Norsk Hydro

The role of the administrative, management and supervisory bodies

Reference: pages 40-46; content index p.274 points GOV-1 to Corporate governance: Board of Directors; Board People and Remuneration Committee; Board Audit Committee; President & CEO and the Executive Leadership Team.

Hydro is a Norwegian public limited company following "the most recent Norwegian Code of Practice for Corporate Governance (NUES) dated August 28, 2025" (p.41).

Composition (p.42). "The Board of Directors consisted of 11 members as of December 31, 2025. Seven are elected by the General Meeting of shareholders, four are elected by and among the company's employees in Norway." "All shareholder elected members were in 2025 deemed to be independent according to the Norwegian standards." "No members elected by and among the employees are part of the company's executive management." Board committees are the Board Audit Committee and the Board People and Remuneration Committee (pp.40, 42). Gender distribution of the Board and the Executive Leadership Team is disclosed in note S1.2 (p.260).

Sustainability responsibility. "The Board works to ensure that sustainability is considered in the company's activities and value creation, and is regularly informed by the President & CEO about material impacts, risks and opportunities related to sustainability matters" (p.42). The Board's annual work plan includes "health and safety, and sustainability, including social responsibility, climate, and environment" (p.42). The double materiality assessment is "reviewed by Hydro's disclosure committee and approved by the Board of Directors" (p.73), and the sustainability statements are "approved by the Board of Directors" (p.70). Signed in Oslo on 12 February 2026 (p.135).

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

Reference: pages 40-46, 71, 131; content index p.274 points GOV-2 to Corporate governance: Board of Directors; President & CEO and the Executive Leadership Team.

Sustainability reaches the Board through the annual work plan, which carries "recurring topics such as strategy review, business planning, risk and compliance oversight, financial reporting, people strategy, succession planning as well as health and safety, and sustainability, including social responsibility, climate, and environment" (p.42). "Impact, risks, and opportunities related to sustainability, including environment and climate change, social responsibility, diversity, health, safety, and compliance, are integrated into the group's risk management and strategy processes, and are at the center of the Board's considerations and decision making throughout the year" (p.42).

Specific reporting lines. Risks over sustainability reporting "are reviewed with the Board Audit Committee and discussed with Hydro's external auditors who provide limited assurance over the sustainability statement" (p.71). On business conduct, "The Chief Compliance Officer reports to the Board of Directors through the Board Audit Committee at their own discretion... participate in all Board Audit Committee meetings and provides quarterly compliance updates to the audit committee", and "an annual compliance report is submitted to the Board of Directors" (p.131). The Chief Audit Executive "provides quarterly updates to the Committee and Corporate Management on matters reported through the AlertLine" (p.131). Tailings governance is "clearly defined, starting at the Board of Directors" (p.110). "There is a yearly compliance deep dive session for the board Audit Committee" (p.132).

Integration of sustainability-related performance in incentive schemes

Reference: page 72; content index p.274 routes GOV-3 to the remuneration report by incorporation by reference: General information: Incorporation of ESRS requirements by reference to other sections of the annual report and the remuneration report (see also p.71).

"Sustainability is integrated in the remuneration incentives of the Executive Leadership Team (ELT). Hydro's performance against targets for climate and nature comprise four percent of the CEO's short-term incentive plan and two percent or more of the short-term incentive plan of other members of the ELT. In 2026, the CEO will receive a climate related bonus equivalent to 5 percent of the base salary. See Hydro's remuneration report for more information on incentive schemes." (p.72)

The climate link is repeated in the climate chapter: "The climate strategy is integrated in the Executive Leadership Team's (ELT) remuneration and followed up as a quarterly KPI on the CEO's balanced scorecard. See the remuneration report for more information." (p.80)

Gap to note. The detailed datapoints required under ESRS 2 GOV-3 (the full performance metrics used, the linkage to GHG reduction targets, and the proportion of variable remuneration recognised in the year that is sustainability-linked) are not set out in the sustainability statement itself; they are incorporated by reference to the separate remuneration report, which is not part of this document.

Statement on due diligence

Reference: page 72; content index p.274 points GOV-4 to General information: Sustainability due diligence.

"Requirements for sustainability due diligence and risk management are embedded in business processes based on Hydro's global governing documents, including Hydro's human rights policy, Hydro's Code of Conduct and Supplier Code of Conduct, and Hydro's global sustainability policy." (p.72)

"The sustainability statements' chapter corresponding to each material sustainability matter provides an overview of risk assessment and due diligence processes in relation to each sustainability topic, including Hydro's assessment of identified adverse impacts, Hydro's actions to address identified impacts, and the results of these efforts." (p.72) That mapping is how Hydro satisfies the ESRS 2 GOV-4 table: the due diligence elements are distributed to the topical chapters rather than tabulated in one place.

"When planning new projects, major developments or large expansions, it is a requirement to evaluate the environmental and social impact. Hydro follows standards such as the International Finance Corporation Performance Standards, Equator principles, and the UN Guiding Principles on Business and Human Rights. This includes the principle of free, prior, and informed consent when indigenous and traditional people are involved." (p.72)

Impact materiality is assessed "in accordance with the GRI Standards and OECD Due Diligence Guidance for Responsible Business Conduct" (p.73).

Risk management and internal controls over sustainability reporting

Reference: page 71; content index p.274 points GOV-5 to General information: Risk management and internal control over sustainability reporting.

"Hydro regularly assesses risk and controls over its sustainability reporting process. The risks are reviewed with the Board Audit Committee and discussed with Hydro's external auditors who provide limited assurance over the sustainability statement. The external assurance process is risk based, and the external auditors provide feedback on their assessment of risks to the Board Audit Committee and Hydro's management. The auditors also provide feedback to the Board of Directors in relation to the Board's review and approval of the integrated annual report." (p.71)

Reporting systems are described alongside: environmental metrics come from "Hydro's environmental reporting system on an annual basis"; health and safety metrics "using the reporting systems for incident reporting"; diversity and other own-workforce metrics "from Hydro's HR system and employee engagement surveys"; value chain and community data "based on Hydro's due diligence processes and data collected from the business areas, procurement teams, and alerts reported to line management" (p.70).

Reporting change in 2025. "To improve access and analysis of quantitative ESG data, all quantitative sustainability metrics have been moved to a single ESG fact book in the Appendix. Metrics in the appendix are part of Hydro's management report, approved by the Board of Directors, and subject to the same level of control and external assurance as the sustainability statements." (p.71)

The description is qualitative; no risk register, control-testing results or identified control deficiencies are quantified.

Strategy, business model and value chain

Reference: pages 10-18, 71; content index p.274 points SBM-1 to Our business: About Hydro; Main inputs and outcomes; Business areas; Own workforce: Note S1.1; Consolidated financial statement: Note 1.4.

Hydro is an integrated aluminium and renewable energy company with an equity-basis Scope 1 and 2 footprint of 8.75 million tonnes CO2e in 2025 (p.78) and 33,400 employees at year end (note S1.1, p.259). The value chain runs from bauxite mining at Paragominas in Pará, Brazil, through alumina refining at Alunorte, primary aluminium production (five fully owned smelters in Norway plus Albras in Brazil and part-owned plants in Australia, Canada and Qatar), casting, recycling and extrusion, supported by captive renewable power: "the company operates 42 renewable power plants with a combined output of 13.7 TWh in a normal year. Adjusted for ownership shares, Hydro's captive hydropower production is 9.4 TWh in a normal year" (p.81).

The supply chain is described in the value chain workers chapter: "a network of more than 30,000 suppliers across over 40 countries and 30,000 customers worldwide" (p.117); note S2.1 reports 42,850 supplier vendor records and NOK 159,401 million of supplier spend in 2025, with "approximately 39,000" unique suppliers (p.266).

Product brands carrying sustainability attributes are named: Hydro REDUXA low-carbon primary aluminium "below 4.0 kgCO2e per kilo aluminium, which is significantly less than the global average of 14.4", and Hydro CIRCAL with "more than 75 percent PCS" and "a market leading CO2 footprint of 1.9 kg of CO2e/kg aluminium" (p.83).

SBM-1 is disclosed by incorporation by reference (p.71) rather than as a dedicated ESRS 2 section.

Interests and views of stakeholders

Reference: page 72; content index p.274 points SBM-2 to General information: Interests and views of stakeholders; Materiality assessment; Corporate governance: Board of Directors; Executive Leadership Team.

Hydro maps stakeholders into four groups on p.72: Market (commodity and stock exchanges, competitors, customers, insurers and banks, partners and joint ventures, suppliers, other business relations); Society (academia, authorities, industry associations, lobby groups, local communities, media, national and international unions, NGOs, politicians, public offices, R&D funding bodies); Owners (owners and shareholders, the Norwegian government, financial markets, analysts, traders, brokers, ratings agencies); and Internal (Board of Directors, employee representatives, employees).

"Hydro consults affected stakeholders to identify, assess, and manage actual and potential social, health, safety, environmental, and economic impacts associated with its activities and business relationships." (p.72)

Link to the materiality assessment. "The views of Hydro's stakeholders are integrated in the annual update of the materiality assessment. Hydro's group functions and business areas summarize input provided to them through their engagement with affected stakeholders and their interaction with external sustainability experts and users of Hydro's sustainability statement." (p.73)

Link to governance. "Dialogue with affected stakeholders and their proxies gives input to action plans to prevent potential impacts and manage actual impacts. The input of affected stakeholders are integrated in the reporting on sustainability topics to Hydro management." (p.72) "All business areas have a forum for dialogue between management and union or employee representatives." (p.72)

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

Reference: pages 73-77; content index p.274 points SBM-3 to General information: Materiality assessment; Reporting changes and prior reporting errors; and disclosures in relation to each ESRS topic.

The summary materiality table (p.73) rates each topic on impact and financial materiality using a scale from "Significant adverse impact or risk" to "Strong beneficial impact or opportunity", flagged actual (A) or potential (P). Ten topics are in scope: E1 Climate change, E2 Pollution, E3 Water, E4 Biodiversity and ecosystems, E5 Resource use and circular economy, the Hydro-specific topic Legacy assets, S1 Own workforce, S2 Workers in the value chain, S3 Affected communities and G1 Business conduct. S4 Consumers and end users is "Not material" and "Not in scope". G1 carries "N/A" for impact materiality and a significant potential adverse risk for financial materiality.

Pages 74-77 then set out per-topic tables of "Material impacts" and "Material risks and opportunities" as bullet lists, and connect each to the enterprise risk register: for example climate IROs are "connected to other risks, including macroeconomic developments, geopolitical tensions, protectionism and trade disruptions; complex and evolving sustainability landscape; regulatory and policy framework uncertainty; climate change; and insufficient asset integrity described in the chapter on enterprise risk management" (p.74).

"Not all sustainability related impacts and risks in the sustainability statements are specifically highlighted in Hydro's aggregate risk profile described in the Risk review section." (p.73)

Limitation. The IRO tables name each impact, risk and opportunity in prose and place it in own operations or the value chain, but they do not tag time horizons uniformly per row, and no anticipated financial effects are quantified (E1-9, E2-6, E3-5, E4-6 and E5-6 are all under phase-in, p.70).

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

Reference: pages 73-77; content index p.274 points IRO-1 to General information: Materiality assessment (table).

"Hydro assesses material sustainability related impacts, risks, and opportunities according to the ESRS concept and requirements of double materiality. The assessment is reviewed by Hydro's disclosure committee and approved by the Board of Directors." (p.73)

Inputs. The assessment draws on "input from Hydro's subject matter experts in group functions for climate, environment, social responsibility, health and safety, communication and investor relations, compensation and benefits, diversity, inclusion and belonging, compliance, and enterprise risk management, as well as input from risk management and sustainability functions in each business area" (p.73).

Impact materiality is "assessed based on the severity and likelihood of impacts occurring... based on the primary consequence scales in Hydro's global ERM directive. For potential incident related environmental impacts, materiality is assessed based on the environmental consequence scales in Hydro's Guidance for HSE Incidents management. For human rights impacts, reference is made to the metrics for assessing severity of human rights impacts defined in the ICMM Human Rights Due Diligence Guidance." (p.73)

Financial materiality is "assessed in terms of risk of negative reputational, financial or commercial consequences for Hydro... The materiality of risks and opportunities is assessed based on the likelihood and magnitude of anticipated effects on Hydro's performance, financial position, cash flow, access to finance, or cost of capital." (p.73)

Topic-specific screening methods are set out per standard on pp.74-77, including WRI Aqueduct for water, the SBTN materiality screening tool and ENCORE for nature (p.93), IPCC scenarios for physical climate risk and EcoVadis country risk scores for the supply chain (pp.74, 119). No quantitative materiality threshold is published.

Climate-specific risk identification and scenario analysis is also presented under E1-2 (2025 ESRS numbering).

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

Reference: pages 274-276 (the ESRS content index); signposted at page 71.

"A content index with the ESRS Disclosure Requirements that are covered by the sustainability statement (IRO-2), is included in the Appendix." (p.71)

The index is a three-column table (ESRS standard / Disclosure requirement / Reference to annual report) running over pages 274-276. It lists BP-1, BP-2, GOV-1 to GOV-5, SBM-1 to SBM-3, IRO-1, IRO-2, E1-1 to E1-6 and E1-8, E2-1 to E2-5, E3-1 to E3-4, E4-1 to E4-5, E5-1 to E5-5, S1-1 to S1-6 and S1-8 to S1-11 and S1-13 to S1-17, S2-1 to S2-5, S3-1 to S3-5, and G1-1 to G1-6. References are given as section names, not page numbers.

Disclosure requirements absent from the index: E1-7, E1-9, E2-6, E3-5, E4-6, E5-6, S1-7, S1-12 and the whole of S4.

Declared phase-ins. "Hydro follows the phase in provisions for disclosure requirements E1-9, E2-6, E3-5, E4-6, E5-6." (p.70)

One nil return is recorded inside the index itself: E3-3 Targets related to water and marine resources carries the reference "N/A: No group targets related to water" (p.275), which matches the water chapter: "There are no group wide targets for water, but operational sites must develop context relevant targets" (p.90).

A companion appendix, "List of data points that derive from other EU legislations", begins on p.277.

Transition plan for climate change mitigation

Reference: pages 79-83; content index p.274 points E1-1 to Climate change: Strategy and transition plan; Net-zero Hydro; Emission reduction activities; Adressing climate risks and opportunities; Potential carbon lock-in in the aluminium value chain; EU Taxonomy.

"Hydro's climate strategy and transition plan is an integral part of its overall business strategy. Hydro's net-zero ambitions are based on a successful transition to a 1.5-degree economy, and are in line with climate science and the Paris agreement as expressed by the industry decarbonization pathways developed by the International Aluminium Institute (IAI)." (p.79) The strategy has three pillars: Net-zero Hydro, Net-zero products and Net-zero societies.

Targets and progress. 10 percent reduction in Scope 1 and 2 by 2025, 30 percent by 2030 and net-zero by 2050 or before, from a 2018 baseline of "about 10 million tonnes CO2 equivalents" (p.80). "In 2025, Hydro reached a reduction of 18.7 percent, thus reaching its 2025 target" (p.80). Upstream Scope 3 targets are minus 15 percent absolute and minus 30 percent per tonne of aluminium by 2030 (p.83).

Levers. A decarbonisation table on p.79 lists each lever with status: the Alunorte fuel switch from heavy fuel oil to natural gas (~434,000 tonnes CO2e, Completed), three 60MW electric boilers (~248,000 tonnes, Completed), 104 kton biomass fuel (Ongoing), renewable PPAs, biomethane at Sunndal, plasma remelting, green hydrogen at Høyanger (Ready for operation 2026), CCS ("Industrial concept pilots under construction by 2030"), HalZero and carbon removal (R&D).

