DOF Subea

The role of the administrative, management and supervisory bodies

Reference: pages 36-38.

DOF's governance principles follow the Norwegian Code of Practice for Corporate Governance. The Board of Directors, Audit Committee and Executive Management interface is "responsible for oversight, control and management of identified material Impacts, Risks and Opportunities (IROs)", with DOF's Risk Management Framework, based on the COSO model, as the key mechanism (p.36).

Board composition: seven non-executive directors, 43% female / 57% male, 72% independent by the Norwegian Corporate Governance Board's recommendation. The Executive Management Team (EMT) has ten members, 20% female / 80% male, none holding Board seats (p.36).

In 2025 DOF established a Governance, Risk and Compliance (GRC) Committee, chaired by the CFO, plus a new Group Risk Appetite Statement and Key Risk Indicators (p.36). Other committees are the Audit Committee (oversight of ESG performance, management and control of operations/risks/material topics, financial and sustainability reporting principles, risk management and internal control, auditor independence), the Remuneration Committee and the Nomination Committee (p.38).

"In 2025 the Audit Committee received several CSRD briefing sessions in addition to an overview of IROs" (p.36).

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

Reference: page 37.

"In 2025, the Audit Committee met five times", with DOF's risk management framework a standing agenda item, "including reviews of IROs, improvements to the risk management framework and emerging risks". Significant IRO or emerging-risk updates go to the Board quarterly via both the Audit Committee Chair and the CFO (p.37).

"All material impacts, risks, and opportunities addressed by the Board and Executive Management are defined through the Double Materiality Assessment (DMA) process, presented at Audit Committee meetings, and detailed in the SBM 3 IRO Table" (p.37). The Board also receives updates on CSRD compliance, CDP reporting and Ethics Helpline cases, with health and safety "a routine topic of discussion" (p.37).

The CEO provides leadership for the Global Improvement Programme, where strategic and key ESG initiatives are organised and managed, since sustainable development sits within the CEO's day-to-day management responsibility (p.37).

Integration of sustainability-related performance in incentive schemes

Reference: page 37.

DOF states plainly: "DOF does not integrate sustainability-related performance in our incentive schemes."

The company's governance structure does include a Remuneration Committee, described elsewhere in the Sustainability Statements as "a preparatory and advisory sub-committee of the Board in questions relating to the Company's strategy for the compensation of its executive management", ensuring "thorough and independent preparation of matters relating to compensation of the Company's executive management" (p.38). That committee's remit, as described, concerns executive compensation generally; nothing in the report links its review process to sustainability-related performance targets. The CEO is separately noted (in the financial statements) as eligible to participate in a long-term share incentive scheme for senior executives, again without a stated sustainability-performance linkage.

Statement on due diligence

Reference: page 37, incorporated by reference to the "Core elements of due diligence" table, page 55.

GOV-4 itself is brief: "See Core elements of due diligence on page 55" (p.37).

The page-55 table maps the five core elements of due diligence to other disclosures:

DOF also has 84 clients across six continents and more than 6,000 people in 26 offices (p.37), with client decarbonisation expectations described as "key strategic drivers for our organisation's future value creation" (p.37).

Risk management and internal controls over sustainability reporting

Reference: page 39.

"The core ESG team brings together specialists from Environmental, Health and Safety, Human Resources, Supply Chain Management, Communications and Governance." The CFO holds overall responsibility for Group ESG Reporting; operational responsibility sits with the Head of ESG Reporting, who "leads the consolidated DMA, climate-risk evaluation, and the Group's sustainability data collection and conversion processes" (p.39).

"Key challenges include human error, data misalignment across regions, and ongoing system integration following the DOF Denmark acquisition" (p.39).

Internal controls described: defined roles/responsibilities for data owners; formal data collection protocols (standardised templates, documented assumptions, version-controlled methodologies); system-based controls (validation rules, access permissions, revision logs); periodic quality reviews with cross-checks against operational metrics and historical trends; and risk-based prioritisation, giving "enhanced scrutiny, additional supporting evidence, and secondary validation by subject matter experts" to the sustainability topics and data points with the highest potential for misstatement (p.39).

Strategy, business model and value chain

Reference: pages 39-41; incorporation by reference to pages 15, 16 and 23 (per IRO-2, p.52).

"DOF operates as an international contractor to offshore energy producers, subsea engineering companies and offshore windfarm developers." Integrated subsea and marine services are the primary value-generating activity; the fleet "is the source of the Group's largest GHG emissions" (p.39). DOF employs more than 6,000 people across 6,130 onshore/offshore/marine roles in 14 countries (Brazil 2,164, Norway 982, Australia 749, Denmark 524, and smaller teams elsewhere) (p.39).

Sector exposure (EU Taxonomy basis): "the majority of DOF's business was providing key support activities for oil and gas operations" (anchor handling/towing, mooring, subsea IMR), classed in the fossil fuel sector – revenue USD 1,804.63 million. "Other" activities (transmission/distribution of electricity; demolition and wrecking of structures) – USD 66.48 million (p.40).

The value chain runs from upstream shipyards, fabrication and port facilities through direct fleet operations to downstream energy producers and, increasingly, offshore wind developers, which DOF frames as "a significant organic diversification opportunity" (pp.40, 43).

Interests and views of stakeholders

Reference: pages 41-42.

DOF's 2025 stakeholder engagement expanded on 2024, "engaging critical internal and external stakeholders, including new senior management teams... key clients with significant backlog revenue, external financial stakeholders, industry peers, member groups" (p.41).

The stakeholder-engagement table (p.42) sets out, per group, channels, key topics and 2025 measures for: Own workforce (surveys, townhalls, the Ethics Helpline; expectations of "meaningful work, equitable treatment and compensation"); Value chain workers (Supplier Code of Conduct, union negotiations; expectations of "adequate working conditions, secure employment, and fair wages"); Customers (contract reviews, audits; DOF expected "to anticipate and deliver a vessel fleet and subsea services that prioritise responsible practices"); Suppliers (Supply Chain Managers Forum); and Financial/investor stakeholders (quarterly reporting, budgeting; expecting DOF "to implement strategies, plans, and actions aimed at mitigating short- and long-term risks").

