Odjefell Shipping

The board of directors (BoD) is committed to upholding the highest standards of corporate governance. It holds supreme responsibility for the oversight of Odfjell's management, operations, and the establishment of control systems. The BoD is tasked with setting the independent overarching direction and strategic objectives for the company, providing oversight, and ensuring accountability. The functions and proceedings of the BoD are dictated by its rules of procedure and the relevant legislation that outlines its responsibilities, duties, and administrative processes i.e. the Norwegian Company Act and Code of Corporate Governance. The BoD also approves significant sustainability strategies, objectives, and targets. It routinely reviews, monitors, and deliberates on the group's sustainability and climate-related strategy, targets, performance, risks, and reporting. The BoD has six directors, where the chair is dependent and the majority owner, and five directors are independent (83% independent). The BoD has a 50/50 gender diversity.

In 2023, the scope of the board audit committee (AC) was broadened to encompass sustainability issues. The AC serves as an advisory body to assist the BoD in its supervisory role regarding sustainability and ESG reporting. Committee members possess the requisite knowledge and expertise in sustainability matters.

Odfjell executive management consists of the chief executive officer (CEO), chief financial officer (CFO), chief sustainability officer (CSO), chief technical officer (CTO), chief commercial officer (CCO), and managing director Terminals (MD Terminals). All executive managers are male and have long experience in the sector, services, and locations.

The CEO is authorized to ensure that our sustainability ambitions and priorities are monitored, managed, and seamlessly integrated into our corporate strategy and ethos. The operational lines of business are responsible for enacting the agreed-upon strategy, and for managing associated risks and performance metrics. Decarbonization is a material topic in Odfjell. The technology section of the Ship Management division is responsible for ensuring compliance and driving energy efficiency and decarbonization initiatives in the fleet.

Odfjell established the CSO role in 2020 as an integral part of the executive management team, ensuring that sustainability remains a focal point in executive discussions. The CSO regularly updates the BoD and AC on sustainability-related matters, such as reporting, regulatory, performance and training issues, among other updates. In collaboration with the CFO, the CSO is responsible for ESG reporting. Additionally, the CSO leads the DMA and IRO processes. The CSO also drives relevant sustainability training.

The Chief Compliance Officer (CComO) reports to both the CEO and the BoD via the AC.

OVERSIGHT OF IMPACTS, RISKS, AND OPPORTUNITIES

The BoD holds ultimate responsibility for oversight of Odfjell's IROs. Management is responsible for presenting the BoD with updated and relevant assessments of IROs, facilitating thorough discussion, review, and strategic alignment. These assessments are integrated into our corporate risk assessment process and included in the double materiality assessment (DMA) review to ensure alignment with Odfjell's overarching sustainability strategy.

The Audit Committee (AC) plays a key role in the frequent follow-up of ESG reporting and progress. It conducts in-depth reviews of specific reporting elements, monitors internal controls over sustainability reporting, and advises the Board of Directors (BoD) on ESG disclosures. The AC liaises with management and the sustainability auditor to ensure the accuracy and accountability of sustainability disclosures. However, the Board retains full responsibility for reviewing and approving the ESG reporting.

RESPONSIBILITIES IN TERMS OF REFERENCE, MANDATES, AND RELATED POLICIES

Board responsibilities are defined in alignment with the Norwegian Company Act and the Norwegian Code of Corporate Governance. The AC operates under a dedicated charter, available on Odfjell's website, which defines its role in ESG reporting oversight. The responsibilities of the CEO and the CSO are outlined in their job descriptions, with the CSO also designated as CComO to reinforce alignment with regulatory and ESG requirements.

MANAGEMENT'S ROLE IN GOVERNANCE PROCESSES, CONTROLS, AND PROCEDURES

The CSO, as part of the executive management team, is pivotal in overseeing and managing impacts, risks, and opportunities within Odfjell's risk review and strategy sessions. The CSO also facilitates focused discussions on relevant IROs and aligns them with the organization's strategic goals. The CSO reports directly to the CEO and, in the capacity of CComO, also reports to the AC, ensuring a direct line of accountability for compliance and sustainability matters.

Dedicated control functions for managing sustainability-related IROs are currently in development, with integration into broader internal functions to ensure consistency and accountability in governance.

Management is responsible for preparing and updating medium-term targets and goals, which are subject to BoD approval and monitored closely to ensure alignment with Odfjell's IROs as identified through the DMA process.

DESCRIPTION OF SKILLS AND EXPERTISE FOR SUSTAINABILITY OVERSIGHT

Odfjell conducts its own annual review across the BoD and management to ensure sustainability-related expertise is current and sufficient. Key roles, such as the chair of the AC and the CSO, regularly participate in external training programs to enhance their knowledge in emerging sustainability practices. In addition, periodic reviews and consultations with the ESG auditor are valuable for tapping into current trends and expertise.

Odfjell's organizational review processes evaluate the adequacy of skills and expertise for managing sustainability-related IROs. The organization prioritizes tailored training, professional development, and competence-building initiatives to meet the evolving demands of sustainability governance. This approach ensures that Odfjell's oversight bodies are equipped to respond effectively to material sustainability IROs in a complex and highly regulated shipping environment.

FREQUENCY AND PROCESS FOR INFORMING GOVERNANCE BODIES ON MATERIAL IMPACTS, RISKS, AND OPPORTUNITIES (IROS)

In alignment with Disclosure Requirement IRO-1, Odfjell has established a robust process for regularly informing the BoD and the AC on material impacts, risks, and opportunities related to sustainability:

BoD: CSO provides a sustainability update at each of the seven annual board meetings, ensuring that sustainability remains an integral part of board discussions throughout the year. Climate and nature risks, as well as human rights impact assessments, are included in the BoD's annual review of IROs, forming a key component of the DMA process. These IROs serve as the basis for the board's annual strategic review and the setting of sustainability-related goals and targets, and they are also fundamental to management's annual priorities, which the BoD reviews. Essential IROs are listed in Odfjell's corporate risk register, which is reviewed at each board meeting to ensure ongoing alignment with Odfjell's strategic and sustainability ambitions and targets.

AC: The AC has a standing agenda item dedicated to ESG reporting, with the CSO present at each meeting to provide updates. The AC has the mandate to conduct in-depth reviews of specific IROs throughout the year, allowing for comprehensive evaluation of critical sustainability topics.

Management: Sustainability IROs are reviewed at all management meetings, with corporate risk discussed and assessed across departments. The management team also prepares the annual risk assessment and DMA, aligning IROs with operational priorities. The CSO is responsible for ensuring effective due diligence, monitoring the results, and assessing the effectiveness of sustainability policies, actions, metrics, and targets adopted to address these IROs.

CONSIDERATION OF IMPACTS, RISKS, AND OPPORTUNITIES IN STRATEGIC AND OPERATIONAL DECISIONS

Odfjell integrates sustainability IROs and ESG considerations into its strategic planning, decision-making processes, and risk management. Key sustainability matters are embedded in the strategy preparation, and all major transactions, investments, and target-setting activities consider these IROs. As an integral member of the executive management team, the CSO ensures that sustainability issues are addressed in relevant meetings and that these considerations guide Odfjell's approach to potential trade-offs.

In cases where trade-offs are required, the BoD and management evaluate factors such as compliance obligations, the materiality of specific ESG investments, and the expected return on these initiatives. For instance, decisions may involve determining whether to exceed compliance requirements or to proceed with less material ESG investments that may yield a lower or negative return. This balanced approach enables Odfjell to make informed, strategic decisions that align with its sustainability commitments while considering the broader business impact.

The list of the material impacts, risks and opportunities has been aligned with the administrative, management and supervisory for the relevant reporting period. No specific IROs have been identified by governance bodies that have not already been addressed by management.

ODFJELL STATEMENT ON INCENTIVE SCHEMES LINKED TO SUSTAINABILITY PERFORMANCE

Odfjell integrates sustainability-related performance metrics into its incentive schemes for all shore-based employees, including members of executive management, to ensure alignment with our strategic sustainability goals, specifically in safety and decarbonization. These incentive programs are structured to reinforce Odfjell's commitment to environmental and social responsibility within the organization. Members of the BoD are not included in the incentive schemes.

KEY CHARACTERISTICS OF THE INCENTIVE SCHEMES

Odfjell offers two primary incentive programs: a short-term incentive plan (STIP) for all shore-based employees and a long-term incentive plan (LTIP) for members of executive management. Since 2018, the STIP has offered eligible employees an annual bonus of up to four months' salary based on performance, with the executive management eligible for up to six months. The LTIP offers executive management the opportunity to earn shares vested over three years, with a target bonus of up to 33% of their annual salary (50% for the CEO).

PERFORMANCE ASSESSMENT AGAINST SPECIFIC SUSTAINABILITY-RELATED TARGETS

Both the STIP and LTIP include specific sustainability-related targets to promote safe and sustainable operations: • For the shipping division, 17% of the STIP is dedicated to decarbonization objectives. • For headquarters and terminal operations, 22% of the STIP is linked to safety and spill-prevention metrics. • The LTIP dedicates 33% of its target to decarbonization performance, specifically aligned with Odfjell's annual efficiency ratio (AER) targets, measuring the degree to which emissions reductions align with Odfjell's climate commitments.

INCLUSION OF SUSTAINABILITY METRICS IN REMUNERATION POLICIES

Sustainability-related metrics, including safety and decarbonization, serve as key performance indicators within both the STIP and LTIP frameworks. These metrics are incorporated into Odfjell's annual remuneration policy and reflect the company's strategic focus on reducing environmental impact and ensuring safe operations.

APPROVAL AND UPDATING OF INCENTIVE SCHEME TERMS

The terms and metrics of both the STIP and LTIP are subject to annual review and approval. The Odfjell General Meeting approves guidelines for the incentive programs, while specific KPIs and targets are reviewed and approved by the Board of Directors' Remuneration Committee to ensure that they remain aligned with current sustainability ambitions and targets.

Statement on due diligence with regard to sustainability matters

SCOPE, MAIN FEATURES, AND COMPONENTS OF THE RISK MANAGEMENT AND INTERNAL CONTROL PROCESSES AND SYSTEMS IN RELATION TO SUSTAINABILITY REPORTING

Odfjell's risk management and internal control processes over sustainability reporting are based on the COSO Internal Control–Integrated Framework, addressing five key components:

Control Environment: Odfjell fosters a strong ethical foundation and clear governance structures, supported by the AC and BoD. The AC oversees the effectiveness of sustainability reporting controls, ensuring alignment with regulatory requirements (e.g., EU Taxonomy, ESRS).

Risk Assessment: Risks, including data inaccuracies and regulatory non-compliance, are systematically identified and prioritized, through a risk assessment process described in our risk policy. Internal control risk over sustainability reporting is assessed in the process and aligned with the AC and external auditor.

Control Activities: Policies, automated system checks, validation procedures, and regular internal and external audits mitigate identified risks.

Information and Communication: Effective communication systems ensure that internal functions and external stakeholders receive timely and accurate sustainability data.