Governance. "The technology and decarbonization roadmap is approved by the Executive Leadership Team." (p.80) "All significant investment decisions are assessed for their impact on Hydro's climate strategy according to Hydro's policies addressing climate change mitigation." (p.80)

Carbon lock-in is addressed explicitly on p.85, including Qatalum's integrated gas-fired plant and the residual-emission risk from CCS capture efficiency. "Hydro is not excluded from EU Paris aligned Benchmarks." (p.85)

Identification of climate-related risks and scenario analysis

Back-filled from ESRS 2 IRO-1 (p.74) and the E1 section "Addressing climate risks and opportunities" (pp.84-85), where this content is disclosed in the FY2025 report. This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Reference: pages 74, 84-85, 147.

Classification (¶15). Risks are separated into physical and transition. Physical: "acute and/or chronic changes in rainfall patterns, flooding, shortages of water or other natural resources, variations in sea levels, storm patterns and intensities as well as temperatures... Such risks can result in flooding of facilities, interruptions to production processes, infrastructure failures and potential accidents" (p.84). Transition risks are broken into regulatory, market and technology risk (pp.84-85).

Methodology (¶16). "All existing and planned production assets are screened, and all GHG emissions resulting from energy use and aluminium electrolysis processes are calculated. Material GHG emissions in Hydro's value chain are identified and calculated based on the International Aluminum Institute's guideline." "Assets and business activities are screened for transition risks and compatibility with a 1.5-degree scenario as part of enterprise risk and strategy processes. Climate related physical risks are assessed using models for future weather patterns and their impact on production facilities in different scenarios from the Intergovernmental Panel on Climate Change (IPCC) in 2030, 2040, and 2050." (p.74)

Scenarios used (¶17). Physical: "In 2018, Hydro modelled future weather patterns and their impact on its facilities based on climate models and scenarios from the Intergovernmental Panel on Climate Change (IPCC). In 2023, Hydro updated the physical climate risk assessment, which included modelling the risk of climate related events in the current situation, in addition to RCP 4.5 and RCP 8.5 in a 2030, 2040, and 2050 scenario." (p.84) RCP 8.5 is a high-emission scenario, satisfying ¶17(a)(i). Transition: "The company has assessed scenarios for regulatory risks, market risks and technology risks, including scenarios consistent with a 1.5-degree economy, in the short, medium and long-term." (p.84) The 1.5°C reference is the IAI pathway built "based on the International Energy Agency's (IEA) 1.5-degree scenario, combined with IAI's analysis of demand in the aluminium market and material flows" (p.80).

Gaps. No global average temperature projection per scenario is given (¶17(a)(iii)), key assumptions on policy, macroeconomics and energy mix are described qualitatively rather than listed, and the physical assessment has not been refreshed since 2023.

Resilience in relation to climate change

Back-filled from ESRS 2 SBM-3 (pp.73-74), the E1 sections "Addressing climate risks and opportunities" and "Potential carbon lock-in in the aluminium value chain" (pp.84-85), and note 1.1 to the financial statements (p.147), where this content is disclosed in the FY2025 report. This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Reference: pages 84-85, 147.

No ESRS-defined resilience analysis is presented. The report contains no section headed resilience in the climate chapter and no statement that a resilience analysis under ESRS E1 was performed. What it does disclose is the following.

Strategic implications (¶19(a)(i)). "Hydro is well positioned to benefit from the transition to net zero GHG emissions. Hydro generates significantly lower GHG emissions than the industry average, and the average carbon intensity of Hydro's aluminium production is below the 2030 and 2035 targets in the 1.5 degree scenario that the International Aluminium Institute has defined for the aluminium industry." (p.147) Against that: "In the opposite scenario, Hydro will have a disadvantage if significant carbon taxes are placed on emissions in countries or regions where Hydro's production is placed while similar regulation is not introduced in competing regions." (p.147)

How scenario results feed the response (¶19(a)(ii)). "Hydro's long-term positioning, and operational and financial planning, reflect the company's assessment of transition risks in a 1.5-degree scenario." (p.84) "The findings from the updated climate assessment have been integrated in Hydro's risk management system. Several of Hydro's assets have already undertaken significant upgrades to manage climate related risks such as the effects of increased precipitation and associated flood risks." (p.84)

Uncertainty (¶19(b)). "The long-term financial effects of the decarbonization roadmap are highly uncertain." (p.80) "However, Hydro is still exposed to significant transition risks to achieve net zero emissions by 2050, including technology risks, regulatory risks, and market risks. Sufficient renewable energy must be available for our production sites at a cost that is achievable." (p.147) CBAM impact "on Hydro is therefore uncertain" (p.85).

Capacity to adapt (¶19(c)). Adaptive capacity is implied by the technology optionality (HalZero, CCS retrofits, post-consumer scrap) and by hydropower flexibility work at Rjukan, Illvatn and Røldal-Suldal (pp.81-83), but no assessment of financial flexibility, redeployment or asset decommissioning capacity is presented, and no time horizons are attached.

Policies related to climate change mitigation and adaptation

Reference: pages 78-80; content index p.274 points E1-2 to Climate change: Strategy and transition plan.

"Hydro's approach to managing climate impacts and risks, including climate change mitigation and adaptation, is governed by Hydro's sustainability policy and Hydro's global directive for sustainability. Hydro identifies and measures impacts on climate change by calculating and managing its GHG emissions from all its operations and from material parts of its value chain. Hydro's methodologies are aligned with international standards including the Greenhouse Gas Protocol and industry standards from the International Aluminium Institute (IAI)." (p.78)

The policy is anchored at executive level: "Hydro's climate strategy is integrated in the overall strategy as set by the Executive Leadership Team. The business areas are responsible for Hydro's performance and implementation of the climate strategy. All significant investment decisions are assessed for their impact on Hydro's climate strategy according to Hydro's policies addressing climate change mitigation." (p.80)

Offsetting is excluded by policy: "Hydro's decarbonization roadmap addresses actual GHG emission reductions and the ambition is to reach the reduction targets without using carbon offsets." (p.80)

A public elaboration is referenced: "A thorough description of Hydro's climate related impacts and how Hydro works to prevent, mitigate and remediate these, is provided in the white paper Positioning Hydro for the just and green transition." (p.80)

Limitation. The MDR-P datapoints (scope of the policy by activity and geography, the most senior level accountable, third-party standards adhered to, consideration of stakeholder interests, and how the policy is made available) are not tabulated; policy content has to be read out of the narrative.

Actions and resources in relation to climate change policies

Reference: pages 80-83, 100-108; content index p.274 points E1-3 to Climate change: Net-zero Hydro; Emission reduction activities; EU Taxonomy.

Bauxite and alumina. "The Fuel Switch Project was implemented in 2024 and replaced heavy fuel oil with natural gas. The project was further supported by the installation of three electric boilers... It is estimated that the fuel switch project and electric boilers reduced emissions by total of 1,400,000 tCO2e." (p.81) "In 2025, the refinery established solar and wind farms in Brazil's Northeast to sustainably meet its energy demands." At Paragominas the mine ran "four electric trucks, ten electric light vehicles, and more than 30 biofuel powered vehicles", and ore microfragmentation "reduces around 30 percent of emissions during the loading stage" (p.81).

Casting and anodes. "Biomethane deliveries have started at Sunndal and will ramp up to reduce emissions by 20,000 tonnes of CO2e each year. Testing of emission free plasma technology is planned at Sunndal for 2026/27." The Høyanger green hydrogen pilot is "nearing completion, with operations expected to begin in the first half of 2026" (p.81).

Recycling. "In 2025, Hydro increased its post-consumer scrap recycling capacity to 745kt." (p.82) Construction started in March 2025 on a 120,000 tonne recycler in Torija, Spain (pp.82-83).

Resources. Financing is described rather than a climate capex figure: an EU Green Bond and ICMA Green Bond issued in 2025, a USD 200 million sustainability linked loan at Alunorte, and USD 1,600 million and USD 800 million revolving credit facilities refinanced in 2025 as sustainability linked loans whose margin adjusts on CO2 per tonne of hot metal (p.82).

Gap. "Hydro does not have a formal capex plan as described in the Taxonomy regulation (EU) 2021/2178." (p.100) No monetary amount is attributed to the climate actions themselves; taxonomy-aligned revenue was 31 percent and eligible revenue 47 percent in 2025 (p.104).

Targets related to climate change mitigation and adaptation

Reference: pages 78-80, 83; content index p.274 points E1-4 to Climate change: Strategy and transition plan; Net-zero Hydro; Emission reduction activities; Greener sourcing and scope 3 emissions; Adressing climate risks and opportunities; Appendix: Note E1.1.

Scope 1 and 2 (ownership equity basis). "10 percent reduction by 2025 against 2018 baseline, 30 percent reduction by 2030, and net-zero by 2050 or before" (p.78). Performance against that target: (18.7)% in 2025, (16.1)% in 2024, (11.9)% in 2023 (p.78). Absolute emissions were 8.75 million tonnes CO2e in 2025, 8.97 in 2024 and 9.26 in 2023 (p.78). "In 2025, Hydro reached a reduction of 18.7 percent, thus reaching its 2025 target." (p.80)

Scope 3. "In 2022, Hydro set emissions reduction targets for upstream Scope 3 emissions to reduce total upstream Scope 3 emissions by 15 percent by 2030, and to reduce upstream Scope 3 emissions per tonne aluminium delivered to the market by 30 percent by 2030. Both targets refer to a 2018 baseline, except for Hydro's Brazilian activities where the baseline is 2017. Downstream Scope 3 emissions were not included in the targets since upstream emissions represent 90 percent of the total Scope 3 emissions." (p.83) Reported performance: "for 2025, the reduction of total Scope 3 emissions was 30 percent from 2018 baseline. The reduction in upstream Scope 3 emissions per tonne aluminium delivered to market was 20 percent in 2025" (p.83).

Baseline restatement. "The baseline for Hydro's Scope 3 emissions has been recalculated to ensure a consistent methodology... This affects the performance against Scope 3 targets for all reported periods." (p.71) The 2024 over-achievement is explained as partly a market effect and partly "inconsistent use of baseline numbers versus reported performance numbers" (p.83). Hydro also "recalculates the baseline after changes to the portfolio so that progress towards the target reflects actual decarbonization efforts" (p.80).

Product target. "the ambition to deliver Hydro REDUXA 3.0 with a carbon footprint of less than 3 tonnes of CO2e per mt of aluminium by 2030" (p.83).

Gap. No SBTi validation is claimed, and no adaptation target is set.

Energy consumption and mix

Reference: pages 81, 240-241 (notes E1.6 and E1.7); content index p.274 points E1-5 to Appendix Note E1.6; E1.7.

Note E1.6 reports "Total energy consumption in Hydro's controlled operations, reported by energy carrier. Energy consumption includes energy generated by Hydro operations, purchased energy, and energy losses in hydroelectric plants. Other hydrocarbons sources reported include heating, cooling and steam generated in Hydro operations, as well as purchased steam and heat in the Extrusions business area." (p.240) Carriers broken out include coal, electricity, diesel/gasoil and gasoline (p.240). Note E1.7 reports energy intensity (p.241). References given: "GRI Standards 302-1 (2016); ESRS E1-5" (p.240) and "GRI Standards 302-3 (2016); ESRS E1-5" (p.241).

Renewable share, from the narrative. "Over 70 percent of the electricity used in Hydro's primary aluminium production comes from renewable sources. In Norway, Hydro's primary aluminium production is powered by nearly 100 percent renewable energy by following a location based approach." (p.81) "To secure continued supply of renewable power to Hydro's operations in Norway, the company operates 42 renewable power plants with a combined output of 13.7 TWh in a normal year. Adjusted for ownership shares, Hydro's captive hydropower production is 9.4 TWh in a normal year. Hydro also operates a wind farm and purchase more than 9 TWh of renewable power annually in the Nordic market under long-term contracts." (p.81)

Hydro also flags that one E1-5 datapoint is a compliance number rather than a management one: energy intensity "based on net revenue is an ESRS reporting requirement but not an operational target for Hydro, as the value will vary" with market conditions (p.241).

Note. Aluminium production and hydropower generation are both high climate impact sectors under ESRS E1, so the sector-split intensity disclosure applies; the notes are presented as tables in the ESG factbook rather than in the narrative chapter.

Gross Scopes 1, 2, 3 and Total GHG emissions

Reference: pages 78, 80, 83, 237-240 (notes E1.1 to E1.5); content index p.274 points E1-6 to Appendix: Note E1.1; E1.2; E1.3; E1.4; E1.5.

Hydro reports two boundaries side by side and is explicit about why. Note E1.1 gives "Total direct and indirect (scope 1 and 2) GHG emissions, based on ownership equity, reported per business segment... according to the equity share principle... The reported emissions include Hydro's share of emissions from all operations including non-controlled operations where Hydro has a minority interest." (p.237) That is the basis for the targets: 8.75 million tonnes CO2e in 2025 (p.78).

Note E1.2 gives the ESRS boundary: "The following emissions are calculated for Hydro's consolidated operations according to ESRS E1-6. The reported emissions include Scope 1 and 2 GHG emissions on 100 percent basis for fully consolidated units, and on an equity basis for the joint operation, Tomago. Scope 1 and location-based Scope 2 GHG emissions for the non-controlled smelter Alouette and the joint venture Qatalum are included in the reported Scope 3 category 15 'Investment', on an equity basis, including Hydro's share of GHG emissions from the natural gas fired power plant at Qatalum." (p.238) The table gives gross Scope 1, the percentage from regulated emission trading schemes, gross location-based and market-based Scope 2, six Scope 3 categories (purchased goods and services; fuel and energy-related activities; upstream transportation and distribution; downstream transportation; processing of sold products; investments) and total GHG emissions on both location- and market-based bases, for 2025, 2024 and 2018 (p.238).

Market-based method. "Hydro's electricity consumption in Norway is fully covered by green Power Purchase Agreements (PPAs), with about 60 percent through an internal PPA where energy attribute certificates (EACs) are cancelled. The remaining share is covered by external PPAs without EAC cancellation... The table includes consolidated gross market-based scope 2 emissions, acknowledging green PPAs as documentation." (p.238) Residual mix factors are named per region (AiB, NORSUS, Green-e, Australian Government, IEA).

Emission split (p.80): electrolysis process ~30 percent, natural gas in casthouses ~10 percent, Scope 2 ~35 percent, Alunorte fossil fuel ~25 percent. Emission factors: DEFRA 2023; GWPs from IPCC AR6 (p.237).

Internal carbon pricing

Reference: page 85 and note E1.2 (p.238); content index p.274 points E1-8 to Climate change: Internal carbon pricing; Appendix: Note E1.2.

"A large amount of Hydro's aluminium operations falls within the scope of the EU Emissions Trading System (EU ETS). Hydro purchases and surrenders allowances (EUAs) to fulfil the company's compliance obligations under the EU ETS, and receives a proportion of free EUAs. The amount of purchased and received EUAs is publicly available information at a national level by the respective local EU ETS authorities." (p.85)

How the price is applied. "Hydro uses the EU ETS carbon price in internal decision making processes inside and outside of the EU/EEA, and the cost of carbon is integrated in financial and operational decisions. By including a carbon price in Hydro's analysis, costs related to CO2 emissions become a variable operational cost at plant level and CO2 price expectations influence future investment decisions." (p.85)

A second compliance market is disclosed: "Hydro's part owned primary aluminium producer, Alouette, is also subject to carbon market compliance obligations under the Québec cap-and-trade system which is part of the Western Climate Initiative (WCI)." (p.85)

Note E1.2 discloses "Percentage of Scope 1 GHG emissions from regulated emission trading schemes" (p.238), which links the pricing scheme back to the covered emissions.

Gaps. Hydro does not publish a shadow price level in currency per tonne, does not state the share of Scope 1, 2 or 3 emissions covered by an internal price as distinct from the ETS coverage, and does not explain how the price is set or reviewed. The disclosure is effectively a compliance-price description rather than a proprietary internal carbon price.

Policies related to pollution

Reference: page 87; content index p.274 points E2-1 to Pollution: Our approach.