The 2025 employee engagement survey achieved a 71% response rate, scoring 78/100 on Satisfaction & Motivation and 88/100 on Employee Loyalty, which DOF says outperformed its industry benchmark (p.41).

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

Reference: pages 43-44 (SBM 3 IRO Table).

The 2024 DMA was carried forward and updated in 2025. "This includes the addition of two new material IRO's and some changes in trajectory of existing IRO's from previous reporting period. No IRO's from last year have been removed." One new IRO flagged "NEW": "Client Decarbonisation Focus" (E1) – "Clients are more focused on decarbonisation, but current contracts and client appetite do not enable recovery of capital costs for decarbonisation investments" – alongside a new G1 IRO on lifecycle management of end-of-life assets (p.43).

Material IROs are grouped under E1, E2, E5, S1, S2 and G1 (p.43). The table (p.44) tags each IRO by type (potential/actual impact/risk, opportunity), value-chain area and time horizon – e.g. E1 "Emissions from fossil fuels" (actual impact, direct); S1 "Major accident event" (potential risk, direct); S2 "Child and forced labour within extended value chain" (potential impact, upstream).

Changes "did not result in a significant risk of a material adjustment to the carrying amounts of assets and liabilities... within the next annual reporting period" (p.43).

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

Reference: pages 45-46.

The 2025 DMA built on the 2024 methodology, in six steps (p.45): organisational context review (business model, value chain, regulatory landscape, risk register, governance, KPIs); stakeholder engagement (new senior management post-integration, key clients, financial stakeholders, industry peers); examination of IROs across the value chain (direct, upstream, downstream, incl. climate scenario analysis); materiality scoring (impact materiality at "high or critical levels"; financial materiality against a 1% of 2024 revenue threshold); decision-making/internal controls (validated by the GRC Committee, Audit Committee, Executive teams; signed off by the Audit Committee and Board in Q4 2025); and future steps (a new ESG software platform planned for 2026).

"A sustainability topic was classified as material if any associated IRO surpassed the set threshold... Not Material issues were those falling below these thresholds" (p.45).

Climate scenario analysis used three IPCC AR6 scenarios – SSP1-1.9, SSP2-4.5 and SSP5-8.5 (approximating RCPs 2.6, 4.5 and 8.5), built on 2024 workshop outcomes reviewed, not rerun, against the 2025 context review, since "there were no material changes to the activities, areas of work, client base or value chain" (p.46). Time frames: short (0-1 yr), medium (2-5 yrs), long (5+ yrs).

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

Reference: pages 51-52 (content index); page 52 ("Standards not considered material" table).

DOF's own ESRS content index lists, by code, the disclosure and phase-in status. Material standards covered: ESRS 2, E1, E2, E5, S1, S2, G1. Several DRs are flagged as phase-in omissions: SBM-3 (anticipated financial effects), S1-13 (training/skills metrics), S1-14 (partly – days-lost/ill-health case figures), and E1-9 (anticipated financial effects).

Topics assessed and found not material (p.52): E3 Water and Marine Resources – "indirect impacts to marine resource availability and quality because of value chain operations... not deemed material to DOF"; E4 Biodiversity and Ecosystems – invasive-species/habitat-disruption impacts "not deemed material"; S3 Affected Communities – "DOF's material impact on communities is through our environmental impact"; S4 Consumers and End-Users – "DOF is a business-to-business service provider company and does not produce products for consumers and end-users."

A separate "List of data points... that derive from other EU Legislation" table (pp.52-54) cross-references SFDR, Pillar 3, Benchmark Regulation and EU Climate Law datapoints, each marked Material/Not Material with a page or paragraph reference.

Transition plan for climate change mitigation

Reference: page 58.

DOF states plainly: "DOF currently has no formal decarbonisation roadmap or transition plan as defined under ESRS E1." Its approach instead "is focused on ensuring compliance with applicable decarbonisation regulations and meeting client and stakeholder expectations", while continuing "to monitor regulatory developments and strengthen the accuracy of our emissions data, particularly following the significant fleet expansion in late 2024". DOF has "not set absolute emission-reduction targets or developed a transition plan that includes decarbonisation levers or resource requirements" (p.58).

Climate change is nonetheless treated as a significant environmental aspect under ISO 14001, integrated into operational planning and risk assessment so that "fuel consumption and emissions are continuously monitored and optimised". The three strategic avenues named are reducing own emissions, supporting upstream/downstream value-chain decarbonisation, and developing offshore renewable energy services (p.58). Concrete measures pursued in the absence of a formal plan are detailed under E1-3 (decarbonisation levers, p.58-59) and E1-1's own IRO table names the new "Client Decarbonisation Focus" risk: "current contracts and client appetite do not enable recovery of capital costs for decarbonisation investments" (p.58).

Policies related to climate change mitigation and adaptation

Reference: page 58.

Environment Impact Policy (covers all emissions including air emissions): purpose is to support management of climate-related impacts "by committing DOF to minimise environmental impact, promote efficient use of natural resources, prevent pollution and drive continuous improvement in environmental performance". It requires environmental considerations to be integrated into operations, projects and newbuilds, "which supports reductions in fuel use and associated greenhouse gas emissions", and requires the business to "set, review and monitor environmental objectives and targets" (p.58).

Coverage: all onshore and offshore worksites and individuals present on DOF sites. Accountable: CEO. Certified to ISO 14001. Available via the Integrated Management System, SEEMP, website and all worksites; works with the Code of Business Conduct and the Garbage Management Plan.

DOF names three strategic avenues under the policy: reducing own emissions, supporting upstream/downstream value-chain decarbonisation targets, and developing offshore renewable energy services (p.58).

Actions and resources in relation to climate change policies

Reference: pages 58-59.