Monitoring: The internal audit team regularly evaluates control effectiveness, reporting its findings to the AC, which informs the BoD. External auditors provide assurance over ESG reporting to further enhance credibility.

RISK ASSESSMENT APPROACH AND RISK PRIORITIZATION METHODOLOGY

Odfjell employs a structured methodology to assess and prioritize sustainability reporting risks:

Defining Objectives: Objectives align with ESRS requirements and other sustainability and emission reporting standards and regulations (e.g., CDP, Poseidon Principles, IMO DCS, EU MRV).

Identifying Risks: Comprehensive reviews identify risks such as errors in scope 1, 2, and 3 data, pollution reporting inaccuracies, and recycling compliance gaps.

Prioritizing Risks: Risks are ranked based on their potential financial, reputational, and operational impact. Priority is given to regulatory compliance and high-impact areas like emissions and financial disclosures.

The AC reviews the company's risk assessment methodologies, ensuring they adequately address sustainability reporting requirements.

MAIN RISKS IDENTIFIED AND THEIR MITIGATION STRATEGIES

INTEGRATION OF RISK ASSESSMENT AND INTERNAL CONTROLS INTO INTERNAL FUNCTIONS AND PROCESSES

Odfjell integrates risk assessment findings into internal functions and processes through: • Embedding control activities, such as emissions monitoring and supplier evaluations, into routine operations. • Leveraging internal audit findings to refine policies and procedures, ensuring alignment with ESRS and other standards. • Using IT systems for secure and accurate data collection, with automated validation checks and audit trails. • Establishing a feedback loop where risk assessment results inform operational adjustments and continuous improvement.

The AC discusses the findings with management and external auditors, ensuring compliance and the effectiveness of internal controls.

PERIODIC REPORTING OF FINDINGS TO ADMINISTRATIVE, MANAGEMENT, AND SUPERVISORY BODIES

Odfjell has established robust mechanisms for reporting findings related to sustainability reporting:

AC Oversight: • The AC reviews and evaluates the internal control framework, discussing sustainability reporting standards (e.g., ESRS, EU Taxonomy) and their assurance processes with management and external auditors. • The AC reviews the results of annual external assurance and ensures compliance with relevant standards and regulations.

BoD: • The AC informs the BoD about assurance results, explaining their role in ensuring the integrity of sustainability reporting. The BoD provides strategic oversight and monitors progress against sustainability ambitions and targets.

Internal Audit: • The internal audit team conducts periodic evaluations of corporate risks and control processes, reporting findings to the AC and senior management.

External Assurance: • Annual assurance reviews by external auditors are discussed and reviewed by the AC to ensure data credibility and compliance.

Through these reporting mechanisms, Odfjell upholds transparency and accountability, ensuring sustainability reporting meets the highest standards of accuracy and reliability.

Odfjell's strategy centers on providing safe, efficient handling and transportation of hazardous liquids, a crucial function within the global supply chain that supports a wide range of industries. Our core services include specialized chemical tanker shipping and terminal operations in strategic hubs, linking sea and land for safe storage and transit. With a global network and diverse product portfolio, we serve over 600 customers, including major chemical producers, across all continents.

KEY ELEMENTS OF GENERAL STRATEGY AFFECTING SUSTAINABILITY MATTERS

Products, Markets, and Workforce:

Products and Services: Odfjell specializes in transporting chemicals and other liquid products, focusing on specialty and easy chemicals, as well as vegetable oils and, in specific cases, clean petroleum products (CPP). Our vessels, primarily equipped with stainless steel tanks, offer unique versatility, allowing us to handle a broad range of liquid products. This flexibility enables Odfjell to adapt to changing market demands and underscores our resilience within the cyclical shipping industry.

Significant Markets and Customer Base: We operate on a global scale, serving key markets across the Americas, EMEA, Asia, and the Pacific. This global reach connects us with a broad spectrum of customers, including major chemical producers, and industrial manufacturers, supporting essential sectors from food production to construction.

Workforce Composition: The composition of Odfjell's workforce reflects the nature of our operations, divided between seafarers and shore-based employees, as shown in the table below.

Revenue Breakdown by Sector:

Odfjell only operates in one sector, as our revenues from terminals are dividend from joint ventures where we do not have operational control. Gross revenue from sea transport in 2024 was USD 1184.6 million.

Notably, while our fleet does not specialize in transporting fossil fuels, we occasionally transport them. Fossil fuel revenue for 2024 was USD 13 million, down from USD 24 million in 2023, representing 1.4% of total revenues.

Sustainability-Related Goals:

Odfjell's sustainability-related goals apply uniformly across our services, customer categories, geographical areas, and stakeholder relationships. These objectives center on decarbonization, safety, and reducing our environmental impact, in line with our overarching climate targets.

Assessment of Products, Markets, and Customers in Relation to Sustainability Goals:

Shipping remains the most energy-efficient mode of transporting large volumes over long distances. Odfjell's specialized chemical shipping operations play a vital role in supporting industries that produce essential goods, including food ingredients, pharmaceuticals, and fertilizers. These products are fundamental to global food security, healthcare, and agriculture.

Our commitment to sustainability is reflected in our adherence to stringent safety and environmental standards. By optimizing our fleet operations, reducing emissions, and continuously improving efficiency, we enable the safe and responsible transport of critical products while aligning with global sustainability goals.

Strategy Elements Impacting Sustainability:

Odfjell's vision is to be a world-class, preferred provider of transportation and storage for specialty bulk liquids. Sustainability is a core pillar of our strategy, ensuring the safe and efficient handling of hazardous liquids while supporting industries essential to global development.

A key challenge in achieving our sustainability goals is the decarbonization of shipping. This requires navigating evolving regulations, securing access to sustainable fuels, and overcoming technological and financial barriers—all while maintaining the highest safety standards. As regulations tighten and market expectations shift, we must continuously adapt to ensure compliance, operational efficiency, and long-term resilience.

Our approach prioritizes sustainability as a competitive advantage, embedding it into every aspect of our operations. By leveraging innovation, strategic partnerships, and our expertise in safe and responsible shipping, we are committed to driving meaningful change in the industry and contributing to a more sustainable future.

BUSINESS MODEL AND VALUE CHAIN

Odfjell operates an integrated business model centered on chemical tanker shipping and terminal storage, positioning us as a key link within the broader supply chain. Our business model allows for flexibility in product handling and rapid adaptation to market changes, contributing to stability within the cyclical tanker segment.

Inputs:

Our primary inputs include fuel and vessels designed for safe chemical transport, produced and maintained by shipyards that meet our stringent quality standards. Terminals and voyage materials also form part of our upstream value chain, essential for supporting our transportation and storage operations.

Outputs and Outcomes:

Odfjell provides various services, from chemical storage and ship management to reliable and cost-effective product transport. These services yield benefits for customers by ensuring safe, compliant delivery of essential chemicals, contributing to investor confidence and supporting sustainable growth within the chemical shipping sector.

Value Chain Overview:

Our value chain consists of upstream activities, such as ship production and fuel supply, and downstream activities, such as shore based cargo transport, terminal operations, and ship recycling. Our close relationships with key suppliers and customers, vital to Odfjell's value chain, enable us to serve as a lynchpin in the global chemical supply network. This integrated structure supports a sustainable business model, providing transparency and resilience across all aspects of our operations.

At Odfjell, we are committed to developing and implementing our strategy and business model by considering the interests and perspectives of all our stakeholders. Our approach to sustainability is shaped through proactive engagement with our stakeholders, including employees, investors, banks, customers, tonnage providers, suppliers, regulators, and communities. This engagement fosters a comprehensive understanding of their interests, views, and expectations, which we integrate into our strategic decisions.

Our key stakeholders comprise employees, possible employees, investors, banks, customers, regulators, and local communities. Engagement with each group occurs through regular dialogue, facilitated by our commercial, technical, finance, and administrative teams. These interactions are organized to cover key topics, ranging from sustainability, ethics, and safety to efficiency, quality, and business terms. Relevant environmental, social, and governance (ESG) topics are always covered. Specifically:

Commercial Team: Engages continuously with customers and tonnage providers on efficiency, safety, and sustainability expectations.

Technical Team: Regularly interacts with ships, suppliers, and service providers to drive sustainable practices in our operations.

Finance and Administrative Teams: Maintain a constructive dialogue with banks, investors, and community representatives, focusing on sustainable finance and ESG commitments.

Local Offices: Actively involve local stakeholders and communities to ensure our operations meet regional expectations and contribute to local sustainability.

Each engagement is designed to not only understand stakeholder interests but also to translate them into actionable insights. Our commitment to integrating these insights is reflected in our DMA and identified IROs, ensuring a holistic consideration of stakeholder needs in our decision-making.

UNDERSTANDING STAKEHOLDER INTERESTS AND INCORPORATION IN STRATEGY

Through ongoing stakeholder engagement and our due diligence processes, we gain valuable insights that inform Odfjell's strategy and business model. We benchmark our materiality assessments against industry peers and align our approach with inputs gathered through participation in industry groups and events. We address regulatory requirements proactively, adjusting our strategy in response to transition risks and evolving regulations. This ongoing benchmarking and regulatory responsiveness reinforce our competitive position while addressing stakeholder concerns.

Our structured engagements have revealed that our stakeholders are particularly focused on: • Sustainable operations: Emphasis on minimizing environmental impact through innovative practices. • Compliance and ethics: A commitment to uphold the highest standards of safety and integrity. • Operational efficiency: Delivering quality and timely services in line with global standards.

Feedback from stakeholders is regularly presented to management and incorporated into our DMA and IROs. In addition, feedback from multiple ESG ratings, including those from banks, analytics and ratings companies, informs our updates across reporting, communication, and key business elements. Odfjell also participates in reporting through platforms like EcoVadis, CDP, UNGC Communication on Progress, SHE, Euronext, Position Green, and DNV, and using these disclosures as a basis for continuous improvement.

STRATEGIC AMENDMENTS IN RESPONSE TO STAKEHOLDER VIEWS

Odfjell's strategy is dynamically updated to reflect stakeholder feedback. For instance, we have committed to expanding our sustainability initiatives by increasing investment in green technologies and pursuing industry partnerships for sustainable solutions. We recognize that these steps, to be implemented over the next five years, will strengthen our relationship with stakeholders and meet their expectations for sustainable growth. We anticipate enhanced stakeholder satisfaction and alignment with our strategic objectives by fostering transparent and active engagement.

GOVERNANCE AND STAKEHOLDER FEEDBACK

Odfjell's BoD and management are frequently informed of stakeholders' views, especially concerning our sustainability impacts. Management receives regular updates, which are then used to refine our strategy and prioritize sustainability goals. This inclusive governance approach allows us to proactively respond to stakeholder expectations and work towards our sustainability ambitions.

