Norwegian Air Shuttle

Board of Directors

Svein Harald Øygard - Chair Svein Harald Øygard (born 1960) has extensive experience in both public and private sectors. He has had key roles at the Ministry of Finance and McKinsey & Company. In 2009, he served as Interim Central Bank Governor of the Icelandic Central Bank. Mr. Øygard holds a Cand. Oecon degree from the University of Oslo. He chairs the board and serves as an independent board member, re-elected for the period from 2023 to 2025.

Lars Boilesen - Director Lars Boilesen (born 1967) is the CEO of Napatech A/S. He was previously the CEO of Otello Corporation (formerly Opera Software ASA). Prior to that, he gained extensive sales and marketing experience at Lego, Tandberg, and Alcatel-Lucent. He serves on the Board of Airthings ASA. Mr. Boilesen holds a bachelor's degree in business economics from Aarhus School of Business and is an independent board member, re-elected for the period from 2023 to 2025.

Karina Deacon - Director Karina Deacon (born 1969) is an experienced leader with a strong financial background. She brings experience from management positions in multinational enterprises such as ISS A/S, Nilfisk A/S, and Saxo Bank A/S. From 2020 to 2024, she was the Group CFO of DFDS A/S. Ms. Deacon holds a Master of Economics and Business Administration from Aarhus Business School in Denmark. Ms. Deacon is elected for the period 2024-2026 and is an independent board member.

Stephen Kavanagh - Director Stephen Kavanagh (born 1967) is a seasoned airline professional with over 35 years of experience, including serving as CEO of Aer Lingus until 2019. Currently, he is a Non-Executive Director on several boards, including Oman Air and aircraft lessor CDB Aviation. Mr. Kavanagh holds a Master of Business and a Bachelor of Commerce from University College Dublin. He is an independent board member until 2025.

Kate Jane Sherry - Director Katherine Jane Sherry (born 1980) is the Chief Commercial Officer at Edinburgh Airport, joined in 2020 as Aviation Director. Previously, she was Director of Route Development and Head of Retail at Ryanair Group. Earlier, Ms. Sherry was a food buyer at Tesco Group. She holds the MCIPS qualification and a Master of Science in Sports Management from University College Dublin. Ms. Sherry is an independent board member elected for the period from 2023 to 2025.

Eric Holm - Director, Employee Representative Eric Holm (born 1967) joined Norwegian in March 2010 and currently works at Norwegian Cabin Services Norway AS. He holds a master's degree in international security studies from the University of Leicester. Mr. Holm serves as Deputy Board Member at Norwegian Cabin Services Norway, Chairman at Parat Luftfart, and board member (employee representative) at Lufthansa Service Group Norway. He has been an employee representative board member since 2019, re-elected for the period from 2022 to 2024.

Katrine Gundersen - Director, Employee Representative Katrine Gundersen (born 1974) is a Crew Tracker at Norwegian's Integrated Operational Control Centre (IOCC). She entered the airline industry in the late 1990s and joined Norwegian in August 2002. Ms. Gundersen holds a bachelor's degree in economics from BI University. Ms. Gundersen has been an employee representative board member since 2019, re-elected for the period from 2022 to 2024.

Torstein Hiorth Soland - Director, Employee Representative Torstein Hiorth Soland (born 1987) is Director of Lean at Norwegian. He joined Norwegian's Technical Operations Department in 2014. In 2017, he moved to the Network department within the Commercial department as Fleet Manager, and in 2019 he assumed the role of Vice President Fleet Strategy. He holds a bachelor's degree in Aeronautical Engineering from Mälardalen University and a Master of Science in Wind Energy. He has been an employee representative board member since 2022, elected until 2024.

Management

Geir Karlsen - Chief Executive Officer (CEO) Geir Karlsen (born 1965) has been Norwegian's CEO since June 2021. Previously, he served as CFO from April 2018. He has extensive experience with listed companies in the shipping and offshore sectors. Mr. Karlsen held various CFO roles at Golden Ocean Group, Songa Offshore, and Navig8 Group. He holds a Master of Science in Economics from BI Norwegian Business School and a Master of Business Administration from the Norwegian School of Economics.

Hans-Jørgen Wibstad - Chief Financial Officer (CFO) Hans-Jørgen Wibstad (born 1964) has been Norwegian's CFO since May 2022. He has more than 20 years CFO and senior management experience from the defence and engineering industry, shipbuilding and the shipping and offshore sectors. Mr. Wibstad previous roles include CFO at Multiconsult ASA, Kongsberg Gruppen ASA, and senior positions at DFDS. He also has been a corporate banker at Danske Bank, Credit Agricole and Nordea. He holds an MBA from the University of Colorado, USA.

The Board of Directors provides principles for overall risk management and evaluates the Company's objectives, strategies and risk profile every year. The Board of Directors regularly reviews and evaluates the Group's overall risk management systems and environment, at least annually.

Integration of sustainability-related performance in incentive schemes

Roles covered

The extended leadership is incentivised through a compensation scheme to achieve sustainability-related targets.

Scheme application and performance period

The compensation scheme was not offered in 2024 but was offered in 2023 and will be offered in 2025.

Sustainability KPIs and weighting

Financial performance on earnings before interest and tax carries the largest weighting in the compensation scheme. With fuel as the largest individual cost factor in the Company, there is a strong indirect compensation incentive on reducing the consumption of fuel, and as such, total emissions in the Company.

A range of special initiatives also carry a significant weighting in the compensation scheme and includes:

• An organisational management 40/60 gender diversity target (either way)
• Punctuality targets (which implicitly reflect operating efficiency and climate impact, i.e. higher fleet utilisation and more on-time flights result in less resource usage and lower emissions)

Updated scheme for 2025

In 2025, the updated scheme will also include targets linked to:

• Selected efficiency gains with positive climate impact
• ESG rating achieved
• Employee engagement score
• Customer satisfaction level

Assessment against GHG emission reduction targets

The performance of the Board and Executive Management Team has not been assessed against the GHG emission reduction targets reported under E1-4.

Link to STI/LTI

The disclosure does not specify whether the compensation scheme is linked to short-term incentive (STI) or long-term incentive (LTI).

Threshold/target/maximum structure

The disclosure does not provide details on how threshold/target/maximum performance is defined for sustainability KPIs.

Payout disclosure

No payout information against sustainability KPIs is disclosed for the reporting period (the scheme was not offered in 2024).

Risk management in the Norwegian Group is founded on the principle that risk evaluation is integral to all business activities. Policies and procedures have been established to manage risk effectively. The Board of Directors regularly reviews and evaluates the Group's overall risk management systems and environment, at least annually. The Norwegian Group faces several risks and uncertainties in a global marketplace, which has become increasingly uncertain with volatile energy and fuel prices, inflationary pressure, fluctuations in foreign exchange rates, and potential impacts of disruptions in the global supply chain, rising geopolitical tensions, economic tariffs, and the growing trend of protectionist policies.

Financial risk management in Norwegian is carried out by the treasury, under policies approved by the Board of Directors. The team identifies, evaluates and hedges financial risk in close cooperation with the Group's operating units. Financial risk management in Widerøe is carried out by the Widerøe Finance team. The Board of Directors provides principles for overall risk management in relation to foreign currency risk, jet fuel price risk, interest rate risk, credit risk, EU ETS emission allowance price risk, and for the use of derivative instruments, and investment of excess liquidity.

Business strategy

Norwegian has long been recognised as an industry leader in low-cost travel, winning numerous awards during its over 20 years in operation. Norwegian built on its strong foundation when renewing its strategy in 2021, refocusing on the core Nordic market, and operating a European short-haul network with a one-type narrow-body aircraft on routes with proven historic profitability. The Norwegian Groups overall business objective is to be the preferred airline within its core market, to generate attractive returns to its shareholders, and to add lasting value to all stakeholders.

Norwegian meets its customers' needs by offering affordable fares for all, across a broad range of routes in and across the Nordics and Europe. Strong operational performance, and the award-winning Norwegian Reward loyalty programme, are key foundations in delivering an attractive offering to customers that choose to fly with Norwegian, for leisure and business travel needs. The company's vision is to be the most loved and trusted airline in Europe. Widerøe will support the Group's strong customer proposition, through the enabling of seamless travel across an improved route network offering.