"Hydro's approach to managing pollution impacts and risks is governed by Hydro's global directives for sustainability and health, safety, and environment. All operational sites controlled by Hydro shall reduce the risk of negative impact on the environment and prevent or minimize the release of pollutants to air, water, and land in accordance with the environmental licensing and applicable legal requirements. These emissions are typically subject to regulatory controls and requirements such as emission limits, abatement and monitoring. The requirements are reflected in the operational licenses and will differ depending on the type of activity and applicable regulatory frameworks." (p.87)

Substances policy. "Hydro's global governance for health risk management and environment management require all operational sites that are fully owned or operated by Hydro to identify, risk assess, minimize, evaluate for substitution, and appropriately manage all hazardous materials or substances, purchased or generated in its processes, that have the potential to cause ill health or to negatively impact the environment." (p.87)

Product compliance. Products are "subject to compliance declarations according to different EU and U.S. legislations. This includes registration, evaluation, authorization. and restriction of chemicals (REACH) and restriction of hazardous substances (RoHS) in the EU, and the Toxic Substances Control Act and California's proposition 65 in the U.S." (p.87)

Incident prevention. "To avoid incidents of pollution and mitigate impacts in the event of a spill or other unplanned event, all sites are required to perform risk assessments and establish action plans and controls to manage the risk, such as emergency action procedure, secondary containment, and storage basins." (p.87)

Assessment methodology is benchmarked to "the Best Available Techniques Reference documentation (BREF) for the non-ferrous metals industries" (p.74).

Actions and resources related to pollution

Reference: pages 87-88; content index p.274 points E2-2 to Pollution: Our approach (with the actions section on p.87).

Sulphur, nitrogen oxides and particulates. "A key driver for this improvement is the complete replacement of heavy fuel oil with natural gas at Hydro's refinery, Alunorte in 2025." (p.87) "Where technically feasible, Hydro has implemented seawater fed scrubbers to reduce SO2 emissions." (p.87)

Fluoride. "Hydro has set targets to reduce fluoride emissions from its fully owned smelters. These smelters currently perform below the EU regulatory emission limit for existing smelters (0.6 kg F/t Al) and the average across these smelters is also below EU regulatory emission limit for new smelters (0.35 kg F/t Al). Hydro will continue to invest in upgrades to gas treatment centers... As of 2025, four out of Hydro's five fully owned smelters have achieved the target." (p.87)

Mercury. "Inorganic mercury compounds are naturally occurring trace elements within bauxite... To reduce emissions of mercury to air, Hydro has initiated a project to install four non-condensable gases units (condensers) on Alunorte's seven production lines. The first condenser was installed in 2018, as a pilot... A second condenser was installed in 2023 and entered into operation in 2024. The third condenser was installed in 2024 and was operational during 2025. The final condenser was installed in 2025, completing the implementation of all four units." (p.87)

Value chain action. "As an Alliance Member, Hydro has worked with the Stockholm Environment Institute to develop inventories and baselines of material air pollutants, linked to its electricity sourcing and wider value chain. This data will be used as input for future disclosures and target setting." (p.87)

A summary table on p.88 maps each activity (bauxite mining, alumina refining, primary production, recycling, extrusion) to its emissions and named mitigating actions: clarification basins, two-step water treatment, water spraying and geotextile covers, mercury condensers, alumina fed dry scrubbers, seawater fed wet scrubbers, bag filters and wastewater treatment plants.

No monetary amounts are attached to the pollution actions.

Targets related to pollution

Reference: pages 86-87; content index p.274 points E2-3 to Pollution: Actions to reduce risk of pollution.

Three quantified group targets, each against a 2017 baseline, are set out with performance in the topic dashboard on p.86:

"In 2025, Hydro already met its 2030 targets for SO2 and NOx reductions and progressed further towards its PM10 target." (p.86) The chapter restates the percentages: "In 2025, total emissions of SO2, NOx and PM10 were 51 percent, 72 percent and 39 percent lower, respectively, than the 2017 baseline." (p.87) The p.86 chart shows 51, 71 and 39 percent reductions respectively against the 50 percent 2030 target line.

Voluntary status is declared. "Hydro has established a voluntary target to halve material non-GHG emissions (i.e. SO2, NOx and PM10 emissions to air) by 2030, from a 2017 baseline." (p.87)

Fluoride target. "Hydro's 2030 target is to bring individual smelters' performance below the 0.35 kg F/t Al threshold where feasible, acknowledging that outcomes may vary across sites." (p.87)

Gap. No target is set for emissions to water, for substances of concern, or for the value chain; the air pollutant value chain inventory built with the Stockholm Environment Institute is described as "input for future disclosures and target setting" (p.87), not as a target yet.

Pollution of air, water and soil

Reference: pages 86-88 and notes E2.1 to E2.4 (pp.242-244); content index p.274 points E2-4 to Appendix: Note E2.1.

Note E2.1 Emissions to air and water (p.242) carries the reference "GRI Standards 305-6 (2016) and 305-7 (2016); ESRS E2-4". Reported air pollutants across the group are SO2 (12,432 tonnes in 2025), NOx (3,699 tonnes) and PM10 (2,846 tonnes) (p.86), plus fluoride, with the largest emission to water being "the sulfur captured by these seawater scrubbers" (p.87).

Ozone depleting substances. "Hydro uses ozone depleting substances in certain applications in its Brazilian operations and to some extent also in Extrusions. In 2025, Hydro used in total 8.1 tonnes of such substances in its operations. The reported value corresponds to the purchased amount of such substances and can vary significantly according to the need of refilling existing cooling devices... In Hydro Extrusions, hydrochlorofluorocarbon (HCFC) accounts for around one third of ozone depleting substances." (p.87)

Note E2.2 Spills and leakages (p.243) reports "severe and major leakages from Hydro's controlled entities": 0 in 2025, 0 in 2024, 1 in 2023, 1 in 2022, 0 in 2021. The 2023 case "relates to a spill of sulfuric acid at our Extrusions site in Cheltenham, UK. The case was classified as severe due to its potential consequences, not due to actual damage to the environment."

Note E2.3 Environmental permit breaches (p.243), referenced to ESRS E2-4, reports 0 severe or major breaches in 2025, 0 in 2024, 0 in 2023, 3 in 2022 and 2 in 2021.

Note E2.4 Indirect non-GHG emissions related to energy consumption (p.244) is a voluntary addition: black carbon 18 tonnes, carbon monoxide 690, NM VOC 54, NOx 1,941, PM10 654, PM2.5 546 and SO2 3,906 in 2025. "This disclosure is in support of Hydro's commitment to the Alliance for Clean Air and was developed in collaboration with the Stockholm Environment Institute."

E-PRTR threshold reporting is referenced at p.74: "all emissions to air and water above the thresholds defined in the European Pollutant Release and Transfer Register (E-PRTR), are reported in the Pollution chapter."

Soil pollution is addressed separately under the entity-specific Legacy impact topic (pp.109-110).

Substances of concern and substances of very high concern

Reference: notes E2.5 (pp.244-245); content index p.274 points E2-5 to Appendix: Note E2.5, and the note itself carries "Reference: ESRS E2-5".

Hydro states the scope of the metric as covering both limbs of ESRS E2 paragraph 34: "Total amount of substances of concern (SoC) and substances of very high concern (SVHC) that are generated, procured, used or sold in Hydro's production activities." (p.244)

What the substances are. "Hydro's interaction with SoC and SVHC are primarily as part of mixtures, such as paints and solvents used in surface treatment of extruded aluminium profiles, coal tar pitch used for anode production, and cryolite bath used in production of primary aluminium. From 2025, Hydro reports amounts of coal tar pitch used and cryolite sold." (p.244)

Split by hazard class. The table on p.245 reports tonnes of SoC and, separately, tonnes of SVHC across thirteen hazard classes: carcinogenicity categories 1 and 2; chronic hazard to the aquatic environment categories 1 to 4; endocrine disruption for human health; endocrine disruption for the environment; germ cell mutagenicity categories 1 and 2; persistent, mobile and toxic or very persistent and very mobile; persistent, bioaccumulative and toxic; reproductive toxicity categories 1 and 2; respiratory sensitisation category 1; skin sensitisation category 1; specific target organ toxicity repeated exposure categories 1 and 2; specific target organ toxicity single exposure categories 1 and 2; and "negatively affects the re-use and recycling of materials in the product". SVHC is presented separately from SoC as ESRS E2 paragraph 35 requires.

Declared exclusion. "There is significant uncertainty in the classification and measurement of paints, solvents, and substances used in non-production activities such as construction, maintenance and repair, research and laboratory that potentially contain SoCs and SVHC. For these types of mixtures, data on contents per mixture are typically classified with an interval of relevant substances in several hazard classes... making data unavailable at a consolidated level. Therefore, Hydro has chosen to exclude such mixtures from the reporting for 2025." (p.244)

Comparability warning. "The change from 2024 to 2025 is driven by the change in measurement methodology as described in the reporting principles." (p.245) Year-on-year movements in this table should not be read as real changes in volume.

Policies related to water and marine resources

Reference: page 90; content index p.274 points E3-1 to Water: Our approach.

"Hydro's approach to managing water impacts and risks is governed by Hydro's global directive for sustainability. All operational sites controlled by Hydro shall identify material water related risks, and develop action plans and monitoring programs to manage any material risks identified, in line with the mitigation hierarchy. These assessments shall be conducted at a site or catchment level where appropriate." (p.90)

Site-level rather than group-level. "Water risks are location dependent. There are no group wide targets for water, but operational sites must develop context relevant targets and maintain a sufficiently detailed water balance account to reflect the site's water risk exposure and comply with the International Council on Mining & Metals' (ICMM) requirements for water reporting." (p.90)

Discharge quality. "Operational sites must also manage the quality of water discharges and run off to fulfil legal permit limits and mitigate potential negative impacts to the environment and harm to the health and livelihoods of affected communities within the operation's area of influence." (p.90)

Screening tool. "Hydro uses the WRI Aqueduct tool to analyze Hydro's freshwater footprint in water stressed areas, defined as locations with high or extremely high baseline water stress." (pp.75, 90)

For hydropower, the governing framework is regulatory rather than internal: operations "are covered by concessions, with site specific requirements for upgrades and environmental improvement measures. All impacts on surface water bodies are identified and managed by regional water basin management plans (WBMP)" under the EU Water Framework Directive (p.90).

Note. The policy does not address marine resources or water in the value chain as separate commitments, and no water-related product or supplier standard is described.

Actions and resources related to water and marine resources

Reference: page 90; content index p.274 points E3-2 to Water: Our approach.

Brazil. "Hydro has implemented strategies to reduce its dependency on freshwater withdrawals, related to its activities in Brazil. In 2026, 30 percent of Hydro's surface water withdrawals was rainwater, primarily captured at Alunorte and Paragominas in Brazil. Approximately 85 percent of Paragominas' water demand was met by recovery of water from the beneficiation process and six percent from water captured in the reservoirs, significantly reducing dependency on water withdrawals from the Parariquara river. Alunorte receives a large volume of water entrained in the bauxite product it receives through the pipeline from Paragominas, totalling 12.4 million m3 in 2025. 39 percent of this water was reused in the refining process." (p.90)

The report prints "In 2026" in that passage; from context this appears to be a typographical error for 2025.

Extrusions. "Hydro has also implemented water use efficiency programs in its Extrusion business to reduce water intensity and operational costs. Total water withdrawals in Extrusions have reduced 34 percent since 2021." (p.90)

Hydropower. "Hydro monitors and models water levels in its reservoirs to optimize electricity production which, in turn, helps to mitigate consequences of extreme weather events like heavy rainfall and flooding." (p.90) "Hydro continuously works with voluntary and mandatory rehabilitation, and restoration measures in the waterways... Hydro also works with initiatives to reduce the risk of erosion and sedimentation around the reservoirs, such as reinforcement of reservoir edges with stones and gravel." (p.90) Current WBMPs "were approved by the Norwegian Government in October 2022, and are valid until 2027. There is an ongoing process to establish WBMPs for the period 2028-2033."

Renewables. Hydro Rein "is invested in two solar projects and one wind project in areas of medium-high and extremely-high overall water risk in Brazil. Water management plans and monitoring of drainage systems and water resources were part of the basic environmental management plans requested and followed up by authorities." (p.90)

No monetary resources are attached to these actions.

Targets related to water and marine resources

Reference: page 90; the ESRS content index records E3-3 with the reference "N/A: No group targets related to water" (p.275).

This is a nil return, disclosed rather than omitted. The water chapter gives the reasoning: "Water risks are location dependent. There are no group wide targets for water, but operational sites must develop context relevant targets and maintain a sufficiently detailed water balance account to reflect the site's water risk exposure and comply with the International Council on Mining & Metals' (ICMM) requirements for water reporting." (p.90)

The underlying materiality position supports it. Hydro's water IRO is narrow: "Potential short-term impacts on local water resources associated with freshwater withdrawals" and a dependency risk "in the event of acute drought" (p.75). And on exposure: "Less than one percent of Hydro's freshwater withdrawals are related to operational assets located in water stressed areas in 2025, so over exploitation of natural water resource availability is not considered material for Hydro today." (p.90) "Around 75 percent of Hydro's total water withdrawal occurs in Norway from fjords (sea water) and rivers (fresh water) that supply these fjords. These water sources are vast and their availability is not materially affected by Hydro's operations." (p.90)

How effectiveness is tracked in the absence of a group target – MDR-T's alternative limb. Site-level context-relevant targets are mandatory under the global directive; performance is monitored through the water balance accounts, the WRI Aqueduct screening, and the dashboard on p.89, which tracks the number of sites in water stressed areas (34 in both 2025 and 2024), freshwater withdrawals in water stressed areas (1.0 million m3 in 2025 against 1.2 million in 2024, a 17 percent fall) and those withdrawals as a share of the total (0.83 percent in 2025 against 1.03 percent in 2024).

Reader caution. Because the index reference is "N/A" rather than a section pointer, a reader looking only at the index could mistake this for a non-disclosure. The substantive answer is on p.90.

Water consumption

Reference: page 89 and notes E3.1 to E3.3 (pp.245-246); content index p.275 points E3-4 to Water: Our approach; Appendix: Note E3.1.

Note E3.1 Water interaction (pp.245-246) reports total water interaction across 116 locations in 2025 (116 in 2024 and 2023, 111 in 2022, 114 in 2021), broken down by withdrawal source (surface water split into river/stream/lake and rainwater capture, ground water, seawater, third-party supply), by discharge destination (surface water, ground water, seawater, third-party supply), and by total water consumption and total water reused or recycled, with a separate low-quality water column for 2025. Reference given: "GRI Standards 303-3, 303-4 and 303-5 (2018); ESRS E3-4" (p.245).

Methodology. "All operations related to the aluminium value chain maintain a water balance, in line with regulatory requirements and the minimum disclosure requirements dictated by ICMM's 2021 Water Reporting: Good practice guide... Where operational sites receive their water supply from third parties, like the municipal water infrastructure, the quantities are based on invoiced volumes across the year. In operations that manage their own water extraction and discharges, the data can be directly measured using flow meters, or inferred from pumping capacity and run times. Hydro does not have instances of 'Other Managed Water'... so this parameter is not included in Hydro's reporting." (p.245)

Water stress split. Note E3.2 gives water withdrawal by country and note E3.3 water interaction in water-stressed areas (p.246). The dashboard on p.89 reports 34 sites in water stressed areas, 1.0 million m3 withdrawn there in 2025 (down 17 percent from 1.2 million in 2024), 0.83 percent of total freshwater withdrawals (1.03 percent in 2024), and 125.5 million m3 of water recycled or reused in 2025 against 68.9 million m3 in 2024, an 82 percent increase.

The five-year series on p.89 shows the water-stressed share falling from 1.13 percent (2021) through 1.15, 1.15, 1.03 to 0.83 percent in 2025.

Transition plan on biodiversity and ecosystems

Reference: page 94; content index p.275 points E4-1 to Biodiversity and ecosystems: Integrating nature in Hydro's strategy and business model.

