SalMar

SalMar's Board of Directors is responsible for overseeing the Group's sustainability matters. The composition of the Board of Directors is presented below:

Among the seven Board members, two are employee representatives. Among the five shareholder-elected board members, three are considered independent. This makes the percentage of independent board members 60%.

SalMar's Risk and Audit Committee has overseen the identification and assessment of impacts, risks, and opportunities on behalf of the Board. The Executive Management team has also been actively involved in this process. Coordination and execution were led by the Head of Sustainability, who worked alongside internal and external experts and reports directly to the Executive Management.

The process of identifying and assessing impacts, risks, and opportunities, as well as defining time horizons and risk classifications, was aligned with SalMar's internal risk management practices. Targets addressing material impacts, risks, and opportunities are set by Executive Management, guided by these assessments.

SalMar has utilized internal and external expertise within the different sustainability topics when assessing impacts, risks and opportunities. To keep the assessments as relevant as possible for SalMar, the engaged experts were closely connected to either SalMar's own operations or SalMar's value chain.

Business conduct is a key responsibility of both the Board of Directors and the Executive Management, encompassing areas such as corporate culture, animal welfare, and the prevention of corruption and bribery. SalMar places great emphasis on its corporate culture, viewing it as a cornerstone of its success. Strengthening and sustaining this culture, which fosters ambition and dedication among employees, remains a top priority for the Board of Directors.

As a fish farming company, SalMar upholds high animal welfare standards as a fundamental principle. The company's strategic focus is to produce salmon "on the salmon's terms," placing animal welfare at the heart of its operations. The Executive Management is responsible for ensuring that this commitment is implemented consistently across the organization.

The Group's Executive management is responsible for monitoring, managing and overseeing impacts, risks and opportunities on a day-to-day basis. Each member of the management team monitors the impacts, risks and opportunities relevant for its segment and oversight is managed through executive management meetings.

Relevant developments are brought to these meetings, and if necessary, elevated to the Board of Directors. Dedicated protocols and procedures are implemented to ensure effective management of impacts, risks and opportunities. This governance is, where applicable, integrated with the internal operational and quality systems.

Board sustainability and innovation competence

The Board of Directors is formally mandated to oversee all material sustainability and ESG impacts, risks, and opportunities. During the reporting year, the Board received training on the new Corporate Sustainability Reporting Directive (CSRD) and approved the process and results of the double materiality assessment.

The Board of Directors possesses broad expertise across a variety of sustainability topics.

Gustav Witzøe, the Founder and Chair of the Board, has guided SalMar's evolution into a globally recognized food producer with a strong focus on sustainability. He has developed expertise in vital sustainability areas such as food safety, marine resources, biodiversity, climate change, and animal welfare. His commitment to innovation is exemplified by the recent launch of Salmon Living Lab.

Leif Inge Nordhammer, who served as SalMar's CEO for 17 years, has played a pivotal role in the company's development and possesses a similar depth of knowledge in the aforementioned sustainability areas. Arnhild Holstad brings valuable experience in biodiversity and forest management from her role as regional manager of Statskog.

Margrethe Hauge and Morten Loktu, both members of the Audit and Risk Committee as well as the Board, bring extensive expertise in product development and innovation. Margrethe, as the CEO of Goodtech ASA, leads technological solutions across various industries. Morten, with his experience as the Senior Vice President of Research & Innovation at Equinor and CEO of SINTEF, adds further depth to the Board's competence in advancing sustainable innovation.

For the Double Materiality Assessment (DMA), the Executive Management were informed on the process and findings. They were then involved in the verification and discussions of accuracy in the assessment. All sustainability matters within the DMA were addressed by the Executive Management team.

Likewise, the Risk and Audit Committee was informed of the results and engaged in discussions regarding their validity. The assessment of impacts, risks and opportunities will remain an ongoing process, with the Executive Management and Risk and Audit Committee receiving regular updates minimum annually.

The Board of Directors is informed on the results of the double materiality analysis at least annually and validate that the results are aligned with the company's strategic goals.

The Executive Management addresses the implementation of due diligence, as well as the results and effectiveness of policies, actions, metrics, and targets, both as issues arise and at least annually. The team's assessment of impacts, risks, and opportunities is integral to SalMar's strategic development, providing a foundation for all company activities – including major transactions. These assessments include the impacts on animal welfare, biological risk, climate change mitigation and adaptation risks and opportunities, impacts on water bodies and marine resources, impacts on own workforce, food safety and business conduct.

