Odfjell Drilling

Norway|Oil & Gas – Services|FY2024|Auditor: Unknown

ESRS 2General Disclosures

GOV-1The role of the administrative, management and supervisory bodies
Reported

The Group's governance framework ensures effective oversight of sustainability-related IROs. The Board holds ultimate accountability for integrating sustainability into corporate strategy and decision-making, including:

• Policy development and oversight • Risk management and internal controls • Performance monitoring to align with evolving regulatory requirements and best practices

The Audit Committee, in coordination with the Board, reviews sustainability performance on a quarterly basis, with additional meetings as necessary. The Board receives regular updates and discusses material sustainability matters, ensuring that relevant expertise is leveraged across the organisation. Employee representation is only in Norwegian subsidiaries.

The governance model embeds sustainability oversight through clearly defined responsibilities across the organisation (see Figure 1: Sustainability Organisational Structure). Dedicated internal controls and procedures are integrated with Enterprise Risk Management (ERM) systems.

The Board and Executive Management Team (EMT) possess the necessary skills and expertise to oversee sustainability matters, including climate risk, decarbonisation, pollution control, and employment practices. Targeted training and development programmes are implemented to address competency gaps as needed.

The Board consisted of two independent non-executive directors and two non-executive directors, one of which is also the largest beneficial shareholder and one which has been employed in the Group in a senior position in the last five years. All the shareholder-elected members of the Board are independent of the Group's Executive Management and three are independent of the Company's major shareholder.

As of 31 December 2024 the Board consisted of 75% males and 25% females, and three of the directors were UK resident. They possess the relevant expertise, capacity and diversity as set out in the Code and are elected on an annual basis at the Annual General Meeting, except for vacancies, which may be filled by the Board.

GOV-2Information provided to and sustainability matters addressed by the undertaking's administrative, management and supervisory bodies
Reported

The Board and its committees are systematically informed about sustainability-related IROs. This includes due diligence implementation, policy effectiveness, risk mitigation, and progress on sustainability targets, metrics, and initiatives, aligned with ESRS.

The Vice President (VP) of Sustainability, in collaboration with corporate functions, provides periodic updates to the Board and the EMT, ensuring the integration of sustainability into business strategy and risk management processes.

The Audit Committee reviews quarterly and annual sustainability reports, ensuring compliance with regulatory standards and strategic objectives. External third-party representatives contribute to discussions where relevant. The annual DMA is reviewed by the Audit Committee before being approved by the Board.

Sustainability risks and opportunities are embedded in the Board's strategic oversight, major transaction decisions, and ERM processes. The Enterprise Risk Register systematically reports significant sustainability risks to the Board, ensuring that emerging and material risks are identified and addressed at the highest governance level.

GOV-2(was GOV-3)Integration of sustainability-related performance in incentive schemes
Reported

The variable remuneration criteria include strategic targets including emissions reduction and Quality, Health, Safety, Security and Environmental (QHSSE) targets and performance. See the Executive Remuneration Report for more information on the incentive schemes.

Key events affecting remuneration: The 2024 EBITDA of USD 345 million reflects the ongoing cost discipline and efficient operations being delivered by the Group. QHSSE performance saw further reductions in the total number and rate of recordable incidents and the dropped objects > 40 joule frequency. Progress continues in moving towards our net zero emission targets. Through collaboration, employee engagement and communication, and optimal resource management, the Executive Management have delivered a successful year for the Group. For these reasons, the Board approved the payment of bonuses for 2024.

GOV-3(was GOV-4)Statement on due diligence
Reported

In line with the adaptation to the CSRD and the ESRS, the Group has restructured its sustainability reporting. The corresponding accounting principles describe whether practices have changed, potential sources of measurement uncertainty, value chain assumptions, estimates or in the event errors have occurred since the prior reporting period.

The statement has been subjected to limited assurance by the external Group auditor.

Following the Group's partial pre-implementation of the CSRD in 2023, the internal control systems have been expanded and developed to encompass the full scope of our sustainability reporting.

To enhance the reliability of sustainability reporting, the Group conducts regular internal reviews and independent third-party verification of key sustainability disclosures. The sustainability reporting framework is aligned with financial internal controls and risk management principles, following the COSO framework and ISO 31000 risk management guidelines. Additionally, an annual internal audit of sustainability-related processes is conducted to ensure accuracy and completeness of reporting.

GOV-4(was GOV-5)Risk management and internal controls over sustainability reporting
Reported

Following the Group's partial pre-implementation of the CSRD in 2023, the internal control systems have been expanded and developed to encompass the full scope of our sustainability reporting.

To enhance the reliability of sustainability reporting, the Group conducts regular internal reviews and independent third-party verification of key sustainability disclosures. The sustainability reporting framework is aligned with financial internal controls and risk management principles, following the COSO framework and ISO 31000 risk management guidelines. Additionally, an annual internal audit of sustainability-related processes is conducted to ensure accuracy and completeness of reporting.

To support a structured and standardised approach to risk management, the organisation applies the International Organisation for Standardisation (ISO) 31000 framework, which guides the identification, evaluation, mitigation, and escalation of sustainability-related risks. This approach is reinforced through task-based assessments and climate risk evaluations, conducted at both operational and strategic levels to proactively assess and mitigate potential sustainability risks.

Additionally, the Corporate Risk Committee (CRC) plays a critical role in risk governance, ensuring that high-value tenders and contracts undergo thorough risk assessments. These assessments consider both financial and non-financial impacts, including integrity risks, to ensure that sustainability considerations are fully integrated into decision-making and long-term business strategy. Risk is also managed through internal audits and lessons learned reviews to ensure compliance, improve our practices, and enhance control measures.

SBM-1Strategy, business model and value chain
Reported

Strategy, business model and value chain

Business model overview

With over five decades of experience and expertise from operations across the globe, Odfjell Drilling offers a state-of-the-art fleet of semi-submersible Mobile Offshore Drilling Units (MODUs).

The Group has two main business segments: Own fleet and External fleet, with operational management in Norway, the UK, and Malta.

The Group creates value by operating MODUs efficiently and safely, impacting hydrocarbon production and CO2 storage developments for Exploration and Production (E&P) companies. Contracts include a fixed day rate for providing production facilities, asset hire, exploration drilling, Plug and Abandonment (P&A), and an operating fee. Different E&P clients influence drilling operations, leading to individualised procurement for each rig. Odfjell Drilling holds a key role in the upstream value chain but has limited control over IROs as dictated by the licence holder, the E&P operator under contract.

Products, services and markets

Our activities encompass the management and operation of MODUs. The total revenue in 2024 was USD 775 million whereof USD 769 million was from the oil and gas sector, and USD 6 million taxonomy-aligned from the waste treatment and disposal sector from CO2 storage activities.

Key markets: The Group's activities are located in the upstream value chain for the oil & gas sector, during exploration and development phases of the energy production cycle. This includes the field decommissioning stage, including the subsequent redeployment or recycling of our owned MODUs. As of 2024, the Group had activities in the downstream value chain for the Carbon Capture and Storage (CCS) sector. Deepsea Stavanger drilled one appraisal well on the Smeaheia field on the NCS. Our fleet can conduct exploration, development drilling, and P&A of CO₂ storage wells.

Sustainability goals embedded in business model

The Group prioritises operational efficiency while enabling emission reductions in line with operator and regulatory requirements, ensuring sustainable and cost-effective operations for clients and stakeholders. Sustainability-related goals, actions and elements of the strategy that relates to or impact on sustainability matters are outlined in respective sustainability topics reporting.

Value chain description

Oil & gas value chain positioning: As illustrated in figure 3, the oil and gas sector is divided into upstream, focusing on exploration and production; midstream, handling processing, transportation and storage; and downstream, covering refining and distribution of end products. The Group's activities are located in the upstream value chain for the oil & gas sector, during exploration and development phases of the energy production cycle.

Carbon Capture and Storage value chain positioning: As of 2024, the Group had activities in a new value chain, in particular, the downstream value chain for the Carbon Capture and Storage (CCS) sector.

Upstream value chain: The upstream value chain are suppliers and sub-suppliers delivering products and services necessary to conduct the drilling operations. This includes all direct suppliers and sub-suppliers of equipment, software, office space, drilling control systems, Remote Operating Vehicles (ROVs), operational technology and navigation. It further includes contracted services and support activities such as human resources, supply chain management, agents, consultants, cleaning services, and food and catering. The Group also use transportation services to ship equipment to the desired location. This upstream value chain is neutral in regards to the oil & gas and CCS operations.

Downstream value chain: The downstream value chain is defined by the sector activity of offshore oil & gas or CO2 storage, reflecting the E&Ps activities.