Interests and views of stakeholders

Since 2020, Odfjell has conducted materiality assessments, transitioning to the concept of double materiality in 2022. In 2024, we refined this process to comply fully with ESRS standards, leveraging extensive stakeholder engagement and internal evaluations. This systematic approach enabled us to identify material IROs, their origins, and potential effects on our business model, strategy, and financial performance.

BRIEF DESCRIPTION OF MATERIAL IROS AND THEIR CONCENTRATION IN THE BUSINESS MODEL AND VALUE CHAIN

Through our double materiality assessment, we identified key material IROs affecting our operations, upstream supply chain, and downstream activities. The IROs are presented in the following table, and specified under relevant topical standard.

CURRENT AND ANTICIPATED FINANCIAL EFFECTS OF MATERIAL IROS AND STRATEGIC RESPONSES

Current Effects: Transition risks associated with climate change and compliance with evolving regulations, such as the EU ETS, create financial implications in the short term. Transition costs related to scope 1 decarbonization are being managed through targeted investments and operational efficiencies and further described in our transition plan.

Anticipated Effects: Medium- to long-term impacts include capital allocation to low-carbon technologies, resilience investments, and potential financial penalties for non-compliance. Strategic responses include robust mitigation plans, outlined in our transition plan, and enhanced governance oversight.

Adaptations: Odfjell has integrated sustainability risks into corporate strategy, driving adjustments in fleet operations, procurement, and workforce management.

MATERIAL POSITIVE AND NEGATIVE IMPACTS ON PEOPLE AND ENVIRONMENT AND CONNECTION TO BUSINESS MODEL

The following table provides a high-level overview of the material IROs identified through our materiality assessment. These topics are regarded as having actual and/or potential positive and negative impacts on people and the environment.

FINANCIAL EFFECTS OF MATERIAL RISKS AND OPPORTUNITIES

Financial Position: Current risks impact financial performance through cost of regulatory compliance (e.g. EU MRV, IMO DCS) and emission-related penalties. Opportunities arise from enhanced ESG ratings and access to sustainable finance.

Phase in: For the 2024 reporting period, Odfjell has incorporated financial assessments of material IROs; however, the specific financial impact assessment for each IRO is subject to a phase-in period. During this phase-in, we have used a guiding scale to evaluate anticipated financial effects, focusing primarily on qualitative assessments for this reporting cycle. Detailed financial assessments of individual IROs are still under development and will be completed in subsequent reporting periods.

Short-Term Effects: Increased operational costs due to regulatory requirements and decarbonization measures.

Medium- to Long-Term Effects: Expected shifts include enhanced revenue streams from sustainable shipping services and improved access to green finance. Investments in fleet modernization and CapEx for decarbonization initiatives are planned and will be funded through sustainable financing.

RESILIENCE OF STRATEGY AND BUSINESS MODEL

Odfjell's business model for seaborne chemical transportation has demonstrated resilience through decades of operational expertise, strategic market positioning, and adaptability to evolving global dynamics. This resilience is assessed through a combination of qualitative and quantitative evaluations, incorporating historical data, market analysis, and climate scenario modeling.

In 2024, Odfjell conducted a comprehensive assessment of its business model's ability to address material impacts, risks, and opportunities. These evaluations, which are subject to continuous review, apply the previously defined time horizons and consider potential regulatory shifts, decarbonization trajectories, and economic fluctuations. Scenario modelling indicates that Odfjell's strategy remains robust under multiple plausible futures, with no identified risk of stranded assets. Fleet modernization efforts ensure compliance with evolving regulatory requirements while maintaining operational flexibility to adapt to market developments.

A key pillar of Odfjell's resilience lies in the flexibility of its fleet and commercial strategy. The company's stainless steel chemical tankers are fitted with advanced systems for heating, cooling, inert gas application, and cleaning, enabling the transportation of a wide range of chemical and specialty liquid products. This versatility makes the fleet highly robust to shifts in customer demand, ensuring continued relevance across a broad customer base of more than 600 clients.

This flexibility extends to Odfjell's commercial model, which balances long-term contracts with spot market exposure, allowing the company to optimize market opportunities while managing commercial risks effectively. The ability to adjust to fluctuations in demand, shifting trade patterns, and emerging market needs has been a cornerstone of Odfjell's business success.

Odfjell's long-term resilience is further supported by its industry's strong historical correlation with GDP growth and recovery patterns during economic downturns. While future uncertainties remain, the chemical transportation market is deeply integrated into global supply chains, and no fundamental risks to the continuity of core markets have been identified.

Recognizing the inherent uncertainties in forward-looking projections, Odfjell remains committed to continuous monitoring and adaptation. By integrating quantitative scenario analysis with qualitative risk mitigation strategies, the company aims to sustain its resilience and ability to capture emerging opportunities, while addressing material risks, in an evolving regulatory and environmental landscape.

IROS COVERED BY ESRS DISCLOSURE REQUIREMENTS VS. ENTITY-SPECIFIC DISCLOSURES

Entity-Specific Disclosures: Ship Recycling, reflecting unique operational challenges in end-of-life vessel management.

Odfjell undertook a thorough process in 2023 to identify, assess, and prioritize material IROs, adhering to the principles of double materiality as outlined in the European Sustainability Reporting Standards (ESRS). The process ensured that the organization's impacts on people and the environment, and the financial implications of sustainability-related risks and opportunities, were fully considered. This disclosure outlines the steps taken, methodologies applied, and integration mechanisms used to align with the ESRS framework.

FIVE PHASES

Odfjell conducted the DMA in five structured phases:

1. Understanding and Mapping: Defined the context and scope of Odfjell's operations and value chain.
2. Identification: Pinpointed actual and potential impacts, risks, and opportunities.
3. Assessment: Evaluated the materiality of identified IROs using qualitative and quantitative criteria.
4. Decision-Making and Strategy Integration: Prioritized and consolidated material IROs into strategic ESG focus areas.
5. Reassessment: Conducted reviews and refinements to ensure accuracy and relevance.

PROCESS TO IDENTIFY, ASSESS, PRIORITIZE, AND MONITOR IROS

The first phase involved understanding and mapping Odfjell's operational context, including its activities, value chain, and business relationships. All business segments and geographic regions were analyzed to identify areas of potential impact. This phase also included updating the stakeholder analysis to incorporate both qualitative and quantitative feedback. Stakeholder engagement was critical to understanding Odfjell's significant impacts on people and the environment, and in identifying new sustainability matters.

In the second phase, Odfjell identified actual and potential impacts, risks, and opportunities through consultations with internal and external stakeholders. The activities were mapped against ESRS topics, sub-topics, and sub-sub-topics to ensure alignment with the reporting framework. Past materiality assessments provided a foundation for this process, which also incorporated sector-specific and geographic considerations.

We have also considered the connections between our impacts and dependencies and the risks and opportunities identified from these. We have not identified any clear dependencies where the dependency itself is identified as a risk. We have integrated dependency assessments into our risk assessment in the DMA process.

During the third phase, Odfjell assessed the materiality of identified IROs. A comprehensive matrix was used to evaluate impact materiality based on scale, scope, rememberability, and likelihood. Financial materiality was assessed by analyzing the magnitude, likelihood, and nature of potential financial effects. The assessment also integrated climate and nature risk evaluations, employing scenario analysis to understand physical and transitional risks across short-, medium-, and long-term horizons.

In the fourth phase, decisions were made to prioritize material IROs. This process involved multiple discussions with senior management, the audit committee, and the board of directors. Material IROs were consolidated into eight strategic ESG focus areas, which informed Odfjell's corporate strategy. Internal controls and governance processes ensured that the prioritization adhered to ESRS requirements and aligned with Odfjell's sustainability goals.

The fifth and final phase involved reassessment to validate and refine the materiality assessment. Peer reviews and consultations with industry experts were conducted to benchmark findings. Minor adjustments were made to reflect evolving regulatory and market contexts. This reassessment ensured that the identified IROs remained accurate and relevant.

METHODOLOGIES AND ASSUMPTIONS APPLIED

Odfjell's double materiality assessment applied methodologies consistent with ESRS 1. Impact materiality was evaluated by assessing the scale, scope, irreversibility, and likelihood of impacts on people and the environment. Financial materiality was determined by analyzing the potential magnitude, likelihood, and nature of financial effects on Odfjell's position, performance, and cash flows. Specific thresholds for short-, medium-, and long-term impacts were defined, drawing on Odfjell's enterprise risk management (ERM) system to ensure consistency with corporate risk practices.

STAKEHOLDER ENGAGEMENT

Stakeholder engagement played a crucial role in the DMA. Internal stakeholders provided insights into potential impacts and risks across Odfjell's operations, while external stakeholders, including suppliers and industry experts, contributed perspectives on value chain risks and opportunities. Interviews and workshops were conducted to gather input, with particular focus on high-impact areas such as ship recycling and dry-docking processes. This engagement ensured that the materiality assessment reflected a diverse range of perspectives and addressed the most significant sustainability matters.

INTEGRATION WITH RISK MANAGEMENT PROCESSES

The process to identify and assess IROs was fully integrated into Odfjell's broader risk management framework. ESG risks identified through the DMA were incorporated into corporate risk assessments and reviewed quarterly by the board of directors and senior management. Internal control measures were developed to ensure accurate and consistent reporting of material IROs. The audit committee oversaw the alignment of ESG risks with corporate governance processes, ensuring that sustainability considerations were embedded in decision-making.

INTEGRATION OF OPPORTUNITIES INTO MANAGEMENT PROCESSES

Opportunities identified during the DMA were incorporated into Odfjell's strategic planning and management processes. These included opportunities such as transitioning to low-carbon operations, leveraging green finance, and adopting innovative technologies. Each opportunity was evaluated for its alignment with Odfjell's long-term business goals and integrated into operational and financial planning.

RESILIENCE AND MONITORING

The outcomes of the DMA demonstrated the resilience of Odfjell's business model in addressing sustainability-related risks and opportunities. Scenario analyses were conducted to anticipate potential impacts under different sustainability scenarios, and periodic reassessment ensured the continued relevance of identified IROs. This approach enabled Odfjell to adapt proactively to emerging challenges and opportunities.

FUTURE STEPS

Odfjell remains committed to refining its processes for identifying and managing IROs. Annual reviews will be conducted to ensure that the DMA reflects the latest regulatory, market, and stakeholder developments. Plans are underway to integrate double materiality findings into Odfjell's ERM and management systems, further strengthening the alignment of sustainability considerations with corporate decision-making. This iterative process underscores Odfjell's commitment to sustainability and its alignment with ESRS standards.

The content index table on pages 15-17 provides a comprehensive list of all Disclosure Requirements in ESRS covered by Odfjell's sustainability statement, indicating whether each requirement is material/obligatory and providing references to the relevant sections of the report.

The report indicates that a transition plan for climate change mitigation is included in accordance with ESRS E1-1, with references to climate targets and progress. The plan outlines concrete measures to reduce carbon intensity in the short term and aims for net-zero emissions, although it notes that sectoral pathways for shipping have not yet been defined by public policy to determine explicit 1.5°C alignment. Odfjell has a target to reduce carbon intensity by 57% by 2030 compared to 2008 levels and aims for a climate-neutral fleet from 2050, only ordering newbuildings with zero-emission capable technology.