DOF applies five recognised decarbonisation levers ("measures"), each assessed vessel-by-vessel since applicability varies by vessel type, operations and area (p.58):

1. Digital fleet/client support – speed management, reduced non-ECO transit; 41 vessels fully connected, 29 partially, by end-2025; 2025 OPEX USD 75,377; estimated 2.5% reduction.
2. Enhanced SEEMP – operational/technical efficiency measures via the mandatory Ship Energy Efficiency Management Plan; estimated 2.5% reduction.
3. Biofouling management – antifouling products, robotic hull cleaning; no dedicated OPEX/CAPEX; estimated 5-10% reduction (up to 90% with full HVO use).
4. Battery/hybrid integration – 15 priority dynamic-positioning vessels identified, no committed projects yet; estimated 1.5% reduction.
5. Biofuel adoption (HVO) – case-by-case; 15 priority vessels; estimated 11-13% reduction.

Each lever maps to the Environmental Impact Policy with a stated progress/horizon; none has dedicated CAPEX/OPEX beyond the USD 75,377 noted above (p.58-59).

Targets related to climate change mitigation and adaptation

Reference: page 59.

DOF states: "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."

No near-term or long-term absolute GHG reduction target, Scope 3 target, or net-zero commitment is disclosed. Progress is instead tracked through the decarbonisation-lever actions under E1-3 (estimated per-lever reduction potentials of 1.5%-13%) and through the gross emissions figures reported under E1-6, which show a year-on-year increase in Scope 1 (537,909 to 752,767 tCO2eq, +40%) and Scope 3 (307,940 to 377,755 tCO2eq, +23%) driven by the DOF Denmark fleet integration (p.60-61). DOF links its absence of targets to the absence of a formal transition plan (E1-1, p.58) and the early stage of strengthening emissions-data accuracy following the 2024 fleet expansion.

Energy consumption and mix

Reference: page 60.

Coal, natural gas, other fossil sources, nuclear and self-generated renewable energy are all reported as zero in both years; DOF purchases no Renewable Energy Certificates, so all purchased electricity/heat/steam/cooling is allocated to the fossil-source line (p.60).

The primary energy source is marine gas oil (MGO) on board vessels, using DEFRA conversion factors. The increase from 2024 to 2025 reflects the integration of the DOF Denmark vessel fleet from Q4 2024. DOF is classified under NACE sections B (mining/quarrying), F (construction) and H (transportation/storage) as high climate impact sectors; energy intensity is 1,420 MWh/million USD (2024) rising to 1,469 MWh/million USD (2025), +3% (p.60).

Gross Scopes 1, 2, 3 and Total GHG emissions

Reference: pages 60-61.

Scope 1 covers Marine Gas Oil combustion on vessels under DOF's operational/financial control; Scope 2 covers purchased electricity/heating/cooling for offices and vessel shore power. Scope 3 categories determined not material: employee commuting (travel included in category 6), upstream leased assets (reported in Scope 1 due to operational control), downstream transportation (included in Scope 1), processing/use/end-of-life of sold products (DOF does not sell products), downstream leased assets (reported in Scope 1), and franchises (DOF has none) (p.60).

"DOF measures GHG intensity relative to operating revenue... this corresponds to 'net revenue'" under ESRS terminology (p.60). No emissions figures have been externally validated beyond the assurance provider (p.61). The large Scope 1 and Scope 3 increases are attributed throughout the chapter to the DOF Denmark fleet acquisition integrated from Q4 2024.

GHG removals and GHG mitigation projects financed through carbon credits

Reference: page 62.

DOF states: "In 2025, DOF has not participated in GHG removals and GHG mitigation projects financed through carbon credits."

No removal projects, nature-based sequestration initiatives, or carbon-credit financed mitigation projects are described anywhere in the sustainability statement. This is consistent with E1-1's statement that DOF has no formal transition plan and no decarbonisation levers that rely on removals or offsets; the five decarbonisation measures described under E1-3 are all direct operational/technical efficiency actions rather than removals.

Internal carbon pricing

Reference: page 62.

DOF states: "DOF does not currently have an internal carbon pricing scheme."

No shadow price, internal levy, or carbon-price-adjusted investment appraisal mechanism is described. This is consistent with E1-9, where DOF also declines (via the phase-in allowance) to disclose anticipated financial effects of climate-related risks, and with E1-1's statement that capital allocation for decarbonisation is not yet formalised.

Identification of climate-related risks and scenario analysis

Back-filled from ESRS 2 E1 IRO-1 (pages 45-46) and SBM-3 (pages 43-44). This DR did not exist under the 2023 ESRS the report was prepared against.

Risk classification (¶15): the E1 IRO table tags each climate IRO by type and value-chain area – "Emissions from fossil fuels" (actual impact, direct) and "Client Decarbonisation Focus" (potential risk) (p.58).

Methodology (¶16): risk analysis runs across short (0-1 yr), medium (2-5 yr) and long-term (5+ yr) horizons in DOF's Corporate Risk and Opportunity register, "including scenario modelling for various IPCC global warming models" (p.43).

Scenario analysis (¶17) – used. Three IPCC AR6 scenarios: SSP1-1.9, SSP2-4.5, SSP5-8.5, "approximately corresponding to" RCPs 2.6, 4.5 and 8.5 (p.46). (a)(i) SSP5-8.5 is the high-emission physical-risk scenario; (a)(ii) no scenario is explicitly labelled 1.5°C-aligned for transition risk [uncertain: whether SSP1-1.9 plays that role; not stated]. (a)(iii) no global average temperature projection is given for any scenario – an omission worth flagging. (b) "did not use geospatial data" but "did consider our global operational footprint". (c) Assumptions cover policy, macro trends, energy mix, technology. (d) 2024 outputs were reviewed, not rerun, "as there were no material changes" (p.46).

Resilience in relation to climate change

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

DOF's E1 IRO-1 section states: "Resilience analysis assumes the transition to a lower-carbon economy will drive increased demand for renewable energy infrastructure, offshore wind expansion, and advanced subsea technologies, while acknowledging uncertainties such as policy shifts and market adoption rates" (p.46).

