Odfjell Drilling

The role of the administrative, management and supervisory bodies

Reference: page 23; datapoints incorporated by reference from the Corporate Governance Report (pages 11, 13) and the Audit Committee and Board of Directors reports (pages 12, 19).

"The Board holds the ultimate accountability for sustainability-related IROs and integrates sustainability-related aspects into corporate strategy and decision-making. Responsibilities include policy approval and oversight, risk management and internal controls, monitoring sustainability performance, and overseeing regulatory compliance and best practice" (page 23).

"The Audit Committee, in coordination with the Board, reviews sustainability performance quarterly and convenes additional meetings as needed. Employee representation is present in Norwegian subsidiaries." The Board and the Executive Management Team (EMT) "have the expertise to oversee the material IROs identified in the DMA. Training and development programmes are implemented if and where competency gaps are identified" (page 23).

Executive oversight for specific sustainability topics is set out in the governance model (Figure 1, page 23), supported by internal controls integrated into the Enterprise Risk Management (ERM) framework. The VP Sustainability, together with corporate functions, provides regular updates to the Board and EMT. The Group applies the ISO 31000 risk management framework (page 23).

Board composition datapoints (number of executive and non-executive members, gender diversity ratio, percentage of independent members) are incorporated by reference to the Corporate Governance Report, page 13; Board competencies to page 11 (BP-2 table, page 22). The policy framework and the bodies responsible for each policy are set out on page 26.

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

Reference: page 23; material IROs addressed by the Board incorporated by reference to the Board of Directors report, page 19.

"The Board and its committees receive systematic updates on sustainability-related IROs. This includes the annual DMA, quarterly and annual sustainability reports, updates on due diligence processes, policy compliance, risk mitigation measures, and progress on sustainability targets, metrics and initiatives, aligned with the ESRS" (page 23).

"Before approval by the Board, the Audit Committee reviews the annual DMA, as well as quarterly and annual sustainability reports, ensuring compliance with regulatory requirements and strategic objectives" (page 23).

The Corporate Risk Committee (CRC) "ensures that high-value tenders and contracts undergo comprehensive risk assessments covering financial and non-financial exposures, including sustainability and integrity risks" (page 23). Sustainability-related IROs form part of the Board's strategic oversight including major transactions and the ERM process, with Operational Risk Registers feeding into the ERM (page 23).

The 2025 DMA report "was presented to the Audit Committee for review before it was discussed and approved by the Board" (page 29). The policy framework is also referenced under GOV-1 and GOV-2 on page 26.

Integration of sustainability-related performance in incentive schemes

Reference: page 23; further detail incorporated by reference to the Executive Remuneration Report, page 16.

"Variable remuneration criteria are linked to strategic objectives, including emissions reduction and QHSSE performance. Further information on the incentive schemes is available in the Executive Remuneration Report" (page 23). The BP-2 incorporation-by-reference table records this as "GOV-3, E1.GOV-3 Information on sustainability-linked remuneration", pointing to page 16 (page 22).

Caveat worth noting. The E1 targets section states the opposite for climate specifically: "Executive management is accountable for delivering the Group's climate strategy, however, executive remuneration is not currently linked to climate-related performance metrics or GHG emission reduction targets" (page 34). The two statements are not reconciled in the report, and no percentage of variable remuneration linked to sustainability performance is quantified in the sustainability statement itself.

Statement on due diligence

Reference: page 23 (mapping table "Reference to core elements of due diligence").

"Sustainability due diligence is embedded in the Group's governance framework, strategy, and business model, through binding policies and procedures, as outlined in the policy framework. The 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" (page 23).

The mapping table on page 23 locates each core element:

• Embedding in governance, strategy and business model: GOV-1 p.23, GOV-2 p.23, GOV-3 pp.23 and 16, SBM-3 p.28
• Engagement with affected stakeholders: GOV-2 p.23, SBM-2 p.27, IRO-1 p.29, MDR-P E1-2 p.31, E2-1 p.41, E4-2 p.43, E5-1 p.44, S1-1 pp.49-52, S2-1 p.56, G1-1 p.58
• Identifying and assessing adverse impacts: SBM-3 p.28, IRO-1 p.29 and the topical IRO-1s (E1 pp.31-32, E2 p.41, E4 p.43, E5 p.44, S1 pp.47-52, S2 p.56, G1 pp.58-60)
• Actions to address adverse impacts: MDR-A E1-3 p.33, E2-2 pp.41-42, E4-3 p.43, E5-2 pp.44-45, S1-4 pp.49-52, S2-4 p.57
• Tracking effectiveness and communication: MDR-M and MDR-T entries across pp.34-36, 42-46, 52-55, 57, 59-60

"Potential adverse impacts are mitigated through the Group's risk-reducing measures and controls. Identified actual adverse impacts are remediated on a case-by-case basis, depending on severity, scope, and the Group's leverage. Business opportunities carrying unacceptably high risks are rejected" (page 23).

Risk management and internal controls over sustainability reporting

Reference: page 25; incorporated by reference to the Audit Committee report (page 12) and Corporate Governance (page 13).

"The Group's sustainability risk and quality management processes are supported by internal control systems that cover the full scope of sustainability reporting. These controls are aligned with the Group's financial reporting control framework and follow the Committee of Sponsoring Organisations of the Treadway Commission (COSO) framework and ISO 31000 risk management guidelines" (page 25). The framework is illustrated in Figure 3 (page 25).

"To ensure reliable sustainability reporting, a dedicated reporting system serves as the centralised sustainability reporting hub, streamlining data collection, standardising reporting processes and providing built-in quality controls, including audit trails. Internal reviews, cross-functional verification, annual internal audits, and independent third-party assurance further strengthen reliability" (page 25).

"The CRC and the Audit Committee have oversight of sustainability-related risks and the risk management framework, consistent with the governance structure described in GOV-2" (page 25). For value chain data the Group "works closely with suppliers to secure a shared understanding of data requirements and quality expectations" (page 25).

The statement records no risk register of sustainability reporting risks with likelihood and magnitude, and no description of how findings from these controls were reported to the Board during 2025.

Strategy, business model and value chain

Reference: page 24; fleet and operations detail pages 6-9 and 19.

Odfjell Drilling is a drilling contractor operating "a state-of-the-art fleet of semi-submersible Mobile Offshore Drilling Units (MODUs)" for Exploration and Production (E&P) companies, creating value "across exploration drilling, field development activities, plug and abandonment (P&A), and CO2 storage appraisal and well operations" (page 24).

"In 2025, the Group's total revenue was USD 901 million, comprising USD 846.5 million from the oil and gas sector and USD 54.5 million from the Carbon Capture and Storage (CCS) sector. The CCS-related revenue is taxonomy-aligned under the Waste Treatment and Disposal category" (page 24). Two business segments, Own Fleet and External Fleet, with operational management in Norway, the UK and Malta (page 24).

Operational context is disclosed candidly: "The Group operates as a drilling contractor within a scope defined by E&P operators who hold production licences and are responsible for regulatory compliance, impact assessments and permitting. The Group does not hold production licences and does not decide where drilling activities take place, which technologies are selected, or the broader field development strategy" (page 24).

Upstream: "suppliers providing equipment, technology, services, and operational support needed for offshore drilling... neutral with respect to whether the rig is engaged in oil and gas or CO2 storage activities". Downstream: "defined by each E&P operator's sector activity and strategy for offshore oil and gas or CO2 storage" (page 24). Figure 2 sets out the oil and gas value chain; a separate CCS value chain is described. "To deliver on the Group's and operators' ambitions to reduce emissions from drilling operations and reach net zero, the Group depends on close collaboration and co-investment with E&P operators" (page 24).

Interests and views of stakeholders

Reference: page 27 (stakeholder table); further stakeholder engagement under E5 on page 45 and S2 on page 56.

"Through effective stakeholder engagement, the Group seeks to understand external priorities and perspectives, and to assess both positive and negative impacts from its activities" (page 27). "Insights from the Group's stakeholder engagement processes inform both the strategy and business model and form a core component of the DMA as described in IRO-1 in the DMA Process. As part of the annual DMA cycle, the Group assesses stakeholder views and adjusts its strategy where relevant in response to these inputs" (page 27).

The table on page 27 sets out six stakeholder groups with the engagement channels, purpose and value created for each: investors and financial institutions (quarterly and annual reporting, roadshows, investor conference Q&A); rig owners (operational performance reports, joint ventures, safety and environmental compliance updates); clients (service performance reviews, feedback sessions); suppliers (performance feedback and improvement plans, audits, collaboration on innovation and sustainability initiatives); employees including local unions and employee groups (town halls, engagement surveys, union negotiations, exit interviews); and authorities (compliance reporting, industry forums, community engagement).

"The Group's governance structure, as disclosed in GOV-1, ensures that material stakeholder insights are communicated to the EMT and the Board of Directors as part of decision-making on strategy and sustainability priorities" (page 27).

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

Reference: page 28 (2025 DMA results table); topical SBM-3 entries on pages 31, 43, 47, 49-52, 56, 58-60.

"The DMA identified 19 material IROs covering the following seven main topics: E1 Climate Change, E2 Pollution, E4 Biodiversity, E5 Resource Use and Circular Economy, S1 Own Workforce, S2 Workers in the Value Chain, and G1 Governance" (page 28).

"The identified IROs with double materiality are climate change mitigation, pollution of water, resource use, health and safety, labour conditions, corruption and bribery risk, and management of suppliers. The identified positive and negative impacts are pollution of air, waste, equal treatment and opportunities, psychosocial work environment, training and skills development, human rights and labour conditions, and corporate culture. The identified financial risks and opportunities are climate change adaptation and climate change mitigation" (page 28).

The table records for each IRO the category (actual/potential negative or positive impact, risk, opportunity), value chain location (US upstream, OO own operations, DS downstream) and time horizon (S 1-2 years, M 3-5 years, L more than 5 years), with impact and financial materiality shown as one, two or three bars (page 28).