Key inputs and outputs

Revenue by significant sustainability matter (2024):

  • Oil and gas sector: USD 769 million
  • Waste treatment and disposal sector (CO2 storage activities, taxonomy-aligned): USD 6 million
  • Total revenue: USD 775 million

Key inputs: The Group's key inputs include fossil fuels (Marine Gas Oil), equipment, drilling control systems, ROVs, operational technology, navigation systems, human resources, supply chain management services, and contracted services (agents, consultants, cleaning, food and catering, transportation).

Key outputs: The Group's main output is drilling services for exploration, development, P&A, and CO2 storage well operations. In 2024, the own fleet consumed an average of 10,936 tons of Marine Gas Oil (MGO) diesel annually, resulting in 142,354 tons of CO₂e emissions.

SBM-2Interests and views of stakeholders
Reported

Interests and views of stakeholders

Overview

The Group continuously engages with stakeholders to deliver on commercial, financial, environmental, and social targets, while fostering mutually beneficial relationships. Recognising that sustainable practices and transparent dialogue are key to long-term success, the Group integrates stakeholder insights into decision-making, ensuring alignment with industry standards, regulations, and evolving expectations.

The Group seeks to understand the unique value drivers of each group, by involving stakeholders to evaluate both positive and negative impacts from our activities. This approach ensures that diverse perspectives contribute to informed decisions, aligning with the Group's objectives on material sustainability matters.

Stakeholders include anyone who may influence or be affected by the Group's operations. The Group engage with representatives of affected stakeholders, such as unions and non-governmental organisations, suppliers, business partners, clients, and industry associations. In addition, the Group actively engages with users of the Sustainability Statement, including authorities, banks and investors.

Identified stakeholder groups and engagement methods

Stakeholder groupHow we engageWhy we engageValue created
Investors and financial institutions• Regular financial reporting (quarterly/annual reports)<br>• Lender and investor conferences, in person meetings and investor roadshows<br>• Direct communications through newsletters, e-mails, and updates<br>• Question & answer sessions during investor conference callsFoster an open dialogue and build trust, transparency, and lender and investor confidence by communicating the Group's performance and strategy.• Increased lender and investor confidence and transparency<br>• Better financial support and investments<br>• Strengthened market reputation
Rig owners• Operational performance reports<br>• Regular meetings and updates on market trends<br>• Joint ventures and strategic partnership discussions<br>• Safety and environmental compliance updatesEnsure alignment on operational goals, compliance and safety standards.• Enhanced operational efficiencies and safety standards<br>• Strengthened partnerships and collaborations<br>• Shared best practices and innovation
Clients• Regular service performance reviews<br>• Customised presentations on new services<br>• Feedback sessions to understand client needs and improve serviceEnsure services meet contractual terms and client expectations.• Increased client satisfaction and loyalty<br>• Tailored solutions meeting client needs<br>• Long-term business relationships
Suppliers• Supplier meetings and workshops<br>• Performance feedback and improvement plans<br>• Collaboration on innovation and sustainability initiatives<br>• Regular communication on procurement policies and forecasts<br>• AuditsImprove supplier performance and ensure alignment with expectations and ensure suppliers are informed about policies and future needs.• Stronger supply chain relationships<br>• Enhanced product quality and innovation<br>• Efficient and sustainable supply processes
Employees, including local unions and employee groups• Regular town hall meetings<br>• Subsidiary Board meeting participation<br>• Engagement surveys and feedback mechanisms<br>• Training and development programmes<br>• Negotiations and consultations with unions<br>• Health, safety, and wellness programmes<br>• Intranet; Pulse<br>• Exit interviewsProvide transparency on organisational updates and foster employee engagement. Gather input on employee needs and assess satisfaction level while ensuring the well-being and safety of employees.<br>Address labour concerns and maintain positive relationships with unions.• Improved employee morale and job satisfaction<br>• Survey feedback informed wellness programmes<br>• Enhanced skills and productivity<br>• Stronger labour relations<br>• Reduced turnover and sick leave rates
Authorities• Compliance and regulatory reporting<br>• Meetings and briefings on industry regulations<br>• Participation in industry forums and committees<br>• Community engagement and environmental stewardship programmesMeet regulatory obligations and demonstrate adherence to legal and industry standards.<br>Contribute to industry-wide initiatives and standards.• Compliance with legal and regulatory standards<br>• Positive community relations<br>• Contribution to industry standards and practices

Integration of stakeholder views

Stakeholder input is integrated into decision-making processes at all levels. The Group monitors stakeholder relationships through recurring engagement activities and performance reviews, ensuring continuous improvement and alignment with expectations.

Beyond key stakeholder dialogue, the Group engages with internal subject-matter experts to understand material IROs. These experts include key employees with responsibilities and insights into specific parts of the business model and operations.

The Double Materiality Assessment and the information in the Sustainability Statement encompass the most important topics for stakeholders, as they consider the identified interdependencies and IROs related to the value chain.

Distinction between affected stakeholders and users of sustainability information

Following ESRS 1's definition of stakeholders, the Group focused on affected stakeholders and users of the Sustainability Statement, including clients, suppliers, financial institutions, employees, and authorities.

Outcomes of stakeholder engagement, including methods and specific impacts, are summarised in the stakeholder dialogue table. The engagement methods are designed to address specific stakeholder interests, such as operational safety, environmental impact mitigation, and financial transparency.

SBM-3Material impacts, risks and opportunities and their interaction with strategy and business model
Reported

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

List of material IROs

Odfjell Drilling conducted a Double Materiality Assessment (DMA) to determine key topics of economic, environmental, and social impacts relevant to the Group, as well as the issues that influence stakeholder decisions. The material IROs identified were integrated into the Group's risk management processes and decision-making frameworks.

The identified material IROs of 2024 are outlined in the table below:

Material impact, risk or opportunityCategoryValue chain locationTime horizonMateriality
+/-Upstream / Own Ops / DownstreamShort-term / Medium-term / Long-termImpact / Financial
ENVIRONMENT
E1 Climate change mitigation & adaptation - CO₂e emissions from operations and value chainActual impact-✓ / ✓ / ✓✓ / -
E1 Climate change adaptation - Energy market transition, regulatory changes and CO2 well market expansionActual and potential risk and opportunity+/-✓ / ✓ / ✓✓ / ✓
E2 Pollution to air - NOx emissionsActual impact-✓ / ✓ / ✓✓ / -
E2 Pollution to water - Well blow out and uncontrolled spills to seaPotential impact and risk-✓ / ✓ / ✓✓ / -
E2 Substance of concern - Hazardous chemical use causing spills and health concerns offshorePotential impact-✓ / ✓ / ✓✓ / -
E4 Impacts on the state of species - Operational noise pollution, pollution to seaPotential impact-✓ / ✓ / ✓✓ / -
E4 Direct impact drivers of biodiversity loss - Seabed disturbance from drillingPotential impact-✓ / ✓ / ✓✓ / -
E5 Resource use - Lifecycle management, resource use and circular economy related to SPS wasteActual/potential impact and risk+/-✓ / ✓ / ✓✓ / ✓
E5 Resource use - Waste generated from SPSPotential impact-✓ / ✓ / ✓✓ / -
SOCIAL
S1 Human rights and labour conditions - Safety standards, fair wages, working hours, contract terms, and labour rights enforcementActual and potential Impact and risk+/-✓ / ✓ / ✓✓ / ✓
S1 Health & safety - Potential hazardous working conditions offshore with risks of injuries and fatalitiesPotential impact and risk-✓ / ✓ / ✓✓ / -
S1 Psychosocial work environment - The work environment impact employee well-beingPotential impact-✓ / ✓ / ✓✓ / -
S1 Equal treatment and opportunities - Facilitating an inclusive and diverse work environmentActual and potential impact+✓ / ✓ / ✓✓ / -
S1 Competence and training - Upskilling of the workforceActual impact+✓ / ✓ / ✓✓ / -
S2 Human rights and labour conditions - Dependency on products and services provided by suppliers and contractorsPotential impact+/-✓ / ✓ / ✓✓ / -
GOVERNANCE
G1 Corporate culture and risk management - Ethical decision-making, regulatory compliance, and business resilienceActual impact+✓ / ✓ / ✓✓ / ✓
G1 Corruption and bribery - Distortion of decision-making and market competition, resulting in unfair advantages and increased legal and financial risksPotential impact and risk+/-✓ / ✓ / ✓✓ / -
G1 Management of relationships with suppliers - Reputational, legal and financial risk related to human rights, environment and operational factorsActual impact and risk-✓ / ✓ / ✓✓ / -
G1 Protection of whistleblowers - Ensuring trust in reporting channels to discover possible adverse impactsPotential impact+✓ / ✓ / ✓✓ / -
Cyber security - Risk of cyber security attacks affecting operationsPotential risk-✓ / ✓ / ✓✓ / -
  • (positive), - (negative), Own Ops (Own Operations) Short-term (1–2 years), medium-term (3–5 years), and long-term (beyond 5 years) horizons

Time horizons

The Sustainability Statement follows the categorisation of short, medium and long-term time horizons as defined in ESRS 1, section 6.4:

  • Short-term: 1-2 years
  • Medium-term: 3-5 years
  • Long-term: beyond 5 years

Value chain location

The Group's activities are located in the upstream value chain for the oil & gas sector, during exploration and development phases of the energy production cycle. This includes the field decommissioning stage, including the subsequent redeployment or recycling of owned MODUs.