On capacity to adapt (¶19(c)/AR10): "Assets most at risk, particularly those tied to fossil fuel exploration, are integrated into our strategy and investment decisions, with mitigation efforts including service diversification, R&D in low-carbon technologies, and workforce training for sustainable operations" (p.46). DOF separately frames its move into offshore wind as "a significant organic diversification opportunity" drawing on the existing fleet's transferable skills (SBM-1 p.40; SBM-3 p.43).

On uncertainty (¶19(b)): policy shifts and market-adoption rates are named explicitly as sources of uncertainty in the resilience assumption (p.46).

The report does not state whether this analysis meets the formal ESRS definition, nor whether it is refreshed annually – DOF neither affirms nor explicitly declines having performed an ESRS-defined resilience analysis. Worth flagging rather than assuming either way.

Policies related to pollution prevention

Reference: page 63.

"The most pertinent and material pollution topic for DOF is the liability towards costs associated with large-scale pollution spill events, including remediation and contractual obligations towards third parties" (p.63).

Environment Impact Policy (covers all pollutants and substances): "treats all environmental incidents as preventable and sets an ambition of zero spills to the external environment, while also committing to reduce and restrict environmentally harmful waste". Certified to ISO 14001; accountable: CEO; works with the Code of Business Conduct, the Planet Manual and the Environmental Compliance Standard (p.63).

DOF's strategic approach: cooperation with strategic partners on industry best-practice pollution-prevention methodologies; open stakeholder communication; proactive risk management; crew training and preparedness; reducing liability through contract management; and supply chain management (p.63).

Actions and resources in relation to pollution

Reference: page 64.

Four named actions: (1) Proactive risk management – risk assessments embedded in the Integrated Management System, emergency response framework including SOPEP and Project Emergency Response Plans; continuous, ongoing. (2) Crew training and preparedness – quarterly SOPEP/SMPEP drills scheduled for all vessels per the Drill Matrix; continuously monitored. (3) Reducing liability – DOF "only accepts liability for pollution caused by its own equipment and vessels", excludes liability for pollution from underground reservoirs/permanent installations/uninsurable risks, and passes pollution liabilities to vendors "on a knock-for-knock basis"; continuous, applied across the Group unless otherwise authorised. (4) Supply chain management – pre-qualification and tendering require upstream parties to follow the same preventative/mitigation measures: desktop reviews, audits, onsite inspections scaled to work-scope criticality (p.64).

All four actions map to the Environmental Impact Policy's commitments to assess/control environmental impacts and apply best practice where legislation is deficient (p.64).

Targets

Reference: page 63.

DOF defines a significant spill as "any loss of secondary containment over fifty Liters" and has "an ambition of reaching zero significant spills through implementing robust preventative and mitigation measures offshore". As a relative metric, it tracks "the number of significant spills to the environment per million manhours", with "our global improvement program sets a target of less than four significant spills per million manhours" (p.63).

This relative target has been "tracked and agreed upon by the Executive Management team over several years" and is described as voluntary, layered on top of DOF's mandatory reporting/investigation obligations across jurisdictions. Both the spill-frequency target and the total-spill-volume metric cover DOF's direct value chain including chartered vessels. "Targets are not based on conclusive scientific evidence" (p.63). Performance against the target is reported under E2-4 (0.21 spills per million manhours in 2025, against the <4 target).

Pollution of air, water and soil

Reference: page 65.

"DOF evaluated its direct value chain... 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." GHG pollutants from marine diesel combustion are cross-referenced to the E1 chapter rather than reported here (p.65).

Three 2025 spills: Skandi Acergy and Skandi Nomad – unplanned hydraulic-oil releases from equipment failure, combined 180 litres, root cause "defective equipment, machinery or tools"; Skandi Niteroi – 155 litres of diesel from "a failed bilge pipe and improper operation of bilge valves". Neither incident resulted in fines or legal action. The company also assessed that "there are no significant sources" of microplastics pollution from its operations, though these are "not specifically measured" (p.65).

Substances of concern and substances of very high concern

Reference: page 65.

DOF states: "The value chain was evaluated and there were no substances of concern or substances of very high concern that are generated, procured, or used across our facilities."

This is a nil return rather than a refusal to quantify: DOF evaluated its operations and value chain specifically for SoC/SVHC (the only E2 sub-topic it has deemed material alongside pollution of air/water/soil, p.52) and found none generated, procured or used. No tonnage table is therefore presented for this DR, consistent with the nil conclusion stated.

Policies related to circular economy

Reference: page 66.

"DOF's most material concern in relation to Circular Economy is the actual impacts associated with the generation of waste materials as part of day-to-day operations" (p.66).

Environment Impact Policy: commits DOF "to minimise environmental impact through efficient use of natural resources, waste reduction and recycling", including "commitments to reduce environmentally harmful waste" and to consider environmental improvements in projects/newbuilds "supporting more resource-efficient asset design and operations". Covers all onshore and offshore worksites and downstream suppliers; accountable CEO; certified ISO 14001; works with the Code of Business Conduct and the Planet Manual (p.66).

Two strategic levers: "utilizing industry best practice standards and methodologies to meet and extended asset useful life" and "environmental improvement during projects and new buildings" (p.66).

Actions in relation to resource use and circular economy

Reference: page 67.

Two named actions: (1) Garbage and Waste Management Plans – IMO-approved plans on all vessels that "prioritise waste reduction, recycling, and responsible disposal" and segregate waste streams for proper processing; fleet-wide, ongoing as part of the Business Management System. (2) Project HSE Management Plans – established ad hoc per project to manage project-specific or remote/sensitive-environment waste streams (p.67).

On decommissioning: "DOF is involved in the value chain of offshore decommissioning. DOF acts on behalf of its clients to recover, segregate and deliver end-of-life subsea products to onshore waste disposal facilities", using "modular breakdown, use of ROV cutting to preserve component integrity, refurbishment of components where feasible and... chain of custody-tracking to avoid waste leakage" (p.67). "No major vessel conversions or asset decommissioning activities occurred during the reporting period" in 2025, so no substantial manufacturing by-products were identified.