"All material IROs have been assessed for near-term financial effects, with no significant risk of material adjustment identified" (page 28). Two changes from 2024: "The DMA now incorporates the impact of E2 Substances of Concern under S1 Health and Safety, reflecting updated internal evaluations of chemical exposure risk. In addition, the IRO for Biodiversity was consolidated into one high-level IRO" (page 28).

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

Reference: page 29; topical IRO-1 sections on pages 31-32 (E1), 41 (E2), 43 (E4), 44 (E5), 47-52 (S1), 56 (S2) and 58-60 (G1).

"The scope of the DMA included the Group's own operations and value chain. Seven ESRS topics were assessed as material, of which five have double materiality. The assessment was based on inherent risks and impacts" (page 29).

Five-step methodology, unchanged from 2024 (page 29): (1) identification of sustainability topics from a review of the FY24 DMA, the climate risk assessment, ESG ratings, industry reports and peer analysis; (2) assessment of impact materiality through stakeholder workshops and internal subject matter experts considering severity, scope and likelihood, with external stakeholders including clients consulted; (3) assessment of financial materiality "through discussions with the CFO and Senior Vice President (SVP) Finance... based on the Group's ERM framework and financial risk matrices"; (4) validation by the Sustainability team; (5) "Review and approval by the Audit Committee and the Board".

Thresholds are stated: "Impacts in the first tier of suppliers and business relationships are prioritised, as the Group has greater influence over those areas. Both actual and potential impacts are assessed across short, medium and long-term time horizons, with severity taking precedence over likelihood for human rights risks" (page 29). The financial materiality threshold covers effects on "development, financial position, financial performance, cash flows, access to finance, or cost of capital over the short, medium, or long-term" (page 29).

No numeric scoring scale or cut-off score is published.

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

Reference: page 30 ("ESRS Disclosure Requirements", labelled IRO-2); appendix "IRO-2: Datapoints deriving from other EU legislation", pages 107-109.

The Group prints a full ESRS content index on page 30. Each disclosure requirement is listed with either a page reference, the marker "Phase-in", or "Not material".

Marked Phase-in (six entries): E1-9, E2-6, E4-6 and E5-6 (all four anticipated-financial-effects DRs), S1-7 characteristics of non-employee workers, and S1-11 social protection. Basis of preparation confirms: "The Group has applied the relevant transitional provisions as outlined in ESRS 1:137, including those affected by the EU's 'stop-the-clock' decision, allowing continued phase-in of certain data points" (page 22). The E1-9 phase-in is restated in the text: "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" (page 37).

Marked Not material (seven entries): E2-5 substances of concern and very high concern; ESRS E3 water and marine resources in full; E5-4 resource inflows; S1-12 persons with disabilities; ESRS S3 affected communities in full; ESRS S4 consumers and end users in full; G1-5 political influence and lobbying activities.

The appendix on pages 107-109 tabulates the datapoints deriving from other EU legislation (SFDR, Pillar 3, Benchmark Regulation, EU Climate Law) against page references or a "Not material" marker.

Transition plan for climate change mitigation

Reference: page 31; actions and levers page 33.

"The Group's transition plan sets out the activities and measures required to achieve the target of reducing emissions from the Own Fleet by 21 % by 2030 and to enable zero-emission drilling by 2050. It follows a merit-order approach that prioritises emission reductions through efficiency improvements, then hybrid solutions, and ultimately alternative low-and zero-carbon fuels and solutions" (page 31).

"The transition plan is approved by the EMT and the Board to ensure robust governance and accountability" (page 31).

Paris alignment is expressly denied. "The transition plan is not Paris-aligned, as the oil and gas sector is excluded from the EU Paris-aligned benchmarks" (page 31). The 2050 ambition is nonetheless described elsewhere as "Zero emission drilling by 2050, aligning with a 1.5°C trajectory, in accordance with the Science Based Targets initiative" (page 34). The report does not reconcile the two statements and no SBTi validation is claimed.

Investments. "As of 2025, the Group has invested USD 49 million in CapEx to implement measures and activities outlined in the transition plan, such as retrofitting of battery, hybrid solutions, and technical modifications. These investments are partially supported by the Norwegian NOx Fund" (page 31).

Locked-in emissions. "Because the fleet consists of diesel-powered drilling units designed for 30-40 years of operation, a share of emissions remains locked in until major upgrades are implemented" (page 31). The assessment is qualitative; no locked-in emissions figure is given.

Headline progress: "34 % reduction in absolute emissions from the own fleet since 2019" (page 31).

Identification of climate-related risks and scenario analysis

Back-filled from ESRS 2 IRO-1 and the E1 climate risk section, where this content is disclosed in the FY2025 report (page 32). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Classification (adopted E1 paragraph 15). The risk table on page 32 classifies each climate risk explicitly as transition risk (market, policy and legal, reputation) or physical risk (acute, chronic), and lists three opportunities (market, reputation).

Methodology (paragraph 16). "The Group's assessment of climate-related risks and opportunities is conducted in line with the Task Force on Climate-related Financial Disclosures (TCFD) framework... The Group has screened its activities and plans to identify actual and potential future GHG emission sources and other climate-related impact drivers across own operations and the value chain" (page 32). "The climate risk assessment was reviewed and updated in 2025. It covers all the Group's activities and operational locations and takes geographic variations into account. It was developed with contributions from Corporate Management, Finance, Supply Chain, Human Resources (HR), and technical disciplines" (page 32).

Scenarios (paragraph 17). Physical risk used "the Intergovernmental Panel on Climate Change (IPCC) Shared Socioeconomic Pathway 5-8.5, representing a high-emissions scenario with increased frequency of extreme weather events" - satisfying the high-emission scenario limb. Transition risk "was analysed using IPCC Shared Socioeconomic Pathway 1-2.6 (low-carbon transition) and the International Energy Agency (IEA) Net Zero by 2050 scenario, assessing the impact of stricter climate policies, lower fossil-fuel demand, and financing challenges. The analysis also considered stranded-asset risks, carbon-pricing exposure, and capital-cost fluctuations" (page 32).

Gap. No global average temperature projection per scenario is stated (paragraph 17(a)(iii)), and the key assumptions on public policy, macroeconomics, energy mix and technology are not itemised.

Notable finding: "The identified physical climate risks were assessed as not material in the 2025 DMA and are therefore not reflected in the DMA results" (page 32).

Resilience in relation to climate change

Back-filled from ESRS 2 SBM-3 and the E1 climate risk section, where this content is disclosed in the FY2025 report (pages 28 and 32). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Results of the analysis (paragraph 19(a)). "Climate-related risks and opportunities inform the Group's strategic direction, business model development, and long-term resilience. Insights from the climate-risk assessment are incorporated into investment decisions and operational planning to ensure that the Group remains competitive in an evolving energy market. Additionally, the climate-risk assessment ensures that the Group has considered its access to capital under several scenarios" (page 32). "By assessing climate-related opportunities, the Group also builds the resilience to successfully adapt its business model to market developments and regulatory changes" (page 32). Page 28 confirms "the strategy and business model resilience have been assessed for all material IROs".

Uncertainty (paragraph 19(b)). "The main uncertainties primarily relate to potential changes in regulatory requirements and financing conditions" (page 32).

Capacity to adjust or adapt (paragraph 19(c) / AR 10). "Climate risk assessments inform the Group's evaluation of financial resilience and are integrated into impairment testing to ensure that financial assumptions reflect relevant climate scenarios. Ongoing access to finance is secured by aligning asset plans with climate scenarios, which guide decisions on redeployment, upgrades, and decommissioning. The scenarios are consistent with the climate-related assumptions used in the financial statements. Time horizons are aligned with asset lifetimes, strategic planning, and capital allocation horizons" (page 32).

"No assets have been identified as requiring material additional effort to reach the 2030 emission reduction target and the 2050 ambition for zero-emission drilling, beyond what is already outlined in the transition plan" (page 32).

The report does not label any of this as an ESRS-defined resilience analysis, and gives no quantified resilience results.

Policies related to climate change mitigation and adaptation

Reference: page 31 (marked "E1-2, MDR-P").

"The Group's approach to climate mitigation and adaptation, including the approach to physical and transition climate risks and opportunities, is anchored in our Sustainability Policy. It is supported by the Energy & Emissions Policy, the Energy & GHG emissions management procedure and the Environment, Social, Responsibility and Governance in Odfjell Drilling procedure. Together, these policies and procedures outline the Group's commitment to continuously reduce its GHG emissions in line with industry best practices and ensure effective energy management. They also formalise the efforts to work towards enabling zero-emission drilling operations" (page 31).

The policy table on page 26 records the Energy & Emissions Policy as owned by the CEO, covering "The Group, business partners, suppliers, contractors, and agents", incorporating the Paris Agreement, the International Maritime Organisation and ISO 50001, and mapped to section E1. The Sustainability Policy is approved by the Board and covers E1, E2, E4, E5, S1, S2 and G1.

"The policies are reviewed regularly and updated to reflect regulatory developments, emerging risks, and industry best practice, with a minimum updating frequency of every third year. Most of the policies listed in the policy table are publicly available" (page 26). Operational responsibility "lies with line management and is embedded in the CMS through procedures and routines. Compliance is monitored through several channels such as internal audits, client verification, and third-party assessments" (page 26).

No policy is described as setting quantified climate exclusions or thresholds.

Actions and resources in relation to climate change policies

Reference: page 33 (marked "E1-3, MDR-A"); Figure 4 transition plan on the same page; investment figure also page 31.

"The Group has conducted an industry and MODU scenario analysis on future net zero solutions to identify key decarbonisation levers. The scenario analysis includes an assessment of internal factors such as technological maturity and availability, and external factors such as market and regulatory developments. The transition towards zero-emission drilling requires a combination of improved operational efficiency, integration of new technologies, and availability of alternative low and zero-carbon fuels" (page 33).