As of 2024, the Group had activities in the downstream value chain for the Carbon Capture and Storage (CCS) sector. Deepsea Stavanger drilled one appraisal well on the Smeaheia field on the NCS.

The upstream value chain includes suppliers and sub-suppliers delivering products and services necessary to conduct drilling operations. The downstream value chain is defined by the sector activity of offshore oil & gas or CO2 storage, reflecting the E&P activities.

Interaction with strategy and business model

The Group's strategy and business model are an integral part of the DMA, covering the Group's actual and potential impact on people and the environment, as well as financial risks and opportunities arising from sustainability factors.

The current financial effects of the identified material risks and opportunities are limited, and the Group has capacity to address the identified material impacts and risks as well as to take advantage of material opportunities. E1 Climate Change, E5 Resource Use and Circular Economy, S1 Own Workforce and G1 were identified as having a potential material financial impact.

The Group prioritises operational efficiency while enabling emission reductions in line with operator and regulatory requirements, ensuring sustainable and cost-effective operations for clients and stakeholders.

The assessment informed the Group's operational strategies, ensuring alignment with ESRS topical standards identified as material. The conclusions of the DMA contributed to shaping the Group's strategy and action plan for 2024-2026. The results of the DMA are integrated into the Group's ERM process to ensure that material IROs are regularly monitored and updated in alignment with strategic priorities.

Integrating double materiality into business strategy

The Group conducted a five-step process to identify and assess the IROs in the value chain:

  1. Identification of sustainability topics: The identification process began with a review of internal due diligence frameworks, company policies, and prior risk and materiality assessments. Industry-specific standards, such as the Sustainability Accounting Standards Board (SASB) and Global Reporting Index, were used to ensure an industry relevant lens on material topics. A long list of sustainability topics was generated, and input from stakeholders refined the initial list.

  2. Assessment of impact materiality: Stakeholder engagement workshops involved all Odfjell Drilling functions, as well as one-on-one meetings with subject matter experts. Topics were assessed based on actual and potential impacts, considering severity, scope, and likelihood. External stakeholders, including clients, suppliers, and financial institutions, were also consulted. Findings were consolidated into the reporting software for scoring and prioritisation.

  3. Assessment of financial materiality: Financial materiality was assessed through dialogue with the CFO, VP Finance, and General Manager, alongside the Sustainability team. The process used the Group's ERM framework and financial risk matrices to evaluate potential risks and opportunities that could affect financial position, performance, and long-term value creation. Risks were prioritised based on financial value and likelihood.

  4. Finalisation and documentation: Results were validated by the Sustainability team. Comprehensive documentation, including workbooks, interview summaries, and rationale for scoring, was prepared to support the assessments.

  5. Audit Committee review and approval: the Group's DMA outcome was presented to the Audit Committee for review and further discussed and approved with the Board.

Threshold of materiality

Impact materiality is defined if the Group's impact on people or the environment meets set thresholds. Impacts in the first tier of suppliers and business relationships are prioritised due to their higher influence. Both actual and potential impacts are assessed over short, medium, and long-term horizons, with severity taking precedence over likelihood for human rights risks.

Impact materiality threshold: impact meets the severity threshold (scale, scope, and degree of irremediability) combined with the likelihood of occurrence

Materiality from a financial perspective focuses on risks or opportunities that affect the Group's financial position, performance, cash flows, or access to capital over time. Financial materiality extends beyond the Group's direct control to include material risks and opportunities within its value chain.

Financial materiality threshold: risks or opportunities that have a material influence or could reasonably be expected to have a material influence on the Groups development, financial position, financial performance, cash flows, access to finance, or cost of capital over the short, medium, or long-term

Resilience to identified IROs

The current financial effects of the identified material risks and opportunities are limited, and the Group has capacity to address the identified material impacts and risks as well as to take advantage of material opportunities.

By continuously assessing and addressing climate-related risks and opportunities, the Group remains committed to adapting the business for a changing climate. No assets of the Group are identified as requiring significant efforts to align with climate-neutral goals outside of what has been estimated for zero emissions operations.

Climate-related risk assessments are aligned with the Group's impairment testing, ensuring that financial assumptions reflect climate scenarios. The Group will expand to quantification of the climate related risk assessment in the coming years.

Commentary on specific material IROs

E1 Climate Change:
The Group operates in a carbon-intensive industry, where greenhouse gas (GHG) emissions from fleet, offshore drilling, energy consumption, and supply chain, present a negative impact on the environment. The Group faces regulatory, financial, and operational risks as the industry transitions to a low-carbon economy. Opportunities are identified for net zero emission drilling projects and the new market for drilling of CO₂ storage wells.

The Group is committed to enable low-carbon drilling solutions while aligning with the Paris Agreement to achieve climate neutrality by 2050. As part of long-term strategy, the Group is adapting the business model to a low-carbon economy by integrating energy-efficient technologies and enabling net zero solutions. The Group has invested USD 49 million in CapEx as of 2024 for battery retrofitting and technical modification.

S1 Own Workforce:
The Group has an impact on its workforce by offering jobs with fair working conditions globally. The Group prioritises permanent positions, offering secure employment and stable working conditions. Material topics include human rights and labour conditions, health and safety, psychosocial work environment, equal treatment and opportunities, and competence and training.

The Group ensures all employees have an adequate wage and total annual remuneration. 100% of the total workforce has an employment contract with defined employment terms. The Group targets zero injuries at the workplace and zero incidents of discrimination, bullying and harassment. A target of 40% women in leadership positions by 2030 has been set.

IRO-1Description of the process to identify and assess material impacts, risks and opportunities
Reported

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

Methodology and Approach

The methodology for assessing material IROs complies with CSRD requirements and the Materiality Assessment Implementation Guidance by the European Financial Reporting Advisory Group (EFRAG) published in May 2024. The process is based on a structured methodology using qualitative and quantitative assessments, applying assumptions on risk severity, likelihood, and financial exposure. Software was used to conduct the assessment and complete scoring.

The process focused on the Group's drilling services, upstream value chain and the geographical location of the 2024 operations. The assessment is based on inherent risk and impacts as well as activities integrated in the Group's operations to mitigate or reduce potential impacts and risks. The identified risks from the DMA are integrated to the ERM.

Step-by-Step Process

The Group conducted a five-step process to identify and assess the IROs in the value chain:

1. Identification of sustainability topics: The identification process began with a review of internal due diligence frameworks, company policies, and prior risk and materiality assessments. Industry-specific standards, such as the Sustainability Accounting Standards Board (SASB) and Global Reporting Index, were used to ensure an industry relevant lens on material topics. A long list of sustainability topics was generated, and input from stakeholders refined the initial list.

2. Assessment of impact materiality: Stakeholder engagement workshops involved all Odfjell Drilling functions, as well as one-on-one meetings with subject matter experts. Topics were assessed based on actual and potential impacts, considering severity, scope, and likelihood. External stakeholders, including clients, suppliers, and financial institutions, were also consulted. Findings were consolidated into the reporting software for scoring and prioritisation.

3. Assessment of financial materiality: Financial materiality was assessed through dialogue with the CFO, VP Finance, and General Manager, alongside the Sustainability team. The process used the Group's ERM framework and financial risk matrices to evaluate potential risks and opportunities that could affect financial position, performance, and long-term value creation. Risks were prioritised based on financial value and likelihood.

4. Finalisation and documentation: Results were validated by the Sustainability team. Comprehensive documentation, including workbooks, interview summaries, and rationale for scoring, was prepared to support the assessments.

5. Audit Committee review and approval: the Group's DMA outcome was presented to the Audit Committee for review and further discussed and approved with the Board.