Policies related to climate change mitigation and adaptation

Odfjell has established policies that address climate change mitigation and adaptation as material impacts, risks, and opportunities identified through its double materiality assessment.

Environmental Policy

Odfjell's Environmental Policy is part of a comprehensive framework designed to manage material impacts, risks, and opportunities related to climate change mitigation and adaptation.

General objectives and key content:

• Reducing greenhouse gas emissions
• Enhancing energy efficiency
• Supporting the transition to renewable energy sources
• Addressing operational emissions, regulatory compliance, and technological advancements
• Setting Odfjell's climate targets

Scope: The policy encompasses all company activities, including upstream and downstream value chains, across all geographies where the company operates. It includes stakeholders such as employees, customers, suppliers, and regulatory bodies. The policy excludes no significant activities or geographies, ensuring a holistic approach to environmental management.

Governance and oversight: The board of directors and executive management hold ultimate responsibility for overseeing the company's environmental strategy and ensuring adherence to this policy. The chief sustainability officer (CSO), operational and ship management teams are tasked with implementing environmental initiatives and regularly updating the board on progress.

Alignment with international standards: Odfjell's Environmental Policy aligns with third-party standards and initiatives, such as:

• International Maritime Organization (IMO) regulations
• Paris Agreement ambitions

Stakeholder consideration: In setting the policy, Odfjell considers the interests of key stakeholders, including customers and regulatory authorities, to ensure it meets their expectations and requirements.

Public availability: The policy is made available to all potentially affected stakeholders through the company's website and internal communication channels, ensuring transparency and accessibility.

Implementation and monitoring: The process for monitoring involves regular assessments and reporting to ensure continuous improvement and adherence to environmental standards.

Climate change mitigation measures:

• Investing in low and zero-carbon capable ships
• Utilizing net-zero fuels
• Optimizing route planning to reduce emissions

Climate change adaptation measures:

• Supporting the development of zero-emission technologies and infrastructure to enhance resilience

Energy efficiency: Energy efficiency is a core focus, with continuous improvements in operational practices and technological upgrades. Additionally, the policy promotes the deployment of renewable energy sources to further reduce the company's environmental footprint.

Actions and resources in relation to climate change policies

Odfjell has identified several key decarbonization levers and actions to achieve its emission reduction targets, organized around fleet transition, operational efficiency, technology deployment, and value chain collaboration.

Fleet Transition Plan

New vessel acquisitions and long-term time charters:

• Action: Committed to acquisition of 18 new vessels (2 owned ships and 16 vessels on long-term time charter)
• Scope: Own operations
• Time horizon: Delivery between Q2 2024 and 2028
• Description: Modern stainless steel chemical tankers, frequently including purchase options, designed to be retrofitted for operation with net-zero fuels. One vessel under construction in China, 17 in Japan
• Resources: Not publicly disclosed; vessels secured under TC arrangements
• Link to policy/target: Supports net-zero by 2050 target and requirement that all newbuildings be net-zero capable

Supersegregator replacement programme:

• Action: Potential construction of 6-12 newbuildings to replace ageing supersegregator fleet
• Scope: Own operations (owned and controlled fleet)
• Time horizon: Construction anticipated to commence in 2027, over next 3-8 years (long term)
• Description: Large stainless steel ships with multiple segregations and stainless steel tanks, incorporating latest energy efficiency and fuel technology
• Resources: Estimated USD 500-900 million investment (subject to vessel configurations, shipyard availability, pricing and market considerations). Overall investments may be lower if some vessels committed through long-term time charters
• Link to policy/target: Fleet transition strategy to achieve net-zero emissions by 2050

Technology and Energy Efficiency Initiatives

Suction sails retrofit:

• Action: Retrofit first ship with suction sails and evaluate efficiency
• Scope: Own operations
• Time horizon: Short term (2024-2026)
• Link to policy/target: Energy efficiency and decarbonization initiatives

Energy-saving devices:

• Action: Long history of investing in energy-saving devices on vessels
• Scope: Own operations
• Resources: Not publicly disclosed; payback periods ranging from 1 to 7 years with net positive return
• Expected outcomes: Reduced fuel costs and emissions
• Link to policy/target: Operational efficiency measures contributing to 57% emissions reduction by 2030

Operational efficiency improvements:

• Action: Improving operational efficiency through optimal speed, weather routing, hull cleaning, port efficiency, and utilization
• Scope: Own operations
• Time horizon: Short term (2024-2026) through long term (2031-2050)
• Description: Improving information and digitalization for better decision support
• Link to policy/target: Continuous optimization to minimize emissions

Alternative Fuels

Biofuel adoption (B-30):

• Action: Start using biofuel B-30 to reduce carbon intensity of fuel on fleet basis
• Scope: Own operations
• Time horizon: Short term (2024-2026)
• Description: Align with FuelEU Maritime regulations
• Resources: Anticipated shift towards biofuels expected to be more expensive than conventional fuels (specific costs not disclosed). Contracts include bunker adjustment clauses to manage fuel expense fluctuations
• Link to policy/target: FuelEU Maritime compliance and carbon intensity reduction

Net-zero capable vessels and alternative fuel integration:

• Action: Initiate investment plan for net-zero capable ships; pilot alternative fuel technologies; fully transition to low-carbon or net zero-emission fuels
• Scope: Own operations
• Time horizon: Medium term (2027-2030) for investment plan initiation; long term (2031-2050) for full transition
• Link to policy/target: FuelEU Maritime, Global Fuel Intensity standard, and net-zero by 2050 target

Value Chain and Scope 3 Initiatives

Supplier collaboration for Scope 3 reporting:

• Action: Actively collaborating with suppliers to improve scope 3 reporting accuracy by transitioning from spend-based to activity-based reporting approach
• Scope: Upstream value chain
• Time horizon: Ongoing (short to medium term)
• Description: More than 80% of scope 3 emissions attributed to fuel production, closely linked to scope 1 reduction efforts
• Link to policy/target: Net-zero emissions across all scopes; well-to-wake emissions coverage

Time chartered vessel efficiency collaboration:

• Action: Engaging with owners of time chartered vessels to enhance efficiency and reduce emissions
• Scope: Upstream value chain (chartered vessels in operated fleet)
• Time horizon: Ongoing
• Description: Knowledge sharing and implementation of technical and operational measures, though vessels are not under direct control
• Link to policy/target: Scope 1 emissions reduction (chartered vessels contribute to operated fleet emissions)

Renewable energy in offices:

• Action: Implementing energy-saving measures and increasing use of renewable energy across office locations
• Scope: Own operations (Scope 2)
• Time horizon: Ongoing
• Description: Scope 2 emissions represent less than 1% of overall footprint
• Link to policy/target: Scope 2 reduction commitment

Research, Development and Infrastructure Support

R&D and technology development:

• Action: Initiate R&D projects for next-generation technologies; support initiatives to develop technology for decarbonization, energy efficiency, and net zero emissions
• Scope: Own operations and broader value chain
• Time horizon: Short term (2024-2026) for initiation; ongoing through long term
• Description: Actively supports development of infrastructure and technologies necessary to achieve net zero-emission shipping industry
• Link to policy/target: Climate target 4: "Support initiatives to develop technology for decarbonization, energy efficiency, and net zero emissions, promoting a fair and equitable transition"

Vessel Lifetime Extension

Life Cycle Assessment for lifetime extension:

• Action: Conducted Life Cycle Assessment (LCA) for specific ship class to evaluate requirements for lifetime extension
• Scope: Own operations and upstream value chain (shipbuilding scope 3 emissions)
• Description: Assessment evaluated requirements for lifetime extension, feasibility of certification beyond design life, and total emissions throughout ship life cycle
• Expected outcomes: Findings revealed scope 1 emissions during operational phase significantly exceed scope 3 emissions from construction; life extension does not substantially impact total life cycle emissions
• Link to policy/target: Reducing total emissions including value chain; integral to transition planning

Implementation Roadmap

Short term (2024-2026):

• Complete ongoing fleet renewal initiatives
• Implement identified energy efficiency measures across the fleet
• Initiate R&D projects for next-generation technologies
• Set targets for scope 2 reduction
• Increase use of activity-based scope 3 data
• Retrofit first ship with suction sails and evaluate efficiency
• Start using biofuel B-30 to reduce carbon intensity
• Update strategy following IMO MEPC 83 decisions and roadmap

Medium term (2027-2030):

• Ensure compliance with new IMO regulations
• Scale up successful efficiency initiatives
• Initiate investment plan for net-zero capable ships
• Initiate integrating net zero-emission capable vessels into the fleet
• Assess sourcing of alternative fuel
• Fleet renewal in accordance with fleet transition plan

Long term (2031-2050):

• Progressively replace older vessels with net zero-emission capable ships
• Fully transition to low-carbon or net zero-emission fuels in line with FEM and GFI
• Continuously optimize operations to minimize emissions
• Pilot alternative fuel technologies
• Fleet renewal in accordance with fleet transition plan

Sustainable Finance Frameworks

Sustainability-Linked Financing (SLF) framework:

• Action: Established SLF framework for general purpose financing
• Scope: Corporate/financial
• Description: Enables issuance of bonds and securing loans linked to sustainability targets. Externally verified by third-party, aligned with ICMA and LMA principles
• Resources: Strong demand from investors and financial institutions (specific amounts not disclosed)
• Link to policy/target: Supports overall sustainability and climate targets

Transition Finance Framework (TFF):

• Action: Introduced TFF in 2024 as use-of-proceeds framework
• Scope: Corporate/financial
• Description: Enables issuance of bonds and loans specifically linked to activities supporting transition to net-zero. Externally verified, aligned with ICMA and LMA principles
• Resources: Use-of-proceeds framework (specific amounts not disclosed)
• Categories covered: 1) Low-carbon and zero emissions ships, 2) Fuel switching and carbon reduction, 3) Research and development and transition strategy, 4) Infrastructure, 5) Vessel lifetime extensions, 6) Low-carbon and zero emissions newbuildings
• Link to policy/target: Net-zero transition and climate targets

Governance and Responsibility

Technology section responsibility:

• Responsible party: Technology section of Ship Management division
• Scope: Own operations (fleet)
• Description: Responsible for ensuring compliance and driving energy efficiency and decarbonization initiatives in the fleet
• Link to policy/target: Decarbonization as material topic

Resources Summary

Capital Expenditures:

• 18 new vessels (2 owned, 16 TC) delivering 2024-2028 (amounts not disclosed)
• Potential USD 500-900 million for 6-12 supersegregator newbuildings over 3-8 years from 2027 (subject to configuration and market conditions)
• Energy-saving device investments with 1-7 year payback periods (amounts not disclosed)

Operational Expenses:

• Anticipated higher fuel costs for biofuels vs. conventional fuels (specific amounts not disclosed)
• Bunker adjustment clauses in contracts to manage fuel expense fluctuations
• Contract clauses ensure customers bear increased costs of EU emission allowances

Note: Specific CapEx figures not publicly disclosed. Deep-sea chemical tankers not EU Taxonomy-eligible until achieving zero tailpipe emissions; newbuildings will be taxonomy-aligned when operating on net-zero well-to-wake fuels.