Figure 4 groups the plan into four categories: adjusted activity; completed activities and installed measures; increased energy optimisation / measures to be installed; and alternative fuels and electrification.

Completed and installed measures (page 33): "Installed hybridised power systems, reducing the need for additional generators"; "Implemented energy monitoring systems for real-time optimisation"; "Conducted feasibility study of ammonia as a retrofit solution for drilling rigs (2025)"; "Conducted electrification feasibility studies to identify further emission-reduction potential (2025)"; "Energy management coaching (2025)"; "DNV notation Abate P+ (2025)".

To be implemented: "Optimising power consumption through energy-efficient technologies"; "Reducing thruster use during anchoring to minimise fuel consumption"; "Upgrading cooling systems to lower power demand"; "Automating emissions tracking"; "Assessing offshore electrification potential"; "Strengthening supply chain readiness for low-carbon fuel adoption" (page 33).

Resources. "The actions outlined in the transition plan require significant capital investments, with a cumulative USD 49 million spent as of the end of 2025 on efficiency improvements, new technology, and emissions data management" (page 33). Future needs "are expected to include continued CapEx for fleet upgrades and decarbonisation solutions" but are not quantified.

Dependencies. "Implementation of these levers depends on the availability of alternative fuels and infrastructure for electrification, regulatory incentives and emission trading schemes, technological advancements in low-emission drilling solutions, and operator collaboration" (page 33).

Targets related to climate change mitigation and adaptation

Reference: page 34; Figures 5-8 on the same page.

"These targets apply to Scope 1, Scope 2 (market based scenario), and Scope 3: Category 1, 2 and 13. The Group has also established a company-specific target for emissions per well" (page 34).

Own Fleet (Scope 1 and Scope 3 C13). "Following the acquisition of Deepsea Bergen, the 2030 target has been updated from 30% to 21% to reflect the fleet expansion. The current fleet reduction targets are: 21% reduction by 2030; Zero emission drilling by 2050, aligning with a 1.5°C trajectory, in accordance with the Science Based Targets initiative" (page 34). "The targets are based on a 2019 baseline of 210,685 tCO2e... Since 2019, the Group has reduced emissions by around 34% (Scope 1 and Scope 3: C13), equivalent to 71,880 tCO2e" (page 34).

Scope 2. "The Group has set an absolute target of zero Scope 2 emissions by 2030. This will be achieved through the purchase of Guarantees of Origin (GoOs) to match electricity consumption with certified renewable energy sources" (page 34). Scope 2 was 0.2% of total market-based emissions in 2025.

Scope 3 C1 and C2. These "together accounted for 38% of the Group's total emissions in 2025" and are calculated on spend-based secondary data; the target is a data-quality target - "to increase the share of primary activity data and primary emission factors for C1 and C2 in the medium-term" - not an absolute reduction target (page 34).

Emissions per well. "40 % reduction by 2026; Zero emissions per well by 2050", against "a 2014 baseline of 6,700 tCO2e". "In 2025, the Group achieved a 27% reduction in emissions per well compared to 2014"; the year-on-year increase "is due to an increase in well length and complexity compared with 2024 well operations" (page 34).

An additional Scope 1 target is "to maximise shore-power use where available" during yard stays, unquantified (page 34).

"Executive management is accountable for delivering the Group's climate strategy, however, executive remuneration is not currently linked to climate-related performance metrics or GHG emission reduction targets. GHG emissions reductions are externally verified by the Group's auditor" (page 34).

Energy consumption and mix

Reference: page 36 (table and accounting policies).

"The Group operates in the oil and gas sector, classified as a high climate impact sector under the ESRS" (page 36).

Shares: market based fossil 99.8%, renewable 0.1%, nuclear 0.07%; location based fossil 99.5%, renewable 0.5% (page 36). The source-mix breakdown is given as fossil fuel 84% / nuclear 10% / renewable 6% under the market based method and fossil 2% / renewable 98% under the location based method for purchased electricity (page 36).

"For 2025, the Group did not purchase GoOs or other renewable energy certificates" (page 36). "The Group does not consume renewable fuels"; self-generated non-fuel renewable energy was 56 MWh (53 MWh) (page 36).

Energy intensity from high climate impact activities: 214 MWh per USD million (2024: 240), a 11% decrease, calculated on net revenue of USD 847 million from NACE code 09.10 activities (page 36). "The 2024 numbers have been updated from the 2024 annual report due to the availability of more accurate factors for the energy consumption mix" (page 36).

Gross Scopes 1, 2, 3 and Total GHG emissions

Reference: page 35 (table and commentary); accounting policies page 37.

Scope 3 is 98% of total market based emissions (page 35). GHG intensity was 268 tCO2e per USD million (2024: 324), down 17% (page 35).

Scope 1 rose 1,771 tCO2e "due to the Deepsea Stavanger SPS, the Deepsea Aberdeen SPS and the Deepsea Nordkapp yardstay" (page 35). "GHG emissions from regulated emission trading schemes" were 0% (page 35).

Methodology (page 37). Reporting follows the GHG Protocol, ISO 14064 and ESRS E1-6. Scope 1 arises "when the Group's Own Fleet is off contract"; C13 "covers emissions from the Group's Own Fleet when on contract". C1 and C2 use a spend-based method. Primary data is 80% for activity data and 30% for emission factors. Seven Scope 3 categories are reported; C3, C8, C9, C10, C11, C12, C14 and C15 are excluded. Deepsea Bergen emissions are included from 15 December 2025; C4, C5, C6 and C7 2024 figures were restated. "The Group did not have any biogenic emissions in 2025" (page 37).

GHG removals and GHG mitigation projects financed through carbon credits

Reference: page 37.

A nil return, stated in full: "The Group did not acquire carbon credits in 2025, or in previous years" (page 37).

E1-7 is listed in the ESRS content index with a page reference to page 37 (page 30), so it is disclosed rather than omitted. No GHG removals in own operations or the value chain are reported, and the climate targets are set out without any removals or credit component: the 2030 and 2050 targets are absolute reduction targets against a 2019 baseline of 210,685 tCO2e (page 34).

The Group's only CO2-storage involvement is as a contractor drilling appraisal wells for the Smeaheia and Havstjerne CCS projects for client licence-holders, disclosed under the EU Taxonomy as activity 5.12 "Underground permanent geological storage of CO2" generating USD 54.5 million of taxonomy-aligned turnover (pages 24, 38, 39) - not as a removal or credit claimed by the Group.

Internal carbon pricing

Reference: page 37.

A nil return, stated in full: "The Group does not have internal carbon pricing as of 2025" (page 37).

E1-8 is listed in the ESRS content index with a page reference to page 37 (page 30), so the absence of a scheme is a disclosure rather than an omission.

Carbon pricing nonetheless appears in the Group's risk analysis rather than its internal decision-making: the E1 IRO section records exposure "to the risk of increased cost due to emerging carbon pricing mechanisms and regulatory requirements for rig retrofitting" (page 31), and the transition-risk scenario analysis "also considered stranded-asset risks, carbon-pricing exposure, and capital-cost fluctuations" (page 32). The policy and legal transition risk row on page 32 names "Higher costs from carbon pricing, regulatory emission standards, and potential rig retrofitting requirements", with the response being to "Proactively work to reduce the Group's climate footprint in accordance with the transition plan and integrate regulatory developments in long-term planning".

In 2025 "the scope 1 emissions were not regulated under any emission trading schemes" (page 37).

Policies related to pollution

Reference: page 41 (marked "E2-1, MDR-P").

"The Group's approach to preventing and managing pollution is anchored in the Sustainability Policy and supported by the HSE Policy and the Environmental Principles. Together, these documents formalise the Group's commitment to prevent harm to people and the environment and ensure compliance with applicable environmental regulations across all operations" (page 41).

"The policies cover operational emissions, blowout risk and environmental performance requirements, and are integrated in the Group's management system through maintenance routines, barrier management, well control procedures, and emergency preparedness. This integration ensures that pollution prevention is carried out consistently and effectively across all operations" (page 41).

The policy table on page 26 records the HSE Policy as CEO-owned, covering "The Group, business partners, suppliers, contractors, and agents", incorporating ISO 45001, ISO 14001 and HSE legislation, and mapped to sections E2, E4, E5 and S1. The Environmental Principles are also CEO-owned and mapped to E2, E4 and E5, and "guide responsible chemical management" (pages 26, 43).

The policies are not described as addressing substances of concern or substances of very high concern as a separate commitment; the DMA folded chemical exposure into S1 Health and Safety (page 28).

Actions and resources related to pollution

Reference: pages 41-42 (marked "E2-2, MDR-A").

"The Group's strategy prioritises the prevention of major accidents, reduction of emissions to air, and robust emergency preparedness, as core elements of responsible offshore drilling. The Group's QHSSE Programme serves as the central framework for defining actions and monitoring performance across these focus areas. The programme consolidates internal requirements, client expectations, and regulatory obligations, into a unified annual plan with measurable KPIs" (page 41).

Well blowout prevention (page 42). Compliance with "stringent external regulations" and internal barrier management and well-control procedures, "equipment certification, SPSs, and a maintenance programme". Collaboration with the IADC, the International Association of Oil & Gas Producers and the IWCF. "All offshore personnel receive systematic well control training, including bi-annual certification in accordance with the IWCF"; "the Group conducts weekly well control drills".

Air pollution (page 42). "To drive NOx reductions, the Group has equipped several rigs with Selective Catalytic Reduction (SCR) systems. These installations enable NOx reductions of 70-80% compared to standard exhaust configurations. In addition, the Group has implemented fuel-efficient hybrid power solutions and energy management system upgrades to improve engine performance and reduce operating hours at suboptimal loads."

Resources. "As of 2025, the Group has invested a total of USD 49 million on our green rigs' projects. Several of these projects were supported by the NOx fund" (page 42). This is the same cumulative CapEx figure cited for the climate transition plan (pages 31, 33); the report does not split it between climate and pollution outcomes.