Targets related to resource use and circular economy

Reference: page 66.

DOF states: "DOF has not established measurable targets in relation to resource use and circular economy. A key challenge for DOF regarding reducing waste is that it is difficult to decouple the rate in which waste is generated from the level of activity."

"As resource in-flows and outflows are not considered material, DOF has not adopted absolute or relative targets. Additional targets will be assessed when shipbuilding or asset decommissioning activities substantially increase" (p.66). In place of numeric targets, DOF tracks effectiveness through garbage-management-plan non-conformity counts (one recorded in 2025, a clerical miscategorisation of incinerator ash, since corrected) and through the safety-observation-card and audit processes (p.66).

Resource in-flows

Reference: page 67.

"DOF has identified virgin steel as a critical raw material input, in the areas of new-build and major vessel conversions." DOF has an active new-build programme with one vessel currently under construction; "the nature of DOF's 2025 newbuild program was not deemed extensive enough to consider resource in-flows as a material topic in the context of our value chain" (p.67).

Other inputs – process materials, semi-manufactured goods, heavy machinery, transport vehicles and IT equipment – are used but "sporadic, localised, and no single resource input is fundamental to the marine contracting services DOF provide". New-build vessels incorporate "circular design" considerations for preventative maintenance and long-term specification, intended to ensure each vessel "fulfills its budgeted lifespan" (p.67).

Resource out-flows

Reference: pages 67-68.

"Following our materiality assessment, no material impacts, risks, or opportunities related to resource outflows from products and services were identified" (p.67) – DOF's own operations generate waste (covered separately under the Waste disclosure) rather than outflows embedded in a sold product or service.

Circular-economy focus in outflows centres on decommissioning: "maximizing recovery efficiency, promoting material recirculation, minimizing waste, and ensuring proper segregation for future recycling and recovery" (p.67). End-of-life machinery components, consumables, sea-fastening grillage, installation aids and IT equipment are generated irregularly and in varying quantities, "rather than being fundamental to the direct value chain" (p.67). The detailed waste-outflow quantities (generation, recycling, incineration, disposal) are reported under the Waste disclosure (pp.67-68).

Waste

Reference: pages 67-68 (ESRS 37(a)-(d) paragraph references used directly by DOF).

"During 2025, our operations generated approximately 79,295 metric tonnes of waste... 35,040 metric tonnes were classified as hazardous waste and 44,254 metric tonnes as non-hazardous waste"; 97% of waste volume is non-recyclable, "principally because of the large quantities of oily water waste streams in addition to seawater discharges that are treated and discharged under MARPOL requirements (52% of total waste volume)" (p.68). The year-on-year reduction is "attributed largely to a significant reduction in treated sewage discharges". DOF flags measurement uncertainty: weight is derived from "a combination of direct weighing, precise measurement, and... established volume to weight conversion factors", with "some uncertainty" remaining "because certain figures are estimated by crew" (p.68). One non-conformity was recorded in 2025 (garbage-record miscategorisation, since corrected) (p.66).

Policies related to own workforce

Reference: pages 78-80 (wage/compensation, human rights), 87 (health and safety), 90-91 (equal opportunities), 95 (data privacy).

DOF groups own-workforce policy under five sub-topics. Wage and compensation / working conditions: Equal Employment Opportunity Policy and Human Resources Policy, both accountable to the CEO, covering "working hour requirements and timely payment of wages according to national legal standards or industry benchmarks" (p.79). Human rights: Business Integrity and Ethics Policy, Code of Business Conduct and a new Transparency Statement aligned to the Norwegian Transparency Act ("Åpenhetsloven"), reviewed annually "to meet June 30th update deadline" (p.80).

Health and safety: Health, Safety and Working Environment Policy (ISO 45001 / OHSAS 18001 certified) and a Security Policy covering physical, operational and cyber security (p.87). Equal treatment: Workplace Harassment Policy, Equal Employment Opportunities Policy and Human Resource Policy, all referencing the Dignity & Respect in the Workplace guide (p.90-91). Data security/privacy: Security Policy, a Personal Data Protection (Privacy) Standard aligned to GDPR and Brazil's LGPD, and a Cyber Security Management System certified to ISO 27001 (p.95). All policies are accountable to the CEO/Board and incorporate the UN Guiding Principles, OECD Guidelines and ILO Declaration.

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

Reference: page 81.

DOF's 2025 global employee engagement survey achieved a 71% response rate with more than 3,400 employees, consistent with 2024 findings; "the highest-scoring engagement drivers are again cooperation, job content, and health and safety" (p.81). A parallel 2025 culture survey ("SafeMind") assessed safety culture across regions. Managers own team/department action plans; the EVP People & Organisation oversees the overall process; the Global HSEQ Lead owns the culture-survey response rate.

Other engagement channels: regional safety delegates, working environment committees (minimum four meetings/year), employee representatives, vessel PECs (Protection and Environment Committees), over 2,500 internal audits in 2025, and vessel visits. DOF adheres to the Maritime Labour Convention (MLC) 2006 and has collective bargaining agreements with seafarer trade unions, supplemented by the "Fifty-fifty" gender-balance programme and a Diversity Equity and Inclusion committee (established 2024) for seeking perspectives of workers particularly vulnerable to impacts (p.81).

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

Reference: page 82.

"Our comprehensive grievance mechanism allows all internal and external stakeholders to report concerns and complaints via our ethics helpline", operated by a third party "to ensure the confidentiality and the psychological safety of individuals", available anonymously or with an open identity (p.82). The Code of Business Conduct's non-retaliation policy "strictly prohibits acts of retaliation or harassment against any person who has raised a concern in good faith" (p.82).

Alternative channels: supervisors, HR, legal department, employee/safety representatives, union representatives and work environment committees; offshore workers additionally have an Onboard Complaint Procedure with Dedicated Person Ashore follow-up. DOF flags a gap itself: "the 2025 employee survey response revealed that 9% of our employees does not know where they can report harassment or other critical conditions", prompting continued promotion of the channel (p.82). A separate channel for human rights violation inquiries, tied to the Transparency Act statement, received no inquiries in 2025 (p.82).