Inputs to the Assessment

Internal inputs:

  • Internal due diligence frameworks
  • Company policies
  • Prior risk and materiality assessments
  • Enterprise Risk Management (ERM) framework
  • Financial risk matrices
  • Internal risk registers
  • All reported incidents
  • Risk assessments and management reviews
  • Verifications and audits, including third party audits
  • Direct feedback from delegates, representatives, employees, and health services

External inputs:

  • Industry-specific standards (SASB, Global Reporting Index)
  • ESRS guidance
  • DNV's newly published report for the OG21 "Evaluation direct emission reduction pathways for Norway's oil and gas industry in line with 2050 targets"
  • Stakeholder engagement (clients, suppliers, financial institutions, employees, authorities)
  • External health provider surveys
  • Reports from recognised external sources

Subject matter experts and consultants:

  • Internal subject-matter experts with responsibilities and insights into specific parts of business model and operations
  • External stakeholders (clients, suppliers, financial institutions)
  • CFO, VP Finance, General Manager, Sustainability team
  • Cross-functional teams from corporate, risk management, finance, supply chain, Human Resources (HR), and technical disciplines

Scoring Criteria for Impact Materiality

Impact materiality threshold: impact meets the severity threshold (scale, scope, and degree of irremediability) combined with the likelihood of occurrence.

Impacts are assessed based on:

  • Scale - the gravity of the actual or potential impacts on human rights
  • Scope - the number of individuals that are or could be affected
  • Irremediability - the ease with which those impacted could be restored to their prior enjoyment of the relevant right
  • Likelihood - the likelihood of the impact occurring in the future

Severity takes precedence over likelihood for human rights risks. Both actual and potential impacts are assessed over short, medium, and long-term horizons. Impacts in the first tier of suppliers and business relationships are prioritised due to their higher influence.

Scoring Criteria for Financial Materiality

Materiality from a financial perspective focuses on risks or opportunities that affect the Group's financial position, performance, cash flows, or access to capital over time.

Financial materiality threshold: risks or opportunities that have a material influence or could reasonably be expected to have a material influence on the Groups development, financial position, financial performance, cash flows, access to finance, or cost of capital over the short, medium, or long-term.

Financial materiality extends beyond the Group's direct control to include material risks and opportunities within its value chain.

Threshold for Materiality

Seven ESRS topics are material for the Group, with five of them having double materiality. Most significant material topics were E1 Climate Change and S1 Own Workforce.

The current financial effects of the identified material risks and opportunities are limited, and the Group has capacity to address the identified material impacts and risks as well as to take advantage of material opportunities. E1 Climate Change, E5 Resource Use and Circular Economy, S1 Own Workforce and G1 were identified as having a potential material financial impact.

Frequency and Last Review

The DMA was conducted in 2024 for the first time under CSRD. The annual DMA is reviewed by the Audit Committee before being approved by the Board.

Use of Value Chain Mapping

The assessment covered the main value chain of the Group, including the Impacts, Risks, and Opportunities (IROs) identified in the Group's own operations, upstream, and downstream value chain. Operational control is defined as when the Group has full authority to introduce and implement its operating policies at the asset.

The Group's strategy and business model are an integral part of the DMA, covering the Group's actual and potential impact on people and the environment, as well as financial risks and opportunities arising from sustainability factors.

Material IROs Identified

The identified material IROs of 2024 are outlined in the following table:

Material impact, risk or opportunityCategoryValue chain locationTime horizonMateriality
Up-StreamOwn OpsDown-Stream
ENVIRONMENT
E1 Climate change mitigation & adaptation - CO₂e emissions from operations and value chainActual impact-
E1 Climate change adaptation - Energy market transition, regulatory changes and CO2 well market expansionActual and potential risk and opportunity+/-
E2 Pollution to air - NOx emissionsActual impact-
E2 Pollution to water - Well blow out and uncontrolled spills to seaPotential impact and risk-
E2 Substance of concern - Hazardous chemical use causing spills and health concerns offshorePotential impact-
E4 Impacts on the state of species - Operational noise pollution, pollution to seaPotential impact-
E4 Direct impact drivers of biodiversity loss - Seabed disturbance from drillingPotential impact-
E5 Resource use - Lifecycle management, resource use and circular economy related to SPS wasteActual/ potential impact and risk+/-
E5 Resource use - Waste generated from SPSPotential impact-
SOCIAL
S1 Human rights and labour conditions - Safety standards, fair wages, working hours, contract terms, and labour rights enforcementActual and potential Impact and risk+/-
S1 Health & safety - Potential hazardous working conditions offshore with risks of injuries and fatalitiesPotential impact and risk-
S1 Psychosocial work environment - The work environment impact employee well-beingPotential impact-
S1 Equal treatment and opportunities - Facilitating an inclusive and diverse work environmentActual and potential impact+
S1 Competence and training - Upskilling of the workforceActual impact+
S2 Human rights and labour conditions - Dependency on products and services provided by suppliers and contractorsPotential impact+/-
GOVERNANCE
G1 Corporate culture and risk management - Ethical decision-making, regulatory compliance, and business resilienceActual impact+
G1 Corruption and bribery - Distortion of decision-making and market competition, resulting in unfair advantages and increased legal and financial risksPotential impact and risk+/-
G1 Management of relationships with suppliers - Reputational, legal and financial risk related to human rights, environment and operational factorsActual impact and risk-
G1 Protection of whistleblowers - Ensuring trust in reporting channels to discover possible adverse impactsPotential impact+
Cyber security - Risk of cyber security attacks affecting operationsPotential risk-

Note: + (positive), - (negative), Own Ops (Own Operations) Short-term (1–2 years), medium-term (3–5 years), and long-term (beyond 5 years) horizons

Integration with Due Diligence

The DMA is closely interlinked with the sustainability due diligence process. The Group conducts due diligence to identify, mitigate and account for actual and potential adverse impacts on environment, people and society, caused or connected with the business. The identification of actual and potential adverse impacts supports the identification of material topics subject to the CSRD.

Due diligence is embedded as a part of the governance, strategy, and business model, through binding policies and procedures, namely the Sustainability Policy, the Human Rights Policy and the Risk Framework. The sustainability due diligence process is aligned with the United Nations (UN) Guiding Principles on Business and Human Rights and the Organisation for Economic Co-operation and Development (OECD) Guidelines for Multinational Enterprises.

The responsibility for assessing and identifying actual and potential adverse impacts are firmly anchored throughout the Group, within the ERM process and in the CRC. The value chain is assessed as described in G1-2.

Human Rights Risk Assessment

Human rights risks within the value chain are assessed in accordance with the Human Rights Assessment Procedure. The information retrieval for all risk assessments is broad and includes internal risk registers, all reported incidents, stakeholder engagement, audits, and reports from recognised external sources.

The risk assessment is conducted based on internal and external human rights expertise, involving relevant stakeholders. In addition to the listed channels for engagement with employees, the assessment is informed by:

  • Data and trend variations quarterly
  • Risk assessments and management reviews
  • Verifications and audits, including third party audits subject to flag state, governmental authorities and clients
  • Direct feedback and knowledge transfers from delegates, representatives, employees, and health services
  • Changes affecting continuity of business, like legislative, security, political, or environmental changes

Integration with Strategy and Business Model

The identified material IROs are outlined in the table and further described under each topic in the Sustainability Statement. The Group's strategy and business model are an integral part of the DMA, covering the Group's actual and potential impact on people and the environment, as well as financial risks and opportunities arising from sustainability factors.

The content of the Sustainability Statement reflects the outcome of the DMA and provides insights on:

  • current and anticipated effects of material IROs or whether they originated or are connected with the business model and strategy
  • how the IRO affects people or environment
  • expected time horizon
  • nature of activities

The assessment informed the Group's operational strategies, ensuring alignment with ESRS topical standards identified as material. The conclusions of the DMA contributed to shaping the Group's strategy and action plan for 2024-2026. The results of the DMA are integrated into the Group's ERM process to ensure that material IROs are regularly monitored and updated in alignment with strategic priorities.

Climate-Related Risk Assessment

The climate risk assessment, completed in 2023, covered all the Group's activities and operational locations, considering geographic variations. The assessment was in accordance with the Taskforce on Climate related Financial Disclosures (TCFD) framework and involved cross-functional teams from corporate, risk management, finance, supply chain, Human Resources (HR), and technical disciplines. Risks were identified, assessed using sensitivity analysis, and stress-tested for physical and transition risks.

Physical risk was assessed using the International Panel on Climate Change (IPCC) Shared Socioeconomic Pathways (SSP) 5-8.5, representing a high-emissions scenario, with increased frequency of extreme weather events. This scenario was used to evaluate potential disruptions to offshore operations, increased maintenance costs, and operational downtime due to severe weather.