SalMar has a performance-based short-term incentive scheme (bonus) for leaders and key personnel, primarily driven by the achievement of the Group's sustainability and financial targets. Different metrics and targets are applied to different individuals based on their roles and responsibilities within the organization. For instance, each sea farm has specific targets tied to fish welfare, with metrics such as survival rate and feed conversion ratio factoring into the performance-based bonus assessments.

The proportion of variable remuneration dependent on sustainability-related targets and performance varies for different functions. Performance is evaluated based on the fulfilment of activity-specific targets, that are linked to the company's sustainability targets on a Group level. For a fish farming unit at sea, a key sustainability-related target within the incentive scheme is the feed conversion ratio. This target is important to reduce climate impact, environmental impacts and provide cost savings. While the target for feed conversion ratio may vary by geography or production methods, it is anchored in the Group's overarching targets for this metric.

In a processing facility, by contrast, feed conversion ratio is not relevant. Instead, sustainability-related targets within the incentive scheme may be linked to product quality, recall rates, customer satisfaction, or other activity-specific goals.

Climate-related considerations are incorporated into the short-term incentive schemes for members of the Executive Management who have relevant operational targets related to climate impacts. This includes the COO of Farming who ensures that SalMar does not exaggerate fish feed usage and the COO of Sales & Industry, who ensures that climate impact is considered when routing the finished product to the market.

The Board of Directors is responsible for approving the metrics used in the Chief Executive Officer's incentive scheme. The CEO, in turn, approves the metrics applied to the incentive schemes for other members of the Executive Management, who subsequently approve the metrics utilized in the incentive schemes for their respective management teams.

SalMar ASA also offers a longer-term share-based incentive scheme (Restricted Share Unit Plan) for senior executives and key personnel employed within the company and its subsidiaries. This share-based scheme is tied to the Group's financial performance across three vesting periods and is not directly linked to sustainability-related targets. For details on the company's remuneration practices, refer to the company's latest Remuneration Report.

The Board of Directors is not eligible for incentive schemes and instead receives a fixed annual compensation.

The core elements of due diligence are reflected directly in Disclosure Requirements set out in ESRS 2 and in the topical ESRS, as illustrated below:

SalMar's Head of Sustainability is responsible for conducting the Group's sustainability reporting. The report, as well as all targets and metrics applied are decided by the executive management. As an example, the metrics related to biological performance is proposed by the Chief Operating Officer of Farming and his team and brought to the executive management for approval. The executive management is central in assessing SalMar's impacts, risks and opportunities, and validating the relevance of the applied metrics and targets. Risks were assessed in line with the Implementation guidance for the materiality assessment by the European Financial Reporting Advisory Group (EFRAG) and prioritized based on relevance to the company.

The Board's Audit and Risk Committee monitors the sustainability reporting process and ensures that it complies with relevant reporting standards. Internal control of sustainability reporting is achieved through day-to-day follow-up by management and process owners in the reporting period, and supervision by the Audit and Risk Committee. Non-conformances and improvement opportunities are followed up and corrective measures implemented where necessary. SalMar also works closely with external experts to ensure that the sustainability reporting follows relevant standards and guidelines.

Findings from the risk assessments are presented for the executive management and highlighted to the Audit and Risk committee for evaluation. The senior management reviews the findings and recommends mitigating steps, which are subsequently integrated into the relevant internal processes.

This report is SalMar's first sustainability statement under the Corporate Sustainability Reporting Directive (CSRD). The company will monitor closely the developments of the directive and perform benchmarking against it peers to ensure that its reporting is as relevant for the reader as possible.

The CSRD has introduced greater responsibilities for the Board and its committees. The Audit and Risk Committee has heightened its focus on risk management and internal control processes related to sustainability reporting. SalMar aims to strengthen internal control procedures for sustainability reporting, seeking greater alignment with the company's established internal controls for financial disclosures.

The Board is informed on material findings in the internal controls as matters arise and at least annually.

SalMar is the second largest salmon producer in the world. In 2024, SalMar's consolidated harvest volume was 231,800 tons of salmon, and the company sold its products to 54 different countries worldwide. SalMar's main market in 2024 was Europe followed by Asia and North America. The majority of SalMar's customers are retailers, meaning that SalMar rarely distributes its salmon directly to the consumer.

SalMar's employees are located in the following countries:

There is an active market ban for products such as salmon from Europe to Russia and Belarus due to the ongoing war in Ukraine.

The total revenue for the SalMar Group in 2024 was 26,426 MNOK. SalMar is not active in fossil fuel (coal, oil and gas) sectors, chemical production, controversial weapons or the cultivation and production of tobacco, and none of SalMar's revenue is related to these sectors.