Taking action on material impacts on own workforce

Reference: pages 83 (wages), 88 (health and safety), 92 (equal treatment), 97 (data privacy).

Working conditions (p.83): Korn Ferry job-evaluation grading for salary benchmarking with annual settlement reviews; an annual minimum/living-wage benchmark report produced with the Slave Free Alliance; flexible/hybrid work arrangements for onshore staff.

Health and safety (p.88): a Q2 "5+2+1=Zero" safety campaign; a simplified OHS management system using electronic permits-to-work and toolbox talks; monthly HSEQ safety-theme videos; a new emergency management tool with over 10,000 drills and 80+ Level 2 exercises logged in 2025; ongoing monitoring of high-security-risk areas with partners Risk Intelligence, DNK and International SOS.

Equal treatment (p.92): the Fifty-fifty programme, the DOF Ambassador leadership-development programme (female representation "gradually increasing"), the new official DOF LeaderShip programme, graduate/cadetship/traineeship schemes, and updated employer branding to widen the diversity of the applicant pool.

Data privacy (p.97): ISO 27001-aligned Cyber Security Management System implemented in 2025; mandatory cyber/GDPR onboarding training repeated every 2-4 years; Cyber Security Awareness Month activities; cyber-crisis drills.

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

Reference: pages 84 (working conditions), 89 (health and safety), 94 (equal treatment), 97 (data privacy).

Working conditions (p.84): rolling targets of voluntary turnover ≤7% (2025 actual: 7.7%) and 80% performance-review completion (2025 actual: 69%) – both rolling/annual targets with no fixed base year.

Health and safety (p.89): a full HSEQ target table – Lost Time Injury Frequency Rate target <0.3/million man-hours (actual 0.91); Total Recordable Injury Rate target <1.1 (actual 2.03); First Aid Cases target <7.5 (actual 8.9); a new 2025 metric, Serious Incident Frequency, target <1 (actual 0.7); incident close-out rate target 90% within 90 days (actual 89.9% excl. safety observation cards, 61.2% incl.).

Equal treatment (p.94): 25% female representation among onshore professionals/managers by 2025 (first set 2021); actual 24.6% (up from 17.5% in 2021, 23.7% in 2024); target "will continue in 2026."

Data privacy (p.97): DOF states it "has not established any measurable or time-bound outcome-oriented targets" for data privacy, tracking effectiveness instead via data-breach monitoring and training-completion/simulated-attack reporting.

Characteristics of DOF's employees

Reference: page 84.

2025 headcount: 5,487 employees (4,670 male, 817 female), up from 4,744 in 2024. By employment category: 1,000 onshore, 1,207 offshore and 3,280 marine employees. Employee turnover rate 12.7% (2024: 12.44%), with 591 employees leaving during the year (2024: 433) – "includes resignation, pension, end of contract and redundancy" (p.84).

By country, the largest workforces are Brazil (2,164), Norway (982), Australia (749), Denmark (524) and the UK (200). The 743-person year-on-year increase is attributed mainly to the DOF Denmark acquisition integration, requiring recruitment in several regions (notably Brazil, where DOF Denmark vessels transferred into the Brazilian fleet). The Australia increase "is mainly due to incorrect entity reporting for DOF Singapore in 2024" being restated under Australian legal entities (p.84).

Characteristics of Non-employees in own workforce

Reference: page 85.

"In addition to employees, our workforce is comprised of 866 'non-employees'" (2024: 696) – "self-employed workers, independent contractors, freelancers and personnel provided by staffing or manning agencies", including crewing and agent support as part of DOF joint ventures, plus suppliers such as seafarers from OSM (disclosed separately under S1) (p.85). Headcount is as of 31 December 2025, consolidated regionally into one group report.

"The growing number of non-employees in 2025 compared to 2024, reflects increased project activity across all regions" (p.85). DOF notes internal HR KPI reporting groups casual and contracted personnel together as "contracted workforce" for monthly usage tracking, while CSRD reporting uses point-in-time headcount as of 31 December – "both datasets use the same source systems but differ in methodology by reporting purpose" (p.85).

Collective bargaining and social dialogue

Reference: page 85.

"74% of our employees are covered by collective bargaining agreements. There is more than one collective bargaining agreement covering our workforce, and differences vary between countries." (p.85)

Coverage/social-dialogue representation is reported by region (EEA employees by country: Denmark, Norway; non-EEA by region: Atlantic minus EEA, North America, Asia Pacific, South America) using banded ranges from 0-19% to 80-100% (p.85). Non-guaranteed-hours contracts "help manage workforce demand fluctuations, especially in regions with variable project work" (p.85).

Diversity metrics

Reference: page 94.

"DOF's target is to reach 25% female leaders in the seasoned professionals and management group onshore, by 2025" (p.94). By end-2025: Staff 17% female (703 of 4,189); Managers/seasoned professionals 10% female (62 of 639); Senior Managers 20% female (7 of 35). Aggregate female onshore leadership: 24.6%, against the 25% target (p.94).

Age-group breakdown of employees: under 30: 1,025; 30-50: 3,110; over 50: 1,352 (p.94). The target was "first announced in 2021, initiated by the stakeholders involved and because of the commitment to the 'Fifty-fifty' programme", evaluated at year-end and monitored via Power BI reports and quarterly reporting. "Although no KPI is set [for] the offshore workforce, we monitor development, and see there is significant work to improve female representation in the offshore and marine workforce" (p.94).

Adequate wages

Reference: page 85.

"All employees receive a fair and adequate wage. The company has conducted a comprehensive mapping exercise, examining the minimum wages in the countries where we operate, and ensured that the wages provided are above these thresholds." Wages are paid "in full and on-time, using national legal standards or industry benchmarks as a minimum requirement" (p.85).

Supporting action under S1-4 (p.83): together with the Slave Free Alliance, DOF produces an annual report benchmarking minimum and living wages in every country of operation, used "to assist in verifying that all employees are paid an adequate wage"; performed annually and "complete for 2025" given fluctuating benchmarks across DOF's footprint.