2025 addition: "the Group strengthened the focus on energy management through the energy management coaching initiative, initiated in 2025 and will continue throughout 2026" (page 42). Personnel in safety-critical roles "must hold valid well control certification in accordance with IWCF requirements and complete refresher training every two years" (page 42).

Targets related to pollution

Reference: page 42 (marked "MDR-T").

"The Group has a continuous non-scientific operational target of zero uncontrolled spills, embedded in the QHSSE Programme. This target supports the prevention of pollution to air and water, protection of ecosystems, and compliance with regulatory and client requirements. Performance is monitored through Synergi reporting, incident investigations, and management reviews. The target applies to all operations across the short, medium and long-term" (page 42).

"When setting targets, the Group, relies on industry knowledge and stakeholder insights, collected through the Stakeholder Engagement Processes" (page 42).

No air-pollution target is set. "The Group does not operate with a quantitative reduction target for NOx emissions but continues to implement technical and operational measures to reduce emissions over time, as described in the actions section above" (page 42).

Performance against the spills target in 2025 was zero uncontrolled spills to sea, unchanged from 2024 (page 42). No baseline year, no interim milestones and no scientific evidence base are given for the zero-spill target, which the Group itself labels "non-scientific".

Pollution of air, water and soil

Reference: page 42 (metrics table and accounting policies).

"NOx emissions are calculated using a rig specific conversion factor for the amount of ton NOx per m3 fuel. From 2025, the reporting methodology has been updated to include all operational NOx emissions, and is no longer limited to the scope defined by the Norwegian excise tax regulations" (page 42). The change is also flagged in the basis of preparation, which lists methodology updates to "greenhouse Gas (GHG) emissions, energy consumption and NOx emissions" among the changes from the 2024 report (page 22).

"Data for pollution-related accounting and reporting is collected through monitoring systems that track quantities of gases, including those added during installation, maintenance, or due to leakage. This data is stored in the CMS system as work orders, including records of checks, repairs, and purchases, along with details of recycling, recovery, and disposal" (page 42).

Only two metrics are given. No microplastics, emissions to water or soil figures are reported, consistent with the DMA identifying only pollution of air and pollution of water as material (page 28), and with the E-PRTR pollutant listing not being presented.

Transition plan on biodiversity and ecosystems

Reference: page 43 (marked "IRO-1, E4-1"); listed in the ESRS content index at page 43 (page 30).

The Group states plainly that it has none, and gives its reason: "The materiality and scope of the impact will be evaluated further in the coming years to ensure effective mitigation of potential environmental impacts. Consequently, the Group does not have a transition plan for biodiversity and ecosystems, and has opted for the phase-in options for E4 Biodiversity" (page 43).

The consideration of biodiversity in the strategy and business model is disclosed instead through the operational context: "The Group operates as a drilling contractor within a defined scope set by E&P operators, who hold production licences and are responsible for environmental impact assessments, permitting, and regulatory compliance. The Group does not hold production licences and is not involved in opening new areas for oil and gas production or CO2 storage. Operational parameters and drilling equipment are determined by client contracts and well programmes. Additionally, the operators are responsible for assessing Particularly Valuable and Vulnerable Areas (SVOs)... Therefore, the Group's influence on biodiversity-related factors is limited" (page 43).

"While no direct dependency or financial risk related to biodiversity or marine ecosystem changes has been identified for the Group's core activities, we remain committed to maintaining high environmental standards and supporting our clients' biodiversity objectives" (page 43).

The single material biodiversity IRO is that "Offshore drilling may disturb marine habitats and affect ecosystems", a potential negative impact in own operations and downstream over short, medium and long term (page 28).

Policies related to biodiversity and ecosystems

Reference: page 43 (marked "E4-2, MDR-P").

"The Group's commitment to biodiversity and environmental protection is anchored in the Sustainability Policy, HSE Policy, Environmental Principles, and Social Responsibility Principles. Together, these policies set clear expectations for environmental stewardship, responsible operations, and continuous improvement across the Group" (page 43).

"In line with the HSE Policy, the Group is committed to mitigating biodiversity and ecosystem impacts in accordance with the Global Biodiversity Framework. The Sustainability Policy further emphasises Environmental Care, committing the Group to minimise environmental impact with a focus on GHG emissions, pollution of air, and pollution of sea. The Environmental Principles guide responsible chemical management" (page 43).

The policy table on page 26 confirms the HSE Policy incorporates the Global Biodiversity Framework alongside ISO 45001, ISO 14001 and HSE legislation, is owned by the CEO, and covers "The Group, business partners, suppliers, contractors, and agents" across sections E2, E4, E5 and S1.

The policies are not described as addressing traceability of products, deforestation or sustainable land and ocean use practices as separate commitments, and no biodiversity-specific policy is disclosed.

Actions and resources related to biodiversity and ecosystems

Reference: page 43 (marked "E4-3, MDR-A").

"The Group's approach to biodiversity protection is embedded in the management system and ensures consistent identification, assessment, and mitigation of biodiversity impacts and risks across all operations. Biodiversity considerations are incorporated into planning, operations, and continuous improvement processes" (page 43).

"Despite the Group's limited control over biodiversity-related factors, it recognises that its operations may have a potential negative impact on biodiversity through emissions to air or potential uncontrolled spills to sea. Emissions management is addressed in E1 Climate Change, while spill prevention and discharge control is addressed in E2 Pollution" (page 43).

The one quantified operational fact disclosed: "While operators lead SVO assessments, the Group supports their planning to ensure that environmental risk management remains proportionate to local ecosystem sensitivity and aligned with regulatory and client expectations. In 2025, the Group did not conduct drilling operations within SVO areas" (page 43), SVO being Particularly Valuable and Vulnerable Areas.

"Environmental performance is followed up through internal audits, management reviews, and regular reporting to EMT and the Board. Insights from these processes, regulatory developments, and client requirements, are used to strengthen procedures, operational practices, and reporting quality" (page 43).

No financial resources are allocated to biodiversity actions in the disclosure, and no mitigation hierarchy, offsets or restoration measures are described.

Targets related to biodiversity and ecosystems

Reference: page 43 (marked "E4-4, MDR-M, E4-5").

The Group sets none and says so: "For 2025, the Group has not identified material biodiversity-related impacts that require specific targets outside of what is already established for E1 Climate change, E2 Pollution and E5 Resource use and circular economy" (page 43).

Read with the E4 IRO section, the reasoning is that the Group's influence over biodiversity outcomes is constrained by its role: "The Group operates as a drilling contractor within a defined scope set by E&P operators, who hold production licences and are responsible for environmental impact assessments, permitting, and regulatory compliance... Therefore, the Group's influence on biodiversity-related factors is limited" (page 43). The Group "has opted for the phase-in options for E4 Biodiversity" and states that "The materiality and scope of the impact will be evaluated further in the coming years" (page 43).

The targets the Group does rely on for biodiversity outcomes are therefore the E2 zero-uncontrolled-spills operational target (page 42) and the E1 fleet emission reduction targets of 21% by 2030 and zero-emission drilling by 2050 (page 34).

No ecological thresholds, no biodiversity baselines and no interim milestones are disclosed, and the target section carries no base year or scope.

Impact metrics related to biodiversity and ecosystems change

Reference: page 43 (marked "E4-4, MDR-M, E4-5"); listed in the ESRS content index at page 43 (page 30).

No quantified biodiversity impact metrics are presented. The disclosure is combined with targets under the heading "Targets and metrics", where the Group states: "For 2025, the Group has not identified material biodiversity-related impacts that require specific targets outside of what is already established for E1 Climate change, E2 Pollution and E5 Resource use and circular economy" (page 43).

The one measurable statement about biodiversity impact in the reporting year is a nil return on operations in sensitive areas: "In 2025, the Group did not conduct drilling operations within SVO areas" (page 43), SVO being Particularly Valuable and Vulnerable Areas assessed by the licence-holding operators.

The identified impact pathway is described qualitatively: "Anchoring or riser placements may cause short-term disturbances to local biodiversity and seabed integrity, particularly in areas with sensitive habitats, such as cold-water corals or sponge grounds. The identified potential impacts are based on the fleet's geographical site of operations in 2025, as outlined in the Board of Directors report" and "cumulative operations in concentrated offshore regions could contribute to wider ecosystem pressure when combined with other industrial activities" (page 43).

No land or sea-use change metrics, no number or area of sites near biodiversity-sensitive areas, and no species or ecosystem condition metrics are given.

Policies related to resource use and circular economy

Reference: page 44 (marked "E5-1, MDR-P").

"The Group's approach to resource use and circular economy is anchored in the Sustainability Policy, HSE Policy, the Environmental Principles, and Environment, Social Responsibility and Governance policy. The Sustainability Policy sets the overarching direction for minimising environmental impact through responsible use of materials, efficient operations, and sound environmental practices. The HSE Policy and Environmental Principles complement this by requiring efficient use of natural resources, reduction of waste, and responsible chemical management" (page 44).

"Together, these policies and principles establish clear expectations for responsible resource management, waste reduction, and continuous improvement across the Group's operations" (page 44).

Operational policies sit beneath the framework: "The Group follows a global waste management procedure and a dedicated hazardous waste procedure to mitigate the potential negative impacts associated with waste. These procedures place strong emphasis on reducing, reusing, and recycling materials as far as possible, and on segregating waste into appropriate fractions to ensure safe storage, handling, and disposal. Waste segregation plans are implemented across all facilities, including rigs, offices, warehouses, and yards" (page 45), together with "Rig-specific waste management plans and procedures" (page 45).

The policy table (page 26) maps the Environmental Principles and the HSE Policy to section E5. No policy commitment on the waste hierarchy, on sustainable sourcing of renewable resources or on avoiding virgin non-renewable resource use is stated as such.

Actions and resources related to resource use and circular economy

Reference: pages 44-45.

Actions fall under two headings: life cycle management (LCM) and waste management.