Climate Targets: • Reduce carbon intensity by 57% by 2030, compared to 2008 levels • Achieve a climate-neutral fleet from 2050 • Only order newbuildings with zero-emission capable technology • Achieve minimum C-rating for all vessels under the Carbon Intensity Indicator (CII)

Odfjell has been able to achieve its target of minimum C-rating for all vessels since we started to report on the actual Carbon Intensity Indicator (CII) of our vessels in 2023.

About the targets: The targets are entity-specific KPIs including: • Annual Efficiency Rate (AER) according to IMO standard • Carbon intensity reporting exclusively for the controlled fleet

Odfjell reports carbon intensity exclusively for the controlled fleet consisting of vessels for which Odfjell can influence carbon intensity through both operational and technical measures.

Energy consumption and mix

Scope and methodology:
Energy values are calculated per quantity of fuel type using the energy consumption calculator tool by the Sustainable Energy Authority of Ireland (SEAI) since 2011. All conversion factors are based on net calorific values. Numbers exclude Terminals JV and are not comparable with earlier reported numbers in previous annual reports.

Energy intensity (total energy consumption per net revenue) associated with activities in high climate impact sectors:

Net revenue from activities in high climate impact sectors (Tankers) and total net revenue from annual report 2024, Note 4 Segment information and disaggregation of revenues.

Gross Scopes 1, 2, 3 and Total GHG emissions

Scope Overview and Methodology

Fleet categorization and consolidation:

• Odfjell Controlled Fleet: Owned, Bareboat
• Odfjell Operated Fleet: Owned, Bareboat, Time Chartered to Odfjell and pool
• Financial control (ESRS): Owned, Bareboat, Time Chartered to Odfjell and Time Chartered out from Odfjell*
• Operational control (ESRS): Owned, Bareboat, Time Chartered to Odfjell, Time Chartered out from Odfjell and pool

*Note: Odfjell has one vessel, Flumar Brazil, time chartered out to Petrobras mainly for storage in Brazil. The vessel is owned by Odfjell but excluded from IMO DCS reporting and therefore not reported as Odfjell's controlled fleet. The vessel is included in Operational controlled fleet in 2024. The vessel represents 0.58% difference of Operated Control and Odfjell Operated fleet.

The sustainability statement consolidates all controlled entities in the Odfjell Group, the same as the financial reporting. Odfjell's investments in terminals (joint ventures) are not consolidated in Scope 1, 2, 3 reporting.

Scope 1: Direct GHG emissions from vessels. Emissions are quantified based on fuel consumption using emission factors according to EU Regulation 2023/1805. GHGs covered: CO₂, CH₄, N₂O. Odfjell reports Scope 1 for multiple fleet definitions.

Scope 2: Indirect emissions from purchased electricity (offices). Location-based and market-based methods used. National electricity generation emission factors and/or national electricity residual mix factors for Norway, The Philippines, Singapore and Brazil by Carbon Footprint Ltd. were used. Bergen office in Norway has a 100% renewable energy certificate of origin (11.6% of total location-based Scope 2 emissions). Scope 2 represents <0.1% of total emissions.

Scope 3: Value chain emissions across 9 relevant categories (of 15). Methodology:

• Category 1 (Purchased goods and services): Spend-based method using EXIOBASE v.3.3 MRIO database. Inflation adjustment of 27.5% applied to emission factors (HICP for EU 2011-2024). In 2024, a new category covering port costs (including towage), IT purchases and all provisions on board was introduced using spend-based method.
• Category 2 (Capital goods): Spend-based, extrapolated at 0.3% of total location-based GHG emissions from 2022.
• Category 3 (Fuel and energy-related activities): For 2024, shifted from spend-based to volume-based approach using IPCC 2021 GWP100 factors with fuel-specific well-to-tank (WTT) emission factors from Ecoinvent 3.9.1. This methodological change results in a reduction in reported Scope 3 cat 3 emissions between 2023 and 2024.
• Category 4 (Upstream transportation and distribution): Spend-based, extrapolated at 0.1% of total location-based GHG emissions from 2022.
• Category 5 (Waste generated in operations): Average-data method using primary data. Emission factor for municipal waste from the Norwegian Emission Inventory 2016 by Statistics Norway. Waste from ships measured for 2024.
• Category 6 (Business travel): Distance-based method using primary data (plane and car travel for crew and employees).
• Category 7 (Employee commuting): Distance-based method using average kilometer commute per employee (offices in Bergen, Manila, Singapore, Sao Paulo).
• Category 12 (End-of-life treatment of sold products): No vessels recycled in 2023 or 2024, resulting in zero downstream emissions.
• Category 15 (Investments): Scope 1, 2, 3 emissions from JV terminals in USA and South Korea. 2024 data estimated from 2023 reported data, representing 3.9% of all Scope 3 emissions.

Categories not relevant: 8, 9, 10, 11, 13, 14.

Scope 3 represents 36.3% of Odfjell's total location-based GHG emissions. 85% of Scope 3 is directly correlated with Scope 1 emissions. 1.2% of Scope 3 emissions calculated using primary data for categories 5 and 6.

2021 baseline: Full Scope 3 analysis not available in 2021; historical data recalculated based on average Scope 3-to-Scope 1 ratio observed in 2022 and 2023.

GHG intensity: Total GHG emissions per net revenue (tCO₂eq/USD).

EU ETS: In 2024, shipping was included in the EU ETS. 16.3% of Scope 1 GHG emissions (Odfjell Operated fleet) from regulated emissions trading schemes.

Total GHG emissions disaggregated by scope 1, scope 2 and significant scope 3

Note: all numbers, excluding Terminals JV, not comparable with earlier reported numbers in previous annual reports.

Total GHG intensity per net revenue

Note: Net revenue from activities in high climate impact sectors (Tankers) and total net revenue from annual report 2024, Note 4 Segment information and disaggregation of revenues.

Biogenic CO₂ emissions

Not separately disclosed.

GHG removals and GHG mitigation projects financed through carbon credits

Odfjell does not have any GHG removals or GHG mitigation projects financed through carbon credits.

Internal carbon pricing

Odfjell does not apply internal carbon pricing schemes in its business.

Anticipated financial effects (E1-9)

Odfjell 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 standards. The transition plan and climate risk assessment present a thorough insight into the risks and opportunities and financial effects.

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

Phase-in exemption statement

Odfjell 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 standards. The transition plan and climate risk assessment present a thorough insight into the risks and opportunities and financial effects.

Qualitative assessment of financial effects

Financial Position: Current risks impact financial performance through cost of regulatory compliance (e.g. EU MRV, IMO DCS) and emission-related penalties. Opportunities arise from enhanced ESG ratings and access to sustainable finance.

Phase in: For the 2024 reporting period, Odfjell has incorporated financial assessments of material IROs; however, the specific financial impact assessment for each IRO is subject to a phase-in period. During this phase-in, we have used a guiding scale to evaluate anticipated financial effects, focusing primarily on qualitative assessments for this reporting cycle. Detailed financial assessments of individual IROs are still under development and will be completed in subsequent reporting periods. This approach aligns with the phase-in provisions outlined in ESRS 1 Appendix C and ESRS 2 SBM-3. Additionally, capital expenditure (CapEx) plans related to our transition strategies are included in the transition plan and provide further insights into our financial planning.

Short-Term Effects: Increased operational costs due to regulatory requirements and decarbonization measures.

Medium- to Long-Term Effects: Expected shifts include enhanced revenue streams from sustainable shipping services and improved access to green finance. Investments in fleet modernization and CapEx for decarbonization initiatives are planned and will be funded through sustainable financing.

Climate risk assessment methodology

Risk in 3 different Climate Scenarios (ref. IPCC AR6 scenarios)

Where:

• CN1: Climate-Related Direct Physical Risk
• CN2: Climate-Related Transition Risk
• CN3: Climate and Nature Litigation Risk
• CN4a: Value Chain and Cross Border Direct Climate Risk
• CN4b: Value Chain and Cross Border Transition Climate Risk
• CN5: Climate and Nature Reputation Risk
• CN6: Nature-Related Direct Risk
• CN7: Nature-Related Transitional Risk
• CN8: Nature-Related Systemic Risk

Financial materiality assessment approach

The financial effects of our material risks and opportunities on our financial position, financial performance and cash flows were evaluated in the financial materiality assessment in the DMA process and follow our corporate risk level definitions for consequences.

Resilience of business model

The resilience analysis has been conducted as part of our ongoing risk management and strategic planning efforts. We have systematically assessed transition risks, direct physical risks, and financial implications using climate scenario analysis aligned with the requirements set out in ESRS 2 IRO-1. These assessments consider multiple time horizons to evaluate both short- and long-term risks to our fleet, business operations, and financial performance.

Our risk assessments include evaluating the financial impact of transition risks, such as regulatory changes, carbon pricing mechanisms, and evolving market expectations. The analysis also considers direct risks posed by physical climate hazards, including extreme weather events and long-term shifts in environmental conditions. The findings from these assessments are integrated into our broader corporate strategy and sustainability roadmap.

The results of our resilience analysis indicate that Odfjell's business model is currently robust when considering the impacts of climate change and transition risks as they are presently understood. Our strategic initiatives to reduce emissions across our existing fleet, coupled with the estimated lifetime of our vessels, ensure that we do not face a risk of stranded assets.

Scenario modelling indicates that Odfjell's strategy remains robust under multiple plausible futures, with no identified risk of stranded assets. Fleet modernization efforts ensure compliance with evolving regulatory requirements while maintaining operational flexibility to adapt to market developments.

Policies related to pollution

Odfjell has identified pollution to air and water as material concerns through its comprehensive assessment and value chain analysis. Pollution to soil is not considered material as maritime operations occur at sea and office activities do not constitute a significant source of pollution.

Environmental Policy

Odfjell's Environmental Policy addresses pollution-related impacts alongside climate change mitigation and adaptation.