Social Protection

Reference: page 85.

"As of 2025, the majority of DOF employees are covered by social protection against income loss for sickness, unemployment (from start of employment), employment injury/acquired disability, parental leave, and retirement, through statutory systems and/or employer benefits. Coverage is not yet universal across all geographies" (p.85).

Coverage gaps named explicitly: Angola – employees not protected against unemployment; Ghana – not protected against unemployment; Singapore – not protected against unemployment; USA – no paid parental leave (p.85).

Health and Safety metrics

Reference: page 89.

"All workers on vessels and worksites are covered by the Occupational Health and Safety management system" – 100% coverage, both employees and non-employees, certified to ISO 45001 (yearly audit, three-year recertification by DNV) (p.89).

"There were no fatalities due to work-related injuries and work-related ill health in the year. There were 29 recordable work-related accidents, and the rate of accidents was 2.03" (p.89). DOF's own content index flags this row as partly phased in, specifically omitting "cases of work-related ill-health and... number of days lost to injuries, accidents, fatalities and work-related ill health" (p.52 index) – days-lost and ill-health-case figures are therefore not presented alongside the fatality/injury-rate data above.

Remuneration metrics (pay gap and total remuneration)

Reference: page 94.

"The average hourly wage of a female employee was approximately 79.6% of the average male employee's remuneration across all employees" in 2025 (implying a gender pay gap of 20.3%, shown in the pay-gap trend table: 2024 18.33%, 2025 20.3% – labelled differently within the report's own table and text, a minor internal inconsistency worth checking against the source) (p.94).

"The total remuneration of the highest paid individual was 20.4 times the median total remuneration for the company in 2025" (2024: 18.9) (p.94). DOF states: "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" (p.94).

Incidents, complaints and severe human rights impacts

Reference: page 86.

"In 2025, we received a total of 96 complaints through our various grievance mechanisms, and 23 of the cases were incidents of discrimination and harassment." 87 were raised via the whistleblowing system. "Among the incidents reported via the ethics helpline, 32 were substantiated and resulted in disciplinary action, training or review of policies. Seven (7) cases led to dismissal" (p.86).

"There were no reported severe human rights incidents, nor did we receive any complaints through the National Contact Point for OECD Multinational Enterprises. There were no significant fines or monetary sanctions related to workplace discrimination, complaints, or severe human rights incidents" during the year (p.86).

Policies related to Workers in the Value Chain

Reference: pages 98-99.

"The Supplier Code of Conduct addresses potential labour practices, human rights, health and safety, environmental and bribery and corruption risk in the supply chain. It is integrated into purchase agreements with suppliers... All new suppliers must commit to the code as a prerequisite for transacting business with our company" (p.99).

Supplier Code of Conduct: purpose is "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"; covers the supply chain; accountable CEO; aligned to the International Bill of Human Rights, ILO conventions and UN Guiding Principles (p.98). A companion Supply Chain Management Manual outlines engagement responsibilities including vessel-officer involvement and supplier feedback loops.

The identified IRO this topic addresses is child/forced labour risk "concentrated within DOF's use of shipyard facilities, manning agencies and utilization of manufactured goods received via upstream value chain" (p.98).

Processes for engaging with value chain workers about impacts

Reference: pages 99-100.

"Our engagement strategy unfolds at various stages of the supply chain process, beginning with the selection of suppliers and extending through regular, biannual reviews of working practices and conditions." Supplier selection is "built on UN Global Compact requirements and followed up with risk criteria inspections and audits", overseen by the EVP Marine & Asset Operations with supply chain managers (p.100).

Onboard engagement occurs via "daily meetings, inspections and direct dialogue with the workers in safety meetings"; at shipyards via "audits, day-to-day follow-up and collaboration with workers and their supervisors." DOF also runs client feedback surveys. Effectiveness is monitored by reviewing "outcomes of our initiatives, assess[ing] improvements in working conditions and the fulfillment of our agreements" (p.100). An onboarding induction programme introduces value chain workers to DOF's expected working environment, and some regular value-chain workers onboard vessels are included in DOF's own engagement surveys.

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

Reference: pages 99-100.

"Supplier engagement is monitored through our platforms, and where suppliers have not undertaken mandatory training, noncompliance is addressed as a part of ongoing supplier management" (p.99).

Value chain workers can access the Ethics Helpline (24/7, anonymous option, third-party operated) on the same terms as DOF's own employees; "DOF does not execute a systematic measure to check or validate if value chain trusts the structures and processes... Nevertheless, spot checks are performed during inspections, audits and onboardings" (p.100). The same non-retaliation policy embedded in the Code of Business Conduct applies. "All stakeholders, including value chain workers, can raise concerns regarding financial or legal impropriety through DOF's whistle-blowing system, detailed in G1-1." "The main concern is exposure to non-compliance labour and human rights practices, using short-term contracts and temporary employment through manning agencies, which may weaken worker's rights" (p.100).

Taking action on material impacts on value chain workers, and approaches to managing risks and pursuing opportunities related to value chain workers, and effectiveness of those actions

Reference: pages 100-101.

"DOF's resources allocated to manage these material impacts are embedded in the organization and way of working." Responsible functions: "HSEQ and ESG resources; Supply Chain, including procurement and logistics. The HR function for contract and training: Officers onboard, to oversee alignment with the ILO principles" (p.100).

Concrete 2025 actions (p.101): (1) an annual Human Rights and Modern Slavery due diligence assessment, complete for the 2025 reporting period; (2) an expanded Vendor Evaluation Questionnaire, adding questions on minimum wage and overtime pay, implemented in 2025; (3) regional supplier workshops across business areas to share values, human rights policies and the grievance mechanism. Each action maps to the Supplier Code of Conduct's alignment with the International Bill of Human Rights, ILO conventions and UN Guiding Principles.

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

Reference: page 101.

DOF states: "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."