Strong Nordic-focused network

Norwegian's network is an optimised short-haul network, developed and refined since 2002, with a core Nordic footprint. In recent years, Norwegian has optimised the route portfolio to a network of close to 350 routes, with the majority having historically performed well. The network also ensures that the Norwegian Group maintains the strong presence and connectivity, that customers value highly.

The Company is a leading carrier for leisure-oriented traffic in the Nordics and has in recent years also been taking market share within the corporate travel market. Within the Nordics, the Company is the largest airline group measured on production (ASK) in Norway, and the second largest in Denmark, Sweden, and Finland. The route network is designed to maintain and further strengthen this position. Furthermore, the network is also designed to improve operational efficiency, partly achieved by prioritising routes to the most popular destinations with significant traffic flows.

Competitive cost base

Norwegian's foundation is a low-cost operating model. This model features low complexity, high reliability, and a rightsized and competitive cost base. It enables the Company to provide affordable fares while delivering returns to shareholders. The Company will leverage and strengthen its cost advantage going forward, boosted by the efficiency gains obtained in the restructuring in 2021.

This model allows Norwegian to compete effectively on price versus legacy carriers, on scale versus new entrants, and with a superior quality offering to that offered by the ultra-low-cost carrier (ULCCs) airlines. Maintaining and improving on its competitiveness, by striving every day for increased cost-efficiency, in combination with a customer offering of high quality, is key to Norwegian's DNA.

Mission, vision & values

Norwegian launched its mission, vision, and values in 2022, in conjunction with the Company's 20-year anniversary. More than 150 colleagues contributed with their input on what Norwegian truly cares about, and what is needed to capture the opportunities that lie ahead. The vision, mission, and values are based on this input.

Norwegian Vision: The most loved and trusted airline in Europe

Norwegian Mission: Together, we fly above and beyond to serve people the Norwegian way

Norwegian Values: • A caring heart • In it together • Courageously inventive • Passionately Norwegian

Interests and views of stakeholders

Overview

Engaging with stakeholders is an important aspect of the Company's strategic approach. This interaction gives an understanding of material issues and aims to ensure support for solutions and initiatives for the approach to ESG matters. Engagement is generally initiated by the Company through the relevant business unit and includes engagement with its own workforce, workers in the value chain and consumers & end-users. Respecting their human rights and using their views to inform strategy and the business model are part of the engagement.

The Company has not amended and is currently not planning to amend its strategy or business model based on stakeholder inputs. It will monitor on an ongoing basis if there is stakeholder input calling for strategic change.

The Norwegian Group's Board are informed about the views and interests of affected stakeholders, regarding the Company's sustainability-related impacts, by the Executive Management Team members who have responsibility for the engagement. Management prioritises communicating stakeholder viewpoints, based on their judgement, whether those views may be relevant to the Board's decision-making.

Management also considers whether stakeholder views about the Company's sustainability-related impacts should be shared with key groups or persons within the business on a similar basis.

Stakeholder perspectives are essential features of the Company's materiality assessment and due diligence efforts.

Stakeholder groups and engagement

Integration into due diligence process

The materiality assessment table maps stakeholder engagement activities to key steps of the due diligence process:

Stakeholder engagement in materiality assessment

The initial phase of the Double Materiality Assessment (DMA) evaluated the Company's activities, business relationships, value chain and affected stakeholders to identify relevant sustainability matters. Subsequently, the IRO identification was carried out through document review and stakeholder interviews. The identification was based on the Company's value chain description, and stakeholder insights were included to understand impacted parties and users of information.

The Company used stakeholder engagement to inform the assessment of impacts, risks and opportunities across various topics:

• E4 – Biodiversity and ecosystems: Affected communities were not directly part of stakeholder engagement regarding this topic, although engagement happened with an NGO to get insights into issues related to these communities.

• E2 – Pollution, E3 – Water and marine resources and E5 – Resource use and circular economy: Affected communities were not directly part of this stakeholder engagement, but an NGO was utilised as a proxy to gain insights into issues related to these communities.

• S2 – Workers in the value chain: The Company engages with value chain workers through reliable intermediaries including the supplier assessor EcoVadis.

• S4 – Consumers and end-users: The Company regularly engages with its customers and other key stakeholders through surveys, feedback mechanisms, and various aviation industry initiatives.

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

Overview

The Company has evaluated the resilience of the Company's business model and strategy. This is further described in E1 under SBM-3.

The material impacts, risks and opportunities identified during the materiality assessment are presented in this Sustainability Statement, alongside the topical ESRS for E1 Climate change, E2 Pollution, E4 Biodiversity and ecosystems, S1 Own workforce, S2 Workers in the supply chain, S4 Consumers and end users and G1 Business conduct.

The Company has concluded that there are no current or anticipated effects on its business model, value chain, strategy and decision-making arising from the identified IROs, that it is not already aware of and managing.

Material IROs by topic

E1 Climate change - Material impacts, risks and opportunities

E2 Pollution - Material impacts

E4 Biodiversity and ecosystems - Material impacts

S1 Own workforce - Material impacts and risks

S2 Workers in the value chain - Material impacts

S4 Consumers and end users - Material impacts and risks

G1 Business conduct - Material impacts

Location in value chain and time horizon

Interaction with strategy and business model

The Company considers the interests, views and rights of affected stakeholders when setting its strategy and business model. The Company acknowledges that its strategy and business model may have impacts on stakeholders, and these impacts are described in the relevant sections.

Management prioritises communicating stakeholder viewpoints to the Board, based on their judgement of whether those views may be relevant to the Board's decision-making. Management also considers whether stakeholder views about the Company's sustainability-related impacts should be shared with key groups or persons within the business on a similar basis.

The Company monitors activity in its own workforce, as well as industry and stakeholder information, and regulatory development, to understand the impacts, risks and opportunities that may be affecting different groups. Information collected through these processes and from other sources is used to identify and inform the selection and implementation of suitable approaches and specific actions.

Where applicable the Company adapts its business model and strategy to address or avoid certain impacts, such as switching to a different supply chain model or changing the way it operates.

Resilience analysis

The Company considered a basic and broad climate change scenario in its DMA process to inform the identification and assessment of physical risks and transition risks and opportunities over different time horizons. The scenario used was general in nature and does therefore not necessarily cover all plausible risks and uncertainties.

The Company has not conducted a climate-related scenario analysis to aid in the identification and assessment of physical and transitional risks and opportunities across different time frames.

The Company will conduct a climate scenario analysis in 2025, assessing the resilience of its strategy and business model, and adaptive measures to enhance climate resilience. The results of this analysis will be published in the Company's annual reporting for 2025.

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

Overview

During 2024, the Company conducted a DMA based on the ESRS requirements. The assessment involved a group of key employees identifying and objectively assessing impacts, risks and opportunities (IROs). The IROs are described in the relevant ESRS chapters in the Sustainability Statement.

The DMA was informed by previous materiality assessments conducted by the Company but introduced a more rigorous methodology than previously applied. This has resulted in more specific IROs, as well as a broader scope including the Company's upstream and downstream activities in its value chain. The Company aims to revisit and update the DMA annually.

The identification, assessment and management of sustainability-related IROs are not currently fully integrated into the Company's enterprise risk management process. The prioritisation of sustainability-related IROs against enterprise risks is currently undertaken on a case-by-case basis.

Internal controls

The Company was supported by external advisors to facilitate the DMA process. All inputs from external advisors were adjusted and approved by the Company to be applicable throughout the process. All inputs for the assessment, including the descriptions and scoring of the identified IROs were documented in an audit-ready software provided by a third party. The results and findings were presented to the Executive Management Team after being concluded by the internal experts and project team. The DMA was discussed and approved by the Audit Committee and the Board.

Methodologies and assumptions

A quantitative bottom-up approach was applied in the DMA process. The input and assessment relied on existing internal documentation and knowledge in the Company, as well as expert interviews carried out in the process. This aims to ensure that the contributors possess sufficient insights to accurately identify and assess actual and potential IROs.

It is further assumed that the qualitative descriptions can be accurately quantified on a five-point-scale and that this scale provides a sufficient granular outcome. The thresholds rest on assumptions that the Company, or the sources used to decide thresholds, has sufficient insight in what is considered an appropriate threshold for the Company. Stakeholder interviews were used to inform the long list under the assumptions that they represent the views of impacted stakeholders and that they have sufficient insights on the topic.