Transition risk was analysed using IPCC SSP 1-2.6 (low-carbon transition) and the International Energy Agency Net Zero by 2050 scenario, assessing the impact of stricter climate policies, shifts in fossil fuel demand, and financing challenges. This analysis helped evaluate stranded asset risks, carbon pricing exposure, and capital cost fluctuations.

Biodiversity Impact Assessment

Biodiversity was identified as a material topic in 2024 due to its relevance to the Group's drilling activities and downstream value chain. Regulated EIAs, risk registers, and research, have been assessed to determine materiality. The public EIA, as performed by the E&P operators, consults with relevant stakeholders and affected communities. The identified potential impacts are based on the fleet's geographical site of operations in 2024.

No operations in 2024 were located near biodiversity sensitive areas, consequently, none of them have a material negative impact on the areas.

IRO-2Disclosure requirements in ESRS covered by the undertaking's sustainability statement
Omitted

E1Climate Change

E1-1Transition plan for climate change mitigation
Reported

Transition plan for climate change mitigation

Scope of the plan

The transition plan covers the Group's own fleet (6th generation MODUs) operating on the Norwegian Continental Shelf (NCS) and internationally. The plan addresses emissions from:

  • Scope 1: Direct emissions from the Group's own fleet when off contract
  • Scope 2: Indirect emissions from purchased electricity and heating at business premises and operational base in Norway
  • Scope 3: Indirect emissions from the value chain, covering both NCS and international operations (Categories 1, 2, 4, 5, 6, 7, and 13)

Target year(s) for net zero / carbon neutral

The Group has committed to:

  • 35% reduction by 2030 (from 2019 baseline)
  • Net zero emissions by 2050, aligning with the Paris Agreement and a 1.5°C trajectory

Scope 1, 2, 3 reduction milestones with baseline years

Scope 1 and Scope 3 Category 13 (own fleet) target:

  • Baseline year: 2019 (210,685 tCO2e total fleet emissions)
  • Progress to 2024: Around 30% reduction in absolute emissions achieved (68,331 tCO2e reduction), with 2024 emissions totalling 142,354 tCO2e
  • 2030 target: 35% absolute reduction
  • 2050 target: Net zero emissions
  • Additional target: Maximise use of shore power instead of fuel consumption during yard stays where available

Scope 2 target:

  • 2030 target: Net zero Scope 2 emissions in the market-based scenario, to be achieved through Guarantees of Origin (GoOs)

Scope 3 Category 1 and 2 (Purchased Goods & Services, Capital Goods):

  • Medium-term target: Increase the proportion of primary activity data and emissions factor data for these categories

Alignment with 1.5°C / SBTi validation status

The transition plan is aligned with:

  • Paris Agreement goal of limiting global warming to 1.5°C
  • Science Based Targets initiative (SBTi) draft guidelines for the oil and gas sector (will be revised upon publication of final guidelines)
  • DNV's report for OG21 on direct emission reduction pathways for Norway's oil and gas industry in line with 2050 targets

The Group is excluded from the EU Paris-Aligned Benchmarks and continues to evaluate regulatory developments to align with global decarbonisation frameworks.

Key levers / decarbonization pillars

The transition plan prioritises a merit-order approach with three core strategies:

1. Technical modifications and installed measures (9% reduction achieved by 2024):

  • Installation of hybridised power systems, reducing need for additional generators
  • Implementation of energy monitoring systems for real-time optimisation
  • Electrification feasibility studies

2. Energy optimisation (5% further reduction expected by 2030):

  • Optimised power consumption through energy-efficient technologies
  • Reduced thruster use during anchoring to minimise fuel consumption
  • Upgraded cooling systems to decrease power demand

3. Planned measures (10% reduction expected):

  • Deployment of additional energy efficiency measures across rigs
  • Further automation of emissions tracking

4. Alternative fuels & electrification (key to net zero by 2050):

  • Exploring hybrid and alternative fuel options
  • Assessing electrification potential offshore
  • Strengthening supply chain readiness for low-carbon fuel adoption

Key technologies:

  • PowerBlade™ Hybrid (PB-H) System: Battery and hybrid solutions for peak shaving on drilling loads, reducing fuel consumption
  • HVAC waste heat utilisation: Components using waste heat for energy efficiency
  • Shore power: Maximising use during yard stays
  • Alternative fuels: Future fleet-wide implementation planned

CapEx / investment commitments

USD 49 million invested in CapEx as of 2024 (USD 46 million in 2023) for:

  • Battery retrofitting
  • Technical modifications
  • Emissions data management
  • Efficiency improvements and new technology

These investments are partially supported by the Norwegian NOx Fund and focus on reducing MGO fuel consumption and integrating low-carbon solutions. The investments relate to the Group's economic activities involving oil, gas and carbon storage.

The Group aims to align investments with the EU Taxonomy for climate change mitigation, prioritising activities that reduce fossil fuel dependency and support the transition to a net zero economy.

Locked-in emissions and stranded asset analysis

Current locked-in emissions:

  • The Group's own fleet currently consumes an average of 10,936 tons of Marine Gas Oil (MGO) diesel annually
  • This results in 142,354 tons of CO2e emissions in 2024
  • Given the 30–40-year operational lifespan of assets, emissions are locked in until retrofitting the fleet with low-carbon alternatives or transitioning to alternative fuels

Mitigation efforts:

  • Deployment of hybrid and battery technology to reduce fuel consumption
  • Evaluation of alternative fuels for fleet-wide implementation
  • Continuous retrofitting initiatives to accelerate decarbonisation

Stranded asset assessment:

No assets are identified as requiring significant efforts to align with climate-neutral goals outside of what has been estimated for zero emissions operations. Climate-related risk assessments are aligned with the Group's impairment testing, ensuring that financial assumptions reflect climate scenarios.

Use of carbon credits / removals

The Group has not acquired any carbon credits in 2024 or in previous years.

Implementation timeline

The Group has been executing its transition plan since 2014, with milestones in:

  • 2026
  • 2035
  • 2050

The transition plan is fully integrated into the corporate strategy and financial planning. It has been approved by the Executive Management and Board to ensure robust governance and accountability.

Dependencies and external factors

Implementation of the decarbonisation levers is dependent on:

  • Availability of alternative fuels and infrastructure for electrification
  • Regulatory incentives and emission trading schemes
  • Technological advancements in low-emission drilling solutions
  • Operator collaboration for deployment of net zero solutions

For Scope 3 reductions, key challenges include:

  • C1 and C2: Availability and accuracy of emissions data from suppliers
  • C4: Availability of low-carbon transport solutions from third-party logistics providers
  • C6 and C7: Travel demand and transport availability, requiring collaboration with employees and travel partners
E1-4(was E1-2)Policies related to climate change mitigation and adaptation
Omitted
E1-5(was E1-3)Actions and resources in relation to climate change policies
Omitted
E1-6(was E1-4)Targets related to climate change mitigation and adaptation
Omitted
E1-7(was E1-5)Energy consumption and mix
Omitted
E1-8(was E1-6)Gross Scopes 1, 2, 3 and Total GHG emissions
Omitted
E1-9(was E1-7)GHG removals and GHG mitigation projects financed through carbon credits
Omitted
E1-10(was E1-8)Internal carbon pricing
Omitted
E1-11(was E1-9)Anticipated financial effects from material physical and transition risks and potential climate-related opportunities
Reported

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

Phase-in Exemption

The Group has opted to exercise the phase-in allowance to omit the financial effects from material physical and transition risks and potential climate-related opportunities required in E1-9.

Transition Plan Implementation and CapEx Investments

Investments in climate mitigation

To implement the transition plan, the Group has invested USD 49 million in CapEx as of 2024, with funding allocated for battery retrofitting and technical modification.

These investments, partially supported by the Norwegian NOx Fund, focus on reducing MGO fuel consumption and integrating low-carbon solutions. The CapEx amounts invested are related to the Group's economic activities involving oil, gas and carbon storage.

Additionally, the Group aim for the investments to align with the EU Taxonomy for climate change mitigation, prioritising activities that reduce fossil fuel dependency and support the transition to a net zero economy.

Locked-in Emissions

The Group's own fleet currently consumes an average of 10,936 tons of Marine Gas Oil (MGO) diesel annually, resulting in 142,354 tons of CO₂e emissions in 2024. Given the 30–40-year operational lifespan of our assets, emissions are locked in until retrofitting the fleet with low-carbon alternatives or transitioning to alternative fuels.

Climate Target

The Group's absolute CO₂e targets for own fleet include a 35% CO2e reduction by 2030 and Net Zero as a long-term goal.