"Hydro's current business model has several impacts and dependencies on nature and the ecosystem services it provides. Based on the materiality of these impacts and dependencies, and the risks and opportunities that they present for Hydro, the company has developed a strategy that seeks to mitigate nature related risks, safeguard its business, and improve its resilience to an evolving regulatory and market framework. Hydro has developed this strategy as part of its transition plan to align with the 2030 objective and targets of the Global Biodiversity Framework agreement and address the main drivers of nature loss most relevant to its business model. By doing so, Hydro aims to contribute meaningfully to the global effort to transition to a nature positive future." (p.94)

Scope. "The primary focus of the nature strategy is in relation to Hydro's direct operations and their interface with nature, where the company has the greatest level of control and influence on nature related risks." (p.94) "Hydro's strategy also addresses indirect nature related risks in its value chain and the wider landscapes where it operates. This includes establishing an inventory and baseline for material air pollutants in Hydro's value chain... and an extensive partnership arrangement, the Corridor Program, with research institutions, NGOs, companies, and communities to identify opportunities for the conservation and restoration of nature along the bauxite pipeline between Paragominas and Barcarena." (p.94)

Drivers addressed. Hydro states that "Hydro's activities are relevant to all five of the main drivers of nature loss: land and water use change; pollution; direct exploitation of natural resources; introduction of invasive, alien species; climate change" (p.91), and the p.92 table maps each driver to its relevance and to the strategic response.

Gap. The plan is not dated, has no milestone timeline, and no financial resources are attached to it. The Global Biodiversity Framework alignment is asserted rather than mapped target by target.

Policies related to biodiversity and ecosystems

Reference: pages 91-94; content index p.275 points E4-2 to Biodiversity and ecosystems: Our approach; Identified impacts.

"Hydro's approach to managing biodiversity and ecosystem impacts and risks is governed by Hydro's global directive for sustainability. All operational sites controlled by Hydro are required to identify material risks to biodiversity and ecosystem services in all relevant activities and processes, and develop action plans and monitoring programs to manage any material risks identified, in line with the mitigation hierarchy. These assessments identify and describe priority biodiversity features or ecosystem services that occur within the operation's area of influence, consider the full lifetime of the operation, including closure, and establish requirements for mitigation actions according to the biodiversity mitigation hierarchy." (p.91)

No-go commitments (p.94). "To avoid impacts to areas of especially high biodiversity value, Hydro has committed to not develop new projects in UNESCO World Heritage Sites and Legally Protected Areas that are classified as IUCN Protected Area Management Categories I-IV. Hydro will also not develop new projects in other Legally Protected Areas if the project will cause irreversible impacts to the biodiversity values for which the legal protection has been assigned."

No Net Loss requirement (p.94). "Hydro has also established a minimum requirement for new projects and major changes to existing operations that risk impacting natural and critical habitat, to establish a biodiversity action plan that documents a credible No Net Loss strategy for the biodiversity features at risk. This strategy must align with the biodiversity mitigation hierarchy and be designed to deliver the No Net Loss outcome within the project's lifetime or sooner."

Invasive species (p.92). "Global governance on risk related to invasive species, that requires operations to implement effective management to avoid the introduction of invasive species. If an introduction does occur, operations must implement an effective management to remove it."

Hydro Rein applies "IFC Performance Standards and Equator Principles" and national nature accounting methods (p.95). The policies do not extend a biodiversity standard to suppliers beyond the Supplier Code of Conduct.

Actions and resources related to biodiversity and ecosystems

Reference: pages 94-96; content index p.275 points E4-3 to Biodiversity and ecosystems: Our approach; Actions to mitigate and compensate for mining impacts on biodiversity; Actions to minimize impacts in hydropower operations.

Mining. "Hydro has developed a reforestation program that seeks to mitigate the impact of forest removal through time bound targets to replant and reforest the areas. Currently, Hydro works to progressively rehabilitate mined areas available for reforestation and replant these areas within two complete hydrological seasons, referred to as Hydro's 1:1 rehabilitation target." (p.94) Tailings rehabilitation needs "a specialized rehabilitation technique... amending tailings with organic material like green manure and decaying wood" (p.94). Research is funded through the Biodiversity Research Consortium Brazil-Norway (BRC), established 2013 and "renewed in 2023 for a further five years", with "Twenty five research projects... funded to date" and "Four new projects... selected from these proposals, with contracts to be finalized in 2026" (p.94).

No Net Loss scope extended. "Announced in 2023, Hydro has also increased its No Net Loss ambition for biodiversity for the bauxite mine. In addition to achieving No Net Loss for the future expansion of the mine, Hydro will also include impacts that have occurred since 2020 for the existing mining footprint as well." (p.94)

Hydropower. "Independently of concession renewals, Hydro is performing biodiversity risk assessments for all its operated hydropower. The risk assessments are being carried out by a third party specialist... These assessments were finalized in 2025." (p.95) "The Illvatn Pumped Storage Project, that began execution in the fourth quarter 2025, is the first hydropower related project in Hydro to qualify under our No Net Loss of biodiversity commitment." (p.95) Two concession processes are live: Fortun-Granfasta (revision) and Vigelandsfoss (application). "In 2025, Hydro established a wild reindeer strategy with guidance from Norsk Villreinsenter Sør." (p.95)

Wind and solar. At Tonstad, "Buffer zones were established around known nesting sites for priority bird species and construction activities near these areas were scheduled outside the breeding season" (p.95). "There has been no vegetation suppression in Hydro Rein's projects during 2025, but there are still ongoing reforestation measures related to past vegetation removals in Hydro Rein's Brazilian projects." (p.95)

The p.96 table pairs each activity with its impacts and named mitigating measures (ecological flow releases, fish passages, salmon ladders, restoration in water bodies, road closures in wild reindeer areas). No monetary resources are quantified.

Targets related to biodiversity and ecosystems

Reference: pages 91, 94; content index p.275 points E4-4 to Biodiversity and ecosystems: Identified impacts; Integrating nature in Hydro's strategy and business model; Actions to mitigate and compensate for mining impacts on biodiversity; Actions to minimize impacts in development of wind- and solar power.

Quantified target, with performance. The topic dashboard on p.91 reports "Rehabilitation of mining areas" against the target "1-to-1 rehabilitation of mined areas in Paragominas, within two hydrological cycles", achieved at 100 percent in 2025, 2024 and 2023. "The percentage indicates share of released land that has undergone rehabilitation within two hydrological cycles of being released from mining activities." (p.91)

Group-wide commitments (p.94), presented under the heading "Group wide targets and commitments related to biodiversity and ecosystems":

• No new projects in UNESCO World Heritage Sites or Legally Protected Areas in IUCN categories I-IV, and none in other Legally Protected Areas "if the project will cause irreversible impacts to the biodiversity values for which the legal protection has been assigned".
• For new projects and major changes that risk impacting natural and critical habitat, a biodiversity action plan documenting "a credible No Net Loss strategy... designed to deliver the No Net Loss outcome within the project's lifetime or sooner".
• An extended No Net Loss ambition for the bauxite mine covering "impacts that have occurred since 2020 for the existing mining footprint as well".

Framework reference. The nature strategy is developed "as part of its transition plan to align with the 2030 objective and targets of the Global Biodiversity Framework agreement" (p.94).

Gaps against MDR-T. Apart from the Paragominas 1:1 rehabilitation figure, the commitments are directional: no base year, no target year, no measurable value and no stated methodology for verifying No Net Loss at group level. Nature accounting is described as a pilot: "Hydro is piloting a nature accounting framework, which is being developed by Fornybar Norge" (p.95), and Hydro "has, as part of our membership in Renewables Norway, taken an active role in developing the new Norwegian method for nature accounting" (p.95).

Impact metrics related to biodiversity and ecosystems change

Reference: pages 92-93 and notes E4.1 to E4.7 (pp.247-254); content index p.275 points E4-5 to Appendix: Note E4.1; E4.6.

Land-use footprint. "The total land use footprint of Hydro's aluminium value chain operations is ca. 25,100 ha. This footprint intersects with eight terrestrial habitat types, following the IUCN habitat classification system. The majority of the footprint, ca. 23,700 ha, relates to the upstream bauxite and alumina activities, which are located within the habitat type 'Forest - Subtropical-Tropical moist lowland'." (p.92) "Hydro's mine covers an area of ca. 18,700 ha." (p.92) Notes E4.1 and E4.2 give the aluminium value chain land-use footprint and the split by country (pp.247-248); note E4.4 covers the energy value chain footprint (p.250) and note E4.3 land use and rehabilitation at Paragominas (p.249).

Biodiversity sensitive areas. Note E4.5 (pp.251-252) summarises "Hydro controlled assets, within the aluminium value chain, that are located in or near biodiversity sensitive areas, as defined by the European Sustainability Reporting Standards (i.e. Legally Protected Areas, Key Biodiversity Areas and UNESCO World Heritage Sites)", plus separate tables for hydropower operations and for significant renewable facilities under PPA, reporting area overlap in hectares with legally protected areas, with KBAs and with UNESCO World Heritage Sites. "Of the named assets, the bauxite mine in Paragominas is the only asset that is certain to have an impact on a biodiversity sensitive area as it overlaps with a Key Biodiversity Area called Rio Capim." (p.251) Reference given: "GRI Standards 304-1 (2016); ESRS E4-1, SBM-3, IRO-1".

Threatened species. Note E4.6 reports "Threatened species within Hydro's area of influence" (pp.252-253), and note E4.7 sets out nature accounting for the Illvatn pumped storage project (p.254).

Interpretation caveat given by the company. "Having proximity to these biodiversity sensitive areas does not mean that these operations have a negative impact on the biodiversity values for which these designations were assigned and, in many of these instances, the operations on the site pre-date the establishment of the formal designation of the biodiversity sensitive area." (p.251)

Gap. No ecosystem condition metric or species population indicator is reported at group level; the metrics are footprint, proximity and species presence rather than measured biodiversity change.

Policies related to resource use and circular economy

Reference: page 98; content index p.275 points E5-1 to Resource use and circular economy: Our approach.

"Hydro's approach to managing resource use and circular economy impacts and risks is governed by Hydro's global directives for sustainability and for health, safety and environment. All operational sites controlled by Hydro shall promote the efficient use of materials, minimize waste generation and environmental impacts from waste storage, handling, transportation and disposal, and eliminate waste to landfill where feasible." (p.98)

"Hydro's technology and decarbonization roadmap and strategic focus on metal recycling aims to contribute to a circular economy by supplying the transition to a low-carbon and resource efficient economy with sustainable materials use through partnerships and innovative business models. To enable this transition, Hydro takes a proactive approach to integrate circular economy principles in business development around three main pillars: innovate for circularity, recycling and sorting, and waste to value." (p.98)

Waste hierarchy. "Hydro's goal is to first minimize the amount of waste produced in its operations and then reuse or recycle it. When this is not possible, the company shall deposit it in a secure way in compliance with regulatory standards and legal requirements. All targets related to waste are set by Hydro on a voluntary basis and are not imposed by legislation or regulations." (p.99)

Third-party handling. "In many cases, waste is managed by third parties, which are required to adhere to the Hydro Supplier Code of Conduct. All Hydro locations are required to ensure safe transport of hazardous waste in accordance with global and local regulations, and evaluate critical waste receivers and include these in a supplier development system." (p.256)

Tailings policy. Tailings management is governed under a separate policy set – the ICMM framework, the Aluminium Stewardship Initiative practices and the Global Industry Standard on Tailings Management (pp.109-110) – reported under the entity-specific Legacy impact topic rather than E5.

Actions and resources related to resource use and circular economy

Reference: pages 98-99; content index p.275 points E5-2 to Resource use and circular economy: Increasing recycling of aluminium and developing more circular solutions; Waste management.

Recycling capacity and technology. "Hydro's target is to increase installed post-consumer scrap recycling capacity to 850,000-1,100,000 tonnes in 2030. To reach its target, Hydro is improving its processes to combine process scrap with post-consumer scrap recycling. The technology is being rolled out to Hydro's remelting and recycling plants as a part of Hydro's recycling improvement program." (p.98) "In 2025, the HySort concept has been successfully installed in Alumetal's Nowa Sol plant in Poland. This expanded the existing innovative sorting process with HySort LIBS devices." (p.98) "An upgrade and expansion of Alumetal's Kety plant in Poland is now operational, in addition to installing solar panels." (p.98) "In March 2025, an official ceremony marked the start of construction of the future state-of-the-art specialty extrusion ingot recycling facility in Torija, Spain. The facility is designed for a total capacity of 120,000 tonnes." (pp.98-99)

Tailings. "Hydro's Tailings Dry Backfill technology at the Paragominas mine allows tailings to dry in shallow areas before being excavated and returned to the mined strip from where they originated... 85 percent of the total tailing generated in 2025 was directed to this backfill process, with the remaining 15 percent directed to traditional permanent TSFs." (p.99)

Bauxite residue. "Hydro's state of the art press filter technology allows for storage of dry filtered stacks... The residual moisture content is reduced to 22 percent." "Hydro has a commercial research partnership with WAVE Aluminium... a bauxite residue processing plant is being built at Alunorte, which will initially have the capacity to process 100,000 tonnes per year of bauxite residue to produce pig iron. In 2025, Hydro sent 36,000 tonnes of bauxite residue to its commercial research partnerships for recycling." (p.99)

Spent pot lining. "In Brazil, the Albras smelter has received Intertek's 'Zero Waste to Landfill' certification. This includes its SPL, which is sent to the cement industry for co-processing. In Norway, the majority of Hydro's SPL is landfilled as opportunities for recycling or reusing the waste are limited." (p.99)

No monetary resources are attached to the E5 actions.

Targets related to resource use and circular economy

Reference: pages 97, 99; content index p.275 points E5-3 to Resource use and circular economy: Increasing recycling of aluminium and developing more circular solutions; Waste management.

Three quantified targets, with performance, on p.97:

Progress and regression are both explained. "The reduction of landfilled waste is largely driven by actions to minimize and/or recycle waste bauxite, hydrate, alumina and coal at Alunorte within the relevant production processes. The increase in landfilling of SPL is largely due to an increase in SPL generation linked to relining of electrolysis pots at Norwegian smelters that have no alternative to landfilling available, today." (p.97) The chapter repeats it: "In 2025, 47 percent of generated SPL in Hydro was landfilled, four percent more than in 2024." (p.99)

"In 2025, approximately 16 percent of the total non-mineral waste generated by Hydro was landfilled. This is an improvement of three percentage points compared to 2024." (p.99)

Recycling capacity. "In 2025, Hydro increased its post-consumer scrap recycling capacity to 745kt" (p.82), against the 850,000–1,100,000 tonne 2030 target.

Voluntary status is declared. "All targets related to waste are set by Hydro on a voluntary basis and are not imposed by legislation or regulations." (p.99)

Gap. No target is set for resource inflows, for recycled content in products at group level, or for the value chain.

Resource inflows

Reference: page 98 and note E5.1 (p.255); content index p.275 points E5-4 to Resource use and circular economy: Our approach; Appendix: Note E5.1, and the note carries "Reference: GRI Standards 301-1 and 301-2 (2016); ESRS E5-4".

Named materials, 2025 (thousand metric tonnes, virgin material inflows, controlled entities): bauxite 13,193; alumina 2,993; aluminium 4,051; aluminium fluoride 30; alloying metals 58; lime 48; sodium hydroxide 627; sulphuric acid 17; thickener 5; petroleum coke 395; pitch 85. Comparatives for 2024, 2023, 2022 and 2021 are given alongside (p.255).

Aluminium scrap inflows, 2025: post-consumer scrap 496 kt, pre-consumer scrap 1,021 kt, total aluminium scrap 1,516 kt, against 451 / 771 / 1,222 kt in 2024 (p.255).

