

• Supplier Code of Conduct implementation and enforcement
• Fair procurement strategy incorporating worker protection requirements
• Regular communication with suppliers on labour practices
• Annual workshop sessions focusing on worker welfare
• Supply Chain Managers Forum to address systematic issues

Monitoring and Oversight:

• Oversight of performance and contractual issues including worker welfare aspects
• Audits of suppliers with focus on labour conditions
• Code of Business Conduct within contract terms ensuring worker protection

Risk Management Approach:

DOF implements targeted approaches to manage material risks:

Manning Agency Risk Management:

• Enhanced due diligence on agencies providing temporary workers
• Strengthened contractual requirements for worker protection
• Regular monitoring of employment practices
• Direct worker consultation where feasible

Compliance Framework:

• Systematic compliance with ILO standards
• MLC (Maritime Labour Convention) implementation
• UN Guiding Principles on Human Rights adherence
• Modern Slavery Act compliance
• Transparency Act reporting requirements

Effectiveness Assessment:

Continuous Improvement:

• Regular review of supplier performance on worker welfare
• Assessment of due diligence effectiveness
• Stakeholder feedback incorporation
• Best practice sharing across the organisation

Opportunities Pursued:

• Development of preferred supplier relationships with strong labour practices
• Industry collaboration on worker protection standards
• Technology and process improvements to enhance worker welfare
• Capacity building with suppliers on labour rights

2024 Results: Implementation of systematic governance practices and enhanced due diligence processes, though the complexity of global supply chains and temporary employment practices continues to require ongoing vigilance and improvement.

Future Actions: Continued strengthening of due diligence processes, enhanced supplier engagement, and systematic monitoring of labour conditions across the value chain with particular focus on temporary employment arrangements.

Targets related to value chain workers

DOF has not committed to any targets that align with CSRD to manage material negative impacts, advancing positive impacts, and managing material risks and opportunities within this area.

Future Ambitions (not yet targets)

DOF states the following ambitions:

• Ambition: Collaborate with Factline to enhance vendor evaluation questionnaire by including questions regarding expectations towards the supply chain, specifically regarding minimum wages and overtime pay. This could form the basis for mapping supplier adherence to pay an adequate wage.

• Future aim: Set target for direct suppliers to pay their workers a living wage and implement a system for validating based upon the supplier's self-assessment and audits.

No quantified targets, baseline years, target years, or timelines have been established for these ambitions.

Business Conduct Policies and Corporate Culture:

DOF Code of Business Conduct: DOF maintains a comprehensive DOF Code of Business Conduct that serves as the foundation for ethical business practices across the organisation.

Core Values and Mission:

Mission Statement: "We aspire to be a trusted and leading partner delivering integrated subsea and marine services globally for a sustainable utilisation of offshore energy and other subsea resources."

Code of Business Conduct Application:

• Applied across all employees and contractors
• Code of Business Conduct within contract terms for suppliers
• Integrated into onboarding and training programmes
• Regular communication through DOF portal/intranet
• Reinforced through performance appraisals

Ethical Culture Development:

Speak Up Culture: Following 2023 surveys, DOF identified the need to strengthen "Speak Up" culture and implemented:

• "Speak Up" and "Stop Work" culture empowering employees to report concerns
• Protection for reporting any breach of law or any violation of the DOF Group's policies
• Assurance of no fear of intimidation or reprisal for ethical reporting

Dignity & Respect Campaign:

• Comprehensive Dignity & Respect campaign focused on workplace conduct
• Identifying, managing, and reporting inappropriate behavior
• Campaigns ran throughout 2024 and will continue into 2025
• Dignity and respect in the workplace guide providing behavioral guidance

Governance Framework:

Leadership Structure:

• CEO and Executive Management commitment to ethical practices
• Board oversight including independent directors
• Audit Committee oversight of conduct and compliance
• Regional management accountability for local ethical standards

Ethics Infrastructure:

• Ethics Helpline for confidential reporting of concerns
• Enterprise Risk Management process incorporating ethical risks
• Regular training and awareness programmes
• Performance measurement including ethical conduct indicators

Global Application:

With operations across 6 continents, DOF ensures consistent ethical standards while respecting local laws and customs:

• Consistent Code of Business Conduct application globally
• Local adaptation where required by law
• Regional management accountability
• Cross-cultural sensitivity training

Continuous Improvement:

2024 Initiatives:

• Employee engagement survey including ethics and conduct assessment
• HR Employee Survey improvement plans based on feedback
• Organisational development workshops including ethics components
• Enhanced workplace safety environment focus extending to ethical conduct

Industry Leadership: DOF participates in industry forums and associations, contributing to sector-wide ethical standards and best practices development.