E2Pollution

E2-1Policies related to pollution
Omitted
E2-2Actions and resources related to pollution
Omitted
E2-3Targets related to pollution
Omitted
E2-4Pollution of air, water and soil
Reported

Pollution of air, water and soil

Emissions to air

Pollutant20242023Unit
NOx314tonnes
Fluorine and inorganic compounds (HF)29.5n/akg

Accounting methodology (NOx): NOx emissions are calculated by using a rig specific conversion factor for tonne fuel per kilogramme NOx emission, based on the Norwegian excise tax regulations.

Accounting methodology (Fluorine compounds): The fluorine and inorganic compounds spill reported were caused by a weakness in vibration, and a flexible hose not fit for its intended purpose. Data for pollution-related accounting and reporting is collected through monitoring systems that track the potential spills automatically.

The Group's own fleet currently consumes an average of 10,936 tons of Marine Gas Oil (MGO) diesel annually, resulting in 142,354 tons of CO₂e emissions in 2024.

Emissions/discharges to water

Pollutant2024Unit
Oil based mud0.23
Hydraulic oil0.02
Oil contaminated water0.01
Water based mud0.50

Accounting methodology: In 2024, the Group had 6 spills to sea, where the content of the spills was oil based mud, hydraulic oil, oil contaminated water, and water based mud. Spills to sea are monitored and tracked automatically.

The Group has set the target for continuous zero uncontrolled spills, in own operations, with the aim to prevent pollution and emissions to air and water, prevent spills, safeguard ecosystems, and uphold environmental standards. There has been zero serious uncontrolled spills in 2024.

Emissions/discharges to soil

Substance of concern2024Unit
Copper280kg

Accounting methodology: During the Special Periodic Survey (SPS), the Mobile Offshore Drilling Units (MODUs) undergo hull cleaning and get a coat of new hull paint. This hull paint includes the substance of concern, copper, identified to be over the threshold as outlined in Annex II of the European Pollutant Release and Transfer Register. The Group estimates a total of 280kg copper is emitted to sea annually from the four own units. The estimation is based on supplier-specific data.

E-PRTR reference

The 2024 review of substances of concern concluded on copper in hull painting (reference to Annex II of the European Pollutant Release and Transfer Register).

Multi-year comparison

Comparative data provided for NOx emissions (2024: 31 tonnes; 2023: 4 tonnes). No comparative data provided for fluorine compounds in 2023. No comparative data provided for discharges to water or substances of concern.

E2-5Substances of concern and substances of very high concern
Omitted
E2-6Anticipated financial effects from pollution-related impacts, risks and opportunities
Reported

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

Phase-in exemption applied

Odfjell Drilling has applied the transitional provision in ESRS 1:137 allowing for phasing-in certain data point disclosures for the first year of reporting under ESRS, specifically encompassing E2-6 (Anticipated financial effects from pollution-related impacts, risks and opportunities).

As stated in the disclosure index table, E2-6 is marked as "Phase-in".

E4Biodiversity and Ecosystems

E4-1Transition plan and consideration of biodiversity and ecosystems in strategy and business model
Reported

Transition plan and consideration of biodiversity and ecosystems in strategy and business model

Transition plan

The Group does not have a transition plan for biodiversity and ecosystems.

Operational context and business model considerations

Biodiversity was identified as a material topic in 2024 due to its relevance to the Group's drilling activities and downstream value chain. Regulated EIAs, risk registers, and research, have been assessed to determine materiality. The public EIA, as performed by the E&P operators, consults with relevant stakeholders and affected communities.

As a drilling contractor, the Group operates within the scope defined by operators' well programmes and licences, resulting in a limited control over specific parameters and operational locations. Drilling equipment and methodologies are dictated by E&P operators through contracts. While operators are responsible for EIAs, permitting, and regulatory compliance, the Group recognises its role in minimising potential environmental impacts, particularly in the case of sensitive marine ecosystems during exploration drilling.

The Group does not hold production licences and are not involved with opening new areas for oil and gas production and CO2 storage, but our operations may impact biodiversity through emissions to air, spills and discharges to sea, waste and effluents.

No direct dependency or financial risk from biodiversity or marine ecosystem changes has been identified for the Group's core activities or business model.

Material impacts identified

The identified potential impacts are based on the fleet's geographical site of operations in 2024, as outlined in the Board of Directors report.

Two potential impacts to the environment have been identified in own operations and our downstream value chain:

  • Seabed change by creating boreholes, cutting piles, and drill cuttings that may degrade benthic habitats. This can potentially cause sediment resuspension, leading to physical disruptions to marine ecosystems
  • Noise from rig equipment (e.g., blowout preventers, thrusters) generates anthropogenic sounds that disrupt marine life, especially marine mammals, and may decrease fish populations near drilling sites

The materiality and scope of these impacts will be evaluated further in the coming years to ensure effective mitigation of potential environmental impacts. No risks have been identified for the Group's activities related to biodiversity and ecosystems.

Material impacts, risks and opportunities table

Material impact, risk or opportunityCategoryValue chain locationTime horizonMateriality
Up-StreamOwn OpsDown-Stream
Impacts on the state of speciesPotential impact-
Direct impact drivers of biodiversity lossPotential impact-
  • (positive), - (negative), Own Ops (Own Operations)
E4-2Policies related to biodiversity and ecosystems
Omitted
E4-3Actions and resources related to biodiversity and ecosystems
Omitted
E4-4Targets related to biodiversity and ecosystems
Omitted
E4-5Impact metrics related to biodiversity and ecosystems change
Reported

Impact metrics related to biodiversity and ecosystems change

Odfjell Drilling has stated that no operations in 2024 were located near biodiversity sensitive areas, and consequently none of them have a material negative impact on the areas.

The company explicitly states: "Therefore, we have no biodiversity specific metrics, nor have we set a base year from which progress is measured."

Key contextual information

  • No operations in 2024 were located near biodiversity sensitive areas
  • No material negative impact on biodiversity sensitive areas identified
  • The Group does not hold production licences and is not involved with opening new areas for oil and gas production
  • The Group does not incorporate biodiversity offsets into its action plans
  • No relevant material targets have been identified, and the Group has no biodiversity related goals

Disclosure statement

The company has not provided quantified metrics for:

  • Land use footprint
  • Deforestation footprint
  • Operations/sites in or near protected areas or KBAs
  • Species impact metrics (Red List species)
  • Ecosystem condition metrics
  • Restoration metrics
E4-6Anticipated financial effects from biodiversity and ecosystem-related impacts, risks and opportunities
Reported

Anticipated financial effects from biodiversity and ecosystem-related impacts, risks and opportunities

Odfjell Drilling has applied the transitional provision in ESRS 1:137 allowing for phasing-in E4-6 (Anticipated financial effects from biodiversity and ecosystem-related risks and opportunities) for the first year of reporting under ESRS.

No quantified financial effects from biodiversity and ecosystem-related impacts, risks and opportunities are disclosed in this reporting period.

E5Resource Use and Circular Economy

E5-1Policies related to resource use and circular economy
Omitted
E5-2Actions and resources related to resource use and circular economy
Omitted
E5-3Targets related to resource use and circular economy
Omitted
E5-4Resource inflows
Omitted
E5-5Resource outflows
Omitted
E5-6Anticipated financial effects from resource use and circular economy-related impacts, risks and opportunities
Reported

Anticipated financial effects from resource use and circular economy-related impacts, risks and opportunities

The Group has applied the phase-in exemption under ESRS 1:137 for E5-6 in the first year of reporting under ESRS.

No anticipated financial effects from resource use and circular economy-related impacts, risks and opportunities are disclosed for the 2024 reporting period.