"Though we have not set any targets, we have, from 2025, enhanced our data collection from our vendors to include information regarding minimum wages and overtime pay for their workers. This action can lay the basis for mapping our supplier's adherence to pay an adequate wage and can be the foundation that DOF needs to set targets in this area in the future." For 2026, "DOF will evaluate the data that has come in and analyse whether the quality of the data is reliable and if it can be used for developing our targets in this area going forward" (p.101). This mirrors S1-5's data-privacy sub-topic, where DOF similarly tracks effectiveness through monitoring rather than a stated numeric target.

Business Conduct Policies and corporate culture

Reference: pages 103-105.

"Every aspect of DOF's business conduct is anchored in a robust governance framework... incorporat[ing] Anti-Bribery and Anti-Corruption policies, which are consistent with the United Nations Convention against Corruption." The Audit Committee makes compliance recommendations to the Board, which "monitors adherence to the Code of Business Conduct (CoBC) and any reports raised through the whistleblowing system on a quarterly basis" (p.103). DOF maintains "a zero-tolerance risk appetite for compliance" tracked via key risk indicators.

Code of Business Conduct (CoBC) and Business Integrity and Ethics Policy – both accountable to CEO/Board, covering anti-corruption, anti-bribery, conflicts of interest, export/trade law and anti-money laundering (p.104).

Whistleblowing: independent provider, online; in 2025, 87 cases (26 duplicate/related); 75% from South America; of unique closed cases, 32% substantiated, 34% unsubstantiated, 14% insufficient information, 6% referred elsewhere; 7 dismissals (5 DOF, 2 hired) plus one supplier termination; average closure 48 days (target 80) (p.104).

Training: 1,973 employees completed CoBC training in 2025 (3,990 over three years); 1,320 completed Business and Ethics training; new modules on Dawn Raids, Antitrust and Sanctions for higher-risk functions (p.107).

Management of relationships with suppliers

Reference: pages 106-107.

The Supplier Code of Conduct (SCoC) is "incorporated into our standard terms and conditions", applying to 100% of procurement spend unless restricted by local legislation or exempted by subcontracted-work scope. Suppliers must share the SCoC with their own subcontractors (p.106).

Vendor evaluation process: risk-based, aligned to the UN Global Compact's Ten Principles. All vendors complete Vendor Evaluation Questionnaire (VEQ) Part 1; higher-risk vendors complete VEQ Part 1+2 (extended HSEQ controls) via the Factlines platform (EFCAZ for Brazil). Scores ≤55% require formal justification/EVP approval; scores with red flags require documented mitigation before approval. 633 vendor assessments were undertaken in 2025. Minor purchases (meals, subscriptions, government/utility invoices) may be exempted via a formal exemption form. Re-evaluation is required at least every 48 months (p.106-107).

"DOF has no cases of contract termination because of vendor misconduct in 2025." On payment practices for SMEs: standard terms are 60 days; average actual payment period 41 days in 2025; SME payment issues can be raised via a dedicated monitored inbox (p.107).

Prevention and detection of corruption and bribery

Reference: pages 106-107.

"DOF maintains a zero-tolerance approach to bribery and corruption, as outlined in our Code of Business Conduct (CoBC)." Investigations via the ethics hotline are handled by a team operating independently of the management involved, drawing on HR, HSE, finance, marine operations and legal expertise, with automatic exclusion of any named individual from that case's investigation; recommendations go to Executive Management or the CEO (p.107).

"The project management function, supply chain workers and officers on our vessels have been identified as having high exposure to corruption and bribery risks" due to permit-obtaining and government-official interfaces, mitigated through targeted anti-bribery/anti-corruption training (p.103). DOF is a member of the Maritime Anti-Corruption Network (MACN) for updates on developments and incidents, and states it "has implement robust financial controls to detect and prevent corrupt practices and... established systems to monitor transactions and activities for signs of corruption" (p.107).

Incidents of corruption or bribery

Reference: pages 107-108.

"No incidents related to fraud, corruption, bribery or breach of anti-trust or competition laws were reported in 2025." "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" (p.108).

This is reported alongside, but distinct from, the general whistle-blower case data under G1-1 (87 total cases, mostly relating to harassment/conduct rather than corruption specifically, p.104).

Payment practices

Reference: page 108.

"Payment terms listed in our General terms for Purchase is 60 days, unless agreed separately. Some specific agreements may have payment terms of 30 or 45 days." "In DOF the average days from invoice day until payment for 2025 were 41 days and the percentage of invoices paid within 60 days is 87%." This is "continuously monitored through a payment analysis dashboard linked with the ERP system" (p.108).

DOF also discloses, under G1-2 (p.107), that it uses electronic invoicing systems (Peppol, and Norway's EHF – Elektronisk Handels Format) "to enhance payment efficiency", and provides SMEs a dedicated monitored inbox (suppliers@dof.com) for payment-issue queries referencing the PO number.

Targets related to business conduct

Back-filled from the G1-1 and G1-3 business conduct chapter (pages 103, 107), since the 2023 ESRS had no standalone G1 targets disclosure requirement – it fell under MDR-T, which is mandatory only where the topic is material. This disclosure requirement is renumbered, not newly required, for the 2025/2026 ESRS.

DOF's own MDR-T incorporation-by-reference table lists E1-4, E2-3, E5-3 (Environment) and S1-5, S2-5 (Social) as its MDR-T-mapped rows – no G1 row is mapped to MDR-T, and no numeric business-conduct target (e.g. a bribery-incident or training-completion target) is stated anywhere in the G1 chapter.

DOF does describe how effectiveness is tracked instead: it "maintains a zero-tolerance risk appetite for compliance and monitors operational performance with targeted key risk indicators that track compliance across core business areas" (G1-1, p.103), and "has implement robust financial controls to detect and prevent corrupt practices and... established systems to monitor transactions and activities for signs of corruption" (G1-3, p.107). Whistle-blower case closure is tracked against an internal benchmark: "average time to close cases is 48 days... falls within the target of 80 days" (G1-1, p.104) – a handling-speed measure, not a conduct-outcome target, but together these satisfy MDR-T's "effectiveness tracked in the absence of a target" limb.