Scope and method. "The resource inflows table presents the key raw materials used in the alumina refining process (bauxite, lime, sodium hydroxide, sulphuric acid, thickener), and the electrolysis process for primary and recycled aluminium production and casting (alumina, aluminium, aluminium fluoride, alloying metals as well as petroleum coke and pitch for carbon anode production) in Hydro's controlled entities. Virgin material inflows are calculated based on the reported resource use in the business areas. Aluminium inflows include cold metal bought by Aluminium Metal and Hydro Extrusions." (p.255) "Hydro uses a definition for recycling agreed on by the European Aluminium Association... divides recycled scrap in two categories: process scrap, which includes pre-consumer scrap from downstream casthouses, and post-consumer scrap purchased from third parties for recycling into extrusion ingot." (p.255)

Narrative dependency statement. "Hydro's alumina refining and primary aluminium production depend on a reliable resource inflow of bauxite, lime, caustic soda, sulfuric acid, and flocculants in the alumina refining; coke and pitch for production of carbon anodes; aluminium fluoride and metal alloys in aluminium casting; and sulfuric acid for anodizing aluminium profiles." (p.98)

Gap. Biological materials and the share of sustainably sourced biological materials are not reported, and no overall percentage weight of secondary reused or recycled components is given for the group as a single figure.

Resource outflows

Reference: pages 98-99 and notes E5.1 to E5.5 (pp.255-258); content index p.275 points E5-5 to Resource use and circular economy: Increasing recycling of aluminium and developing more circular solutions; Appendix: Note E5.1; E5.2; E5.3.

Products. "Hydro's material outflows are the alumina and aluminium products, and the waste associated with production." (p.98) Note E5.2 Resource outflows – Products reports "production and sales volumes from Hydro's controlled entities" (p.256).

Durability and recyclability. "Aluminium is light, strong, and resistant to corrosion and cracking, and the inherent properties of aluminium make recycling attractive. It can be recycled infinitely without degradation in quality and recycling consumes 95 percent less energy than primary aluminium production." (p.98)

Recycled content in products. "The Hydro CIRCAL product line, offering aluminium with at least 75 percent post-consumer scrap, has among the lowest environmental footprints in the aluminium industry." (p.98) "Hydro can also produce spearhead volumes of near-zero carbon aluminium with 100 percent post-consumer aluminium scrap, Hydro CIRCAL 100R, with a carbon footprint below 0.5 kg CO2e per kg aluminium." (p.83)

By-product recovery rates, 2025. "91 percent of anode butts produced in Hydro's fully owned or operated smelters were recycled in 2025. The remainder was incinerated with energy recovery." "100 percent of the dross produced in Hydro is recycled." (p.99)

Mineral outflows. Tailings and bauxite residue are reported under E5 as resource outflows, with 85 percent of 2025 tailings dry-backfilled at Paragominas and 15 percent to permanent storage facilities (p.99); note E5.5 reports overburden moved in Paragominas (p.258).

Gap. No expected durability figure relative to industry average, no reparability rate and no rate of recyclable content in packaging are disclosed.

Waste

Reference: pages 97, 99 and note E5.3 (pp.256-257); the content index entry for E5-5 Resource outflows points to Appendix: Note E5.1; E5.2; E5.3 (p.275), and note E5.3 carries "Reference: GRI Standards 306-3, 306-4 and 306-5 (2020); ESRS E5-5".

Total. Non-mineral waste was 762,560 tonnes in 2025 against 716,956 tonnes in 2024, with 16 percent directed to landfill in 2025 against 19 percent in 2024 (p.97).

Hazardous waste, 2025 (thousand tonnes, note E5.3, p.257). Split onsite and offsite by treatment: incineration with energy recovery 9.8; incineration without energy recovery 0.3; landfilled 39.5 (8.4 onsite, 31.1 offsite); other disposal operation 4.6; total hazardous waste 54.2 against 44.0 in 2024.

Waste streams named. "Hydro's bauxite mining operations generate tailings and its alumina refining generates bauxite residue. Hydro's aluminium production process generates waste in the form of spent pot linings (SPL) and anode butts from the electrolysis process, dross from metal casting and other categories of waste." (p.98)

Diversion from disposal. 91 percent of anode butts recycled and 100 percent of dross recycled in 2025 (p.99); 85 percent of tailings dry-backfilled (p.99); 36,000 tonnes of bauxite residue sent to research partnerships for recycling (p.99).

Measurement uncertainty, stated by the company. "Note that a lack of standardized methodologies for classifying, measuring and reporting waste across jurisdictions, industries and waste handling operations is a significant source of measurement uncertainty. Changing methodologies over time also creates challenges in comparing consolidated waste data from one year to another." (p.256)

Targets. Eliminate landfill of all recoverable waste by 2040; less than 35 percent of SPL to landfill by 2030, against 47 percent in 2025 (p.97).

Policies related to own workforce

Reference: pages 111-113; content index p.275 points S1-1 to Own workforce: Our approach; Occupational health and safety; People strategy.

"Hydro's people strategy and organizational culture is rooted in its core values: Care, Courage and Collaboration. These values are reflected in the Hydro Code of Conduct, which outlines the shared responsibility of all personnel to foster a respectful, inclusive and safe work environment." (p.112)

Human rights. "Hydro is committed to, and has a human rights policy based on the UN Guiding Principles on Business and Human Rights, and other global frameworks that define human rights principles for businesses." (p.112) Five salient human rights risks are named for own workforce: health and safety; discrimination and harassment; vulnerable individuals and groups; freedom of association and collective bargaining; and access to information and participation in dialogue (p.111).

Health and safety. "Hydro's health and safety activities are governed by the company's HSE policy and the global HSE Directive, which are applicable for all own employees and contractors. Health and safety standards are aligned with ISO standards." (p.112) "Hydro identifies and monitors potential impact on own employees and contractors according to the same standards, Code of Conduct, and other governing policies and documents." (p.112)

Accountability. "The EVP People and HSE is responsible for guiding Hydro's approach to health, safety, and workforce engagement concerning impacts and risks. The operationalization of this is delegated to the HSE and People organizations in the business areas." (p.112) "The CEO HSE Committee is the strategic decision making committee for all main HSE related matters for the Hydro group. The committee is led by the President & CEO." (p.112)

Labour standards. "Through the Global Framework Agreement, Hydro is committed to upholding equality of opportunity and treatment in line with International Labour Organization (ILO) Conventions 100 and 111." (p.115) Hydro's Code of Conduct "sets out the company's position on human rights in all operations, including the opposition to all forms of modern slavery" (p.70).

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

Reference: pages 112, 114; content index p.275 points S1-2 to Own workforce: Our approach.

Direct engagement. "Hydro engages its employees on health and safety issues through frequent health and safety network meetings in business areas. Engagement on diversity and inclusion issues is primarily done through employee reviews and the range of initiatives sponsored by members of the Executive Leadership Team. Targets for own workforce are set based on insights from stakeholder engagement." (p.112)

Surveys. "Hydro monitors its work environment and potential impacts on own workforce through periodic employee engagement surveys. The surveys focus on key engagement drivers and allows employees to provide feedback that is translated into targeted action plans and improvement roadmaps. The surveys also help identify and monitor negative impacts on own employees and pinpointing vulnerable groups risk, including impacts on psychosocial health and well being." (p.112) The survey, Hydro Monitor, is biennial: "Employee surveys are performed every two year, the last one was conducted in 2024" (p.111). A new psychosocial risk indicator (PRI) was established as part of it, with "A process for follow up of the PRI... developed, including guidelines and tools" (p.113).

Representative engagement. "Hydro actively engages with its workers on labor rights through a variety of channels, including meetings with labor unions, work councils, and joint management worker committees. Hydro has maintained a Global Framework Agreement since 2011, and its European Works Council agreement was revised in 2022. Discussions with employee representatives cover topics such as Hydro's people strategy, policies and procedures. Key areas of focus include health and safety, standards for decent work, human rights, labor rights, and compliance with applicable regulations in each country of operation. This collaborative approach ensures employee voices are heard and integrated into decision making processes that impact their working conditions and rights." (p.114) "All business areas have a forum for dialogue between management and union or employee representatives." (p.72)

Engagement on the 2025 workforce reduction is described: "Hydro committed to conducting this transition with transparency and care, ensuring close collaboration with employee representatives throughout the process." (p.114)

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

Reference: pages 113, 131 and note G1.1 (pp.268-269); content index p.275 points S1-3 to Own workforce: Our approach; Occupational health and safety; Diversity; inclusion; and belonging; Business conduct: Our approach.

Channels. "Concerns and complaints can be raised with local management, but employees may also raise the issue directly with Human Resources, HSE, union representatives, Compliance, or Legal. Employees, on site contractors and others can use Hydro's confidential reporting channel, AlertLine, to report concerns to Group Internal Audit & Investigation. The AlertLine allows anonymous reporting and is available in several languages. Reports can be made online or via toll-free phone numbers listed on Hydro's intranet and Hydro.com." (p.131)

Non-retaliation. "The Global Procedure for Managing Alerts ensures no retaliation against anyone who speaks up in good faith to ask a question, raise a concern, report a suspected violation or participate in an internal company investigation." (p.131)

Handling. "Any incidents related to discrimination or harassment are handled confidentially via line management, HR or Hydro's internal grievance mechanism, AlertLine." (p.113) "Group Internal Audit and Investigation (GIA&I) is responsible for overseeing all alerts that are reported through Hydro's AlertLine. The team assesses the relevance and severity of the Alerts, and is responsible for investigating the ones classified as severe. GIA&I consults a Review Committee comprised of representatives from Legal, HR, and Compliance, and supports line management and staff functions in their investigations or other follow up activities." (p.113)

Independence. "The Chief Audit Executive (CAE) is independent from the line organization and reports to the Board of Directors and the Board Audit Committee." (p.131) "Hydro's Group Internal Audit & Investigation has resources in Norway, Brazil and North America." (p.131)

Support. "Hydro has developed employee assistance programs at site level to support affected workers. This includes as a minimum psychological support for those needed, but also includes other types of support depending on the area they operate in, such as financial advice." (p.112)

Remediation outcome. "Hydro takes these issues very seriously and have addressed and put in place corrective actions for all confirmed cases." (p.269)

No assessment of AlertLine's effectiveness against the UNGP criteria is reported for own workforce; that test is applied to the community channel Canal Direto (p.127).

Taking action on material impacts on own workforce

Reference: pages 112-116; content index p.275 points S1-4 to Own workforce: Occupational health and safety; People strategy; Diversity; inclusion; and belonging; Reward; Living wage; Labor rights; Just transition; Security and emergency preparedness.

Health and safety. "The deployment of fatality prevention procedures, and associated life saving rules and behaviors continued in 2025. This contributed to a continued reduction in the number and rates of high risk incidents with the potential to be life changing or fatal. Key initiatives include a self-assessment process for critical programs, electrical committees reviewing high risk incidents..., digitalizing systems and tools with integrated artificial intelligence functionality increasing the quality of the root cause investigations and risk assessments, monthly deep dive incident data analyzes..., HSE development through online and in person training modules, and defining actions to prevent incidents from recurring." (p.112) "Hydro also increased its emphasis on installing engineering controls to prevent high risk incidents from occurring." (p.112)

Occupational health. "Hydro's approach to continual improvement of physical and chemical occupational health is based on Work Environment Risk Assessments (WERA)." (p.113) Mental health work in 2025 covered "stress management, heat stress management, noise management, hygiene and psychological safety", with "psychological safety training for leaders and burnout prevention training" developed (p.113).

Living wage remediation. "In 2024, Hydro conducted a comprehensive wage analysis which identified 396 employees earning below the living wage threshold. Throughout 2025, Hydro implemented targeted measures to close these gaps." (p.114) The 2025 benchmark found "of 31,167 employees assessed, 68 individuals (an 82 percent reduction since 2024) were found to earn below what is considered a 'decent living'... Of these 68 cases, 59 will be resolved through upcoming tariff renegotiations, while the remaining 7 will be addressed in the next compensation cycle." (p.114)

Restructuring. "To strengthen its long-term resilience, Hydro decided to initiate a process in 2025 aiming to cut annual costs by NOK 1 billion, including reducing 750 positions globally... Blue collar positions... were not affected... The planned workforce reduction was carried out in totality in 2025, and the process closed by year end." (p.114)

Third-party assessment. "In 2024 and 2025, Hydro conducted a human rights assessment of its operations and of selected suppliers in Hungary... In relation to own employees, some risks were identified in relation to HSE, discrimination and harassment, and access to grievance mechanisms. The risks are being monitored and managed." (p.115) The 2025 HRIA in Brazil "identified the psychological well being of employees and contractors as an area requiring further attention" (p.115).

Targets related to own workforce

Reference: page 111; content index p.275 points S1-5 to the same set of own-workforce sections as S1-4.

Five targets with performance are set out in the topic dashboard (p.111):

The fatality and injury rows are stated as targets with the performance narrative given in the text rather than as numbers in the extracted table.

Performance against them. "In 2025, Hydro continued to improve its health and safety statistics, with zero fatal and life changing accidents and an improvement to key health and safety statistics, including recordable injuries and high risk incidents." (p.111) "The total recordable injuries rate in 2025 was 1.75 per million hours worked, compared to 2.0 in 2024." (p.112)

Targets reset in 2025. "Hydro set new targets for diversity, inclusion and belonging in 2030, as presented above. Hydro almost met its previously communicated 2025 target for total share of women employees, with 24.2 percent women employees in Hydro's overall workforce against the 2025 target of 25 percent. Hydro maintains its 2025 target of 25 percent women in Hydro's leadership positions as a 2030 target, with 21.1 percent of leaders being women at year end 2025." (p.111)

How targets are set. "Targets for own workforce are set based on insights from stakeholder engagement." (p.112)

The inclusion index is measured biennially: "Employee surveys are performed every two year, the last one was conducted in 2024" (p.111), so the 78 percent target has no 2025 reading.

Gap. No target is set on adequate wages, training, work-life balance or the gender pay gap, despite each being a reported metric.

Characteristics of the undertaking's employees

Reference: note S1.1 (pp.259-260); content index p.275 points S1-6 to Appendix: Note S1.1, and the note carries "Reference: GRI 2-7 (2021); ESRS S1-6".

Head count at 31 December 2025, by gender:

A second table gives the same breakdown by country (p.259).

Method. "Head count at year end, December 31, including both permanent and temporary employees. Gender data are based on the employees' self-reporting; 'not reported' comprises employees for which gender data is not available. Head count per country is based on which country the employees perform their work. Temporary employees include apprentices but exclude contractors. Employee turnover covers permanent employees only and includes resignations, retirements and manning reductions, but excludes closures and divestments." (p.259)

Boundary note relevant to S1-7. "Hydro also engages a small number of non-employee workers and consultants that are not included in Hydro's employee data, but which are included in the health and safety statistics for contractors in note S1.3. See also note 9.2 to the financial statements on the reporting entity." (p.259)

The head count is consistent with the living wage assessment population of 31,167 employees (p.114), which covers permanent employees.

Collective bargaining coverage and social dialogue

Reference: page 114 and note S1.5 (p.262); content index p.275 points S1-8 to Own workforce: Collaborating with unions and employee representatives; Appendix Note S1.5, and the note carries "Reference: ESRS S1-8".

Coverage. "Hydro's major sites in Europe and Brazil are unionized. Extrusions has a major presence in North America, and 44 percent of Hydro's employees in North America are covered by collective bargaining agreements. Overall, 67 percent of Hydro's global workforce are covered by collective agreements. Collective bargaining takes place at a frequency agreed with the local unions." (p.114)

Note S1.5 presents the ESRS template: collective bargaining coverage split into Employees (EEA) and Employees (non-EEA), and social dialogue as workplace representation (EEA), using the banded scale introduced by ESRS S1-8 (0-19%, 20-39% and so on) (p.262).

Method and its limits, stated by the company. "Data on collective bargaining and social dialogue is based on local HR records. An estimated 69 percent of the global workforce is covered by collective agreements, but the records may be incomplete in certain countries due to the sensitive nature of information about individual employment terms and participation in labor unions. The reported data below includes all employees in countries of significant employment, presented using the templates introduced by ESRS S1-8." (p.262)

Note the two figures: 67 percent in the chapter (p.114) and 69 percent in the note (p.262). The report does not reconcile them.