SalMar anticipates no significant changes in its products, services, markets, or customer groups in relation to achieving its sustainability goals. More information on specific steps necessary towards reaching the Group's sustainability targets will be provided in the topical standards.

Value Chain Description

SalMar maintains a dependable network of suppliers across its value chain, engaging multiple suppliers for each input to ensure redundancy and maintain competitive pricing. As SalMar is the largest customer for many of its suppliers, this gives the company leverage and priority in supply agreements.

Additionally, SalMar owns and controls every stage of the salmon lifecycle, from genetics and roe production to final products ready for market. This is an important strategic decision for the business model to ensure quality and predictability in production.

Key aspects of SalMar's upstream value chain include:

• Technical equipment: Essential operational equipment is primarily purchased from Norwegian suppliers.

• Vaccination of smolt: All smolt are vaccinated before transfer to sea cages to reduce disease risk. Vaccines, mostly obtained from Norwegian producers, must be approved by the national Medicines Agency, with their use regulated by permits from the relevant Food Safety Authorities.

• Feed supply: Fish feed represents a substantial portion of SalMar's annual expenditures and consists largely of vegetable and marine ingredients sourced from various regions, including Europe, North and South America, as well as the Atlantic and Pacific Oceans. SalMar's feed suppliers are based in Norway.

• Vessel contracts: Well-boats and service boats are typically hired on a per-operation or time-charter basis with Norwegian suppliers, providing SalMar with flexibility for specific logistical needs.

• Packaging: Packaging materials, essential for preserving salmon quality during transport, are obtained through local suppliers.

In the downstream value chain, distribution partners play a vital role in delivering SalMar's salmon to markets. SalMar often oversees the logistics for salmon transport, coordinating with distributors via various routes – including trucks, trains, boats, and planes – depending on the final destination.

SalMar's stakeholders hold an important role in shaping the company's strategic direction. To effectively align SalMar's strategy with stakeholder interests, purposeful engagement is essential. SalMar aims to conduct stakeholder engagement that not only provides insights into stakeholder priorities but also delivers value to all parties involved. This process strengthens SalMar's ability to deliver stakeholder value.

Stakeholder dialogue at SalMar occurs through various channels, including in-person meetings, media outreach, interim and annual reports, stock market notices, advertisements, R&D initiatives, and the company website. Interactions take place both locally and at the corporate level.

To ensure the highest degree of relevance for external stakeholders, it is common that SalMar's internal teams collaborating closest with these stakeholders also carry out the stakeholder engagement and due diligence, e.g., SalMar's biology and fish feed teams engage with feed suppliers. Engagement with customers, consumers and end-users is vital to ensure that their rights and views are respected. This is done through established feedback channels and customer follow-up.

SalMar's workforce is also a key stakeholder that is engaged regularly, both individually and in groups. The workforce is represented in important internal arenas including:

• The Board of Directors: The workforce has two biennially elected representatives on the Board of Directors, ensuring that employees' perspectives are incorporated into strategic decisions and the development of SalMar's business model.

• Work Environment Committee (AMU): This committee includes both management representatives and nominated employees. It focuses on occupational health, safety, and overall working conditions, reporting to the Group's governing bodies and the employees' union organizations.

• Union organizations: Employee unions advocate for fair treatment, negotiate remuneration structures, and provide a collective voice for the workforce in addressing workplace issues.

These forums play a pivotal role in ensuring that employee interests and rights are effectively integrated into SalMar's strategic and operational decisions.

SalMar's process for identifying relevant stakeholders for engagement is rooted in the Executive Management and SalMar's overarching communication strategy. Corporate-level engagement is central to SalMar's strategic positioning, while local-level engagement addresses operational considerations.

SalMar continually assesses its business model to ensure alignment with the company's core principles and stakeholder expectations. In the reporting year, there were no significant changes to SalMar's stakeholder engagement strategy, nor did interactions significantly impact the business model. The Board is briefed on stakeholder engagement outcomes that are pertinent to SalMar's strategic development.

SalMar is engaged in peer benchmarking, ensuring that the company is familiar with its position in the industry. The company aims to engage its peers in elevating the industry's ESG reporting and benchmarking, and therefore initiated a CSRD Roundtable for the industry, where the companies discussed its understanding of CSRD requirements, and how the industry could apply the new reporting framework in such a way that it provides stakeholders with reliable, relevant and comparable information.

SalMar is also a member and contributor towards several trade and civil organisations. The Norwegian Seafood Federation, the Norwegian Seafood Council, and the Norwegian Seafood Association are among the most important for representation on both a national and international stage.