Input parameters

Several sources of information were used to conduct the DMA, including those used to inform the Company's enterprise risk assessment and internal risk management processes. Material sustainability matters identified through the DMA process have been incorporated or adjusted in enterprise and related management systems if required and applicable.

The following sources provided input to the DMA:

• Existing internal and external reporting – quantitative and qualitative
• Input from internal and external sustainability experts
• Input from informed stakeholders
• Industry reports and statements on industry developments and sustainability-related matters
• Regulatory reports on current and planned industry regulations

Process description

Identification of impacts, risks and opportunities

The initial phase of the DMA evaluated the Company's activities, business relationships, value chain and affected stakeholders to identify relevant sustainability matters. This allowed for a sector-specific examination of critical sustainability matters, alongside an exploration of Company-specific matters. Specific focus was directed to known industry impacts, including operations in known at-risk geographies. These include the Middle East for certain impacts pertaining to workers in the value chain and other geographies, where the potential exists for portions of biofuel (SAF) sourced from unspecified origins.

The Company used the established sustainability matters in ESRS-1 as a starting point for identifying actual and potential IROs at a sub-sub-topic level. All matters were assumed to be relevant until proven otherwise. Additional industry-specific topics were also considered to complement the ESRS-defined matters. Sustainability matters that were proven to be irrelevant were excluded from the materiality analysis.

Subsequently, the IRO identification was carried out through document review and stakeholder interviews. The identification was based on the Company's value chain description, and stakeholder insights were included to understand impacted parties and users of information. This approach allowed the Company to identify both direct and indirect impacts throughout its value chain. Moreover, impacts were identified prior to risks and opportunities in order to ensure that the latter could be identified both on the basis of an impact and a dependency on external factors.

As part of the DMA process, 10 stakeholder interviews were utilised to inform the longlist of actual and potential impacts, risks and opportunities. Employees with insights into impacted stakeholders and the users of the Sustainability Statement, were also appointed to act as liaisons with the Company's stakeholders. External experts in the form of industry consultants also assisted in the process. Interviews with both external and internal stakeholders were conducted to inform sustainability issues and IROs.

Assessment and prioritisation

The scoring of IROs was performed by internal experts to the best of their ability and calibrated with guidance from external experts throughout a series of workshops.

The materiality assessment's scoring method and criteria were established following ESRS 1 requirement:

• Impact materiality: Considering the scale, scope, irremediability and likelihood of impacts being positive/negative and actual/potential.
• Financial materiality: Assessing the financial significance of risks/opportunities, their likelihood and the nature of financial effects.

Identified IROs were individually scored on a 1 to 5 scale for each of the criteria mentioned above.

Thresholds for materiality

The threshold for impact materiality was set to make sure that impacts with a severity score of 4 or above would be deemed material, irrespective of likelihood. The threshold for human rights related impacts was lowered in line with the ESRS guidelines (ESRS 1, §45).

For financial materiality, the thresholds were set to align with the materiality threshold used in the Financial Statements.

A sustainability matter was classified as material if any associated IRO surpassed the set numerical thresholds, indicating either impact materiality, financial materiality, or both. Non-material matters were those falling below these thresholds. To conclude the assessment, the results were presented and validated in a workshop with internal experts and contributors to the assessment.

Use of value chain mapping

The DMA evaluated the Company's activities, business relationships, value chain and affected stakeholders to identify relevant sustainability matters. The identification was based on the Company's value chain description, and stakeholder insights were included to understand impacted parties and users of information. This approach allowed the Company to identify both direct and indirect impacts throughout its value chain.

Frequency

The Company aims to revisit and update the DMA annually.

Specific matter assessments

E1 – Climate change

Identification and assessment of climate-related impacts was undertaken as described in the process description above. The climate accounting of the Company was screened as the primary source to inform the high-level assessment. It was assessed that the Company's climate impact is unlikely to change and that screening the climate accounting would present a representative picture of the impacts.

Identification of climate-related physical and transition risks was based on a screening of identified impacts as well as potential dependencies. Identification of climate-related hazards and transition-risks, and assessment of the Company's exposure to these was undertaken using deep knowledge of the Company and industry. The screening process was general in nature and not based on scientific evidence.

The Company has not conducted a climate-related scenario analysis to aid in the identification and assessment of physical and transitional risks and opportunities across different time frames.

E2 – Pollution, E3 – Water and marine resources and E5 – Resource use and circular economy

The Company has not screened site locations to identify IROs related to pollution, water & marine resources and resource use & circular economy, but based the identification on a desktop analysis and engagement with stakeholders. Affected communities were not directly part of this stakeholder engagement, but a NGO was utilised as a proxy to gain insights into issues related to these communities.

E4 – Biodiversity and ecosystems

The Company has identified a potential impact on biodiversity and ecosystems in the upstream value chain. The impact was assessed in the same way as all other impacts, through quantification of a qualitative assessment of the scale, scope, irremediability and likelihood of the impact.

The Company has identified a dependency on ecosystem services connected to SAF scarcity, which represents a transition risk for the Company as it increases its consumption of SAF. The assessment criteria for this risk were the same as for other risks, relying on a quantification of a qualitative assessment of magnitude and likelihood. Systemic risks have not been considered explicitly but are considered indirectly through deep knowledge of the industry and the risk associated with it. Affected communities were not directly part of this stakeholder engagement regarding this topic, although engagement happened with an NGO also get insights into issues related to these communities. The Company does not have sites located in or near biodiversity-sensitive areas, and it has been concluded that it is not necessary to implement biodiversity mitigation measures.

G1 – Business conduct

Identification of IROs concerning business practices involved assessing business areas or geographies with potential impacts or risks associated with corruption, bribery and human rights issues. The assessment process considered business conduct risks identified in internal risk reviews and processes, considering the potential financial risks and opportunities stemming from identified impacts or dependencies. This included consideration of specific locations in the Middle East, ground handling and service activities where agency outsourcing is used, purchasing from biofuel and catering sectors, and complex transaction structures.

Transition plan for climate change mitigation

Overall plan status

The Company recognises the importance of aligning with the transition to a low-carbon economy. While the Group does not yet currently have a formal transition plan, both Norwegian and Widerøe have prior to the acquisition of Widerøe been working on climate mitigation targets and plans. Since the acquisition, the Group has been evaluating its strategic approach to climate change mitigation to comply with evolving regulatory expectations and industry standards. The Company will define its transition framework and plan in 2025 to strive for alignment and compliance with EU climate regulation and to support its long-term sustainability commitments.

Resilience analysis

Evaluating the resilience of the Company's business model and strategy from the analysis undertaken to date has highlighted two key areas for further strategic investigation and focus. While existing and projected purchasing and consumption of SAF remains viable, there is uncertainty related to both the evolution of the SAF market and development of the associated EU regulations. The analysis indicated that current consumer preferences for affordable and carbon conscious air travel looks to remain stable going forward. However, the ability to maintain consumer demand is linked to several external factors where considerable uncertainty remains, including EU climate regulation as well as the pricing and taxation of GHG emissions.

The Company plans to undertake a detailed resilience analysis to address its physical and transition climate-related risks in 2025. This work will include climate scenario analysis aligned with IPCC pathways, covering the scope of material risks.

Existing targets

The subsidiary Norwegian has a voluntary climate target to reduce its carbon intensity by 45% by 2030, compared to 2019, while Widerøe has a target to reduce the emission intensity by 17% by 2030, compared to 2019, with an ambition for flights to be fossil-free by 2043.

Key decarbonization levers

Fleet renewal

Buying new aircraft is the single most important action an airline can take today to reduce its carbon emissions. The subsidiary Norwegian has a modern jet fleet with an average aircraft age of 8.9 years at year-end 2024.

Replacing older jet aircraft with new and more fuel-efficient models is expected to improve carbon efficiency by between 14 to 20 percent per new aircraft, depending on the age and fuel efficiency performance of the replaced aircraft.

In 2022, Norwegian entered into a landmark deal with Boeing to purchase 50 Boeing 737 MAX 8 aircraft with delivery from 2025 to 2028, with an option to purchase another 30. The new aircraft are predominately replacing previous generation aircraft. By year-end 2024 Norwegian's fleet of 86 Boeing 737s consisted of 22 of the new and more fuel efficient MAX8s. As per note 32: Commitments in the Financial Statements, Norwegian has committed over NOK 30 billion of capital expenditure for jet fleet renewal until 2028. Going forward this will affect the line item aircraft, prepayments and other tangible assets in the Financial Statements, and the future capex KPI for CCM 6.19 in the Taxonomy reporting. In 2025, NOK 4,655 million was capitalized in capex for this KPI in 6.19, as per the Taxonomy report.