Non-covered employees. "In Norway, non-organized workers typically benefit from the same compensation adjustments negotiated at the industry level. In addition, workers on individual agreements may receive adjustments based on company and individual performance, and external benchmarking." (p.114)

Freedom of association as a salient risk. "In light of the threats to freedom of association in a number of countries worldwide, including some of the countries where Hydro operates, Hydro has identified freedom of association and collective bargaining as a salient human rights risk area related to its workforce. In regions where union representation is not permitted, Hydro strives to establish alternative worker management relations to ensure fair treatment." (p.114)

"No strikes exceeding one week and no lock outs took place in 2025." (p.114)

Diversity metrics

Reference: pages 111, 113 and note S1.2 (p.260); content index p.275 points S1-9 to Appendix: Note S1.2, and the note carries "Reference: GRI 2-7 (2021), 405-1 (2016); ESRS S1-9".

Headline metrics (p.111). Share of women employees 24 percent in 2025 (24 percent in 2024, 23 percent in 2023), against a 2030 target of 30 percent. Share of women leaders 21 percent in 2025 (21 percent in 2024, 20 percent in 2023), against a 2030 target of 25 percent. The narrative gives the precise figures: "24.2 percent women employees in Hydro's overall workforce against the 2025 target of 25 percent" and "21.1 percent of leaders being women at year end 2025" (p.111).

Note S1.2 breakdown (p.260). Gender distribution is reported for the Board of Directors (women / men), the Executive Leadership Team (women / men), women at management levels 0-2 and women at management levels 0-3. A separate table gives employees' age distribution. Notes S1.7 (Diversity in management, p.263), S1.8 (Local representation, p.264) and S1.9 (Diversity and inclusion for Norwegian subsidiaries, p.264) extend the disclosure.

Method. "Data on gender distribution in the Board of Directors and the Executive Leadership Team are counted manually at year end. Data on gender distribution at management levels 0-3 and data on employee age distribution are retrieved from Hydro's human resources SAP system. Data on employees' inclusion, engagement, psychosocial well-being and integrity culture are based on Hydro's biennial employee engagement survey, Hydro Monitor." (p.260)

2030 approach (p.113). Four ambitions frame the diversity work: closing the inclusion gap, strengthening inclusive leadership, providing inclusive workplaces, and empowering under-represented groups. "In 2025, Hydro started mapping which locations have the highest inclusion standards, such as personal protective equipment adapted for female operators, period solutions offered to all women employees, and lactation and breastfeeding rooms available on the site to set a benchmark for other locations to follow."

Employee resource groups named include "a global Women in Operations Network, local and regional women's networks, and a Hydro Rainbow LGBTQI+ network in Hydro headquarters" (p.113).

Adequate wages

Reference: page 114; content index p.275 points S1-10 to Own workforce: Living wage.

Hydro discloses a living wage benchmark with a named methodology, a population, a gap and a remediation plan.

"Hydro has an ambition to improve the lives and livelihoods wherever it operates, and to ensure the company has a transparent compensation with due regard to the basic needs of the worker." (p.114)

2024 baseline. "In 2024, Hydro conducted a comprehensive wage analysis which identified 396 employees earning below the living wage threshold. Throughout 2025, Hydro implemented targeted measures to close these gaps and ensure fair compensation for all affected individuals." (p.114)

2025 result. "As part of our ongoing commitment, a new benchmark assessment was carried out in 2025 against living wage standards in the markets where Hydro operates. The results show significant progress: of 31,167 employees assessed, 68 individuals (an 82 percent reduction since 2024), were found to earn below what is considered a 'decent living,' covering basic needs. Of these 68 cases, 59 will be resolved through upcoming tariff renegotiations, while the remaining 7 will be addressed in the next compensation cycle." (p.114)

Benchmark source. "Hydro has used market data from FairWage Network to continuously assess the threshold for living wage in the areas it operates. This allows to constantly assess and improve compensation practices, ensuring sustainable and equitable pay for all employees. Hydro will continue to monitor and close any remaining gaps to uphold its commitment to fair wages." (p.114)

Value chain extension. "As part of strengthening its procurement processes, Hydro has also incorporated living wage requirements. According to the Supplier Code of Conduct, wages and benefits for a standard working week must at least meet national legal or industry standards, whichever is higher. Wages should be sufficient to cover basic needs and provide some discretionary income." (p.118)

Gap. The 68 employees below the threshold are not broken down by country, so the ESRS S1-10 requirement to identify the countries in which employees earn below an adequate wage is not met explicitly.

Social protection

Reference: page 114; content index p.275 points S1-11 to Own workforce: Reward; Labor rights.

"All Hydro employees are covered by the social security systems in their respective countries. At a minimum, all employees receive (in combination with statutory benefits and social security) business travel insurance, benefits covering work related events (accidents and illnesses), and retirement benefit." (p.114)

"Hydro has a global minimum standard of 16 weeks fully paid parental leave for primary caregiver and four weeks fully paid leave for the secondary caregiver." (p.114)

This is a complete nil-gap answer to the core of ESRS S1-11: the statement that every employee is covered by public or company social protection against sickness, unemployment, employment injury and acquired disability, parental leave and retirement is made group-wide, so no country-by-country exception list follows.

The positive impact is recorded in the DMA: "Positive impacts associated with employees personal and career development, and social protection." (p.76)

Gap. ESRS S1-11 asks for the countries in which employees are not covered, event by event (sickness, unemployment from own employment, employment injury and acquired disability, parental leave, retirement). Hydro states blanket coverage rather than working through the five events, and does not name the statutory schemes relied on. The parental leave standard is given as a company minimum rather than as evidence of statutory coverage.

Training and skills development metrics

Reference: page 113 and note S1.4 (p.262); content index p.275 points S1-13 to Own workforce: People strategy; Appendix: Note S1.4, and note S1.4 carries "Reference: ESRS S1-13".

Note S1.4 reports training statistics for 2025 with comparatives, covering completed training modules and training hours (p.262).

Method and its limits, stated by the company. "Training and development statistics is based on training that is completed and registered by Hydro employees in our human resources systems. The reliance on self-reporting of certain training modules can lead to incomplete data. Training, education and career development activities that are not registered by the individual employee, as well as on-the-job training activities, are not captured by the reported metrics. Instructor-led courses that are conducted locally are not always registered and thus not included in the reported metrics." (p.262) "Number of courses is reported based on training modules completed; one employee may complete several e-learning modules related to the same topic and/or participate in both classroom training and e-learning courses on the same topic. Training hours per employee is based on the number of employees reported in Note S1.1." (p.262) "The metrics include both mandatory and voluntary training. See also Note G1.3 on compliance-related training, specifically."

Programme content (p.113). The people strategy pillar "We Grow" covers "hiring to career advancement... building an environment where every employee can see their path, grow their skills and contribute to Hydro's 2030 ambitions... improving Hydro's job architecture, reducing complexity, identifying critical skills and capabilities, and improving Hydro's job portal". "We Lead" covers "the Hydro Leadership Journey... global development programs based on its Leading the Hydro Way framework and activating a data driven succession planning to target development where it matters most, while securing internal competence."

Performance reviews are described indirectly through "regular employee reviews meetings conducted by line managers" (p.76) and "employee reviews" as a diversity engagement channel (p.112).

Gap. ESRS S1-13 asks for the percentage of employees that participated in regular performance and career development reviews, by gender. That percentage is not disclosed.

Health and safety metrics

Reference: pages 111-112 and note S1.3 (p.261); content index p.275 points S1-14 to Own workforce: Occupational health and safety; Note S1.3, and the note carries "Reference: GRI Standards 403-9, 403-10 (2018); ESRS S1-14".

Total recordable injuries (note S1.3, p.261):

"The total recordable injuries rate in 2025 was 1.75 per million hours worked, compared to 2.0 in 2024. The majority of injuries were relatively minor." (p.112) "In 2025, Hydro continued to improve its health and safety statistics, with zero fatal and life changing accidents." (p.111)

Scope. "The data covers employees and contractors at all units within Hydro, including sales offices and administrative functions." (p.261) "Employees are workers under direct supervision of Hydro. For the purpose of recording health and safety statistics, employees include agency workers." (p.261) The note also reports TRI, LTI and HRI rates per million hours, fatal accidents, occupational illness rate and sick leave.

Definitions. "Total recordable injuries (TRI) is calculated as the sum of lost time injuries (LTI) + restricted work cases (RWC) + medical treatment cases (MTC)... High risk incidents (HRI) include major accidents and incidents with major potential." "Actual occupational illnesses are defined by Hydro as either illnesses that have been confirmed by relevant authorities/insurance companies or doctors...; or that have led to any kind of permanent disability, disablement pension, loss of function and/or are a listed occupational disease." (p.261)

Comparability caveat. "Sick leave is recorded based on local definitions which may differ between countries." (p.261)

Gap. The percentage of own workforce covered by a health and safety management system based on legal requirements or recognised standards is not stated as a figure, though "the company's manufacturing sites are certified to internationally recognized health and safety standards" (p.112).

Work-life balance metrics

Reference: page 114 and note S1.2 (p.260); content index p.275 points S1-15 to Own workforce: Reward; Appendix: Note S1.2.

The entitlement side of ESRS S1-15 is disclosed group-wide: "Hydro has a global minimum standard of 16 weeks fully paid parental leave for primary caregiver and four weeks fully paid leave for the secondary caregiver." (p.114) Combined with "All Hydro employees are covered by the social security systems in their respective countries" (p.114), this covers the requirement that all employees be entitled to family-related leave.

Work-life and wellbeing conditions are handled through the psychosocial work environment programme rather than through leave metrics: "To ensure a systematic approach to the psychosocial work environment, Hydro has established a new psychosocial risk indicator (PRI) as part of its employee engagement survey, Hydro Monitor. A process for follow up of the PRI has been developed, including guidelines and tools." (p.113) Note S1.2 reports data on "employees' inclusion, engagement, psychosocial well-being and integrity culture" from the biennial Hydro Monitor survey (p.260).

Part-time working is quantified in note S1.1: 1,229 part-time employees at year end 2025, of whom 624 women and 605 men (p.259).

Gap. ESRS S1-15 asks for the percentage of entitled employees that took family-related leave, split by gender. That take-up percentage is not disclosed for FY2025, and the index reference points to the Reward section and note S1.2 rather than to a dedicated leave metric. The entitlement is disclosed; the uptake is not.

Compensation metrics (pay gap and total compensation)

Reference: page 114 and notes S1.2 and S1.6 (pp.260, 263); content index p.275 points S1-16 to Own workforce: Reward.

Pay gap. "Hydro analyzed global pay statistics in 2025 to assess equal gender pay by accounting for factors such as job type, job level and complexity, experience, education, tenure, performance and work location, in addition to gender. The analysis shows an adjusted pay gap of 5.2 percent due to gender and other potentially unidentified factors. Hydro will address this pay gap and work to ensure equitable compensation for work of equal value." (p.114)

Pay ratio. "The ratio of the highest base salary to the median base salary for all permanent employees was 17.5. For more information, see the Remuneration report." (p.114)

Norwegian statutory disclosure. "See also note S1.6 for detailed pay gap analysis specific to Norwegian employees, based on the Norwegian Equality and Anti-discrimination Act." (p.114) Note S1.6 "Gender and compensation in Norway" is on p.263; disclosures required by the Norwegian Equality and Anti-Discrimination Act are included in the Appendix (p.70).

Reward framework. "In 2024, Hydro embarked on the implementation of a global reward strategy. Hydro works to ensure equitable compensation for work of equal value, regardless of gender. Hydro's reward strategy includes four principles: market competitive, performance oriented, transparent, and holistic, with a balanced mix of monetary and non-monetary compensation elements." (p.114)

Interpretation caution. The 5.2 percent figure is an adjusted gap, computed after controlling for job type, level, experience, education, tenure, performance and location. ESRS S1-16 asks for the unadjusted gender pay gap, the difference in average pay levels between women and men expressed as a percentage of men's average pay level. The unadjusted figure is not given in the sustainability statement, and the two are not comparable. Nor is the annual total remuneration ratio calculated on the ESRS basis (highest paid individual to median annual total remuneration) stated; the disclosed 17.5 is a base salary ratio.

Incidents, complaints and severe human rights impacts

Reference: page 113 and note G1.1 (pp.268-269); content index p.275 points S1-17 to Own workforce: Diversity, inclusion, and belonging (DIB); Appendix: Note G1.1.

Reported cases (note G1.1, p.268):

"From 2024, we made a distinction between Alerts and so-called Non-Alerts, wherein the latter are minor complaints related to personal grievances, disputes over terms and conditions, individual preferences or professional disagreements." (p.268)

Follow-up (p.269). "In addition to the confirmed cases listed above, one confirmed case related to working time was identified through AlertLine in 2025. Most of the confirmed cases of discrimination and harassment are isolated incidents and have not been considered as structural in nature. Hydro takes these issues very seriously and have addressed and put in place corrective actions for all confirmed cases. In addition to the cases listed above, one harassment case has been confirmed which has not been reported through AlertLine or similar. Disciplinary action has been taken in this case. Two of the reported discrimination and harassment cases are currently being assessed further, as part of the human rights due diligence process."

Severe human rights impacts. "No reported cases were filed with the National OECD contact point in 2025 related to of non-respect of the United Nations Guiding Principles (UNGPs), International Labor Organization (ILO) Declaration on Fundamental Principles and Rights at Work, or the OECD Guidelines." (p.269)

Trend caveat. "Since 2022, Hydro have had several awareness raising campaigns about AlertLine, which might be a reason for the significant increase in total number of cases reported in the following years." (p.269)

Gap. No fines, penalties or compensation for damages relating to own-workforce incidents are quantified.

Policies related to value chain workers

Reference: page 118; content index p.275 points S2-1 to Workers in the value chain: Our approach.

"The risk of negative impacts on workers in the value chain is governed through Hydro's Sustainability in the supply chain policy and supply chain management system which includes detailed selection criteria and key elements of human rights due diligence process. This process is described in more detail in the document Human Rights Due Diligence in Hydro, available on Hydro's website under Human Rights and Just Transition." (p.118)

Supplier Code of Conduct. "Hydro's Supplier Code of Conduct sets out the minimum sustainability requirements for all suppliers. The Code is based on internationally recognized standards such as the Universal Declaration of Human Rights and the International Labor Organization (ILO) Core Conventions. The principles in the Code of Conduct are made binding through contractual clauses and the standard purchasing terms, and require suppliers to conduct due diligence in their own supply chain." (p.118)

Reference frameworks. "Hydro's approach to responsible sourcing is based on the UN Guiding Principles on Business and Human Rights, and the OECD Guidelines for Multinational Enterprises on Responsible Business Conduct." (p.118)

Living wage requirement. "According to the Supplier Code of Conduct, wages and benefits for a standard working week must at least meet national legal or industry standards, whichever is higher. Wages should be sufficient to cover basic needs and provide some discretionary income." (p.118)

Consequences. "While failure to comply with the Supplier Code of Conduct may ultimately result in contract termination, Hydro seeks to work with suppliers towards continuous improvement whenever this is in the best interest of the people in the supply chain." (p.118)

Salient risks named (p.117): forced labour, modern slavery and child labour abuse; discrimination and harassment; vulnerable individuals and groups; access to information and participation in dialogue; decent working conditions; health and safety; freedom of association and collective bargaining.

2025 policy work. "Key documents and procedures are being updated to ensure alignment with the Corporate Sustainability Due Diligence Directive (CSDDD) and to strengthen Hydro's consistent approach across business areas." (p.118)

Processes for engaging with value chain workers about impacts

Reference: pages 118-122; content index p.275 points S2-2 to Workers in the value chain: Our approach; Responsible sourcing and due diligence process; Disclosures related to specific countries.

Direct versus indirect. "Contractors working on Hydro's sites are engaged directly on health and safety standards the same way as Hydro's own workforce. Other potentially affected workers in the value chain are engaged indirectly though Hydro's requirements and expectations for workers' rights as set out in Hydro's Supplier Code of Conduct." (p.118)

Three-step process (p.118). (1) "Mapping of risks and due diligence activities" – all suppliers pass a qualification process screening for human and workers' rights risks; medium and high inherent risk suppliers face "further screening, using qualified third party ratings or standard self-assessment forms, combined with desktop research", then review or audit; "For high risk suppliers, follow-up assessments shall be conducted regularly during the contract period." (2) "Clear expectations" through the Supplier Code of Conduct made binding in contracts. (3) "Support and development" – "Hydro builds supplier relationships on mutual trust and development, working to strengthen sustainability performance through dialogue, knowledge sharing, innovation, and supplier development programs."