SalMar also engages with the Norwegian University of Science and Technology (NTNU), the Blue Center of Competence, and several local trade associations to contribute to improved knowledge and research. SalMar contributes financially with several million NOK annually towards these associations.

These engagements are essential for the company to understand stakeholder interests at local, national, and international levels.

Stakeholder Engagement Table

SalMar's process for identifying and assessing material impacts, risks, and opportunities is outlined in the chapter, Impacts, Risks, and Opportunity Management. The identified impacts, risks, and opportunities offer valuable insights that are incorporated into SalMar's strategic processes. As of now, these results have not led to material changes in the business model or strategy. However, they may inform strategic adjustments over time.

Climate change

SalMar has identified several material climate-related risks across its value chain, encompassing both upstream and downstream components as well as its own operations, ensuring that no material elements are excluded.

The identified physical risks include an increased frequency of storms, floods, droughts, icing, and avalanches, alongside rising seawater levels, seawater acidification, and elevated seawater temperatures. While many of these risks have traditionally been regarded as long-term threats, some began manifesting as immediate challenges in 2024. Notably, significantly elevated seawater temperatures, particularly in SalMar's northern operational regions, led to increased sea lice density and reduced appetite among some salmon, thereby impeding growth.

SalMar also experienced the direct impacts of severe storms on its operations, entailing construction damage and escaped salmon. Furthermore, extreme weather events such as storms, flooding, and droughts disrupted the availability of important feed resources required for SalMar's fish feed production.

Salmon farming is intrinsically tied to its operating environment, making SalMar's business model dependent on stable and predictable environmental conditions.

Environmental considerations are integral to SalMar's strategic decisions regarding farming locations. SalMar's robust financial position enhances its resilience to external challenges, providing greater flexibility to adapt operations. However, environmental monitoring and scenario planning remain crucial for ensuring stable operating conditions.

The company has identified transitional risks primarily associated with new laws and regulations, such as carbon taxation and requirements related to circular economies. The EU's climate ambitions may lead to increased taxes on carbon-intensive resources like fossil fuels or impose tariffs on imports and exports, potentially impacting SalMar and its value chain.

To address these challenges, SalMar actively monitors potential regulatory developments within the EU that could affect its operations or value chain. Through resilience analysis and scenario planning, the company conducts "what-if" evaluations to continuously assess its dependencies and their susceptibility to transitional climate risks. This work is ongoing.

Water and marine resources

SalMar's fish farming operations – the core of its value creation and business model – take place in direct interaction with water and marine resources. The company has identified environmental impacts associated with organic loading from fish farming and the potential for crowding out other marine species in the surrounding areas.

The extraction of wild fish for fish meal and fish oil production is also considered to impact marine resources negatively. It is therefore important for SalMar to continuously monitor its dependency on wild stocks to ensure alignment with its strategy.

Additionally, in the reporting year, a small proportion of the marine ingredients used in SalMar's feed composition originated from uncertified fisheries, posing a potential risk with regards to traceability and responsibility in sourcing.

From a financial perspective, risks are present in the upstream value chain, where the availability of fish feed ingredients is crucial to farming activities. Pressure on wild fish stocks may impact supply stability and lead to price volatility in fish feed. However, SalMar also sees opportunities in feed research and development. Novel feed ingredients – including algae, insect meal, kelp, salmon oil, seafood trimmings, and excess raw material from processing – offer alternatives to traditional marine-based ingredients that may contribute to sustainable development.

Own workforce

SalMar's impacts, risks, and opportunities related to its own workforce encompass key areas such as working environments, health and safety, equality, diversity, and freedom of association. These factors are important to SalMar's business model and influence the development of the company's strategy. Given that SalMar's operations are spread across coastal Norway and Iceland, the company depends on a dedicated workforce, requiring employees who are willing to live and work in these remote and often demanding locations. This dependency highlights the importance of fostering a positive and supportive work environment to ensure employee satisfaction and retention.

When evaluating the impacts, risks, and opportunities related to its workforce, SalMar adopts a comprehensive approach that includes both employees and non-employees, regardless of their employment status. Recognizing the diverse nature of its workforce, the company understands that the scope and severity of risks vary significantly based on specific roles and work environments.

Employees in high-risk environments, such as those working aboard vessels, on pens, or handling hazardous equipment like cranes, machinery, and ropes, face greater injury risks compared to those in office-based roles. Similarly, employees in processing plants are exposed to distinct hazards, including fast-paced workflows, sharp tools, forklifts, production noise, and slippery surfaces. Non-employees engaged in short- or long-term projects or specialized operations may encounter similar risks.