Integration with Business Strategy: Ethical conduct is integrated into DOF's strategic priorities including:

• Sustainable finance practices
• ESG leadership maintenance
• Global organisation consistency
• Service expansion with integrity
• Renewable energy growth with responsible practices

Management of Relationships with Suppliers:

Supplier Engagement Framework:

DOF maintains comprehensive supplier relationships through structured management processes:

Communication Channels:

• Regular communication with suppliers on performance and expectations
• Annual workshop sessions bringing together key suppliers
• Day-to-day communication for operational coordination
• Supply Chain Managers Forum for strategic supplier relationship management

Contractual Framework:

Code of Business Conduct Integration:

• Code of Business Conduct within contract terms ensuring ethical standards
• Supplier Code of Conduct establishing clear expectations
• Contractual requirements for compliance with DOF's ethical standards
• Regular review and updating of supplier agreements

Performance Management:

Oversight and Monitoring:

• Oversight of performance and contractual issues through structured reviews
• Audits of supplier operations and compliance
• Regular assessment of supplier adherence to contractual obligations
• Performance scorecards and improvement planning

Procurement Strategy:

Fair Procurement:

• Fair procurement strategy ensuring equitable supplier treatment
• Transparent bidding and selection processes
• Consideration of supplier sustainability and ethical practices
• Long-term relationship building with preferred suppliers

Due Diligence and Risk Management:

Human Rights and Labor Practices:

• Human Rights due diligence and compliance audits of suppliers
• Assessment of supplier labor practices and working conditions
• Monitoring compliance with ILO standards
• UN Guiding Principles on Human Rights implementation in supplier relationships

Risk Assessment: DOF recognizes that our geographical footprint and supply chain exposes DOF to potential compliance issues across fundamental industry labour standards and manages this through:

• Enhanced due diligence processes
• Regular supplier risk assessments
• Continuous monitoring of supplier compliance
• Remediation planning for identified issues

Supplier Development:

Capacity Building:

• Training and capacity-building programmes for suppliers
• Support for supplier improvement initiatives
• Knowledge sharing on best practices
• Technical assistance where appropriate

2024 Supplier Management Initiatives:

Governance Practices:

• Governance and ethical business practices requirements for suppliers
• Enhanced supplier onboarding processes
• Strengthened contractual protections
• Improved supplier performance monitoring

Areas of Focus:

Supplier relationships address key sustainability topics:

• Safety, Health, Security and wellbeing of supplier workers
• Human rights and Labour practices compliance
• Waste and hazardous materials management standards
• Business ethics and anti-corruption measures

Supply Chain Challenges:

DOF acknowledges particular challenges in managing relationships with suppliers providing:

• Short-term contracts and temporary employment through manning agencies which may weaken worker's rights
• Services across multiple jurisdictions with varying legal requirements
• Specialized technical services requiring specific expertise

Continuous Improvement:

• Regular review of supplier management processes
• Stakeholder feedback integration
• Industry benchmarking and best practice adoption
• Technology enhancement of supplier management systems

Strategic Partnership:

DOF promotes responsible business practices and offers partnership on strategic issues with suppliers, fostering long-term relationships built on mutual trust, shared values, and continuous improvement.

The company works with over 130 operators, subsea engineering companies and eight wind farm developers, maintaining diverse supplier relationships across conventional and renewable energy sectors.

Prevention and Detection of Corruption and Bribery:

Ethics Framework:

DOF maintains comprehensive anti-corruption measures through its governance and ethics infrastructure:

Code of Business Conduct:

• DOF Code of Business Conduct includes anti-corruption and bribery prevention measures
• Applied to all employees, contractors, and suppliers
• Code of Business Conduct within contract terms extending requirements to supply chain
• Regular training and awareness programmes on ethical conduct

Detection and Reporting Mechanisms:

Ethics Helpline:

• Ethics Helpline providing confidential channel for reporting corruption concerns
• Protection for whistleblowers ensuring no fear of intimidation or reprisal
• Ability to report any breach of law or any violation of the DOF Group's policies
• Anonymous reporting options available

Governance and Oversight:

Board and Management Oversight:

• Board of Directors oversight of anti-corruption measures
• Audit Committee review of compliance and ethics
• Executive management accountability for corruption prevention
• Regular reporting to governance bodies on compliance status

Risk Management Integration:

Enterprise Risk Management:

• Enterprise Risk Management process incorporates corruption and bribery risks
• Regular assessment of corruption risks across global operations
• Integration of anti-corruption measures into business processes
• Continuous monitoring and improvement of controls