Third-party assessment as a proxy for worker voice. Hydro relies on external human rights assessments in high-risk contexts: the 2023 externally led assessment in China, which "did not identify any indications of forced labor at supplier sites" but found "certain labor risk factors" (p.122); and the 2025 HRIA in Brazil conducted by ERM with "a thorough stakeholder consultation" in which "Rights holders were prioritized in the consultation, including representatives of local and traditional communities, employees, contract workers, public authorities, and NGOs" (p.125).

Qatar. "As a joint venture partner in Qatalum, Hydro actively oversees and promotes the company's CSR program. This includes conducting audits and inspections of employee and contractor' housing facilities. In 2025, Hydro also continued its discussions with local stakeholders and organizations present in Qatar on the developments related to migrant workers' conditions." (p.122)

Collaboration. "Hydro further collaborates with external stakeholders, including unions and industry associations, to promote and implement supplier development programs." (p.118)

Gap. No named worker representative body or worker-led engagement mechanism in the upstream supply chain is described; engagement runs through suppliers, auditors and industry standards.

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

Reference: pages 118, 122, 131 and note G1.1 (p.269); content index p.275 points S2-3 to Workers in the value chain: Disclosures related to specific countries; Business conduct: Our approach.

Channels. AlertLine is open beyond employees: "Employees, on site contractors and others can use Hydro's confidential reporting channel, AlertLine, to report concerns to Group Internal Audit & Investigation. The AlertLine allows anonymous reporting and is available in several languages." (p.131) In Brazil, Canal Direto "is Hydro's operational level grievance mechanism open to all external stakeholders in Brazil" (p.127); it registered 666 grievances in 2025 (p.269).

Supply chain alerts are received and followed up. "In addition to this, we have received a limited number of cases through this mechanism that concern suppliers rather than our own operations. These relate to labour rights, discrimination and harassment. The alerts are being followed up as part of our human rights due diligence process." (p.269)

Remediation route. "If any non-compliance with Hydro's requirements are identified, a corrective action plan is established to close identified gaps." (p.118) Applied in 2025: "Through Hydro's supplier assessments in 2025, a total of 66 cases of non-conformities or adverse impacts were identified, related to environmental or human rights. The majority of these findings were of minor nature and assessed as readily remediable. For human rights, 18 cases were categorized more serious, predominantly related to working conditions and labor practices, such as excessive working hours and occupational health and safety. Hydro takes these issues very seriously and has, in accordance with standard procedures, established corrective action plans in dialogue with the supplier to address the issues and help close the gaps. Of the material issues identified in 2025, all were closed or in the process of being so, by year end." (p.122)

In China, "In 2025, Hydro identified a limited number of cases related to excessive working hours among its suppliers... Hydro continues to engage in dialogue with the relevant suppliers to address these matters, implement corrective actions and close identified findings in line with its established corrective action procedures." (p.122)

Effectiveness. "by the end of 2025, nearly all corrective actions proposed by Hydro had led to improved performance" (p.118).

Gap. Hydro does not state whether value chain workers are aware of, or trust, these channels, which ESRS S2-3 asks for.

Taking action on material impacts on value chain workers

Reference: pages 118-122; content index p.276 points S2-4 to Workers in the value chain: Our approach; Supplier and business partner screening; Findings and impacts; Disclosures related to specific countries.

Audits and corrective actions. "In 2025, Hydro conducted 189 audits and reviews covering topics such as human rights, working conditions, and HSE. Key findings from the audits relate to lack of management systems, environmental awareness, compliance controls and emergency preparedness. Approximately 41 percent of the audits led to corrective action plans, and by the end of 2025, nearly all corrective actions proposed by Hydro had led to improved performance." (p.118)

Screening scale. "As part of the integrity risk management process, more than 7,800 potential or existing counterparties were screened for human rights violations, corruption, money laundering, politically exposed persons, and violations relating to trade sanctions using the Moody's Grid integrity risk tool during 2025... Hydro's operations in North America also use the risk tool MK Denial to screen suppliers against 16 official sanction lists multiple times a year. In 2025, approximately 15,900 customers and vendors were screened in MK Denial." (p.119) "All suppliers, customers and other business partners registered in Hydro's main accounting systems are screened on a weekly basis against recognized international sanction lists." (p.119)

Traceability as a control. "In total for both direct and indirect sourcing in 2025, close to 85 percent of the bauxite can be traced back to mines in Brazil and Australia, where Hydro has a good overview of the risks. The third largest indirect bauxite source, at approximately 6 percent, comes from two mines in Guinea. Given the challenging situation in Guinea, Hydro monitors the situation continuously." (p.120)

Industry standards. "Most of Hydro's sites are Aluminium Stewardship Initiative (ASI) certified, and Hydro promotes ASI's certification program among its aluminium suppliers." (p.118) Both bauxite mines supplying Alunorte – Paragominas and MRN – "are ASI certified" (p.120). Qatalum "received its Performance and Chain of Custody standard certification in 2022. In 2024, Qatalum was recertified by DNV under the updated version of the performance standards, including strengthened human rights requirements." (p.122)

Risk reduction by divestment. "In 2025, Hydro continued the execution of the phase out of its investments in the battery value chains, divesting from Vianode, Lithium de France, and Corvus Energy. This shift reduces direct exposure to battery production and associated supply chain risks." (p.121)

Customer-side due diligence. "Hydro applies human rights due diligence not only to its suppliers, but also to its customers and other business partners." (p.119) In 2025 a review of Israeli business partners led to two relationships triggering further assessment; a contract with a customer operating in Occupied Palestinian Territory "will not be renewed at expiry in 2025" (p.127).

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

Reference: page 117 and note S2.1 (p.266); content index p.276 points S2-5 to Workers in the value chain: Our approach; Appendix: Note S2.2, and note S2.1 carries "Reference: GRI Standards 308-2 (2016) and 414-2 (2016); ESRS S2-5".

Stated target. "Hydro set a group wide target in 2024 to track the share of suppliers with corrective action plans in place for human rights residual risks identified through the due diligence process." (p.118)

Performance (p.117):

Underlying counts (note S2.1, p.266): total suppliers 42,850 in 2025 (43,138 in 2024); total supplier spend NOK 159,401 million (NOK 157,078 million in 2024); 67 percent spent on local suppliers. Due diligence: 7,896 suppliers screened in 2025 (9,520 in 2024); 4,597 medium and high sustainability risk suppliers (3,294 in 2024, restated).

Comparability warnings, given by the company. "The share of suppliers classified as medium or high-risk in 2024 has been adjusted compared to numbers reported in 2024 after a reclassification of certain suppliers' inherent risk rating." (p.117) "Supply chain due diligence metrics are likely to vary significantly over time as due diligence processes evolve with the development of expectations and industry best practice." (p.266) The screened figure is also narrower than the activity: "The reported number is based on the total screenings performed using Moody's Grid, which is the most frequently used screening tool. The total number of screenings conducted is higher, as a single supplier is often screened multiple times using different screening tools." (p.266)

Gap. The target has no target year, no base year and no target value; it is a tracked indicator rather than a dated MDR-T target, and the 93 percent figure has no prior-year comparative.

Policies related to affected communities

Reference: page 124; content index p.276 points S3-1 to Affected communities: Our approach; Policy commitments; Stakeholder engagement; Potential and actual adverse impacts; Appendix: Note G1.1.

"Hydro's commitment to respect the human rights of affected communities associated with its operations and value chain, and to manage any potential or actual adverse impacts is set out in the company's Human Rights Policy, which is approved by the Executive Leadership Team (ELT). The operational responsibility for ensuring engagement with affected communities is conducted as set out in the policy is delegated to the business areas." (p.124)

Standards referenced. "The policy is aligned with the UN Guiding Principles on Business and Human Rights and Hydro's commitment to respect human rights is guided by internationally recognized human rights and labor standards, including those contained in the International Bill of Human Rights. The policy provides reference to the UN Declaration on the Rights of Indigenous Peoples and the Indigenous and Tribal Peoples Convention (International Labor Organization, ILO, Convention 169) and other conventions relevant to affected communities." (p.124)

Indigenous peoples and FPIC. "All affected communities are covered by the policy. The policy includes Hydro's commitment to be particularly attentive to the rights of indigenous and tribal peoples, as well as traditional communities, in particular with regards to their rights to self-determination, to lands which they traditionally occupy, to their customs, traditions and institutions, and to their free, prior and informed consent (FPIC)." (p.124)

Human rights defenders. "In the policy, Hydro also commits to be particularly attentive to the rights of human rights defenders, considering in particular their rights to freedom of expression, association, peaceful assembly, and to protest against Hydro's business and operations." (p.124)

Just Transition Framework. "Hydro has established a framework through which the company seeks to contribute to a transition that leaves no one behind, in line with the UN's 2030 Agenda." Three pillars: "Respecting and promoting human rights", "Supporting local development" and "Investing in education and providing decent jobs" (p.124).

Salient risks for communities are named as health and safety; discrimination and harassment; land rights and resettlement; vulnerable individuals and groups; and access to information and participation in dialogue (p.123). Project-level standards are the IFC Performance Standards and Equator Principles (p.72).

Processes for engaging with affected communities about impacts

Reference: pages 124-128; content index p.276 points S3-2 to Affected communities: Our approach; Policy commitments; Stakeholder engagement; Affected communities in own operations; Affected communities in value chain including joint ventures and joint operations; Appendix: Note G1.1.

Risk-based frequency. "Hydro has committed to engage in regular dialogue with communities in line with the risk based approach established through its human rights due diligence process, including having more frequent and structured dialogue in communities with higher risk of adverse human rights impacts. Hydro's approach to stakeholder dialogue is summarized in three levels of engagement based on a global, regional and local approach." (p.124) The three-tier map on p.124 names global organisations for oversight (IAI, ICMM, ASI, Amnesty International, ILO), regional expertise (Nordic Business Network for Human Rights, regional human rights experts, European Aluminium, regional NGOs, academia, unions) and local stakeholders for direct dialogue (local communities, municipalities, local NGOs, customers, suppliers).

Brazil. "Albras, Alunorte, and Paragominas have adopted a structured approach to inclusive engagement with diverse communities in the region. Senior management holds quarterly meetings with community leaders to address key concerns and share updates on progress, actions, and risk management. In addition, a dedicated team maintains ongoing dialogue with community groups, traditional leaders, and civil society organizations representing women, children, human rights defenders, and other vulnerable or underrepresented groups. The companies have in place a program to invite the communities to visit the plants, to ensure they are aware of the operations, their risks and controls." (p.127)

Formal consultation with Quilombola communities. "Paragominas is conducting a thorough consultation with Quilombola communities, following the Brazilian regulations and ILO Convention 169. Hydro participates in Quilombola Component Studies (ECQs) and Basic Quilombola Environmental Plans (PBAQs), coordinated by the competent authority, INCRA and executed by an independent consultancy with active community participation." (p.127)

Sweden. "As part of early development processes, Hydro Rein conducts impact assessments and initiates consultation with potentially affected stakeholders, in line with the IFC Performance Standards and FPIC principles, when relevant." At Stor-Skjälsjön, "Mitigation measures, such as seasonal activity adjustments and coordination to support reindeer husbandry, were agreed through consultation processes and included in permit conditions." (p.128)

Multi-stakeholder forum. "The Sustainable Barcarena Initiative (SBI) is an independent forum that promotes sustainable development in Barcarena through community led dialogue... In 2025, more than 125 community leaders actively participated in meetings and programs organized by the initiative." (p.128)

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

Reference: pages 124, 127 and note G1.1 (p.269); content index p.276 points S3-3 to Affected communities: Potential and actual adverse impacts; Affected communities in own operations; Affected communities in value chain including joint ventures and joint operations.

Commitment. "If Hydro identifies adverse human rights impact that the company has caused or contributed to, Hydro works to cooperate in, promote access to, and/or provide remediation." (p.124)

Dedicated community channel. "Canal Direto is Hydro's operational level grievance mechanism open to all external stakeholders in Brazil and targeted specifically at affected communities. The mechanism allows community members to raise their concerns anonymously. Each grievance is assessed based on its criticality. The process follows the criteria for effective grievance mechanisms set out in the UN Guiding Principles on Business and Human Rights. The effectiveness of the grievance mechanism is monitored through dialogue with the affected communities, monitoring of the type and volume of cases received, as well as through a satisfaction survey for users." (p.127)

Volume and profile, 2025. "In addition to AlertLine, the grievance mechanism in Brazil Canal Direto registered 666 grievances via telephone, online form and email in 2025. 92 percent of the registrations were identified and 8 percent anonymous. 90 percent were related to requests for information, and the most frequently registered topics were interest in becoming a supplier, job and career opportunities at Hydro, sponsorship, commercial matters and human resources." (p.269)

Environmental route. "Affected or potentially affected stakeholders or communities can use Hydro's grievance mechanism, AlertLine, to report environmental and social issues concerning Hydro operations." (p.87)

Monitoring of remedies. "In cases where mitigating actions are implemented, these are documented as part of Hydro's annual human rights risk assessments and human rights data collection. In areas where higher risks of human rights impacts are identified in relation to Hydro's own operations, the company monitors the effect of the mitigating actions put in place. Hydro is in the process of improving its systems for monitoring the effect of mitigating actions, including in the value chain." (p.125)

Independent escalation. "No reported cases were filed with the National OECD contact point in 2025." (p.269)

Gap. Outside Brazil, no equivalent community-facing grievance channel is described.

Taking action on material impacts on affected communities

Reference: pages 125-129; content index p.276 points S3-4 to the affected communities sections plus Resilient local communities in a changing world; Skills and jobs for the future low carbon economy; Appendix: Note S3.1; S3.2; G1.1.

2025 Human Rights Impact Assessment. "In 2025, Hydro completed its second Human Rights Impact Assessment (HRIA) covering the operations of Albras, Alunorte and Paragominas, including the transmission line and the bauxite pipeline from mine to refinery. The assessment was conducted by an external consultancy (ERM) and updated the human rights baseline, identifying human rights risks and impacts." (p.125) Four risks are named and each is paired with mitigation: indigenous and traditional communities; security contractors; access to information; and quality of natural resources (pp.125-126).

Land conflict. "The pipeline connecting Paragominas mine to Alunorte crosses territories subject to land conflicts, driven by factors such as precarious land registration and the absence of formal demarcation of Quilombola and indigenous lands." (p.125) "Although Hydro is not directly involved in conflicts related to oil palm monocultures, the pipeline crosses this region, creating indirect challenges. To mitigate these risks, Hydro has prioritized dialogue, engagement, and cooperation initiatives with affected groups." (p.126)

Occupation and repossession. "In Barcarena, the companies Alunorte and Albras own an area that has been irregularly occupied since 2016... While Alunorte and Albras have obtained a court order to repossess the area, as a way to mitigate risks to human rights, the companies have engaged with authorities to pursue formal mediation and identify a peaceful resolution, following the guidance from the Brazilian Supreme Court. After almost a year of mediation... Alunorte and Albras [requested] the reinstatement of the repossession order... Hydro has developed a robust social support plan to ensure that any eventual repossession is carried out in compliance with national regulations, good practice and international human rights guidelines." (p.126)

Security. "Hydro mitigates this risk by implementing the guidelines of the Voluntary Principles on Security and Human Rights, and by closely monitoring and training security companies." (p.126) "No armed personnel are used in Hydro's security operations." (p.116)

Resettlement. "The development of two of these projects involved the physical resettlement of families. Throughout 2025, Hydro Rein and its partners continued to actively monitor and engage with the resettled families and affected communities, ensuring alignment with IFC Performance Standards and the Equator Principles. In 2025, Ventos de São Zacarias maintained close monitoring of residual impacts from the construction phase, including cases of damages to property potentially caused by construction activity... an action plan was developed to safeguard the wellbeing of local communities, including house refurbishments and additional resettlements. Implementation of this action plan is underway and is expected to be completed in 2026." (p.127)

Positive contribution. NOK 514 million was spent in 2025 on community investments, Hydro Fund, donations, sponsorships and TerPaz (p.128), and four UsiPaz community centres were completed and handed to the Pará State Government (p.129).