Policy objectives and content:

• Eliminating accidental pollution
• Minimizing emissions
• Phasing out harmful substances
• Compliance with IMO regulations (SOx, NOx, and particulate matter)
• Implementation of advanced waste and ballast water management systems
• Ongoing monitoring of pollutant emissions using best practices and technologies
• Minimizing the use of hazardous substances and phasing out substances of very high concern (SVHC), particularly in shipbuilding and maintenance processes
• "Zero accidents" philosophy, prioritizing prevention of environmental incidents

Pollutants and substances covered:

• GHG, SOx, NOx and particulate matter
• Harmful and hazardous substances
• Substances of very high concern (SVHC)

Scope:

• All company activities, including upstream and downstream value chains
• All geographies where the company operates
• Odfjell's entire operational value chain, including its fleet and supporting logistics
• No significant activities or geographies are excluded

Affected stakeholders:

• Employees
• Customers
• Suppliers
• Regulatory bodies
• Local communities
• Global maritime regulators

Governance and oversight:

• The Chief Sustainability Officer (CSO) is responsible for implementing the policy
• Ship management teams and operational teams support implementation
• Ultimate oversight lies with the Board of Directors and Executive Management
• CSO, operational and ship management teams regularly update the board on progress

Alignment with third-party standards and initiatives:

• International Maritime Organization (IMO) regulations and GHG Strategy
• IMO MARPOL regulations and convention
• Paris Agreement
• United Nations Global Compact
• European Union's Corporate Sustainability Reporting Directive (CSRD)
• European Sustainability Reporting Standards (ESRS)
• National regulations
• Carbon Disclosure Project (CDP)
• Task Force on Climate-Related Financial Disclosures (TCFD)

Stakeholder engagement in policy formulation: Key stakeholders considered include regulators, customers, employees, local communities, suppliers, tonnage providers, and industry partners. The company collaborates with suppliers to reduce scope 3 emissions and works with tonnage providers and industry partners to ensure collective progress toward environmental goals.

Public availability: The policy is available through:

• Odfjell's webpage
• Transparent reporting and disclosures
• Annual sustainability reporting
• Integrated into training programs to educate employees and other implementers

Monitoring of implementation:

• Regular assessments and reporting to ensure continuous improvement and adherence to environmental standards
• Regular reporting aligned with CDP and TCFD frameworks
• Progress reviewed annually in sustainability reports featuring metrics like the IMO's Carbon Intensity Indicator (CII)
• The process for monitoring involves regular assessments to ensure continuous improvement
• Environmental management system audited several times a year as part of the Tanker Management Self-Assessment (TMSA), reported to the Oil Companies International Marine Forum (OCIMF)

Material aspects targeted:

• Emissions (air pollutants, greenhouse gases)
• Marine pollution (wastewater, ballast water)
• Hazardous substances

Actions and resources related to pollution include strict systems to prevent spills and mitigate their effects, including real-time monitoring, robust emergency response procedures, and compliance with international pollution prevention standards. Additionally, spill incidents are tracked and reported with immediate corrective actions, and fines are managed under a structured response framework.

Targets related to pollution

Odfjell has set the following targets related to pollution:

Target 1: Accidental pollution (spills)

Target metric: Number of accidental pollution cases from Odfjell managed vessels

Target value:

• 2024: Below 2 cases (voluntary target)
• Long-term: 1 pollution case

Target type: Absolute

Scope: Odfjell managed vessels (Fleet Bergen, Fleet Flumar, and Fleet Thome - external managed vessels in the controlled fleet)

Baseline: Per year measurement period

Science-based/validation: Not based on scientific evidence; targets not validated externally. Stakeholders were not involved in target setting.

Philosophy: Zero-accident philosophy with ultimate aim of zero spills to the environment

Progress to date

Other pollution metrics (no specific targets set)

SOx, NOx, and black carbon emissions: Odfjell has not set targets for these pollutants as the company must adhere strictly to IMO regulations and EU directives (FuelEU Maritime Regulation and IMO MARPOL regulations). Emissions are closely connected to fuel consumption volume.

Pollution to soil: No targets set as this topic is not material according to Odfjell's Double Materiality Assessment (DMA).

Air Pollution: We evaluated emissions of NOx, SOx, and black carbon due to their broader environmental impacts, including climate change, acidification, and pollution. We noted the reduced impact of SOx emissions due to the widespread adoption of very low sulphur fuel oil (VLSFO). Emissions of black carbon were examined due to their potential contribution to climate change and pollution.

Water and Soil Pollution: Damage to aquatic ecosystems from spills or discharges poses environmental risks. Health risks to communities dependent on marine ecosystems harmed by spills are also considered.

Pollution Control Measures: Odfjell has implemented strict systems to prevent spills and mitigate their effects, including real-time monitoring, robust emergency response procedures, and compliance with international pollution prevention standards. Spill incidents are tracked and reported with immediate corrective actions.

Substances of concern and substances of very high concern

Odfjell does not produce, distribute, commercialize or import/export any substances of concern or substances of very high concern, in our own operations.

All our managed vessels are provided with firefighting foam, containing PFAS, which is a substance of concern. This firefighting foam is only used in an emergency and in line with current regulations. In September 2024, the EU Commission adopted new measures under the REACH Regulation (the EU chemicals legislation) to protect human health and the environment by restricting the use of undecafluorohexanoic acid (PFHxA) and PFHxA‑related substances. We plan to update the firefighting foam on board our vessels to PFAS-free firefighting foam.

Narrative on monitoring and management:

Odfjell's environmental policy focuses on minimizing the use of hazardous substances and phasing out those of very high concern (SVHC), particularly in shipbuilding and maintenance processes. The company prioritizes substituting non-essential hazardous substances with safer alternatives. Regular assessments of shipbuilding and maintenance materials ensure alignment with best environmental practices, minimizing the environmental footprint of operations.

Odfjell will enhance the monitoring of suppliers through the Achilles platform to improve insight into suppliers' use of materials and actions to mitigate pollution in the value chain.

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

Phase-in exemption

Odfjell has opted to exercise the phase-in allowance to omit the financial effects from material pollution risks and potential pollution-related opportunities required in E2-6.

Operating and capital expenditures in reporting period

The operating and capital expenditures incurred in the reporting period, in conjunction with major incidents and deposits, are zero. In the one case of pollution in the terminal area, this can be considered negligible as the affected area on board and at the terminal was promptly cleaned by the personnel on sight, requiring no additional resources.

Odfjell's policies related to own workforce include commitments to safety as a core value, gender equality and prevention of discrimination, training and development, and creating an inclusive workplace. Safety is described as more than a priority - it is a core value and part of their license to operate. The company is committed to ensuring the safety of employees, contractors and surrounding communities.

The company has clear objectives to retain and develop current employees, establish a diverse talent pool, and create an inclusive workplace for all. They have set specific targets to improve gender balance in line with strategy and requirements of the Equality and Anti-Discrimination Act §26.

Odfjell follows national and international regulations regarding employee representation and has established works councils and working environment committees with employee representation to ensure dialogue and alignment on relevant topics and decisions.

Odfjell engages with employees through various channels including: • Intranet updates • Town halls • Workers' councils • Working environment councils • Officers' (seafarers') councils • Employee boards • Social interests/sports committees • Annual individual performance dialogues • Bi-annual employee engagement surveys

Outcomes from employee engagement surveys are analyzed and integrated into decision-making processes. The company has established permanent employee representative bodies and various committees and councils where management and employee representatives meet to discuss relevant issues.

For Odfjell Management AS, they have a works council (WC) with representation from management and elected employees to ensure dialogue and alignment of relevant topics and decisions. They also have a working environment council (AMU) with employee representation.

Employee involvement at corporate level and in subsidiaries abroad is secured by various committees and councils in which management and employee representatives – both onshore personnel and seafarers – meet to discuss relevant issues.

Employees can raise concerns through Odfjell's independent whistle-blowing mechanism. The company has established whistleblowing systems as part of their employee engagement approach.

As a central group of stakeholders, engagement with employees drives key aspects of the people strategy, with focus on employees' health, safety, well-being, and rights being vital to the business. Respect for human rights is integral to the organization.

Odfjell takes various actions to address material impacts on own workforce:

Safety Actions: • Continuous development and monitoring of safety training • No compromise on safety standards • Thorough follow-up measures for Lost Time Injuries • Strengthened efforts to reduce LTIs to zero • Targeted actions to learn from incidents and mitigate risks

Training and Development: • Leadership courses and external assessments of senior officers at sea • Five Odfjell Leadership Training courses in 2024 • Ten Elite Pro assessments • Several Bridge Resource Management (BRM) and Engine Resource Management (ERM) training courses • All-company development program for onshore employees and managers • Fleet Week conferences bringing together colleagues from sea and shore

Workplace Environment: • Holistic development program based on employee engagement survey results • Focus on creating a physically and psychologically safe work environment • Annual performance management wheel enabling structured dialogue between employees and managers • Support for competence development and employee growth

Diversity and Inclusion: • Systematic and continuous commitment to gender equality and prevention of discrimination • Collaboration with employee representatives • Specific targets for gender balance by 2030

Gender Balance Target: Odfjell has set a goal of achieving a minimum 30% gender balance at all levels by 2030.

Current Gender Balance Status: • Bergen headquarters: 66% men and 34% women (consistent with 2023) • Globally: 68% men and 32% women (consistent with previous year) • Board of Directors: 3 of 6 directors are women (50%)

Safety Targets: • Zero incident target for industry leading safety record • Target to reduce Lost Time Injuries (LTIs) to zero • Minimum C-rating for all vessels under Carbon Intensity Indicator (CII)

Entity-Specific KPIs: • Absence rate: Bergen headquarters 2.37% (down from 2.82% in 2023); Seafarers 2.5% (up from 1.35% in 2023) • Total Recordable Case Frequency (TRCF) according to OCIMF standards

Training Target: The aim of the all-company development program is to continue fostering a safe, sustainable, and inclusive workplace where everyone can contribute and is treated with respect to retain and attract tomorrow's talent.

Performance Metrics Integration: Sustainability-related targets are embedded in incentive schemes: • 17% of STIP dedicated to decarbonization objectives for shipping division • 22% of STIP linked to safety and spill-prevention metrics for headquarters and terminals • 33% of LTIP dedicated to decarbonization performance

Workforce Composition

Geographic Distribution

Odfjell operates globally with employees across all continents, serving key markets in the Americas, EMEA, Asia, and the Pacific.

Gender Composition

Bergen Headquarters (170 employees): • Men: 66% • Women: 34%

Global Workforce: • Men: 68% • Women: 32%

Turnover Rates

Entity-Specific Dual Reporting Method: Given the diversity and complexity of Odfjell's workforce categories and employment types, turnover rates and employees who left are reported using both:

1. Mandatory ESRS method
2. Industry-specific INTERTANKO method

2024 Turnover Rates: • Bergen headquarters: 1.18% (down from 3.6% in 2023) • Seafarers: 2.6% (down from 3.4% in 2023)

Absence Rates

• Bergen headquarters: 2.37% (down from 2.82% in 2023) • Seafarers: 2.5% (up from 1.35% in 2023)

Employee Engagement

High scores in engagement and enablement surveys, coupled with low absence rates onshore and at sea and high retention, indicate a robust and healthy working environment.

Board Representation

Board of Directors: • Total directors: 6 • Women directors: 3 (50% gender diversity) • Independent directors: 5 (83% independent)

Executive Management Composition

Executive management consists of: • Chief Executive Officer (CEO) • Chief Financial Officer (CFO) • Chief Sustainability Officer (CSO) • Chief Technical Officer (CTO) • Chief Commercial Officer (CCO) • Managing Director Terminals (MD Terminals)

All executive managers are male with extensive experience in the sector.