Compliance Framework:

Regulatory Compliance: DOF ensures compliance with anti-corruption laws across its global operations, recognizing that:

• DOF's geographic footprint exposes the Group to various compliance risk sources
• Operations span multiple jurisdictions with varying legal requirements
• Consistent standards applied globally while respecting local laws

Due Diligence:

Supplier Due Diligence:

• Human Rights due diligence and compliance audits include anti-corruption assessments
• Supplier Code of Conduct includes anti-corruption requirements
• Audits of suppliers include corruption risk assessment
• Enhanced due diligence for high-risk supplier relationships

Training and Awareness:

Employee Education:

• Regular training on anti-corruption policies and procedures
• Dignity & Respect campaign includes ethical conduct components
• Organisational development workshops incorporating ethics training
• Leadership development including anti-corruption responsibilities

Business Ethics Culture:

Speak Up Culture:

• "Speak Up" culture encouraging reporting of ethical concerns
• Management commitment to addressing corruption risks
• Open communication channels for ethics-related discussions
• Regular reinforcement of ethical expectations

Tools and Control Mechanisms:

DOF maintains robust tools and control mechanisms to support safe, legal and ethical decision making, wherever we do business including:

• Clear policies and procedures
• Regular compliance monitoring
• Internal controls and checks
• External audit and assurance

Continuous Improvement:

• Regular review of anti-corruption measures
• Updates to policies based on regulatory changes
• Learning from industry best practices
• Integration of stakeholder feedback

Global Operations Consideration:

With operations across 6 continents and complex international business relationships, DOF maintains vigilant anti-corruption measures while conducting business with over 130 operators, subsea engineering companies and eight wind farm developers across conventional and renewable energy sectors.

Transparency Commitment:

DOF's commitment to transparency includes clear anti-corruption stance as part of its broader commitment to transparency, accuracy, and clarity in all business dealings and stakeholder communications.

Incidents of corruption or bribery

Confirmed incidents

No incidents related to fraud, corruption, bribery or breach of anti-trust or competition laws were reported in 2024.

Convictions and fines

The company did not receive any convictions or fines for violations of anti-corruption or anti-bribery law in the year, nor has it been subject to any legal action relating to corruption and bribery.

Investigation and speak-up procedures

DOF maintains an independent Ethics Helpline that provides a safe reporting channel maintaining confidentiality and protecting the rights of both the reporter and potential subject. The system is hosted by an independent risk and compliance solution provider via an online portal accessible from the company's website, available 24/7.

Investigations within the ethics hotline are conducted independently of the management organisation involved in the matter. An executive advisor appoints the investigation team based on reported incidents, ensuring investigators have insight into the topic area and any complexities. The system has default safeguards to exclude any investigators mentioned in a case. Assignees have various skill sets within HR, HSE, finance, marine operation and legal.

During 2024, 48 cases were reported through the whistle-blower system. Four reports were duplications. Of the unique closed cases in 2024, 44% were substantiated and 56% unsubstantiated. The most serious reports concerned sexual harassment, physical harassment and poor management behaviours. Some cases led to dismissals, including three DOF employees and two subcontractors. The average time to close cases was 60 days, within the target of 80 days.

Whistle-blowers are protected from any kind of retaliation or discriminatory or disciplinary action in line with EU law and other relevant legislation in Norway, Australia, Brazil, UK, US, and Canada.

Anti-corruption training

DOF conducted anti-corruption and bribery training during the reporting period:

The project management function, supply chain workers and officers on vessels have been identified as particularly high risk for corruption and bribery due to their direct involvement in obtaining permits and interface with external stakeholders, including government officials. DOF mitigates this risk through targeted anti-bribery and anti-corruption training for these individuals.

Payment practices

Standard payment terms

DOF's standard payment terms, as stated in its terms and conditions, are 60 days. However, some specific agreements may have payment terms of 30 or 45 days.

Average payment time

Payment performance is continuously monitored through a payment analysis dashboard linked with the ERP system.

Payment systems

To enhance payment efficiency, DOF uses electronic invoicing systems, including:

• Peppol
• EHF (Elektronisk Handels Format, Norway)

Support for SMEs

DOF recognises the importance of timely payments to small to medium enterprises (SMEs). For the purposes of this disclosure:

• Small enterprises: entities with 1-20 employees
• Medium-sized companies: entities with 21-100 employees

SMEs facing payment issues can contact DOF at suppliers@dof.com, referencing the PO number. This inbox is monitored daily to ensure prompt assistance.

Legal proceedings

There have been no legal proceedings connected to outstanding late payments in 2024.