Life cycle management (page 44). "Lifecycle assessments have been carried out for all rigs and are integrated into the Group's maintenance philosophy, strategy, and management system... Odfjell Drilling's 6th generation MODUs have a design life of 20 years and an operational life expectancy of more than 30 years." Three core elements: (1) Maintenance - "All rigs are maintained to ensure that hull structure, machinery, systems, and equipment remain in sound condition throughout their operational life. Planned and corrective maintenance activities are executed through a class-approved Maintenance Management System"; (2) Continuous class programme - "revising the SPS philosophy and transitioning toward a continuous class programme based on an integrated maintenance philosophy. The main objective is to reduce costs and minimise yard stays"; (3) Reuse and recycling - "a structured approach to circulating equipment through an established equipment pool system. By enabling components, tools, and selected spare parts to be reused across multiple rigs, the system reduces the need for new procurement, minimises waste generated from maintenance activities and supports more circular use of materials".

Waste management (page 45). "During drilling operations, the operator is responsible for managing and disposing production waste, while the Group holds responsibility for waste generated off contract and during SPS activities for the Own Fleet."

Expected outcomes (page 45): a revised holistic LCM strategy, extended fleet operational lifetime, "Reduced resource use and emissions from newbuilds", reduced footprint from waste and rig decommissioning, and improved handling of hazardous and non-hazardous waste.

Resources. No CapEx or OpEx figure is attached to these actions; the report directs readers to "the financial statements, Note 9" for SPS-related CapEx (page 45). Progress is measured through "equipment reliability, maintenance backlog trends, availability, and compliance with class-approved maintenance programmes" and, for waste, "waste volumes, segregation performance, recycling rates" (page 45).

Targets related to resource use and circular economy

Reference: page 45 (marked "MDR-T").

Fleet lifetime extension target. "The Group has set a voluntary target to extend the operational lifetime of its fleet through structured LCM. Target rig lifetimes range from a minimum of 20 years, up to 40 years enabled by structured maintenance programmes and strategic planning. This target is contingent on successfully executing SPS cycles in line with industry safety and maintenance standards. The target is not science-based but based on industry best practice and regulatory expectations" (page 45).

2025 progress is reported rig by rig (page 45):

• Deepsea Atlantic, built 2009, "has reached 16 years and secured an additional 5-year extension following the 2024 SPS"
• Deepsea Aberdeen, built 2014, "has reached 11 years and secured an additional 5-year extension following the 2025 SPS"
• Deepsea Stavanger, built 2010, "has reached 16 years and secured an additional 5-year extension following the 2025 SPS"
• Deepsea Nordkapp, built 2019, "has reached 6 years and secured an additional 5-year extension following the 2024 SPS"

No waste target. "The Group has not established specific, quantifiable targets for waste management, but maintains a strong commitment to compliance with regulated waste management practices, adherence to internal procedures, and an emphasis on waste reduction, reuse, and recycling opportunities during SPS activities" (page 45).

No target is set for resource inflows, recycled content, or the share of secondary materials, consistent with E5-4 being marked "Not material" in the content index (page 30).

Resource outflows

Reference: page 46 ("Resource Outflows", marked "E5-5, MDR-M"); accounting policies on the same page.

For a drilling contractor the outflow disclosure is a waste disclosure: the Group provides drilling services rather than products, and reports no durable products, no recyclable content in products or packaging, and no expected product lifetime.

Total waste generated fell 43% to 573 tonnes (2024: 1,012 tonnes) (page 46). Hazardous waste fell from 618 to 18 tonnes; non-hazardous waste rose from 393 to 555 tonnes. Recycled waste was 527 tonnes (92%) against non-recycled 46 tonnes (8%), the same split as 2024 (928 tonnes / 92% and 83 tonnes / 8%). No radioactive waste in either year.

Scope is narrow and stated. "The waste account covers all material waste generated across the Group's operations during the reporting period. In 2025, this included waste from the Deepsea Stavanger SPS, the Deepsea Aberdeen SPS, and from the Group's operational base. Waste data is collected from third-party waste management providers, who report on the type of waste and treatment method" (page 46). Production waste during drilling is outside the boundary because "the operator is responsible for managing and disposing production waste, while the Group holds responsibility for waste generated off contract and during SPS activities for the Own Fleet" (page 45).

"In alignment with ESRS E5, all waste generated by the Group is classified as hazardous or non-hazardous based on the waste management provider's classification" (page 46).

The year-on-year movement is driven by which rigs went through Special Periodic Survey, not by a change in practice; the report does not comment on the 97% fall in hazardous waste.

Waste

Reference: page 46 (waste tables and accounting policies).

Waste generated and diverted from disposal (tonnes):

Waste sent to disposal (tonnes):

Totals: hazardous 18 tonnes (2024: 618), non-hazardous 555 tonnes (393), radioactive nil, total waste generated 573 tonnes (1,012). Non-recycled 46 tonnes / 8%; recycled 527 tonnes / 92% (page 46).

"The percentage of non-recycled and non-recycled waste is calculated as the amount of non-recycled waste and recycled waste divided by the total waste generated" (page 46, quoting the accounting policy for the recycling rate).

Waste is also an emissions category: Scope 3 C5 waste generated in operations was 2,668 tCO2e in 2025 (2024: 3,788, restated), covering "waste volumes and waste treatment from the operational base and the Deepsea Stavanger and Deepsea Aberdeen SPSs" (pages 35, 37).

Policies related to own workforce

Reference: pages 47 and 49-52 (marked "S1-1, MDR-P" in each of the five S1 sub-sections).

"The Group is committed to foster a safe, inclusive, and high-performing work environment. This commitment is anchored in the Sustainability Policy which sets the overall objectives related to equal treatment, diversity, operational safety, and employee well-being. The HSE Policy, Social Responsibility Principle and Code of Conduct (COC) further specify requirements for preventing harm, protecting life and health, and ensuring safe behaviour and responsible conduct from all personnel working under the Group's operational control" (page 47).

"The Human Rights Policy explicitly prohibits child labour, forced or compulsory labour, and human trafficking, consistent with internationally recognised human rights and labour standards" (page 47). The policy table (page 26) records the Human Rights Policy as Board-owned and incorporating the International Bill of Human Rights, the UN Guiding Principles on Business and Human Rights and the ILO Declaration on Fundamental Principles and Rights at Work.

Policies are then restated per sub-topic: labour conditions - the policies "ensure fair working conditions, equal treatment, equitable remuneration, and respect for freedom of association and collective bargaining for all employees and non-employees, including contractors and consultants, across offshore and onshore operations worldwide" (page 49); equal treatment - "the Group's zero-tolerance approach to discrimination" (page 50); psychosocial environment - "zero-tolerance to harassment and bullying", supported by "the Harassment, Bullying and Discrimination Policy and the Corporate Culture and Employee Behaviour Procedure" (page 50); health and safety - "The Group strives for zero incidents and operates under the principle that every event is preventable" (page 51); competence - "The Competence Policy provides detailed requirements for competence development" (page 52).

Scope is defined: own workforce "covers all individuals with a direct contractual relationship with the Group... It includes employees on the Group's payroll and non-employees such as individual contractors or agency workers provided by third-party entities" (page 47).

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

Reference: page 48 (marked "S1-2, SBM-2"); engagement table on the same page.

"The Group's approach to employee engagement is guided by the People Strategy, which sets clear expectations for how the Group supports, develops, and engages with its workforce... Effective employee engagement processes are essential to delivering on the People Strategy, as they provide key insights that inform decision-making across all functions" (page 48).

"Employee and union representatives are informed and consulted on matters concerning the workforce. In the event of organisational or operational changes that may affect employees, information and dialogue meetings are held with union representatives to ensure transparent communication and participation" (page 48).

The engagement table (page 48) lists twelve channels with their purpose and frequency, including CEO Townhalls (three times per year), the CEO leadership summit (annually), the work environment survey ("Anonymous assessment of employee well-being, working conditions, and organisational climate", annually and biannually), union and safety delegate meetings with the SVP HR (at least annually), employee representative meetings with management (minimum three times per year), negotiation and salary review processes (annually), and the Women in Drilling conference (annually).

Effectiveness assessment. "Annual surveys for onshore employees and biannual surveys for offshore crews and third-party personnel, gather insight into well-being, working conditions, communication effectiveness and trust in reporting channels. Survey results and data from engagement and reporting mechanisms are analysed to identify trends, improvement opportunities, and areas requiring targeted follow-up. Feedback is incorporated into the QHSSE programme, People Strategy, design of surveys, and future engagement activities" (page 48).

No single executive is named as accountable for engagement outcomes, and no survey participation rate is disclosed.

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

Reference: page 48 (marked "S1-3, IRO-1"); remediation described on page 49.

Channels listed on page 48: "Employee representatives across operations, such as the DPA, are available to raise concerns with management on behalf of employees"; "Internal platforms for reporting concerns, including the Safe Cards Reporting System and Synergi"; "Whistleblower portal (grievance mechanism)"; "Work environment surveys conducted by an external health provider"; "Union or employee representatives who are accessible for support and advocacy"; "On-site safety delegates dedicated to workplace safety"; and line manager conversations.

"The Designated Person Ashore (DPA) monitors safety and engages with offshore workers, serving as the link between offshore and onshore management in line with the International Safety Management (ISM) Code" (page 48). The DPA "has a direct reporting line to the CEO" (page 56).

"The Group provides multiple internal and external channels for employees to raise concerns or seek support confidentially. These mechanisms ensure accessibility, anonymity where required, and timely follow-up. For further information on protection of whistleblowers against retaliation, refer to G1 Business conduct" (page 48). The whistleblower protection is that "The Group strictly prohibits retaliation against anyone who reports or participates in an investigation. All individuals reporting in good faith are protected and receive relevant support" (page 58).

Remediation. "If an actual negative impact occurs, the Group ensures timely mitigation and access to remedy in line with local laws and international standards. Remedies may include financial compensation, restitution, rehabilitation, adjusted working conditions, public apologies, or guarantees of non-repetition. Identified impacts are mitigated to prevent further harm, and responsibility for mitigation and remediation lies with relevant management within functions such as QHSSE, HR and Operations" (page 49).