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

Reference: pages 123, 129 and notes S3.1 and S3.2 (pp.267-268); content index p.276 points S3-5 to the affected communities sections plus Note S3.1; Note S3.2; Business Conduct: Note G1.1.

Stated target. "Empower 500,000 people with education and skills development by 2030." (p.123) The indicator is "Total people reached (cumulative) with education and skills development since 2018".

Performance. "Hydro's ambition is to equip 500,000 people with essential skills for the future economy by 2030... In 2025, Hydro reached more than 71,000 people, which makes the total number reached since 2018, 312,000 people. Hydro is still on track to reach the target of 500,000 by year end 2030." (p.129) Note S3.2 gives the series in thousands: 71 (2025), 44 (2024), 40 (2023), 25 (2022), 21 (2021), accumulated 312 since 2018 (p.268). "The increase in 2025 is in large part due to a single project with UNICEF that focuses on providing local teachers with further training and skills development in India." (p.268) "All business areas are contributing in line with the original ambition setting."

Community spending (note S3.1, p.267), NOK million, 2025: community investments 127; charitable donations and sponsorships 49; TerPaz local community centres 338; total 514. The chapter reconciles the movement: "In 2025, Hydro spent around NOK 514 million in total... Excluding TerPaz, there is a 29 percent increase compared to the prior year, mainly due to the increased community efforts in Brazil and an increase through the Hydro Fund." (p.128)

Definitions. "Education refers to initiatives within the formal educational system, from elementary school to university... Capacity or competence building refers to all training and competence building outside formal educational systems... Hydro has developed a framework and methodology for counting people impacted by our programs and initiatives to ensure consistency in how we measure progress across the company." (p.268)

Monitoring framework being built. "Following the recommendations of the Human Rights Impact Assessment (HRIA), Hydro has developed an integrated action plan, which includes a monitoring and evaluation framework to measure the effectiveness and impact of social programs in the local communities." (p.127)

Gap. The 500,000-people target measures positive contribution. No target is set for reducing the negative impacts identified in the HRIA – land conflict, security conduct, access to information and perceived environmental quality.

Business conduct policies and corporate culture

Reference: pages 131-132; content index p.276 points G1-1 to Business conduct: Our approach; Anti-Corruption; Data protection and cybersecurity.

"Hydro's board approved Code of Conduct creates the foundation that supports Hydro's efforts to do the right things and to always act with integrity throughout its global organization, wherever it operates and conducts business." (p.131) "Hydro's Code of Conduct is a constituting document and applies to all Hydro employees throughout the world, as well as to the Board of Directors of Hydro and its subsidiaries. For legal entities where Hydro holds less than 100 percent of the voting rights, Hydro's representatives in such boards of directors or in other governing bodies, shall act in compliance with Hydro's governing documents." (p.41)

Scope of the compliance system. "Special emphasis is made on reducing the risk of noncompliance within financial reporting, anti-corruption, competition, data privacy, economic sanctions, human rights, security, health, safety and environment." (p.131) "Hydro's compliance system is based on a clear governance structure defining roles and responsibilities regarding compliance and all compliance related activities undertaken throughout the company. Compliance risk governance owners define group wide policies and procedures, and are responsible for establishing training and awareness plans." (p.131)

Integration. "The management of compliance risks are integrated in Hydro's business planning, enterprise risk management, and follow up process, including relevant risk mitigating actions and relevant key performance indicators. The progress of actions as well as any noncompliance matters are addressed in the quarterly internal board meetings that each business area has with the CEO." (p.131)

Culture measurement. "Hydro's employee engagement survey, Hydro Monitor, benchmarks employee perception of Hydro's integrity culture." (p.131) The integrity culture index read 77 percent, from the 2024 survey (p.130).

Data protection. "Central to Hydro's privacy governance are its Binding Corporate Rules (BCR), which serve to ensure compliance with the EU General Data Protection Regulation (GDPR) and establish the Hydro data privacy network." (p.132) Cyber training: "Cyber security training for all 13,000 IT users and role specific training for Industrial Control System users are conducted yearly." (p.132)

Whistleblower protection. "The Global Procedure for Managing Alerts ensures no retaliation against anyone who speaks up in good faith." (p.131) Investigations are run by Group Internal Audit & Investigations, "In some cases, when deemed appropriate, external third parties carry out the investigation" (p.134).

Management of relationships with suppliers

Reference: pages 132, 118-122; content index p.276 points G1-2 to Business conduct: Management of relationships with suppliers.

"Combating corruption and respecting human rights are integral to Hydro's supplier requirements. See the Workers in the value chain chapter for information about Hydro's supply chain and how the company screens its suppliers and business partners." (p.132)

Supplier policy. "Hydro's Supplier Code of Conduct sets out the minimum sustainability requirements for all suppliers... The principles in the Code of Conduct are made binding through contractual clauses and the standard purchasing terms, and require suppliers to conduct due diligence in their own supply chain." (p.118)

Selection. "Suppliers are not selected on specific social and environmental criteria, but all suppliers are subject to a qualification process that includes screening for risks related to human rights and workers' rights." (p.118) "Selection of local partners and suppliers/contractors shall be based on competitive bidding to the extent feasible, and in compliance with competition laws and regulations as well as Hydro's requirements." (p.266)

Relationship approach. "Hydro builds supplier relationships on mutual trust and development, working to strengthen sustainability performance through dialogue, knowledge sharing, innovation, and supplier development programs. While failure to comply with the Supplier Code of Conduct may ultimately result in contract termination, Hydro seeks to work with suppliers towards continuous improvement whenever this is in the best interest of the people in the supply chain." (p.118)

Anti-corruption reaches suppliers. "Hydro also provides anti-corruption training to selected third parties, including suppliers." (p.132) Third-party risk management is one of the named pillars of the Anti-Corruption Compliance Program (p.131).

Scale. 42,850 supplier vendor records and NOK 159,401 million of supplier spend in 2025, 67 percent with local suppliers; approximately 39,000 unique suppliers (p.266).

Vulnerability to late payment. Hydro does not discuss the sensitivity of its supply chain to late payment in these terms, but reports payment practices under G1-6 (p.132).

Gap. ESRS G1-2 asks about the undertaking's approach to social and environmental criteria for selecting suppliers. Hydro answers that directly and negatively – suppliers "are not selected on specific social and environmental criteria" – with risk screening applied instead as a qualification gate.

Prevention and detection of corruption and bribery

Reference: pages 131-132 and note G1.3 (p.270); content index p.276 points G1-3 to Business conduct: Our approach; Anti-corruption; Compliance training; Non-compliance with business conduct standards; Appendix: Note G1.3; Governance: Board of directors; President & CEO and the Executive Leadership Team (ELT).

Commitment. "Hydro does not tolerate any forms of bribery or corruption, including facilitation payments and kickbacks. Further, Hydro is committed to complying with all applicable laws and regulations to fight corruption and bribery, including the UN Convention against corruption." (p.131)

Programme elements. "Hydro's Anti-Corruption Compliance Program provides an overview of the main elements in Hydro's anti-corruption efforts, which includes risk assessments, tone from the top, policies and procedures, training and communication, third party risk management, reporting and investigation, and disciplinary measures." (p.131) The framework figure on p.131 sets out preventing, detecting, responding, reporting and roles and responsibilities.

External validation. "A 2024-2025 external assessment of Hydro's Anti-Corruption Compliance Program confirmed the robustness of the program and suggested some potentials for enhancements." (p.131)

Risk targeting. "Functions involved in commercial activities and interactions with government officials, especially in regions with heightened inherent corruption risk, are most at risk and hence targeted for compliance training." (p.131)

Detection. "Hydro identifies inherent risk of corruption and other business conduct issues through corruption indexes and other screening tools, and assess potential impacts and risks through supplier and business partner due diligence processes. Hydro monitors business conduct incidents through cases reported to line management, supporting staff functions, Hydro's grievance mechanisms, AlertLine and Canal Direto, quarterly and year end compliance reporting from its business areas, and information collected from Hydro's legal and compliance departments." (p.77) More than 7,800 counterparties were screened in 2025 using Moody's Grid for, among other things, corruption and money laundering (p.119).

Independence of investigators. "Group Internal Audit & Investigations ensures an independent and objective investigation and reporting of the results." (p.134) The Chief Audit Executive "is independent from the line organization and reports to the Board of Directors and the Board Audit Committee" (p.131).

Training. Note G1.3 reports completed training modules by topic, including anti-corruption, Code of Conduct, general integrity, competition, human rights, data privacy, trade sanctions and market regulations (p.270). Total compliance modules completed: 42,486 in 2025, against 51,216 in 2024 and 29,213 in 2023 (p.130). "Companywide campaigns on preventing bribery/corruption and understanding sanctions and trade compliance were run in 2025." (p.132)

Collective action. Hydro partners with Transparency International Norway, the Maritime Anti-Corruption Network, and since 2018 the Business Pact for Integrity and Against Corruption in Brazil (p.133).

Targets related to business conduct (part of MDR-T/GDR-T disclosures)

Reference: page 130.

Hydro states plainly that it sets no quantitative business conduct target, and describes how it tracks effectiveness instead – the second limb of MDR-T:

"Hydro does not have company wide quantitative targets for business conduct, but tracks its performance on several indicators relevant for business conduct, integrity and responsible business. See the ESG factbook in the appendix for additional metrics related business conduct." (p.130)

The dashboard on p.130 pairs three indicators with the qualitative ambition "Commitment to building a culture of integrity and trust":

The integrity culture index is survey-based and biennial: "Employee surveys are performed every two year, the last one was conducted in 2024" (p.130), so 77 percent is the 2024 reading.

Other effectiveness tracking described in the chapter. Compliance risk management is "integrated in Hydro's business planning, enterprise risk management, and follow up process, including relevant risk mitigating actions and relevant key performance indicators", with progress and non-compliance matters taken to quarterly internal board meetings with the CEO and an annual compliance report to the Board (p.131). The Board Audit Committee receives quarterly compliance updates and "There is a yearly compliance deep dive session for the board Audit Committee" (pp.131-132). Externally, "A 2024-2025 external assessment of Hydro's Anti-Corruption Compliance Program confirmed the robustness of the program and suggested some potentials for enhancements" (p.131).

Standards note. G1-3 Targets related to business conduct is a standalone disclosure requirement only from the 2025/2026 ESRS. This report was prepared under the 2023 ESRS, where business conduct targets fell under MDR-T. Hydro's declaration that it holds no quantitative target, together with the indicator set it monitors instead, answers that requirement.

Incidents of corruption or bribery

Reference: notes G1.1 and G1.3 (pp.268-270); content index p.276 points G1-4 to Appendix: Note G1.1; G1.3.

Cases (note G1.1, p.268):

Consequences. "Dismissals due to breaches of policy" totalled 9 in 2025, against 18 in 2024 (p.268). "The number of dismissals due to breach of Hydro policy is based on cases reported directly or indirectly to Hydro's Internal Audit." (p.268)

Counting convention. "Every report made through the AlertLine is classified as a case, meaning that several cases could be related to the same issue." (p.268)

Fines and legal proceedings. "Instances of non-compliance with laws or regulations that have resulted in a fine of NOK 1 million being issued by a public authority, as well as relevant developments in cases that could have a material reputational or financial impact, are reported in note G1.2. No new non-compliances with laws and regulations that resulted in significant fines were registered in 2025." (p.134) The open matters listed in note G1.2 relate to environmental claims in Brazil rather than to corruption (pp.269-270).

Political contributions. "According to Hydro's global directives, Hydro may not make financial contributions to political parties. Hydro has no indications that such contributions took place in 2025." (p.134)

Training coverage. Note G1.3 reports completed compliance training modules by topic including anti-corruption (p.270); 42,486 modules were completed in 2025 (p.130). "Compliance training is reported based on training modules completed; one employee may complete several e-learning modules related to the same topic and/or participate in both classroom training and e-learning courses on the same topic." (p.270)

Gap. ESRS G1-4 asks for the number of convictions and the amount of fines for violation of anti-corruption and anti-bribery laws. Hydro reports confirmed internal cases and states no new significant regulatory fines, but does not give a conviction count or a fine amount. Nor is the percentage of functions-at-risk covered by anti-corruption training given as a coverage rate.

Political influence and lobbying activities

Reference: pages 133-134; content index p.276 points G1-5 to Business conduct: Public affairs and lobbying.

Resources. "In 2025, a total of 17 full time equivalents (FTE) were dedicated to public affairs and lobbying. This includes persons in Norway, EU, Brazil and the U.S." (p.134)

Registration. "Within the EU, lobbying activities are publicly reported through the EU Transparency Register. In the U.S., Hydro is registered and complying with the Lobby Disclosure Act. To get an overview of Hydro's memberships in different industry associations see Hydro.com." (p.134)

Where and how. "Hydro interacts primarily with decision makers in countries where it has significant operations, such as Norway, Brazil and the U.S., as well as with regional structures like the European Union institutions and the relevant EU Member States. These interactions are mainly related to securing competitive, stable, and predictable industry framework conditions, taxes, and legislation... Hydro's public affairs activities are generally focused on issues related to energy, industry policy, climate, sustainability and trade." (p.133) "Hydro promotes its views on issues of importance either through direct interaction with public authorities and other stakeholders, or through various industry associations. In addition, Hydro participates in think tanks, especially in Brussels and Washington D.C." (p.133)

Positions taken (p.134). "Hydro also supports the climate targets set in the Paris Agreement." "Hydro supports market based solutions for pricing of carbon emissions, like the EU Emissions Trading System (ETS)." On CBAM: "Hydro believes it is important for the aluminium industry that CBAM is reviewed both before final implementation and continuously during the live phase, that all loopholes in the mechanism are closed and that indirect cost compensation remains as an important carbon leakage instrument." In Norway, Hydro works on "access to renewable power at competitive prices and effective measures to mitigate against carbon leakage", particularly the CO2-compensation scheme.

Political contributions. "According to Hydro's global directives, Hydro may not make financial contributions to political parties. Hydro has no indications that such contributions took place in 2025." (p.134)

Gap. ESRS G1-5 asks whether any member of the administrative, management or supervisory bodies held a comparable position in public administration in the two years before appointment. That disclosure is not made. Financial contributions are stated as prohibited, but no monetary total of lobbying expenditure is given.

Payment practices

Reference: page 132; content index p.276 points G1-6 to Business conduct: Management of relationships with suppliers.

"Hydro tracks on time payment statistics to prevent late payments to suppliers, with automatic dashboards to track performance on a daily basis for approximately 82 percent of Hydro's units globally. Payment terms vary between categories of purchase, between regions and by type of business. In 2025 for upstream units, the average payment term days were 38, while for downstream units it was 46 days. 92 percent of invoices were paid on time in line with agreed upon terms." (p.132)

That covers three of the four ESRS G1-6 elements: the average time to pay an invoice from the date the contractual term begins (38 days upstream, 46 days downstream), a description of standard payment terms by main supplier category (terms "vary between categories of purchase, between regions and by type of business"), and the percentage of payments aligned with those standard terms (92 percent).

Coverage caveat. The daily tracking covers "approximately 82 percent of Hydro's units globally"; the report does not state whether the 92 percent on-time figure is drawn from that same 82 percent of units or from a wider population.

Small and medium-sized enterprises. Hydro reports 67 percent of supplier spend going to local suppliers, defined as "suppliers situated in the same country as the site making the purchase" (p.266), but does not identify SME suppliers as a category or report payment terms for them.

Gap. ESRS G1-6 also asks for the number of outstanding legal proceedings for late payments. That figure is not disclosed. Note G1.2 covers non-compliance with laws and regulations more broadly (pp.269-270) and lists environmental claims in Brazil, not payment disputes; "No new non-compliances with laws and regulations that resulted in significant fines were registered in 2025" (p.134).