Collective bargaining coverage and social dialogue

Commitment to collective bargaining and social dialogue

Odfjell maintains a commitment to freedom of association and adherence to local norms and collective bargaining agreements, both onshore and at sea. Through councils, committees, and surveys, the company actively listens to its employees.

Employee representation structures

Odfjell follows national and international regulations regarding employee representation. For Odfjell Management AS, the company has a works council (WC) with representation from management and elected employees to ensure dialogue and alignment of relevant topics and decisions. Odfjell also has a working environment council (AMU), a Norwegian regulation, with employee representation. Offices and companies outside of the EU follow local regulations.

Seafarer collective bargaining coverage

For seafarers managed by Odfjell Maritime Services AS in Norway, wages are tariff-regulated through Collective Bargaining Agreements (CBA), and salary levels are linked to specific positions, ensuring equal pay regardless of gender.

Note: The disclosure confirms the existence of works councils, collective bargaining agreements for Norwegian seafarers, and social dialogue structures, but does not provide quantitative percentage coverage metrics overall, by geography (EEA/non-EEA), or by employee category.

Gender Diversity Metrics

Current Gender Balance (2024):

Bergen Headquarters (170 employees): • Men: 66% (same as 2023) • Women: 34% (same as 2023)

Global Workforce: • Men: 68% (consistent with previous year) • Women: 32% (consistent with previous year)

Board of Directors: • 3 of 6 directors are women (50% gender diversity) • Independent directors: 5 of 6 (83% independent)

Executive Management: • All executive managers are male • Consists of CEO, CFO, CSO, CTO, CCO, and MD Terminals • All have extensive experience in the sector

Gender Balance Target: • Minimum 30% gender balance at all levels by 2030

Commitment to Diversity: Odfjell's commitment to gender equality and prevention of discrimination is carried out systematically and continuously in collaboration with employee representatives. The company has set specific targets to improve gender balance in line with strategy and requirements of the Equality and Anti-Discrimination Act §26.

Strategic Approach: Diversity is not the objective in itself. Research has shown it may promote well-being, contribute to improved decision-making, and help attract and retain talent. In the long run, this contributes to the safety and quality of operations.

Focus Areas: • Retain and develop current employees • Establish a diverse talent pool • Create an inclusive workplace for all

Health and safety metrics

Workforce covered by health and safety management system: 100% of employees (2024, 2023, 2022)

Safety Performance

*Base year LTIF and TRCF

Fatalities: No fatalities occurred among Odfjell's own workforce or within the value chain in 2024. Fatalities include work-related deaths due to injuries or ill health caused by work activities.

Lost Time Injuries: Lost Time Injuries (LTIs) increased from one in 2023 to seven in 2024, with four incidents occurring within Fleet Flumar operations. All affected individuals have recovered well.

Absence rate: In 2024, the absence rate at headquarters was 2.37% (down from 2.82% in 2023). Among Odfjell and Flumar seafarers, the absence rate for 2024 stood at 2.5% (rising from 1.35% in 2023).

Methodology

Safety data is categorized into shore-based employees and crew on Odfjell-managed vessels within its controlled fleet (Fleet Bergen, Fleet Flumar, and Fleet OSM Thome). Fleet OSM Thome crew are defined by ESRS as workers in the value chain. Definitions follow OCIMF standards. Exposure hours for seafarers are defined as 24 hours per day while serving on board according to OCIMF. Exposure hours for shore-based personnel is defined as the working hours per day. LTIF is calculated by multiplying the number of lost time incidents by 1,000,000 and dividing by the number of exposure hours. TRCF is calculated by multiplying the total number of recordable cases by 1,000,000 and dividing by the number of exposure hours.

Compensation metrics (S1-16)

Pay gap

Shore-Based Employees:

Odfjell complies with the requirements of section 26 of the Norwegian Equality and Anti-Discrimination Act. Data from countries with fewer than five employees in any gender group are excluded from the metrics. The gender pay gap is calculated based on the average annual basic salary for full-time employees. The total gender pay gap reflects the composition of the workforce, where men hold a higher proportion of senior-level positions.

Seafarers:

For seafarers managed by Odfjell Maritime Services AS in Norway, wages are tariff-regulated through Collective Bargaining Agreements (CBA), and salary levels are linked to specific positions, ensuring equal pay regardless of gender.

*Includes all seafarers within Odfjell's seafarer pool (Filipino (PHP), North West (NWE), and Flumar seafarers)

Remuneration ratio

Shore-Based Employees:

The remuneration ratio globally is based solely on base salary for all shore-based employees globally. In 2024, the base salary of the highest-paid individual was seven times the median base salary for all shore-based employees globally (2023: seven times).

The remuneration ratio Norway is calculated by comparing the total remuneration of the highest-paid individual to the median total remuneration of all employees in Norway. This includes both female and male employees and accounts for basic salary as well as cash and non-cash benefits. To ensure comparability, the ratio is calculated within Norway, eliminating purchasing power differences across countries. In 2024, the total remuneration of the highest-paid individual was nine times the median total remuneration for Norway (2023: nine times).

Seafarers:

*Includes all seafarers within Odfjell's seafarer pool (Filipino (PHP), North West (NWE), and Flumar seafarers)

Methodology

For shore-based employees, the company utilizes a job architecture comprising over 20 levels, grouped into four broader categories: business support, professionals, frontline management and senior professionals, and executive & leadership. The gender pay gap is calculated based on the average annual basic salary for full-time employees. Data from countries with fewer than five employees in any gender group are excluded from the metrics.

For seafarers, wages are tariff-regulated through Collective Bargaining Agreements in Norway, with salary levels linked to specific positions.

Incidents and Complaints Reporting

Lost Time Injuries (LTIs) - Material Safety Incidents: • 7 LTIs in 2024 (increase from 1 in 2023) • 4 incidents within Fleet Flumar operations • All individuals recovered well • All incidents promptly addressed with thorough follow-up measures

Serious Incidents: • No serious process safety incidents during 2024 • No significant safety or security incidents at ships or terminals

Human Rights and Grievance Mechanisms: • Independent whistle-blowing mechanism available for employees to raise concerns • Whistleblowing systems established as part of employee engagement approach • Focus on employees' health, safety, well-being, and rights as vital to business • Respect for human rights is integral to the organization

Response and Follow-up: • Board expressed concern over LTI increase • Emphasis on strengthened efforts to reduce LTIs to zero • Targeted actions initiated to learn from incidents and mitigate risks • Thorough follow-up measures implemented for all incidents

Broader Human Rights Framework: • Recognition that business impacts people in supply chain • Clear standards and expectations set for suppliers and partners • Corporate supplier conduct principles ensure people's safety and human rights • Dedicated functions for communications with suppliers, partners, agents, external ship managers, T/C vessel owners and shipyards

Compliance Framework: • Workers in the value chain can raise concerns through independent whistle-blowing mechanism • Mandatory reporting system for facilitation requests monitored at headquarters • Whistleblower protections implemented • Periodic internal audits to identify and address potential misconduct

Human Rights Due Diligence: The report notes that Norwegian companies must report in accordance with the Transparency Act on Human Rights Due Diligence, which is issued as a separate report.

Prevention and Detection: • Annual compliance and ethics training for employees with participation tracked • Risk of undetected facilitation, bribery, or illegal activities addressed through structured monitoring • Control actions include mandatory reporting systems and internal audits

Odfjell has set out clear standards and expectations for suppliers and partners in corporate supplier conduct principles to ensure people's safety and human rights. The company has dedicated functions in the organization responsible for communications with suppliers and partners including agents, external ship managers, T/C vessel owners and shipyards, which employ most of the value chain workers.

Odfjell incorporates contractual terms requiring suppliers to adhere to ethical and labor standards. The company conducts due diligence on key suppliers and collaborates with partners to improve visibility and accountability in the value chain.

Odfjell has dedicated functions in the organization responsible for communications with suppliers and partners including agents, external ship managers, T/C vessel owners and shipyards, which employ most of the value chain workers. The company engages with these stakeholders on quality and performance, contributions to emission reduction, Integrity Due Diligence (IDD), Human Rights Impact Assessment, sanctions, waste, circularity, and T/C contracts.

Engagement methods include: • Policies and IDD processes • Pre-qualification and screening • Business reviews • Supplier visits and audits • Event handling systems • Procurement collaboration • T/C owners dialogue meetings and seminars

Workers in the value chain can also raise concerns through Odfjell's independent whistle-blowing mechanism.

Workers in the value chain can raise concerns through Odfjell's independent whistle-blowing mechanism. The company has established clear channels for value chain workers to report issues related to safety, human rights, or other concerns.

Odfjell incorporates contractual terms requiring suppliers to adhere to ethical and labor standards, and conducts due diligence on key suppliers to improve visibility and accountability in the value chain. Internal systems track potential risks and escalate findings for further review.

Actions to Address Material Impacts on Value Chain Workers

Due Diligence and Supplier Management: • Odfjell conducts due diligence on key suppliers and collaborates with partners to improve visibility and accountability in the value chain • Contractual terms requiring suppliers to adhere to ethical and labor standards • Pre-qualification and screening processes for suppliers • Regular supplier visits and audits

Third-Party Platform Integration: • Use of Achilles platform for supplier qualification and due diligence • Enables suppliers to report ESG data in standardized manner • Enhances quality and consistency of upstream ESG data

Human Rights Impact Assessment: • Engagement with suppliers on Human Rights Impact Assessment • Focus on forced labor prevention in supplier operations • Risk mitigation for exploitation and poor working conditions in supplier operations

Safety and Health Measures: • Strengthening due diligence and collaboration with suppliers ensures safer working environments • Risk assessment for injuries and unsafe conditions in supplier operations • Dedicated functions for communications with key stakeholders employing value chain workers

Monitoring and Control Systems: • Internal systems track potential risks and escalate findings for further review • Event handling systems for managing supplier-related incidents • Procurement collaboration to improve standards

Stakeholder Engagement: • Regular business reviews with key suppliers • T/C owners dialogue meetings and seminars • Engagement on topics including quality, performance, emission reduction, sanctions, waste, and circularity

Grievance Mechanisms: • Independent whistle-blowing mechanism available for value chain workers • Clear channels for reporting safety, human rights, or other concerns

Effectiveness Monitoring: • Limited metrics and controls over S2 data acknowledged as area for improvement • Focus on largest suppliers as they represent most substantial impact on operations • Transition from spend-based to activity-based scope 3 data as supplier data improves

Strategic Supplier Focus: • Prioritized engagement with largest suppliers due to their material impact • Recognition of significant variability in supplier reporting maturity • Targeted approach to suppliers with greatest influence on scope 3 emissions and worker conditions

Targets related to value chain workers

Odfjell's overarching target is to prevent any violation of human rights related to its business.

Current Status

Odfjell does not currently have specific quantified targets for forced labor or working conditions within the value chain.