The report does not state whether workers are aware of or trust the channels, beyond noting the 2024 "speak up" campaign "lowers the bar for reporting complaints" (page 55).

Taking action on material impacts on own workforce

Reference: pages 49-52 (marked "S1-4, MDR-A" in each sub-section).

Labour conditions (page 49). "Contracts define guaranteed pay, benefits, and termination terms, benchmarked against the Norwegian Shipowners' Association and global market rates to ensure fair remuneration. Working hours, overtime, time off, and rest periods are monitored through centralised hour-registration systems and workforce surveys." 2025 actions: "Verifications of employment terms and conditions for non-employees" and "Annual Maritime Labour Convention 2006 (MLC 2006) audit of crew placement services".

Equal treatment (page 50). 2025 actions: WISTA partnerships; "Events within the Group's network for women (Women in Drilling)"; "Apprenticeship programmes, with most apprentices being offered permanent positions after completing their contract"; "Analytical recruitment tools to attract diverse talent"; "Events in the network for young employees (Young at Odfjell)". High-risk groups are named: "The workforce groups currently identified as particularly at risk are apprentices and women working offshore" (page 50).

Psychosocial environment (page 50). 2025 actions: "Implemented a holistic health programme covering both physical and mental well-being" and "Active communication from management on the zero-tolerance to harassment and bullying". "In 2025, the holistic health programme had an approximate cost of USD 380,000. These costs were fully covered by the Group."

Health and safety (page 51). 2025 actions include simplifying and standardising procedures, "the annual Always Safe campaigns", "Increased security consciousness, enhancing cyber awareness and responsible use of AI", "Reduced environmental impact through the substitution of chemicals in own operations", and safety performance coaching offshore.

Competence (page 52). "In 2025 the budgeted expenses for courses and training for offshore personnel was approximately USD 7.7 million."

Resourcing caveat. For labour conditions and health and safety the Group states that actions "are integrated into existing functions and daily operations; therefore, no significant dedicated financial investments are required" (page 49) and "no separate CapEx or OpEx budget lines are allocated specifically to health and safety activities" (page 51).

Targets related to own workforce

Reference: page 52 (targets table, marked "S1-5, MDR-T").

"The Group's overarching commitment to provide its own workforce with a safe, inclusive, and rewarding work environment, is supported by targets related to each material IRO under S1. The targets are aligned with the People Strategy and Health and Safety Strategy. The targets were developed based on employee input from engagement channels, business priorities, historical data risk assessments, collective agreements, industry best practices, and legislative requirements. Target performance is reviewed annually" (page 52).

Seven targets are tabulated (page 52), mapped to the five material S1 IROs:

• "80% and 5 out of 6 overall offshore and onshore employee satisfaction score" (labour conditions)
• "Annual sick leave 3% or under" (labour conditions)
• "40% women in leadership positions" by 2030 (equal opportunities)
• "Zero incidents of harassment and bullying" (psychosocial work environment)
• "Zero Lost Time Incidents" (health and safety)
• "90% offshore compliance for training requirements per rig"
• "Reduce 10% hazardous chemicals YoY"

"Changes made for 2025 include the introduction of targets for offshore compliance training per rig, overall employee satisfaction for offshore and for onshore workers, zero lost-time incidents, and reduction in chemicals" (page 52).

Performance in 2025 fell short on several. Total sick leave was 4.2% against the 3% target (page 55); LTI frequency was 1.3 against a target of zero (page 54); and there were six incidents of discrimination including harassment against a target of zero (page 55). Women in leadership stood at 29% against the 40% by 2030 target, from a 2022 baseline of 27% (page 52).

Expected outcomes are stated by time horizon: short term, "reduction of sick leave, unforeseen health incidents, competency related operational failures, and near misses"; medium term, "Stable and predictable % sick leave, low levels of voluntary turnover, cost savings"; long term, "Gradual increase of women in technical and leadership roles" and "Low % injury incidents, with increasing safety mindset" (page 52).

Characteristics of the undertaking's employees

Reference: page 53 (tables and accounting policies).

Headcount at 31 December 2025: 1,643 (2024: 1,547; 2023: 1,563) - 1,542 male and 101 female (page 53).

By country over 50 employees: Norway 1,515 (1,309; 1,157) and Namibia 121 (234; 347) (page 53).

By contract type and gender (page 53):

Employee turnover: 42 leavers, a rate of 2.6% (2024: 58 / 3.8%; 2023: 35 / 2.4%) (page 53).

"The Group headcount numbers include all employees on Group direct payroll in all Group entities as at 31 December 2025. There are no estimates needed as all employees are registered in the Group ERP HR System. All employees are counted as one individual" (page 53). "Data is reported globally and is not broken down by region for 2025. All positions are full-time, unless employees specifically request temporary part-time or lower position %" (page 53).

The Group reports headcount only, not full-time equivalents, and reports gender in a binary "male/female" split with no "other" or "not disclosed" category.

Collective bargaining coverage and social dialogue

Reference: page 53 (table and accounting policies).

"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" (page 53).

"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" (page 53).

Social dialogue is described under S1-2: union and safety delegate meetings with the SVP HR at least annually, employee representative meetings with management a minimum of three times per year, and "Negotiation and salary review processes" annually (page 48). "Employee representation is present in Norwegian subsidiaries" (page 23).

The rise from 91.98% to 95.37% tracks the shift in headcount towards Norway (1,309 to 1,515) and away from Namibia (234 to 121) over the same period (page 53). No breakdown by EEA and non-EEA country is given.

Diversity metrics

Reference: page 53 (age and top management tables).

Age distribution (page 53):

Top management (page 53):

"Top management includes position level L1-L3: CEO and General Manager (L1), Executive Management Team (L2), and Business Area Management (L3)" (page 53).

Female representation at top management has been flat in absolute terms at six people for three years while the male count rose from 18 to 19, so the percentage fell from 25% to 24%. Group-wide, women are 101 of 1,643 employees, 6.1% (page 53).

The S1 targets table sets "40% women in leadership positions" by 2030, with 29% reported for 2025 against a 2022 baseline of 27% (page 52); that leadership measure is broader than the L1-L3 top-management definition used here. Board gender diversity is incorporated by reference to the Corporate Governance Report, page 13 (page 22).

Adequate wages

Reference: page 53 (table and accounting policies).

"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 the industry category, union statistics, and through national employers' groups, and public statistics. The Group surpasses EEA minimum wage standards and Norwegian local minimum wage requirements, and follows collective bargaining agreement wages matrices" (page 53).

The S1 accounting policy notes the reporting boundary: "In line with ESRS reporting requirements, which mandate disclosure for countries with more than 50 employees and representing over 10% of the total workforce, the Group reports figures for employees based in Norway, with the exception of S1-6 employee head count by country" (page 53). Namibia, with 121 employees in 2025, is therefore outside the S1-10 figure even though it is above the 50-employee threshold, because it is below 10% of the 1,643 total.

Remuneration terms are reinforced under S1-4: "Contracts define guaranteed pay, benefits, and termination terms, benchmarked against the Norwegian Shipowners' Association and global market rates to ensure fair remuneration" (page 49). No adequate wage benchmark value is published, and no separate figure is given for non-employees.

Training and skills development metrics

Reference: page 54 (table and accounting policies).

Participation in performance and career development reviews (page 54):

Headcounts behind those rates: 26 onshore women and 27 onshore men, and 12 female and 526 male offshore crew, held reviews in 2025 (page 54).

Average training hours (page 54): onshore female 4 (2024: 22), onshore male 10 (18); international offshore crew female 16 (6), male 21 (23); offshore Norwegian crew 45 (31) and 47 (45) - the last two rows are both labelled "female" in the source table, which appears to be a typographical error for the male row.

"All employees are offered annual performance and career development reviews. Invitations are automatically distributed via Industrial and Financial Systems (IFS) software and include all registered employees. The reported figures reflect the number of confirmed performance and development reviews conducted in response to the invitation" (page 54).

The Group qualifies its own numbers: "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, the reported figures consequently do not provide a comprehensive representation of all development conversations" (page 54). Metrics come from registered training hours in CAMS, recorded in IFS, Rider and Cornerstone and analysed in Power BI (page 54).

Offshore training was budgeted at approximately USD 7.7 million in 2025 (page 52).

Health and safety metrics

Reference: page 54 (table and accounting policies).

Safety performance deteriorated across every frequency measure in 2025, against a target of zero lost time incidents (page 52). No fatalities and no serious incidents in any of the three years.

"Metrics and definitions are built on the ISO 45001" (page 54). Incident frequency is calculated as "X x 1,000,000 hours / Number of worked hours", where X is "incident, accident, LTI, medical treatment incident, first aid treatment". Lost time incidents are "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". "Monthly offshore working hours calculation: number of offshore days x 12 hours per shift x 1.07 (7% overtime)" (page 54).

Sick leave is reported separately as an entity-specific disclosure: offshore 4.4% (2024: 4.2%), onshore 2.4% (0.9%), total 4.2% (3.9%) (page 55).

Coverage of non-employees by the health and safety management system is not separately quantified, and no cases of recordable work-related ill health or days lost to ill health are reported.

Work-life balance metrics

Reference: page 55 (table and accounting policies).

"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" (page 55).

The take-up figure is not reported, and the Group explains why. "The Group does not report metrics for employees who took family related leave in 2025. All data regarding parental, maternity, and paternity leave, as well as other family related leave taken during the regular work schedule, is captured in our 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" (page 55).

That is a data-availability limitation rather than a phase-in claim; S1-15 is listed in the ESRS content index with a page reference to page 55 (page 30), not with a "Phase-in" marker.

Related work-life provisions appear under S1-4: the psychosocial IRO is linked to "extended rotations, prolonged periods away from home, and limited privacy" (page 50), and 2025 actions included a holistic health programme costing approximately USD 380,000 (page 50).