S1Own Workforce

S1-1Policies related to own workforce
Omitted
S1-2Processes for engaging with own workforce and workers' representatives about impacts
Omitted
S1-2(was S1-3)Processes to remediate negative impacts and channels for own workforce to raise concerns
Omitted
S1-3(was S1-4)Taking action on material impacts on own workforce, and approaches to managing material risks and pursuing material opportunities related to own workforce, and effectiveness of those actions
Omitted
S1-4(was S1-5)Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities
Omitted
S1-5(was S1-6)Characteristics of employees
Reported

Characteristics of the undertaking's employees

Employee headcount and demographics

Total headcount by gender (2022–2024)

Gender202420232022
Male1,4821,5051,305
Female655853
Total employees1,5471,5631,358

Note: Refer to Note 6 - Personnel Expenses in the Consolidated Financial Statements

Employee headcount by country (>50 employees)

Country202420232022
Norway1,3091,1571,204
Namibia234347100

Employment contract type and employment type

Employees by contract type and gender

Contract type202420232022
Female / MaleFemale / MaleFemale / Male
Permanent employees54 / 1,43550 / 1,48547 / 1,259
Temporary employees11 / 458 / 476 / 46
Non-guaranteed hours employees0 / 2- / -- / -
Full-time employees64 / 1,48058 / 1,50153 / 1,300
Part-time employees1 / 20 / 40 / 5

Employee turnover

Metric202420232022
Number of employee turnover (head count)583523
Percentage of employee turnover3.8%2.4%1.9%

Age diversity

Age group202420232022
Number under 30 years old (head count)240195158
Percentage under 30 years old15.5%12.5%11.6%
Number between 30 and 50 years old (head count)898933813
Percentage between 30 and 50 years old58.1%59.7%59.9%
Number over 50 years old (head count)409435387
Percentage over 50 years old26.4%27.8%28.5%

Methodology notes

The Group headcount numbers include all employees on Group direct payroll in all Group entities. The reporting is done at the end of the reporting period and includes all direct employees in the month of December every year. All employees are registered in the Group ERP HR System. All employees are counted as one individual. The Group uses simple automated counting where system values are assigned to employees to ensure that no duplications are included for temporary internal transfers or secondments.

All positions are full-time, unless employees specifically request temporary part-time or lower position %. Part-time employees with non-guaranteed hours are not included for 2022 and 2023 because of data limitations.

The Group does not report metrics for non-employees in 2024.

New hires

New hire metrics are not disclosed in the provided excerpts for S1-6.

S1-6(was S1-7)Characteristics of non-employee workers
Reported

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

Disclosure Status

Odfjell Drilling has applied the transitional provision in ESRS 1:137 for the first year of reporting under ESRS, allowing for phasing-in of S1-7 disclosures.

The Group does not report metrics for non-employees in 2024.

Methodology Note

The Group's definition of "own workforce" includes individuals who have a direct contractual relationship with the Group. This encompasses:

  • Employees who are in an employment relationship with the Group
  • Non-employees who are either individual contractors (self-employed individuals), or workers provided by undertakings primarily engaged in employment activities

Non-employees may fill roles within the Group that require specialized skills, or are project-based for a defined duration. Although they are not on the Group's payroll, they are still subject to the Group's policies, procedures, and standards.

The Group's counting methodology uses simple automated counting where system values are assigned to employees to ensure that no duplications are included for temporary internal transfers or secondments. For "contractors hourly/part-time", a Full-Time Equivalent (FTE) principle is used to convert to headcount when contractors are included in the head count.

Limited Historical Data (2022-2023)

For reference, limited data on non-guaranteed hours employees was reported in previous years:

Category2024 Female2024 Male2023 Female2023 Male2022 Female2022 Male
Non-guaranteed hours employees02----

Note: Part-time employees with non-guaranteed hours are not included for 2022 and 2023 because of data limitations.

S1-7(was S1-8)Collective bargaining coverage and social dialogue
Reported

Collective bargaining coverage and social dialogue

Coverage metrics

Metric202420232022
Percentage of total employees covered by collective bargaining agreements (%)91.98%89.84%97.64%
Norway (%)100%100%100%

Workplace representation

Metric202420232022
Norway (%)100%100%100%

Accounting policies

S1-8 Percentage of employees covered by collective bargaining agreements

The percentage of own employees covered by collective bargaining agreements reflects the number of employees working in Norway, including those on the NCS. The Group does not collect unionisation data for other countries but encourages all employees to engage in social dialogue.

In line with ESRS reporting requirements, which mandate disclosure of collective bargaining coverage and workplace representation for countries with more than 50 employees and representing over 10% of the total workforce, the Group reports figures for employees based in Norway. Reporting for other locations is not mandatory, and the small number of employees in these locations raises privacy concerns.

Trade unions and employers' organisations have a strong historical standing in Norway. Legislation, collective agreements, and company-based practices have developed and formed a system of comprehensive workers' rights and privileges. The agreement consists of two parts, nationally negotiated agreements and tariffs, and locally negotiated additional agreements. 100% of the own employees and non-employees in Norway, both onshore and offshore, are covered by the agreements and tariffs signed with the unions, regardless of employee union membership.

Social dialogue processes

The Group maintains a structured process for engaging with the workforce and worker representatives throughout the year:

  • Information on internal website, communication via corporate social media channels
  • CEO Townhall for all employees, 3x per year, and as required
  • Annual and biannual work environment surveys, anonymous feedback from all employees
  • Annual meeting with the CEO and/or SVP HR with union representatives/and safety delegates
  • Employee representatives meetings with management 3x per year, and as needed
  • Region/location/site meeting with management and local employee representative
  • Negotiations and annual salary review processes
  • Regular information meetings with employee representatives regarding changes in business

When potential changes impacting the employees, information meetings are held with union representatives.

S1-8(was S1-9)Diversity metrics
Reported

Diversity metrics

Gender diversity at top management level

Metric2024 Female2024 Male2023 Female2023 Male2022 Female2022 Male
Number of employees at top management level (head count)618618519
Percentage of employees at top management level (%)25%75%25%75%21%79%

Definition: Top management includes position level L1-L3: CEO and General Manager (L1), Executive Management Team (L2), and Business Area Management (L3).

Age band distribution of total workforce

Age band2024 Head count2024 %2023 Head count2023 %2022 Head count2022 %
Under 30 years old24015.5%19512.5%15811.6%
Between 30 and 50 years old89858.1%93359.7%81359.9%
Over 50 years old40926.4%43527.8%38728.5%

Total employee head count by gender

Gender202420232022
Male1,4821,5051,305
Female655853
TOTAL EMPLOYEES1,5471,5631,358

Employees by contract type and gender

Contract type2024 Female2024 Male2023 Female2023 Male2022 Female2022 Male
Permanent employees541,435501,485471,259
Temporary employees1145847646
Non-guaranteed hours employees02----
Number of full-time employees641,480581,501531,300
Number of part-time employees120405

Methodology note

The Group headcount numbers include all employees on Group direct payroll in all Group entities. The reporting is done at the end of the reporting period and includes all direct employees in the month of December every year. All employees are counted as one individual. The employee-related data has not been validated by an external body other than the assurance provider.

S1-9(was S1-10)Adequate wages
Reported

Adequate wages

S1-10 Adequate wages by country

Metric (2024):

  • Percentage of employees paid below the applicable adequate wage benchmark: 0%

Benchmark and methodology:

All employee wages are set in accordance with salary matrices benchmarked against national averages, and negotiated under collective bargaining agreements. All offshore wages are set in accordance with national industry tariff agreements.

The Group benchmarks salary data against:

  • Industry category
  • Union statistics
  • National employers' groups
  • Public statistics

The Group:

  • Surpasses EEA minimum wage standards
  • Surpasses Norwegian local minimum wage requirements
  • Follows collective bargaining agreement wage matrices

Coverage:

100% of the total workforce has an employment contract with defined employment terms. All employees are assured an employment contract specifying the monthly and annual wage that is guaranteed.

Context:

The Group ensures all employees have an adequate wage and total annual remuneration, offering fair compensation that meets the needs of employees and their families. Pay levels for employees working on the Norwegian Continental Shelf are part of a tariff agreement and regulated to ensure fair payment practices. The Group acknowledges collective bargaining and union agreements and facilitates dialogue with union representatives representing the workforce.

S1-10(was S1-11)Social protection
Reported

Social protection

Coverage of employees

Odfjell Drilling does not report quantitative metrics for social protection (S1-11) in 2024. The company has applied the ESRS 1:137 transitional provision, phasing in disclosure of S1-11 data points.

Qualitative disclosure

Coverage against loss of income: All employees are covered by social protection against loss of income due to major life events, either through public programmes or through benefits offered by the Group. The Group complies with local legislation.

Scope:

  • All employees have access to parental leave, holiday, sick leave, and compassionate leave
  • All employees have access to health insurance, including mental health care and physical rehabilitation
  • In international operations, employees are covered under employee handbooks and, in some cases, insurances to protect loss of income

Defined benefit pension schemes: The Group has funded defined benefit pension schemes in one Norwegian company covering:

  • 8 active members
  • 20 pensioners (as at 31 December 2024)

Unfunded defined benefit obligations include early retirement pensions entitling staff to benefits (approximately USD 12,000 per year) from age 62 until eligibility for national insurance pension at age 67.

Contractual pension agreements (CPA): The Group has CPA schemes in Norway established in multi-employer plans, accounted for as defined contribution plans.