Monitoring and KPIs

While formal targets are not established, Odfjell has implemented monitoring mechanisms:

• Worker reporting system at recycling yards: Allows workers to raise concerns about working conditions
• Tracked as KPI: Reported cases are tracked as a key performance indicator
• Purpose: Serves as a tool to assess, address, and improve labor conditions across the value chain

Future Target Development

The company states:

• The absence of standardized and consistent data currently limits the ability to set specific targets
• As data collection processes are refined, the company will evaluate the feasibility of establishing formal, measurable goals
• Long-term targets remain under evaluation

Supporting Initiatives

• Started using the Achilles platform in 2024 to assess effectiveness of the Code of Supplier Conduct and Principles (CSCP) across the supply chain
• Active monitoring of compliance through supplier visits and audits conducted by Odfjell and third parties
• Partnership in the Recruitment Fee Working Group (Institute for Human Rights and Business) to eliminate unethical recruitment practices

Business Conduct Policies and Corporate Culture

Governance Framework: The framework for corporate governance is the Norwegian Code of Practice for Corporate Governance of October 14, 2021. Odfjell is committed to ethical business practices, honesty, fair dealing, and compliance with all laws affecting the business. This includes adherence to high standards of corporate governance.

Code of Conduct: The company has its own Code of Conduct that addresses several business conduct matters. All Odfjell employees are obliged to comply with the Code of Conduct, and the same applies to main suppliers who must adhere to the Supplier Code of Conduct.

Corporate Social Responsibility Policy: The Corporate Social Responsibility policy focuses on: • Quality, health, safety, and care for the environment • Human rights • Non-discrimination • Anti-corruption

Board Oversight of Business Conduct: The Board of Directors (BoD) holds ultimate responsibility for overseeing business conduct within the organization, ensuring alignment with Odfjell's ethical standards and regulatory requirements. Oversight of business conduct has been delegated to the Audit Committee (AC) as part of its ESG mandate.

Integrity Risk Assessment: Management conducts an annual integrity risk assessment to evaluate potential risks associated with business conduct. The outcomes—including reported actions and improvement plans—are presented to the AC for review and discussion.

Anti-Corruption and Bribery Prevention: • Annual compliance and ethics training for employees with participation tracked • Mandatory reporting system for facilitation requests monitored at headquarters • Whistleblower protections implemented • Periodic internal audits to identify and address potential misconduct • Risk mitigation for undetected facilitation, bribery, or illegal activities

Whistleblowing Mechanism: • Independent whistle-blowing mechanism available for employees and value chain workers • Clear channels for reporting concerns about business conduct, safety, human rights, or other issues • Whistleblowing systems established as part of employee engagement approach

External Reviews and Ratings: Any relevant external reviews, ratings or assessments concerning business conduct are presented to both the management team and the BoD to ensure awareness of industry benchmarks and best practices.

Transparency and Accountability: • Transparent practices enhance trust with stakeholders and governments • Integrity in operations fosters long-term relationships and regulatory compliance • Commitment to upholding highest standards of safety and integrity

Expertise Development: Key figures, such as the chair of the AC and the CSO, engage in specialized training programs to stay updated on evolving regulations and best practices in business conduct and ethics. This expertise is periodically evaluated as part of Odfjell's annual organizational review.

Maritime Anti-Corruption Network: Odfjell maintains membership in Maritime Anti-Corruption Network (MACN), demonstrating commitment to industry-wide anti-corruption efforts.

Management of Relationships with Suppliers

Supplier Code of Conduct: Odfjell has established a Supplier Code of Conduct that main suppliers must adhere to, ensuring alignment with the company's ethical standards and business conduct requirements.

Corporate Supplier Conduct Principles: Odfjell has set out clear standards and expectations for suppliers and partners in corporate supplier conduct principles to ensure: • People's safety and human rights • Ethical and labor standards adherence • Quality and performance standards

Due Diligence and Screening: • Due diligence on key suppliers with collaboration to improve visibility and accountability • Pre-qualification and screening processes • Integrity Due Diligence (IDD) processes • Contractual terms requiring suppliers to adhere to ethical and labor standards

Supplier Engagement and Communication: • Dedicated functions in organization responsible for supplier communications • Regular supplier visits and audits • Business reviews with key suppliers • Procurement collaboration initiatives • T/C owners dialogue meetings and seminars

Third-Party Platform Integration: • Use of Achilles platform for supplier qualification and due diligence • Enables suppliers to report ESG data in standardized manner • Enhances quality and consistency of upstream ESG data

Key Supplier Categories: Dedicated engagement with: • Agents • External ship managers • Time Charter (T/C) vessel owners • Shipyards • Port agents • Logistic providers • Ship handlers • Bunker suppliers • Equipment and technology providers

Monitoring and Control: • Internal systems track potential risks and escalate findings for further review • Event handling systems for managing supplier-related incidents • Regular monitoring of supplier performance and compliance

Payment Practices and Relationship Management: • Timely payments and strong relations support supplier stability and community development • Ethical supplier management ensures supply chain stability and aligns with sustainability goals • Risk mitigation for late payments or poor relations that could harm suppliers

Human Rights and Safety Focus: • Human Rights Impact Assessment engagement with suppliers • Focus on preventing forced labor in supplier operations • Strengthening safer working environments in value chain • Risk assessment for injuries and unsafe conditions in supplier operations

Grievance Mechanisms: • Independent whistle-blowing mechanism available for suppliers and value chain workers • Clear channels for reporting concerns about business conduct, safety, or other issues

Strategic Supplier Prioritization: • Prioritized engagement with largest suppliers due to material impact on operations • Focus on suppliers with greatest influence on scope 3 emissions and ESG performance • Recognition of variability in supplier reporting maturity and targeted approach accordingly

Continuous Improvement: • Transition from spend-based to activity-based ESG data collection as supplier data improves • Ongoing efforts to improve data availability and quality from suppliers • Regular assessment and enhancement of supplier management processes

Prevention and Detection of Corruption and Bribery

Training and Awareness: • Annual compliance and ethics training for employees with participation tracked • All Odfjell employees obliged to comply with the Code of Conduct • Focus on ethical business practices, honesty, and fair dealing

Reporting and Monitoring Systems: • Mandatory reporting system for facilitation requests in place, monitored at headquarters • Independent whistle-blowing mechanism available for employees and value chain workers • Whistleblower protections implemented • Clear channels for reporting concerns about corruption, bribery, or other misconduct

Internal Controls and Auditing: • Periodic internal audits to identify and address potential misconduct • Annual integrity risk assessment conducted by management • Risk mitigation for undetected facilitation, bribery, or illegal activities • Results and improvement plans presented to Audit Committee for review

Governance Oversight: • Board of Directors holds ultimate responsibility for overseeing business conduct • Audit Committee delegated oversight of business conduct as part of ESG mandate • Regular review and discussion of integrity risk assessments and outcomes

Policy Framework: • Corporate Social Responsibility policy specifically addresses anti-corruption • Commitment to compliance with all laws affecting the business • Norwegian Code of Practice for Corporate Governance as framework

External Engagement: • Membership in Maritime Anti-Corruption Network (MACN) • Participation in industry-wide anti-corruption efforts • External reviews and assessments of business conduct presented to management and Board

Supplier Requirements: • Supplier Code of Conduct requirements for main suppliers • Corporate supplier conduct principles ensure ethical standards throughout value chain • Contractual terms requiring suppliers to adhere to ethical standards • Integrity Due Diligence (IDD) processes for supplier screening

Risk Assessment: • Internal Control Risk identified as "Risk of undetected facilitation, bribery, or illegal activities due to lack of reporting or monitoring" • Control Actions include tracked training, mandatory reporting systems, whistleblower protections, and periodic internal audits

Transparency and Accountability: • Transparent practices enhance trust with stakeholders and governments • Integrity in operations fosters long-term relationships and regulatory compliance • External reviews, ratings or assessments concerning business conduct presented to management and Board

Continuous Improvement: • Regular assessment and enhancement of anti-corruption measures • Integration of corruption and bribery prevention into broader sustainability and ESG framework • Alignment with evolving regulations and industry best practices

Incidents of corruption or bribery

Confirmed incidents

Odfjell reported 14 registered incidents in 2024 (facilitation payment attempt/requests) compared to 25 in 2023. All incidents are investigated by the fleet manager regarding their severity and lessons learned. Severe cases are reported and discussed in the integrity council and audit committee.

Convictions and fines

There were no convictions and zero fines for violation of anti-corruption and anti-bribery laws and/or regulations in 2024.

Employees dismissed or disciplined

Not disclosed.

Contracts with business partners terminated or not renewed

Not disclosed.

Investigation procedures and speak-up mechanisms

Facilitation payment attempts or requests at ports are reported by all vessels in Odfjell's Portlog system. The cases are investigated by fleet management and reported to the audit committee.

Odfjell has established a dedicated 'Say-No' email address where corruption and bribery attempts can be reported, as well as a reporting hotline (whistleblowing system) where corruption/bribery cases are followed up. The reporting hotline is available internally and externally through Odfjell's website and intranet.

Reported issues are investigated and monitored by designated employees (compliance officers, designated person and their deputies), who log, review, and then thoroughly, promptly, independently and objectively investigate each case, documenting corrective actions as necessary. The chief compliance officer reports to the audit committee on material cases.

Summary table

Political influence and lobbying activities

Political engagement approach and ethical standards

Political influence and lobbying activities (ESRS G1-5) are not considered material according to Odfjell's double materiality assessment.

Political involvement is regulated by Odfjell's Code of Conduct. Odfjell will not participate in any party-political activity nor will it make any political contributions anywhere in the world.

Political contributions

Odfjell does not make political contributions.

Lobbying expenditure

No lobbying expenditure data disclosed.

Trade association memberships

No specific trade association membership fees or names disclosed in relation to political lobbying activities.

Payment Practices

Supplier Relationship Management: • Timely payments and strong relations support supplier stability and community development • Ethical supplier management ensures supply chain stability and aligns with sustainability goals • Recognition that late payments or poor relations can harm suppliers

Risk Mitigation: • Identified material impact: "Late payments or poor relations can harm suppliers" • Connection to Business Model: "Ethical supplier management ensures supply chain stability and aligns with sustainability goals"

Positive Impact Focus: • Timely payments support supplier stability • Strong supplier relations contribute to community development • Emphasis on maintaining positive supplier relationships as part of sustainability strategy

Integration with Supplier Management: • Payment practices integrated into broader supplier relationship management framework • Part of corporate supplier conduct principles ensuring ethical standards • Alignment with sustainable supply chain management objectives

Stakeholder Impact: • Recognition that payment practices affect supplier communities and stability • Focus on supporting supplier development through reliable payment practices • Contribution to sustainable community development through supplier support

Business Model Connection: • Supply chain stability through ethical payment practices • Risk management by maintaining strong supplier relationships • Sustainability alignment through responsible payment practices

The payment practices are positioned as part of Odfjell's broader commitment to ethical supplier management and sustainable business conduct, with recognition that payment behaviors have material impacts on supplier stability and community development.