Fossil fuel free aircraft

Parts of the subsidiary Widerøe's fleet (Dash-8 series 100/200/300) are scheduled for renewal between 2035 and 2037. Widerøe aims to replace these aircraft with electrified alternatives if technological advancements make this feasible. However, due to uncertainties regarding the timeline for the technological development, Widerøe is also considering other alternatives based on current available technology.

Sustainable aviation fuels (SAF)

Norwegian's 737 aircraft can fly on up to 50 percent certified SAF today. A SAF blend of approximately 20 percent is required to reach the subsidiary Norwegian's 45 percent reduction target by 2030, provided Norwegian operates a fleet of only MAX8s and the average SAF life-cycle emission reduction is 80 percent.

The Company is engaging with producers and using its purchasing power to ramp up the production of affordable fuels with high sustainability performance. By blending in SAF, the Company can improve its carbon efficiency compared to only burning conventional fossil jet fuels.

The Norwegian Armed Forces has selected the Company as their airline for approximately 250,000 annual trips starting in 2024 and until 2028. A key factor in this decision was the Company's commitment to providing a 15% SAF blend for all trips in the agreement, representing one of the world's largest voluntary SAF procurement commitments.

Data driven fuel saving

The Company is developing and implementing smart data-tools to improve fuel efficiency performance. The SkyBreathe mobile application helps pilots to fly more fuel efficiently, while the SkyBreathe aircraft performance monitor allows the most efficient aircraft to be operated on the most fuel consuming routes.

Company pilots are using complementary systems to make better route choices, receiving real time updates with advanced weather data straight into cockpit. This helps pilots to calculate the most fuel-efficient altitude depending on the prevailing winds and aircraft performance. The Company aims to improve its carbon efficiency by 2 percent by 2030 (2010 baseline) through full implementation of data driven fuel saving.

The Company provides fuel saving training to its pilots to improve performance and increase the scale at which fuel savings can be achieved. All pilots receive scheduled training on an annual basis to stay updated on the latest fuel saving best practices.

Alignment with Paris Agreement / SBTi

The policy aligns with third-party standards and commitments, referencing the IPCC (Intergovernmental Panel on Climate Change) target of limiting global warming to 1.5°C. Additionally, the policy indicates engagement with the Carbon Disclosure Project (CDP) to report climate-related risks, management and performance.

Policies related to climate change mitigation and adaptation

Norwegian Air Shuttle discloses one primary policy relevant to climate change mitigation and adaptation.

Environmental Management System

Overview

The Environmental Management System (the policy) defines the Company's goals relating to climate change mitigation and energy use and describes the Company's approach to mitigating climate-related impacts by reducing GHG emissions within its own operations.

Key content and principles

• Reducing CO₂ emissions per passenger kilometre
• The subsidiary Norwegian has targeted an intensity reduction of 45% by 2030, compared to a 2010 baseline
• The subsidiary Widerøe has targeted a reduction of 17% by 2030, compared to 2019, with an ambition for flights to be fossil-free by 2043
• Integration of sustainability through efficient aircraft operations, the use of SAF and structured governance
• Compliance with the Corporate Sustainability Reporting Directive (CSRD) and the European Sustainability Reporting Standards (ESRS)
• Use of renewable energy sources, including certified SAF
• The policy is an integral part of the Company's business strategy, supporting operational resilience, regulatory compliance and alignment with strategic sustainability goals that support long-term competitiveness and shareholder value

Scope

• Applies across the Company's entire airline network, with an emphasis on European operations
• Does not state any explicit exclusions regarding specific activities or geographies
• Includes all of the Company's operations and relevant GHG emissions within its value chain i.e. Scope 1, 2 and 3 emissions
• Applies to all staff and operations at the Company

Governance and accountability

• Accountability for implementation of the policy is assigned to the Executive Management Team
• Executive Vice Presidents have designated areas of responsibility with the aim to ensure compliance and the achievement of sustainability targets referenced in the policy
• Vice Presidents of Sustainability and Performance Management are responsible for its implementation and monitoring

Alignment with international standards

• Aligns with third-party standards and commitments, referencing the IPCC (Intergovernmental Panel on Climate Change) target of limiting global warming to 1.5°C
• Indicates engagement with the Carbon Disclosure Project (CDP) to report climate-related risks, management and performance

Stakeholder engagement

• Stakeholder considerations are reflected in the Company's partnerships and regulatory compliance measures, to keep investors, regulators and industry stakeholders engaged in the sustainability transition
• Internal and external stakeholders have been consulted via the Company's materiality analyses
• Stakeholder views have been used by the Company in the preparation of the contents of the policy
• The policy does not explicitly outline a stakeholder consultation process and references regulatory compliance as its primary driver

Monitoring and implementation

• Monitoring the policy's implementation and outcomes is conducted through annual reporting and governance mechanisms designed to track the achievement of sustainability goals
• Policy outcomes are monitored on an annual basis and reported in the Company's Annual Report

Public availability

• The policy is made available to all staff on the intranet and is implemented in accordance with the Corporate Code of Business Ethics and Conduct
• Training and awareness about the policy is provided as part of the employee induction process and regular internal communications
• The policy is made publicly available through the Company's annual reporting and sustainability strategy documents

Coverage of material impacts

The policy addresses the Company's material climate and energy impacts and risks. Climate change adaptation is not explicitly covered by the policy. Through its focus on fuel consumption and GHG emission reductions, the policy inherently influences the Company's approach to carbon related risks and the non-CO2 effects of aviation.

Actions and resources in relation to climate change policies

The Company has taken concrete steps to address its material climate impacts through a series of targeted actions, using decarbonisation levers for climate change mitigation, adaptation and energy efficiency. The Company cooperates closely with its customers, investors, suppliers, regulators and other key stakeholders to succeed in achieving its climate goals.

1. Fleet renewal

What it does: Replacing older aircraft with more fuel-efficient and lesser polluting models such as the Boeing 737 MAX 8.

Scope: Own operations

Time horizon: Until 2028

Resources allocated:

• Financial: Over NOK 30 billion of capital expenditure committed for jet fleet renewal until 2028 (as per note 32: Commitments in the Financial Statements)
• In 2025, NOK 4,655 million was capitalized in capex for Taxonomy KPI 6.19
• Affects line items: aircraft, prepayments and other tangible assets in the Financial Statements

Links to: Environmental policy, climate change mitigation goal, air pollution reduction

2. Fossil fuel free aircraft

What it does: Widerøe aims to replace its Dash-8 series 100/200/300 fleet with electrified alternatives if technological advancements make this feasible.

Scope: Own operations (Widerøe subsidiary)

Time horizon: 2035-2037 (aircraft scheduled for renewal)

Expected outcomes: Enable fossil-free flights by 2043 (Widerøe ambition)

3. Data driven fuel saving

What it does: Development and implementation of smart data-tools to improve fuel efficiency performance:

• SkyBreathe mobile application helps pilots fly more fuel efficiently
• SkyBreathe aircraft performance monitor allows most efficient aircraft to be operated on most fuel consuming routes
• Complementary systems for better route choices with real-time advanced weather data in cockpit

Scope: Own operations

Time horizon: Medium-term (target by 2030)

Resources allocated:

• Non-financial: Pilot training programs, technology systems integration

Expected outcomes:

• Improve carbon efficiency by 2 percent by 2030 (2010 baseline) through full implementation
• In 2024: pilots saved 21,700 tons of fuel amounting to 68.2 tons of CO2 (according to SkyBreathe data)

Links to: Climate change mitigation, carbon efficiency target

4. Fuel saving training

What it does: Scheduled annual training for all pilots on latest fuel saving best practices.

Scope: Own operations

Resources allocated:

• Non-financial: All pilots receive annual scheduled training

Expected outcomes: Achieved 21,700 tons of fuel savings and 68.2 tons of CO2 reduction in 2024

5. Operational efficiency

What it does: Multiple initiatives including:

• Competitive pricing to stimulate higher load factors and reduce emissions per passenger
• Optimised route planning including direct point-to-point flights
• New aircraft cleaning techniques to reduce fuel consumption and extend engine lifetime

Scope: Own operations

Time horizon: Medium-term (target by 2030)

Expected outcomes: Improve carbon efficiency per RPK by 3 percent by 2030

Links to: Climate change mitigation goal

6. Sustainable Aviation Fuel (SAF) procurement

What it does: 15% SAF blend commitment for all trips in agreement.