Compliance: Norwegian subsidiaries comply with the Norwegian Act relating to mandatory occupational pensions.

Related metrics (provided elsewhere):

Sick leave metric202420232022
Percent sick leave offshore (%)4.2%5.1%5.5%
Percent sick leave onshore (%)0.9%1.2%1.0%
Percent total sick leave (%)3.9%4.7%5.1%

Methodology note

The company states it does not report metrics for social protection in 2024, applying the phase-in provision. All employees are entitled to family-related leave per local legislation and collective bargaining agreements where applicable.

S1-11(was S1-12)Persons with disabilities
Reported

Persons with disabilities

The Group does not report metrics for persons with disabilities in 2024.

The Group does not map employees by disabilities because of legal limitations. There is no work performed by employees with below-normal mental or intellectual abilities due to strict safety rules in the industry. If an employee requests an adaptation to their physical work environment, the Group will accommodate whenever possible.

Scope and exclusions

Legal limitations prevent the mapping of employees by disabilities.

S1-12(was S1-13)Training and skills development metrics
Reported

Training and skills development metrics

Performance and Career Development Reviews

Metric202420232022
Onshore employees
Female participation in performance reviews (%)36%27%25%
Male participation in performance reviews (%)19%26%17%
Female headcount in reviews101718
Male headcount in reviews182412
Offshore employees
Female participation in performance reviews (%)32%48%50%
Male participation in performance reviews (%)38%48%30%
International offshore crew
Female headcount in reviews-1NA
Male headcount in reviews4521NA
Norwegian offshore crew
Female headcount in reviews12149
Male headcount in reviews485542292

Average Training Hours per Employee

Employee category202420232022
Onshore employees
Female22112
Male1876
International offshore crew
Female6NANA
Male23NANA
Norwegian offshore crew
Female312031
Male451726

Methodology Notes

Performance reviews: The reported figures reflect the number of confirmed performance and development reviews conducted in response to automated invitations distributed via IFS software to all registered employees. Line managers and employees are encouraged to discuss performance and career development throughout the year independent of the IFS invitation. Such discussions are not tracked, so the reported figures do not provide a comprehensive representation of all development conversations.

Training hours: Metrics on training and skills development are based on registered training hours in CAMS. Training hours are recorded using IFS, Rider, and Cornerstone, with data assembled and analysed in Power BI. All employees are required to complete training in accordance with the internal Training Matrix.

No total investment in training disclosed.

S1-13(was S1-14)Health and safety metrics
Reported

Health and safety metrics

Coverage of health and safety management system

Odfjell Drilling reports that 100% of own workers (employees) are covered by the Group's health and safety management system based on legal requirements and/or recognised standards or guidelines. The system is internally audited and/or audited or certified by an external party.

Health and safety performance metrics

Metric202420232022
Fatalities
Number of fatalities as a result of work-related injuries and work-related ill health000
Recordable incidents
Number of recordable incidents101114
Rate of recordable incidents2.32.64.8
Lost time injuries
Lost time injuries (LTIs)0.70.70.7
Days of lost time injuries (LTI)17534052
Other metrics
Dropped objects frequency >40J2.335.1
Number of serious incidents000

Methodology notes

Metrics and definitions are built on the IADC and ISO 45001 standards. Rates are calculated per 1,000,000 hours worked using the formula: X × 1,000,000 hours / Number of worked hours.

Lost time incident (LTI) is defined as a work-related injury or ill health to an employee in which a physician or licensed health care professional recommends the employee to be away from work due to the incident. Time away from work on the day of the incident is not considered when determining LTI.

Monthly offshore working hours calculation: number of offshore days × 12 hours per shift × 1.07 (7% overtime).

The metrics cover own workforce (employees). No separate disclosure is provided for contractors or value chain workers.

S1-14(was S1-15)Work-life balance metrics
Reported

Work-life balance metrics

Family-related leave entitlement and uptake

Metric202420232022
Percentage of employees entitled to take family-related leave (%)100%100%100%
Number of females entitled to take family-related leave (head count)655853
Number of males entitled to take family-related leave (head count)1,4821,5321,305

Accounting policy

Family-related leave policies for all locations follow local legislation and additionally, collective bargaining agreements where applicable. All employees are entitled to family-related leave.

The Group does not report metrics for employees who took family-related leave in 2024. All data regarding parental, maternity, and paternity leave, as well as other family-related leave taken during the regular work schedule, is captured in the ERP system. The diversity in working schedules limits reliable data collection to the onshore population only. Many instances of leave for offshore workers remain unreported since they often do not overlap with the working schedule.

Additional context

All employees have access to parental leave, holiday, sick leave, and compassionate leave. In 2024 the Group introduced a Life Phase policy to govern how to address employee needs in situations not covered under local employment legislation, such as flexible working hours and work-life balance.

S1-15(was S1-16)Compensation metrics (pay gap and total compensation)
Omitted
S1-16(was S1-17)Incidents, complaints and severe human rights impacts
Reported

Incidents, complaints and severe human rights impacts

S1-17 Metrics

Metric202420232022
The total number of incidents of discrimination, including harassment, reported in the reporting period1--
Number of complaints filed through channels for people in own workforce to raise concerns2--
Number of complaints filed to National Contact Points for OECD Multinational Enterprises---
Amount of material fines, penalties, and compensation for damages as result of violations regarding social and human rights factors---
Number of severe human rights issues and incidents connected to own workforce---
Number of severe human rights issues and incidents connected to own workforce that are cases of non-respect of UN Guiding Principles and OECD Guidelines for Multinational Enterprises---
Amount of material fines, penalties, and compensation for severe human rights issues and incidents connected to own workforce---
Number of severe human rights cases where undertaking played role securing remedy for those affected---

Accounting Policies - S1-17 Number of incidents of concern

The Group has many channels available to report and capture grievance reports of bullying, harassment and discrimination, or other compliance breaches.

The most reliable and complete source of reporting is through anonymous self-reporting via the annual onshore work environment survey and the semi-annual offshore survey.

In 2024 the onshore survey reported 1 incident of self-reported harassment. On average, the percentage of incidents is zero. One limitation in the reporting is that only 72% of employees responded, meaning some information may be missing.

The majority of the reporting requirements were introduced in 2024, and there is no comparable data available for 2023 and 2022.

Additional Context

The Group has not identified any actual negative impacts on human rights or labour conditions in 2024, and has therefore not undertaken remedial actions.

People affected by identified human rights violations will receive appropriate remedy, on a case-by-case basis. Remedy could be financial compensation, restitution or rehabilitation (e.g. reinstating a wrongfully dismissed worker), and/or public apologies or guarantees of non-repetition. Remediation for actions for which the Group is liable will be handled in accordance with local laws.

In the event of reporting via the whistleblower channel, the Compliance Officer will identify the nature of the complaint and forward the report to the relevant function leader. For cases concerning human rights and working conditions, this will be the SVP HR. The report will be investigated and actions tailored to the specific issue, if any finding can be determined. In the event a grievance is raised, the Group may also follow the location disciplinary procedure, or procedure related to bullying, harassment, and discrimination.

G1Business Conduct

G1-1Business conduct policies and corporate culture
Omitted
G1-2Management of relationships with suppliers
Omitted
G1-2(was G1-3)Prevention and detection of corruption and bribery
Omitted
G1-4Incidents of corruption or bribery
Omitted
G1-5Political influence and lobbying activities
Omitted
G1-6Payment practices
Reported

Payment practices

Payment terms and performance

The Group's standard terms of payment are 45 calendar days after receipt of invoice. The Group currently does not differentiate payment terms based on supplier category. Deviations to the standard payment terms of 45 days occur on a regular basis as the procurement or contract team and supplier negotiate the terms and conditions.

Average payment performance (2024):

  • Average time to pay an invoice (from invoice date): 44.8 days
  • Average time to pay an invoice (from contractual commencement of payment term): 39.7 days

Payment practices metrics

Metric2024
Total number of payments14,493
Number of payments aligned with the standard payment terms (45 days)9,998
Percentage of payments aligned to the standard payment terms69%
Number of legal proceedings currently outstanding for late payments-

Payment management approach

Payments are monitored through the ERP system, ensuring timely payment once goods or services are received and verified. Long-distance shipments are paid against proof of delivery, and service invoices are processed after time sheet approval. These practices minimise late payments and support supplier cash flow, particularly for small and medium-sized enterprises.

For specific contract arrangements, payment terms vary:

  • Management fees from drilling contracts are usually payable on a monthly basis
  • Day rate based transaction prices are usually due on a monthly basis
  • Some mobilisation and demobilisation payments may be made up-front or when certain milestones are met