Compensation metrics (pay gap and total compensation)

Reference: page 55 (table and accounting policies).

Both measures worsened sharply, and the report explains one of them: "The annual total remuneration ratio discloses the ratio of the highest-paid individual to the median annual total remuneration for all employees (excluding the highest-paid individual). The gap increased from 11.1% in 2024 to 21.69% in 2025 due to the redemption of the share-based bond for executive management" (page 55).

That sentence attributes the movement to the share-based bond redemption but quotes the gender pay gap figures rather than the remuneration ratio figures, so the report does not separately explain the near-doubling of the remuneration ratio from 7.0 to 16.3.

"All the Group companies are consolidated to get a complete picture of any gender pay gaps. This also ensures that the groups (levels) will contain enough resources to be included in the analysis and to provide the best possible information. Total remuneration, in accordance with the ESRS definition, has been used for the gender pay gap analysis, and the remuneration ratio" (page 55).

The appendix of datapoints from other EU legislation maps "ESRS S1-16 Excessive CEO pay ratio paragraph 97 (b)" to page 55 (page 108). No contextual information on the drivers of the gender pay gap - such as the concentration of women in onshore roles or their 6.1% share of headcount (page 53) - is offered alongside the figure.

Incidents, complaints and severe human rights impacts

Reference: page 55 (table and accounting policies).

"In 2025 the Group had a total of 12 complaints filed through channels for people in own workforce. 6 of these complaints where classified as incidents of discrimination, including harassment" (page 55).

The Group attributes the rise to better reporting rather than more misconduct: "In 2024 the Group conducted a 'speak up' campaign that encouraged employees to report complaints. This strengthens the Group's understanding and oversight over the psychosocial work environment, and lowers the bar for reporting complaints" (page 55). "Our most reliable and complete source of reporting is through anonymous self-reporting via our annual onshore work environment survey and our semi-annual offshore survey" (page 55).

Six incidents sit against a stated target of "Zero incidents of harassment and bullying" from a 2024 baseline of one case (page 52). No amount of fines or compensation is disclosed because none arose, and the report does not say how the six incidents were resolved.

Policies related to value chain workers

Reference: page 56 (marked "S2-1, MDR-P").

"The Group's commitment to human rights and responsible labour practices for workers in the value chain is anchored in the Sustainability Policy and Human Rights Policy. The Supplier Code of Conduct and the Social Responsibility Principles further reinforce the expectations for ethical behaviour and responsible labour practices across our supply chain" (page 56).

"The Supplier Code of Conduct is incorporated into all supplier contracts and requires suppliers to uphold internationally recognised labour rights and ethical business standards. This includes compliance with the International Bill of Human Rights, the UN Guiding Principles on Business and Human Rights, and the ILO Declaration on Fundamental Principles and Rights at Work. It explicitly prohibits forced labour, child labour, and human trafficking, and safeguard the rights to non-discrimination, freedom of association, and safe working conditions" (page 56).

"To ensure strategic alignment and accountability, the COO and SVP HR oversee the integration of value chain worker perspectives into organisational policies and decision-making. The Chief Procurement Officer (CPO) is responsible for monitoring compliance with the Supplier Code of Conduct" (page 56).

The policy table (page 26) records the Supplier Code of Conduct as CPO-owned, covering "Suppliers and contractors", incorporating the UN Universal Declaration of Human Rights and the ILO Declaration on Fundamental Principles and Rights at Work, and mapped to sections S2 and G1.

The material S2 IRO is upstream only: "The Group has a potential negative impact on the working conditions of workers in the upstream value chain through the purchase of goods and services. This relates to health and safety, labour conditions, and respect for human rights among suppliers and subcontractors, particularly in regions with weaker labour laws and enforcement" (page 56).

Processes for engaging with value chain workers about impacts

Reference: page 56 (marked "S2-2, SBM-2").

"The purpose of the Group's processes to engage with value chain workers is to identify, prevent, and address potential negative impacts on labour rights and working conditions... These insights strengthen the Group's ability to detect and mitigate actual and potential impacts and support the continuous improvement of responsible practices" (page 56).

"The Group applies a systematic approach to identifying vulnerable groups in the value chain. This includes supplier risk assessments, reviews of working conditions, dialogue with suppliers and worker representatives, and analysis of geographic and sector-specific risk factors. Information is gathered through supplier questionnaires, audits, and direct feedback from value chain workers" (page 56).

The Group distinguishes two engagement settings. Upstream: "Engagement with workers in the Group's upstream value chain is primarily conducted through audits, inspections, and worker interviews. As these workers are outside the Group's operations, visibility is lower and direct interaction is more limited. Audits are therefore particularly important where vulnerable worker groups are identified... The right to conduct audits is included in the Group's General Terms and Conditions and the Supplier Code of Conduct" (page 56). On rigs and at yards: "Since these workers are part of the Group's daily operations, visibility is higher and concerns can be identified and addressed quicker" (page 56).

"Communication with workers is tailored to the specific audience and purpose of the engagement, considering language, cultural context, and potential power imbalances, to ensure safe and meaningful participation. The Group encourages and supports value chain workers' rights to collective representation" (page 56).

Effectiveness is assessed by "whether workers are aware of and trust available channels to raise concerns, and whether issues raised lead to timely corrective actions" (page 56). No worker representatives are named and no engagement frequency is stated.

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

Reference: pages 56-57 (marked "S2-3").

Channels (page 56). "The whistleblowing system is available to value chain workers to raise concerns and report suspected or known violations of the COC or other compliance-related grievances, including situations where direct reporting is not feasible. The system is publicly accessible via the Group's website and is designed to ensure inclusive and easy access for all stakeholders."

"In addition to the whistleblowing system, offshore workers have access to dedicated grievance channels. Onboard complaint procedures established under the Maritime Labour Convention 2006, enable employees and non-employees to raise concerns with onboard senior management, the flag state of the unit, or their flag state of origin. Offshore workers may also confidentially raise concerns through a DPA, in accordance with the ISM Code, who has a direct reporting line to the CEO" (page 56). These are complemented by non-conformance reporting, operational meetings, supplier experience reports, supply chain safe card reporting and local supplier non-conformance systems.

Remediation (page 57). "These processes form a core part of our human rights due diligence and are activated whenever actual or potential negative impacts are identified through supplier assessments, audits, or worker engagement. Actions to remediate negative impacts depend on the supplier relationship and the nature of the issue. Where non-conformities are identified, the Group engages with suppliers to ensure that appropriate corrective actions are agreed and implemented... If non-conformities remain unresolved, contracts may be suspended or terminated in accordance with the Group's General Terms and Conditions. Where remediation relates to a potential criminal offence, incidents may be reported to relevant authorities."

Effectiveness is monitored through "regular monitoring, data analysis, and stakeholder engagement" and by "categorising and trending non-conformances", reinforced by "internal and external non-conformance reporting as part of the ISO 9001 certification process" (page 56). No number of grievances received from value chain workers is disclosed.

Taking action on material impacts on value chain workers

Reference: page 57 (marked "S2-4, MDR-A").

The action framework is the Supplier Management System, with three named components (page 57):

1. Risk assessment and human rights due diligence. "As part of the supplier qualification process, all suppliers must complete the Human Rights Self-Assessment questionnaire and sign the Supplier Code of Conduct. Responses are used to determine inherent and residual risks related to labour practices, working conditions, and human rights compliance. Additionally, the Group assesses suppliers according to pre-defined supplier risk factors which include assessment of supplier and product type, country index, and human rights risk."
2. Collaboration and training. "Local value chain workers and agents receive relevant training aligned with the Group's competency framework."
3. Supplier audits and compliance monitoring. "A risk-based audit programme is used to evaluate working conditions and verify that suppliers assess and ensure compliance with human rights standards within their own supply chain."

2025 actions (page 57): "Expanded the rollout of the Human Rights Self-Assessment to all framework agreement suppliers"; "Implemented a new supplier management system that improves risk management and data quality"; "Reduced the number of active suppliers to enhance visibility and manageability"; "Continued ongoing 'Duty of Care' verifications for high-risk services, including crewing, freight forwarding, and yard services"; and "Conducted 23 supplier audits covering Human Rights compliance, QHSSE, quality reviews and audits, ISO review audits, prequalification assessments, logistics processes, and environmental performance."

Resources. "Core Supplier Management System activities, including audits, are embedded in the existing SCM operating model and do not require separate CapEx or OpEx budget lines" (page 57).

No number of suppliers screened, no share of spend covered, and no count of non-conformities found by the 23 audits is disclosed.

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

Reference: page 57 (marked "S2-5, MDR-T").

"The Group is committed to ensuring that its operations and business relationships do not cause, contribute to, or are directly linked to human rights violations or inadequate labour conditions. The overarching ambition is to achieve zero HSE breaches and zero breaches of fair working conditions for value chain workers. These targets apply to workers employed by suppliers and contractors performing activities under the Group's operational control or within the Group's frame agreements" (page 57).

"The target has been developed through ongoing dialogue with suppliers conducted via the SCM Supplier Management System, as well as through identified risk areas and findings from supplier audits" (page 57).

"The target applies from 2025, which is the first year of implementation. Accordingly, 2025 serves as both the baseline year and the baseline value for this target" (page 57).

2025 performance. "In 2025, the Group recorded one observation of an unsafe work environment. This was followed up through an HSE audit and corrective actions were implemented at the supplier level. Expected outcomes include verified safe working conditions, improved HSE practices, and strengthened supplier awareness of the Group's zero-tolerance approach to unsafe conditions. Performance is monitored through daily operations, supplier audits, site visits, and non-conformance reporting. Progress on the target will be reviewed annually as part of supplier performance assessments and the company's Human Rights Account reporting under the Norwegian Transparency Act" (page 57).

The target is qualitative and absolute rather than time-bound with interim milestones, and value chain workers were not directly consulted in setting it - the disclosure names supplier dialogue and audit findings as the inputs.