Scope: Own operations

Resources allocated:

• Described as "one of the world's largest voluntary SAF procurement commitments"

Links to: Climate change mitigation, environmental policy

Actions to address climate-related risks

Physical risks - extreme weather

What it does: Day-to-day weather management and monitoring of increased extreme weather impacts.

Scope: Own operations and downstream (airline customers)

Links to: Climate adaptation, S4 (consumers and end-users)

Transition risks - carbon tax and regulatory compliance

What it does: Establishing expertise, monitoring, auditing and training to safeguard compliance with carbon tax requirements and fuel blending regulations. Engagement in industry initiatives, research and innovation projects.

Scope: Own operations

Expected outcomes: Minimize exposure to carbon taxes and regulatory compliance requirements

Links to: Climate change mitigation actions, environmental policy

Targets related to climate change mitigation and adaptation

Group-level target status

The Company is currently evaluating its strategic direction on climate action and will engage further assessments to determine an updated target that aligns with evolving scientific and regulatory requirements, industry standards, corporate sustainability goals and profitability assessments. Hence, at present, the Company does not have a climate target that fulfils the requirements set out by the ESRS at a Group level.

Subsidiary-level targets

However, the Company continues to track its carbon efficiency at a subsidiary level:

Climate change adaptation target

A climate change adaptation target has not been set at this time.

Target validation

The targets are not described as science-based or externally validated (e.g., SBTi). The policy references the IPCC target of limiting global warming to 1.5°C and engagement with the Carbon Disclosure Project (CDP).

Key decarbonization actions supporting targets

• Fleet renewal: 45% carbon intensity reduction target to be supported by 20% SAF blend, provided Norwegian operates a fleet of only MAX8s and average SAF life-cycle emission reduction is 80%
• Data-driven fuel saving: Aims to improve carbon efficiency by 2% by 2030 (2010 baseline)
• Operational efficiency: Aims to improve carbon efficiency per RPK by 3% by 2030
• SAF commitment: 15% SAF blend for Norwegian Armed Forces contract (2024-2028)

Energy consumption and mix

Total energy consumption and mix (2024)

The Company's energy consumption consists of crude oil and petroleum products and purchased or acquired electricity, heat, steam and cooling from fossil sources. In 2024, the Company's total energy consumption was 9,556,388 MWh.

Energy intensity

The Company's energy intensity was 271 MWh per million NOK revenue in 2024. The figure for net revenue used in the presentation of this metric can be found in the Financial Statements and the line item total operating revenue.

Methodology and scope

Energy consumption from non-renewable sources includes all fossil fuels used in aircraft, Company vehicles and ground services.

Energy consumption from renewable sources including biomass: Energy consumption from renewable sources includes SAF (sustainable aviation fuel).

Consumption of purchased or acquired electricity, heat steam and cooling from renewable sources: The Company reports consumption of purchased electricity, heat steam and cooling through invoices and leases. Where invoices are not available, estimations are made based on leased area and statistics on electricity consumption. Where estimation has been used, potential consumption of heat sources has been excluded due to lack of statistics and data.

Scope: The Company accounts for all emissions from operations under its control and has adopted the operation control approach. The reporting considers energy consumption in the Company's own operations.

All revenue is reported as generated from a high climate impact sector. This is reflected in the reported energy intensity and GHG intensity.

Gross Scopes 1, 2, 3 and Total GHG emissions

Scope 1 GHG emissions

Gross Scope 1 GHG emissions were 2,446,900 tCO₂eq in 2024, compared to 2,043,316 tCO₂eq in 2023, representing a 19.8% increase.

Percentage of Scope 1 GHG emissions from regulated emission trading schemes: 87.8% in 2024.

Scope 1 emissions are generated from direct consumption of aviation fuel to power the Company's aircraft (99%), with a minor fraction (1%) from consumption of other fuel and energy sources for ground operations equipment and activities.

Scope 2 GHG emissions

Scope 2 emissions are associated with the indirect production and transmission of electricity and district heating purchased by the Company for heating offices, hangars, powering equipment and associated activities.

Scope 2 methodology: Emissions are calculated using actual energy consumption or estimated based on statistical data for sites where consumption figures are unavailable. Conversion factors from EIA, AIB, and Fjernkontrollen were used. The location-based method was utilised as Guarantees of Origin (GoO) were not purchased.

Scope 3 GHG emissions

Total Gross indirect (Scope 3) GHG emissions were 532,146 tCO₂eq in 2024, compared to 442,655 tCO₂eq in 2023, representing a 20.2% increase.

Scope 3 emissions by GHG Protocol category:

Scope 3 category exclusions:

The Company excluded several Scope 3 categories based on relevance, materiality, or coverage under Scope 1 and 2:

• Category 2 (Capital goods): Primarily spare parts and equipment; emissions estimated as immaterial relative to total Scope 3.
• Category 4 (Upstream transportation): Transport primarily using Company's own aircraft (covered in Scope 1/Category 3); other services result in negligible emissions.
• Category 6 (Business travel): Employees primarily travel on Company's own flights (Scope 1/Category 3); other travel very limited and immaterial.
• Category 7 (Employee commuting): Assessed as immaterial except crew positioning (accounted for elsewhere).
• Category 8 (Upstream leased assets): Leased aircraft and ground vehicles under operational control (reported in Scope 1 and 2); other leased equipment immaterial.
• Categories 9-14: Not applicable to the Company's transport service provider business model.
• Category 15 (Investments): Investments in early-stage companies (Norsk e-Fuel AS, Spenn Group AS) generate very limited operational emissions; deemed immaterial.

Scope 3 methodology: Emissions calculated using spend-based method or estimates. No primary data obtained from suppliers and value chain partners. Category 3 uses activity data from Scope 1 and 2 with upstream/WTT emission factors from DEFRA and IEA. Category 1 includes glycol, inflight goods, and store items using emission factors from AGRIBALYSE 3.1, CONCITO, CEMAsys, and Ecoinvent 3.11. Category 5 (waste) uses DEFRA factors.

Total GHG emissions

Note: The increase in total GHG emissions from 2023 to 2024 is largely due to the acquisition of Widerøe.

Biogenic emissions

Biogenic CO₂ emissions from the combustion of Sustainable Aviation Fuel (SAF) were 14,913 tons in 2024.

GHG intensity based on net revenue

The Company's GHG emission intensity was:

• 84.4 tCO₂eq per MNOK revenue (location-based) in 2024
• 84.6 tCO₂eq per MNOK revenue (market-based) in 2024

The figure for net revenue used is the line item "total operating revenue" from the Financial Statements.

Methodology and boundaries

GHG accounting boundaries: The Company accounts for all emissions from operations under its control and has adopted the operational control approach. No significant exclusions for Scope 1, 2, or 3. The Company uses ESRS and the GHG Protocol to calculate emissions. Emissions are calculated using the 100-year Global Warming Potential (GWP) from the IPCC Assessment Reports.

Greenhouse gases covered: CO₂, CH₄ (methane), N₂O (nitrous oxide), SF₆, HFCs, PFCs and NF₃, all converted into CO₂-equivalents.

Scope 1 emission factors: DEFRA emission factors for fuel combustion in Company vehicles, ground services and jet fuel consumption, and combustion of CH₄ and N₂O from SAF.

Scope 2 emission factors: EIA, AIB, and Fjernkontrollen conversion factors. Consumption reported through invoices and leases; where unavailable, estimated based on leased area and statistics.

Scope 3 emission factors: DEFRA, IEA (Category 3); AGRIBALYSE 3.1, CONCITO, CEMAsys, Ecoinvent 3.11 (Categories 1 and 5).

Uncertainty: Scope 3 methodology involves estimation using spend-based approach and introduces a degree of uncertainty, though figures are considered reasonably accurate. Scope 2 estimations where invoices unavailable are assumed relatively accurate.

Regulated emissions: 87.8% of Scope 1 emissions in 2024 were from flights covered by EU ETS, CH ETS or UK ETS.

Fuel conversion: Fuel reported in litres was converted using density values from the ASTM standard D1655.

Anticipated financial effects from material physical and transition risks and potential climate-related opportunities

Use of phase-in exemption

Due to the level of relative uncertainty in various climate risk scenarios, meaningfully anticipating the financial effects of such risks is inherently difficult. Therefore, the Company has chosen to utilise the phase-in provision to exclude the financial effects of material physical and transition risks, as well as potential climate-related opportunities, as outlined in E1-9.

Voluntary disclosure: SAF blending regulations

However, insight into the anticipated financial effects for SAF blending regulations is voluntarily provided. The Company is mainly operating within the European Union, the European Economic Area and the United Kingdom. As such, the majority of fuel consumption is subject to fuel blending mandates. These include a requirement of 2% SAF fuel blend for defined EU airports in 2025 and 6% SAF fuel in 2030.

Estimates of the future added cost from SAF fuel carry a high degree of uncertainty, but the Company estimates that fuel costs could increase by 3-8% percent in 2025 and 9-24% in 2030, compared to a scenario with no SAF blend.

Policies related to own workforce

Norwegian Air Shuttle discloses three named policies related to its own workforce.

Global People Policy

Policy name: Global People Policy

Scope:

• Applies to the Company's own operations, covering all employees and temporary workers in Norway, Sweden, Denmark, Finland, Latvia, Spain, Ireland and the UK
• Excludes contractors (focused on employees and contractors as primary stakeholder groups)
• Addresses all material impacts, risks and opportunities (IROs) relating to the Company's own workforce

Key content and principles:

• Outlines the Company's commitment to fostering an inclusive, safe and respectful work environment for employees
• States the Company's respect and general approach to fostering and protection of Human Rights, including alignment with internationally recognised Human Rights instruments
• Key objectives include promoting diversity and inclusion, maintaining workplace health and safety, and addressing employee well-being through supportive policies and procedures
• Highlights proactive approach to employee engagement and development, with inclusion, safety and wellbeing as core components of operational priorities
• Specifically addresses human rights issues associated with human trafficking; forced, compulsory and child labour

Governance and accountability:

• The Chief People Officer (CPO) is accountable for the implementation of this Policy, supported by senior management, who oversees specific actions and initiatives related to gender diversity and equal pay, health and safety and working conditions

Links to international standards:

• Commits to align with and respect international frameworks, including:
  • UN Declaration of Human Rights (and UN Guiding Principles on Human Rights)
  • ILO Core Conventions
  • UN Global Compact
  • Norwegian Transparency Act
  • ILO's Declaration on Fundamental Principles and Rights at Work

Stakeholder engagement:

• Considers employee interests by promoting diversity and inclusion, prioritising health and safety, accommodating suitable working conditions and providing mechanisms for raising concerns
• Regular engagement with employees, employee representatives and Work Environment Committees (WECs) aims to ensure that stakeholder input is considered in the Policy's development and implementation

Public availability:

• Communicated to employees during onboarding and through internal communication platforms (onboarding, employee handbook, training and intranet)
• Employees are encouraged to familiarise themselves with the Policy and use established channels for raising concerns or reporting issues
• External stakeholders are provided with the Policy as and when required

Monitoring implementation:

• Monitoring includes regular health, safety and environment (HSE) assessments, annual audits and employee feedback mechanisms, such as surveys and Work Environment Committees (WECs), to track employee well-being and safety performance

Equity, Diversity and Inclusion Policy

Policy name: Equity, Diversity and Inclusion Policy

Scope:

• Applies to management, all employees, candidates/applicants for employment and certain third parties, including vendors, that can be affected because of their relationship with the Company
• Covers all aspects of the employment relationship, including recruitment and selection, training, promotion and career advancement, remuneration and working conditions

Key content and principles:

• Describes the Company's commitment to equity, diversity and inclusion
• Specifies the Company's expectations and approach as well as focus areas
• States that the Company will not unlawfully discriminate based on any social identity such as gender, age, culture, nationality, ethnicity, physical abilities, political and religious beliefs, sexual orientation, or other attributes
• Directly applies to the IROs of gender diversity and equal gender pay

Governance and accountability:

• The Chief People Officer (CPO) is responsible for the Policy and consults with employees, employee representatives and other relevant stakeholders in its development and monitoring

Monitoring implementation:

• Implementation of the Policy is regularly reviewed with specific monitoring of key Policy outcomes
• In relation to the relevant IROs, the Company monitors and reports on remuneration and compensation practices on an annual basis
• This process is used to identify areas of potential concern in terms of equal pay and to put in place remedial measures when deemed appropriate and consistent with applicable law
• The Company also monitors employment practices for equal opportunity and non-discriminatory compliance

Communication:

• The Company's objective is to ensure that management and employees are aware of the Company's commitment to equal opportunities, non-discrimination, diversity and inclusion
• To increase and broaden awareness, the Company prominently displays its equal opportunity policies for all employees, including on relevant internal communication channels, within employee handbooks and manuals, as well as in training sessions

Health, Safety, and Environment Policy (HSE Policy)

Policy name: Health, Safety, and Environment Policy (also referenced as "HSE Policy" and "Corporate Safety Statement")

Key content and principles:

• Emphasizes employee well-being and mental health support
• Outlines the Company's commitment to workplace safety and employee well-being
• Sets out the Company's commitment to operational safety and risk management
• Addresses safety procedures followed by the Company's employees that affect both crew and passengers on flights (relevant for consumers and end users as well as employees)

Governance and accountability:

• The Chief Customer and Corporate Affairs Officer (CCCPAO) is responsible for implementing this policy

Monitoring:

• The Company constantly monitors its health and safety performance, including contributory factors and the measurement of health and safety KPIs
• Number of harassment incidents across all client-facing roles are recorded via the Company's safety management system

Taking action on material impacts on own workforce

The Company assesses actions needed for negative impacts on own workforce on a case-by-case basis, considering the impacted stakeholder, significance of impact, and nature of impact. The Company is not aware of any own practices that cause or contribute to material negative impacts on own workforce.

Resources allocated: The Company utilizes existing resources and expertise in implementation of actions and has not allocated additional resources beyond this for managing material impacts, risks, and opportunities related to its own employees.

Gender diversity and equal pay

Unequal pay actions

Actions taken in 2024 to prevent or mitigate negative impacts from unequal pay, aligning with the Company's Equity, Diversity, and Inclusion Policy and Global People Policy:

• Local pay structure review: Regular pay audits undertaken at least annually to identify and address possible disparities. The Company is preparing for the EU Pay Transparency Directive by conducting preliminary assessment of salary structures for office staff across regions, identifying areas for potential improvement.

• Monitoring regulatory developments: Tracking upcoming EU Pay Transparency Directive requirements, such as salary disclosure practices and employee rights to request pay information, to evaluate adjustments needed for future compliance.

• Awareness and communication: The Company is currently developing a strategy to increase awareness among office staff about local pay structures, factors influencing compensation and the Company's commitment to fair pay. This may include informational updates or sessions to address questions and improve understanding. In 2025, the Company is establishing remuneration policy and procedures for employees with individual set salaries. Efforts are also being made to raise awareness about the equality policy commitments and other relevant criteria in the remuneration system.

Monitoring: Actions are tracked and assessed through annual compensation review and reporting of gender-based employment and remuneration figures (see S1-6 and S1-16).

Gender imbalance actions

Actions taken in 2024 to prevent or mitigate negative impacts from gender imbalance, aligning with the Company's Equity, Diversity, and Inclusion Policy and Global People Policy. [Details not fully provided in excerpt]

Health and safety

Passenger violence and harassment actions

[Details not provided in excerpt]

Psychological health impact management actions

Ongoing actions to prevent and address psychological health impacts to employees, aligning with the Company's HSE Policy which emphasizes employee well-being and mental health. [Details not fully provided in excerpt]

Targets related to own workforce

Gender diversity and equal pay targets

The Company continues to pursue its gender diversity and equal pay targets in line with its own workforce policies. The Company engages with its own workforce through union representatives and WECs in target setting and tracking, including the identification of performance improvement opportunities. These targets were originally set and reported in 2023. With the acquisition of Widerøe, the base year for all targets has been revised to 2024.