Business conduct policies and corporate culture

Reference: page 58 (marked "MDR-P, G1-1" and "G1-1, SBM-1, SBM-3, IRO-1").

"The Group's approach to ethical business conduct is anchored in a framework of governance policies applicable across own operations and the upstream and downstream value chain. The policy framework includes expectations and minimum standards for integrity, fair competition, human rights, anti-corruption, and responsible business behaviour in business relationships" (page 58).

Accountability is split three ways (page 58). The Board "holds ultimate responsibility for establishing and approving the Group's overarching governance framework, including the Ethical Principles, Sustainability Policy, Legal and Regulatory Compliance Policy, Human Rights Policy, Insider Trading Policy, Risk Framework and the Group's Mission, Vision and Values". The CEO "is responsible for implementing and maintaining the governance framework", covering the COC, Supplier Code of Conduct, Competition Compliance Procedure and Sanctions and Export Control Procedure among others. The compliance team, "comprising the Compliance Officer and the General Counsel, is responsible for the Group's compliance programme, including the COC, the whistleblower portal, and the business compliance portal".

Corporate culture. "The corporate culture represents an actual positive impact. An ethical corporate culture drives operational excellence, protects people and society, while safeguarding reputation, strengthening investor and stakeholder confidence, and securing assets" (page 58). "All employees are required to read the COC and confirm their compliance on an annual basis. New employees are introduced to the corporate culture and the COC through mandatory e-learning courses... Failure to comply with the COC may result in disciplinary action" (page 58).

Fair competition. "For the external fleet, the Group has guidelines to ensure compliance with competition law, including the appointment of 'clean persons'. These are designated employees authorised to handle sensitive competitive information under strict confidentiality." "In 2025, there were no legal actions involving the Group related to anti-competitive behaviour or violations of antitrust or monopoly legislation" (page 58).

Whistleblower protection. "The Group strictly prohibits retaliation against anyone who reports or participates in an investigation" (page 58).

Management of relationships with suppliers

Reference: page 60 (marked "G1-2, SBM-3" and "SBM-2, MDR-A"); Figure 12 supplier risk assessment on the same page.

"The Group's approach to supplier management is based on transparency, integrity, and responsible business practices. The objective is to ensure that suppliers are aligned with the Group's commitment to ethical conduct, human rights, and environmental responsibility across the value chain" (page 60).

"All potential suppliers undergo due diligence in accordance with the SCM Third Party Due Diligence Procedure, illustrated in figure 12, before being added to the Approved Vendor List (AVL). The initial supplier risk assessment includes a human rights self-assessment, signing of the Supplier Code of Conduct, and a screening of pre-defined supplier risk factors. Action plans are further developed based on the risk assessment to mitigate the potential identified risks. High-risk suppliers are subject to detailed audits and key performance evaluations. If a non-conformity is detected, the supplier is either supported to improve their practices or removed from the AVL" (page 60).

"Approved vendors are assigned a risk profile and monitored on ESG performance through audits and key performance evaluations... The review plan contains measures such as environmental audits, duty of care verification, incident investigations, and KPI evaluations" (page 60).

"Key suppliers, such as those providing catering, freight, crewing, and critical equipment, are awarded framework agreements that promote close collaboration and long-term partnership" (page 60). "All purchasing and logistics activities are overseen by SCM, which is centrally organised as part of the Global Business Services provided by Odfjell Technology" (page 60).

2025 key actions: "Implemented a new Supplier Management System to enhance oversight across the full supplier lifecycle" and "Reduced the number of active suppliers to enhance visibility and manageability" (page 60). Twenty-three supplier audits were conducted in 2025 (page 57).

The identified IRO is that "Insufficient supplier assessment and follow-up may lead to labour rights violations, unsafe working conditions, and increased environmental risk, particularly in jurisdictions with low regulatory standards and limited enforcement" (page 60). No supplier count, spend coverage or share of suppliers assessed is disclosed.

Prevention and detection of corruption and bribery

Reference: page 59 (marked "G1-3, SBM-3, IRO-1", "G1-3, MDR,P" and "G1-3, MDR-A").

"The Group maintains a zero-tolerance policy for bribery, corruption, and facilitation payments. The COC, Social Responsibility Principles and the Ethical Principles clearly outline this commitment" (page 59).

Where the risk sits. "Internally, functions with authority to make or influence decisions of financial or strategic value are most exposed to corruption risks... Externally, corruption risks are higher in certain geographical areas, particularly in jurisdictions with low scores on the Transparency International Corruption Perceptions Index. The Group may also face increased exposure when entering new markets or in regions where the use of agents is common practice. All agents are classified as high-risk third parties and are subject to integrity due diligence and periodic reviews conducted by the Compliance Officer and the CRC" (page 59).

Conflicts of interest and gifts. Personnel "shall avoid actual or perceived conflicts of interest and report potential conflicts through the business compliance portal"; they "may not accept or offer personal gifts, hospitality, or other benefits to or from clients, contractors, suppliers, agents, or government representatives. Exceptions are permitted only when the value is insignificant" (page 59).

Detection and investigative independence. "The Compliance Team is responsible for investigating allegations of corruption and bribery. The team reports directly to the CEO, the Audit Committee, and the Board. Any allegations involving members of the Compliance Team, Executive Management, or the Board are investigated by external resources to ensure independence and objectivity. The Compliance Officer participates in all Audit Committee meetings" (page 59).

Training coverage (page 59): 42 employees in functions-at-risk during the reporting period, 42 of whom received training, giving 100% of functions-at-risk covered by training programmes. "Functions at risk are identified based on the headcount of employees holding positions within corporate management, tendering and contract negotiations, rig management, and other leadership roles in operational activities."

2025 change: "the COC was revised to strengthen the expectations for ethical behaviour for the Group's own workforce by enhancing its clarity and overall user-friendliness" (page 59). Training coverage is reported only for functions-at-risk, not for the wider workforce or the administrative, management and supervisory bodies.

Targets related to business conduct

Back-filled from the business conduct chapter, where targets are addressed under the MDR-T minimum disclosure requirements rather than as a numbered disclosure requirement. G1-3 Targets became a standalone DR only in the 2025/2026 ESRS; this statement was prepared under the 2023 ESRS.

No measurable outcome-oriented business conduct target is disclosed. The G1 chapter carries no target table equivalent to the S1 table on page 52 or the E1 targets on page 34, and the ESRS content index lists G1-1, G1-2, G1-3, G1-4 and G1-6 but no targets entry (page 30).

Consistent with MDR-T's other limb, effectiveness is tracked in the absence of stated targets. The due diligence mapping table on page 23 places business conduct under "Tracking effectiveness of actions and communication" with MDR-T G1-4 at page 59 and MDR-T G1-6 at page 60, alongside MDR-M G1-4 (page 59) and MDR-M G1-6 (page 60).

What that tracking consists of:

• Anti-corruption training completion. "Through procedures and regular training, the Group ensures that all personnel understand their responsibility to report suspicious activities related to bribery or corruption. Data from the e-learning portal is used to monitor completion of anti-corruption training and annual confirmation of compliance with the COC" (page 59). Coverage reached 100% of the 42 employees in functions-at-risk (page 59).
• Zero-incident outcome metrics. Convictions, fines, confirmed incidents of corruption or bribery, dismissals and terminated contracts were each nil in 2025 (page 59).
• Fair competition. "Training needs are continuously evaluated. In 2025, there were no legal actions involving the Group related to anti-competitive behaviour" (page 58), disclosed under a heading marked "SBM-3, MDR-P, MDR-A, MDR-T".
• Payment practices. Payment performance is monitored against standard 45-day terms, with 80% of 14,910 payments aligned and an average of 39 days to pay (page 60), disclosed under "G1-6, MDR-M, MDR-T".

No base year, milestone or stakeholder consultation on target setting is disclosed for business conduct.

Incidents of corruption or bribery

Reference: page 59 (metrics table, marked "G1-4, MDR-M, MDR-T"); accounting policies on the same page.

All corruption and bribery metrics are nil for 2025 (page 59):

"Metrics related to detection of corruption and bribery are handled by the compliance team" (page 59).

The detection route behind those figures is described alongside: "Allegations or incidents may be detected through reports from employees or external parties via the whistleblower portal, line management, the Compliance Officer, or Corporate Legal. They may also be identified through internal control processes, audits, or procedures requiring dual approvals for financial transactions. Additional information may arise from third-party due diligence, communication from public authorities, or other external sources" (page 59).

"Suspected incidents of corruption or bribery are investigated, and confirmed breaches may result in disciplinary action, including written warnings, dismissal with or without notice, or contract termination, depending on the severity of the case" (page 59).

No comparative figures for 2024 are given in the G1-4 table, and the number of allegations received (as distinct from confirmed incidents) is not disclosed.

Payment practices

Reference: page 60 (marked "G1-6, MDR-M, MDR-T").

"Payments are monitored through the ERP system, ensuring timely payment once goods or services are received and verified. The Group's standard terms of payment are 45 calendar days after receipt of invoice, with no differentiation between small and medium-sized enterprises and non-small and medium-sized enterprises, or on supplier category. Deviations to our standard payment terms occur regularly as the procurement or contract team and supplier negotiate terms and conditions" (page 60).

"In 2025, the Group had 14,910 payments where 11,933 (80%) were aligned with the standard payment terms (45 days). The average time to pay an invoice was 39 days" (page 60).

The average of 39 days sits comfortably inside the 45-day standard term, while one payment in five fell outside the standard terms - the disclosure attributes those to negotiated deviations rather than late payment, and does not split the 20% between shorter and longer agreed terms.

No number of outstanding legal proceedings for late payment is disclosed, and no separate figure is given for payments to small and medium-sized enterprises, consistent with the Group applying a single standard term to all suppliers regardless of size or category.

Supplier payment sits within the wider supplier management framework described under G1-2, where all purchasing and logistics activities are overseen by SCM as part of Global Business Services provided by Odfjell Technology (page 60).