Health and safety targets

The Company has set two annual health and safety targets in line with its Corporate Safety Statement and Health and Safety Policy:

Working hours and crew housing targets

No specific targets for working hours and crew housing have been set at this time. The Company continues to focus on legal compliance, impact and risk reduction.

At year-end 2024, the Norwegian Group had 8,754 employees at its headquarters, support offices, and operational bases across Norway, Sweden, Denmark, Finland, Spain, Latvia, UK and Ireland. Of the employees in the Group, 5,179 were employed by Norwegian, and 3,575 were employed by Widerøe. Figures include apprentices and temporary employees in administrative positions.

Characteristics of non-employees in the undertaking's own workforce

Scope and definition

The Company defines its own workforce as all registered employees of the Company, including contractors that operate in vacancies or roles that otherwise would be filled by own employees and where they for all intents and purposes are operating under the same instructions as an employee. All other workers are considered workers in the Company's value chain.

Quantitative disclosure

No specific quantitative data on the number, breakdown by type (contractor, agency, self-employed), or counting methodology (headcount vs FTE) for non-employee workers is disclosed in the sustainability statement.

The Company states that contractors operating in vacancies or roles that would otherwise be filled by employees are included in the definition of own workforce and are covered by the Global People Policy and other workforce policies. However, the actual number of such contractors is not reported.

Policy coverage

The Global People Policy applies to "all employees and temporary workers in Norway, Sweden, Denmark, Finland, Latvia, Spain, Ireland and the UK" and covers contractors as primary stakeholder groups. The Grievances Policy encompasses "all employees, contractors and other stakeholders directly involved with the Company."

During 2024, we concluded several key collective bargaining agreements. While these agreements resulted in increased personnel cost across several markets, they also provide improved visibility for 2025 with a reduced risk of industrial action.

In June, Norwegian reached an agreement for a new collective bargaining agreement (CBA) with the Norwegian Pilot Union (NPU). Also in the second quarter, Norwegian and Widerøe reached agreements on new collective bargaining agreements (CBAs) with most pilots across the Group, as well as with cabin crew and technicians in certain areas, along with new ground handling and other relevant union agreements throughout the Group. The new agreements helped ensure that the airlines avoided major disruptions during the important peak summer travel season.

Diversity metrics (S1-9)

Executive Management Team Gender Diversity

The percentage of women in the Executive Management Team of the Company is 25%.

Age Band Distribution of Workforce

Gender Pay Gap Context

The gender pay gap at the Company is significantly influenced by the percentage of male pilots (94%), which is a relatively higher paying role than other roles within the Company. Approximately 82% of employees are paid according to pay scales regulated by CBAs. Given the same role and seniority there are no differences in salary between male and female employees paid according to pay scales.

Note: The company states that separate descriptions of diversity in the Executive Management Team and the Board are provided in ESRS2 and description of own workforce in S1-6 (not included in these excerpts).

Adequate wages

All staff at the Company are paid an adequate wage based on the collective bargaining agreements in place for their respective roles and the EU Directive 241.

No living wage benchmark (e.g., Fair Wage Network, WageIndicator, Anker Methodology, or Global Living Wage Coalition) is disclosed. The company references compliance with collective bargaining agreements and EU Directive 241, but does not specify whether employees are assessed against a living wage standard that covers basic living needs for workers and their families in the local context.

No coverage percentage, geographic scope, targets, or methodology for living wage assessment is provided.

Health and safety metrics

The Company constantly monitors its health and safety performance, including contributory factors and the measurement of health and safety KPIs.

Additional context:

• Norwegian Group had no fatal accidents or critical personnel injuries in 2024.
• The Company sets annual health and safety targets: Zero Serious Accidents and Zero Fatalities.
• Number of days lost to injuries, accidents, fatalities or illness is not reported separately in the metrics table.
• Sick leave absenteeism rate for 2024 was 7.14% (7.11% during peak season April-October).

Calculation methodology: The rate of recordable work-related accidents is calculated as the number of work-related accidents reported in the safety system divided by the million hours worked by the employee base.

Work-life balance metrics

Work-life balance satisfaction scores (2024)

The Company uses work-life balance scores from the People Engagement Survey as a KPI to measure employee satisfaction with work-life balance and workload. Results are reported as percentage scoring positive or neutral:

Family-related leave metrics

No specific metrics on family-related leave entitlement, uptake rates by gender, or return-to-work rates after parental leave were disclosed.

Work-life balance initiatives

The Company has established:

• Flexible Workplace Guidelines allowing office employees to work from home up to two days per week (excludes operational staff such as flight crews and ground personnel)
• Work Life Balance Action Group for Crew consisting of representatives from all bases and ranks, management representatives and the internal LEAN team, initiated in 2024 to create an action plan and develop KPIs
• Information provided on voluntary reduction of working hours when operations allow, and the right to apply for reduced working hours due to young children (subject to local legal requirements)
• Core working hours from 09:00 to 15:00 for office employees

Related housing and working conditions reporting

Number of reports related to housing conditions and housing issues impacting crew in 2024: 99

Note: The Company monitors work-life balance primarily through engagement surveys. Approximately 82% of employees are paid according to collective bargaining agreements.

Compensation metrics (ESRS S1-16)

Pay gap

The average wage of a female employee was approximately 42% lower than the average male employee's remuneration across all employees.

The gender pay gap at the Company is significantly influenced by the percentage of male pilots (94%), which is a relatively higher paying role than other roles within the Company. Approximately 82% of employees are paid according to pay scales regulated by CBAs. Given the same role and seniority there are no differences in salary between male and female employees paid according to pay scales. For the remaining 18% of the workforce, salaries are set according to the Korn Ferry Hay Methodology to provide structure and fairness in the process of setting salaries. During annual reviews some differences were identified and corrected during 2024.

The Company will undertake an audit focusing on equal pay and gender gaps during 2025 as part of preparing for the upcoming EU Pay Transparency Directive.

Remuneration ratio

The ratio of CEO to median pay is 11.66:1.

The percentage of women in the Executive Management Team of the Company is 25%.

Methodology

Gender pay gap calculation: The gender pay gap is calculated by subtracting the average salary of all female workers from the average salary of all male workers, divided by the average salary of male employees, multiplied by 100. The average salary is based on the employees' monthly base salary and adjusted to a 100% employment, without accounting for job roles or experience.

Total remuneration calculation: The total remuneration is calculated as the CEO's annual fixed salary divided by the median annual fixed salary for all employees (excluding the CEO). Variable compensation is not included to simplify the calculation. The Company assess that the variable compensation as a fraction of fixed salary would be similar and have limited effect on the calculation.

The metrics presented have not been validated by an external body.

Incidents, complaints and severe human rights impacts

Human rights issues and discrimination incidents

In 2024, no severe human rights issues occurred in the Company's own workforce and there were no issues or incidents that are cases of non-respect of UN Guiding Principles and OECD Guidelines for Multinational Enterprises.

A total of five complaints regarding discrimination or harassment were recorded either via the Company's complaint channels (see grievance mechanisms described in the Grievances Policy) or from other processes in the Company.

No cases resulted in legal proceedings where fines or penalties were issued against the Company.

Two cases are ongoing.

Potential compensation, if any, is not considered material in relation to its requirement for disclosure in the annual financial accounts.

Methodology

Defining complaints as discrimination or harassment is done by using Company and other relevant guidelines on a case by case basis and will be dependent on the relevant circumstances.

Norwegian's objective for Corporate Governance is accountability, transparency, fairness and simplicity with the goal of maximizing shareholder value while creating lasting value for all stakeholders. The objectives are designed in compliance with laws, regulations and ethical standards.

The Company's core values are clearly defined and are reflected in the Corporate Code of Business Ethics and Conduct ("The Code"). The Code includes ethical guidelines and guidelines for corporate social responsibility, hereunder bribery and anti-corruption, unlawful discrimination and human rights, health, safety and environmental issues.

Good corporate governance is a key priority for the Board of Directors of Norwegian Air Shuttle. The Norwegian Group's objective for corporate governance is based on accountability, transparency, fairness, and simplicity with the goal of maximising shareholder value and creating lasting value for all stakeholders. The principles are designed in compliance with laws, regulations, and ethical standards. Norwegian's vision is to be the most loved and trusted airline in Europe, but no business conduct, within the Group, should under any circumstances jeopardise safety and quality.

The Company's core values are clearly defined and are reflected in the Corporate Code of Business Ethics and Conduct ("The Code"). The Code includes ethical guidelines and guidelines for corporate social responsibility, hereunder bribery and anti-corruption, unlawful discrimination and human rights, health, safety and environmental issues.

Incidents of corruption or bribery

Confirmed incidents

The Company reported zero confirmed incidents of corruption or bribery in 2024. As stated in the Sustainability Statement:

"There have been no reported incidents of corruption or bribery at the Company in 2024."

Convictions and fines

No employees were convicted and no fines were levied on the Company:

"Consequently, no employees have been convicted, nor have any fines been levied on the Company."

Additionally, the Company disclosed:

"...no public legal proceedings related to bribery or corruption have been initiated against the Company, its subsidiaries or its employees during this period."

Disciplinary actions

No corrective actions or disciplinary measures were necessary as a result of corruption or bribery incidents:

"As a result, no corrective actions have been necessary."

Contracts terminated

Not disclosed.

Investigation and speak-up procedures

The Company maintains comprehensive anti-corruption procedures and whistleblowing mechanisms:

Whistleblowing system: The Company operates a whistleblowing mechanism available to all employees, affiliates and anyone associated with the Company, with anonymous reporting available via the Company's intranet. In 2025, the mechanism will be made accessible externally via the Company's website. The system adheres to EU Directive 2019/1937 and the Norwegian Working Environment Act.

Whistleblower protection: The Company has implemented measures to safeguard whistleblowers against retaliation, including protection from disciplinary actions, harassment, discrimination or other adverse consequences. Retaliation is explicitly prohibited.

Investigation process: A whistleblowing committee, set up by the Chief People Officer, handles all cases in a fair, prompt and proper manner. A whistleblowing investigator is appointed case-by-case to ensure independence and impartiality. During active investigations, the investigator reports regularly to the whistleblowing committee chairperson. The committee provides quarterly summary reports to the Audit Committee.

2024 whistleblowing activity: A total of 35 whistleblowing reports were made in 2024. All cases were handled and resolved according to the Company's Whistleblower Policy and procedures. However, specific breakdown by type (corruption, discrimination, etc.) was not provided for most reports.

Human rights and discrimination complaints: The Company noted that five complaints regarding discrimination or harassment were recorded through complaint channels or other processes. No cases resulted in legal proceedings with fines or penalties. Two cases were ongoing at year-end. The Company stated these issues were not cases of non-respect of UN Guiding Principles and OECD Guidelines for Multinational Enterprises.

Training: Anti-corruption and business conduct training is being made mandatory for all employees in 2025, integrated into the onboarding process. High-risk functions (corporate finance team handling aircraft purchases, payment team handling credit card contracts, procurement team handling large purchase agreements) receive specific anti-corruption training covering how to identify and handle situations involving corruption, such as offers of private services or kickbacks. The Company aims for 100% coverage of employees within higher-risk functions.

Prevention procedures: The Corporate Code of Business Ethics and Conduct and Financial Crime Policy establish strict prohibitions against offering, accepting or requesting improper advantages. All employees are required to avoid conflicts of interest and report suspicions through established whistleblowing channels.

Political influence and lobbying activities

Political engagement approach

The Company engages with government representatives, politicians, civil servants and industry association representatives to advocate for fair and effective aviation policies. All advocacy efforts are coordinated by the Public Affairs team, which aims to ensure compliance with applicable laws and ethical standards. Employees involved in governmental relations and regulatory affairs must adhere to the established guidelines, maintaining integrity and transparency in all interactions.

The Company works to influence regulatory outcomes in areas critical to its operations through public affairs activities. The Company is committed to engaging with external stakeholders—including media, governments, policymakers and the public—with transparency, ethics and responsibility based on democratic principles and processes.

The Company's approach to public affairs is structured to maintain credibility and compliance with relevant laws. The Communications and Public Affairs Policy establishes clear protocols for engaging with government agencies, media outlets and industry stakeholders, with the aim to ensure that all communications are factual, consistent and transparent. Additionally, it safeguards the Company's reputation by preventing unauthorised or misleading representations of the Company in public discourse.

The CEO is ultimately responsible for the management of any public affairs activity undertaken by the Company and may from time to time delegate this authority. The Board maintains oversight of the Company's public affairs activity, including political engagement and has the responsibility for ensuring that those activities comply with all relevant Company policies and applicable laws and regulations.

Ethical standards and guidelines

Any public affairs activity must be pre-approved by the Public Affairs team to prevent potential conflicts of interest or regulatory breaches. Employees are not permitted to engage with government representatives, politicians, civil servants, or industry association representatives on behalf of the Company without prior approval from the Public Affairs team. Any statement made on behalf of the Company must be transparent, accurate and aligned with the Company's corporate messaging.

The Communications and Public Affairs Policy provides specific guidelines on communications and public affairs efforts on behalf of the Company, worldwide. The Policy is included in the employee handbook, notified to all new employees in their onboarding and training, and is also available on the Company's intranet. The Policy is shared with affiliates as and when required.

This policy applies to all employees of the Company and its subsidiaries, as well as agents, representatives and affiliated service providers engaged in communications and public affairs on behalf of the Company.

Any violation of the Communications and Public Affairs Policy must be reported through the Company's Whistleblowing Procedure. Policy breaches will be investigated under the oversight of the Board and the Chief Legal Officer. Employees found in violation may be subject to disciplinary action, including termination, depending on the severity of the breach.

Political contributions

The Company does not directly or indirectly provide any political funding or make any direct or indirect or in-kind political donations. Employees are prohibited from offering gifts, incentives, or payments to influence public officials.

The Company did not provide any political funding or made any direct, indirect or in-kind political donations in 2024.

Lobbying activities

There are no members of the Company's administrative, management and supervisory bodies who held comparable positions in public administration in two years preceding such appointment.

The Company had no reported incidents of unethical public affairs engagements in 2024.

EU Transparency Register

The Company is registered in the EU Transparency Register, (Norwegian Air Sweden AOC AB), with registration number 48827.

Advocacy topics

In the CEO letter, Norwegian describes its active advocacy on sustainable aviation fuel initiatives:

• Norwegian is actively advocating for Nordic regulators to further strengthen the environment and framework for sustainable fuel initiatives, noting that "with the right support, the goals set in RefuelEU can be achieved through a significant boost in the production of biofuels and electrofuels moving forward."

• In October 2024, Norwegian celebrated the first flight with biofuel on the Norwegian defence sector's corporate travel contract, which was described as "the largest voluntary biofuel agreement in Norway's history, and amongst the first of its kind with NATO countries."

• Norwegian was recognised by EU advocacy group Transport & Environment for its work in promoting production and use of SAF. In their yearly SAF observatory Norwegian was among the top three airlines in the world.

• The Norsk e-Fuel project continues to progress, and Norwegian is actively advocating for Nordic regulators to further strengthen the environment and framework for sustainable fuel initiatives.

Recognition

For 2024, Norwegian maintained the company score in the global climate ranking done by Carbon Disclosure Project (CDP). Norwegian received an overall score of B and the highest possible scores in categories for environmental policies, public policy engagement and industry collaboration.

Payment practices

Payment terms and performance

The Company follows standard payment terms for most of its suppliers. However, payment terms vary across countries and supplier types based on individual negotiations with each supplier. There are no specific or unique supplier payment terms for SMEs.

The Company treats its suppliers in accordance with the legally binding contract they have with each individual supplier and any relevant laws or regulations. The Company's current approach to preventing late payments is that all supplier invoices are paid based on the terms set in the contracts and in the vendor letters.

2024 payment performance:

For the remaining 30% of invoices settled after the due date, payment timing is influenced by operational factors common in large-scale invoice processing. This includes industry-standard batch payment schedules, additional validation steps when required and occasional delays in invoice receipt or approval processes.

Legal proceedings

There are no outstanding legal proceedings for late payments.

Actions to improve payment practices

To further improve its payment practices, the Company has implemented AI based invoice processing system to minimise errors and reduce delays and to follow up on process KPIs on a monthly basis.

In 2025, the Company is committed to developing a formal group-wide Procurement Policy to regulate payment terms, which will improve clarity and efficiency in financial transactions. To keep continuity and quality within its supply chain the Company aims to treat its suppliers fairly and transparently.

Accounting policies

The data is collected from the invoices processed in ERP systems and calculated from the average for all invoices. The metrics presented have not been validated by an external body.