To address these risks and seize opportunities for improvement, SalMar emphasizes mandatory training, strict adherence to safety protocols, and the implementation of robust safety procedures. These actions are essential to mitigating risks, fostering a safety-conscious culture, and safeguarding the well-being of both employees and non-employees across all operational areas.

Material negative impacts on SalMar's workforce are usually related to isolated incidents rather than systemic issues. Comprehensive analyses of equality and anti-discrimination practices within the company have revealed no evidence of structural discrimination and no violations of SalMar's principle of equal pay for equal work.

The workforce is not subject to forced or compulsory labour. There have been occasional instances of employees voluntarily working extended hours over short periods to ensure project deadlines are met or salmon is efficiently processed at facilities.

SalMar maintains strict guidelines for workers under the age of 18, particularly regarding the types of work they are permitted to undertake. Separate risk assessments are conducted for this group to ensure their safety and prevent any risk of harm.

The company has not identified significant impacts on its workforce resulting from the transition to greener or climate-neutral operations. While improvements in operational efficiency and automation may reduce workload per activity, SalMar's growth ambitions are expected to drive a continued demand for skilled and committed workers. The transition to low-emission operating platforms, such as vessels and barges, should reduce pollution, vibration, and noise, thereby positively impacting the working environment.

SalMar provides livelihoods to 3,345 individuals and plays a significant role in supporting vibrant local communities along the coastlines of Norway and Iceland. The company ensures its workforce is well-supported both socially and financially, offering comprehensive insurance coverage, paid sick leave, and parental leave entitlements.

To foster inclusivity and engagement among employees of diverse nationalities, SalMar organizes various initiatives such as language courses, social events including game nights, family days, hikes, sports activities, and dinner parties. Additionally, the company promotes cultural integration through events aimed at familiarizing employees with the local community and Norwegian culture.

Consumers and end-users

SalMar's potential impacts on consumers and end-users are primarily centred on food safety, which is critical to both the company and its customers. SalMar does not sell its products directly to the consumers and end-users, but rather to parties like retailers and restaurants who prepare the products for the consumers. SalMar's strategy and business model is reliant on the company's ability to provide customers with safe, high-quality products and this focus remains a top priority for the company.

In 2024, SalMar served a diverse customer base across 54 countries. The demand for high-quality salmon remains strong, and the company has not identified significant dependencies on specific customers or consumers. SalMar's business model focuses exclusively on salmon, with a strategic aim to produce as many healthy meals as possible for a global market while maintaining sustainable production practices.

As a food producer, SalMar faces an inherent risk that consumers or end-users could become ill due to its products. Such incidents could harm the company's reputation and lead to remediation demands. SalMar's strategy and business model have been strongly shaped by the need for high food safety standards. As a result, the company conducts extensive testing and analysis on each individual salmon in its facilities to ensure compliance with these standards.

The scope of SalMar's disclosures related to consumers and end-users encompasses all consumers and end-users, regardless of size or geographic location. All SalMar's customers are considered equally reliant on accurate and accessible product related information and are therefore treated equally. SalMar have not identified material risk or considerable potential for negative impact on consumers or end-users' rights to privacy, protection of personal data, freedom of expression or non-discrimination. SalMar do not consider specific types of consumers or end-users to be of any particular risk of negative impacts relative to others, nor do SalMar consider any types of consumers or end-users to pose particular risks or dependencies material to the company.

SalMar considers its products to have a significant positive impact on consumers and end-users. Salmon is rich in Omega-3 fatty acids, specifically EPA and DHA, as well as vitamin B12, vitamin D, selenium, and proteins, all of which provide significant benefits for both mental and physical health. Research has demonstrated that consuming oily fish, such as salmon, can help reduce the risk of cardiovascular disease. The World Health Organization, along with numerous other reputable institutions, advocates for increased consumption of salmon as part of a healthy diet for all ages.

Business conduct

SalMar takes pride in acting as a responsible business partner. As the company continues to grow and expand its network of suppliers, customers, and business relationships, ethical business conduct becomes increasingly material.

A strong corporate culture has been a key success factor for SalMar. The company firmly believes that empowered employees drive motivation and dedication. Amidst rapid growth, SalMar has placed a strong focus on integration and inclusion, ensuring that its corporate culture remains a foundation for continued success.

SalMar has identified financial risks related to bribery and corruption. The company remains aware of potential exposure to high-risk environments, where employees may encounter unlawful offers or engage with counterparties with ulterior motives. This requires SalMar's employees to be cognizant and report suspicion of bribery or corruption to the senior management.

SalMar believes it has a strong capacity to address its material impacts and risks in the short, medium and long-term, as well as to leverage material opportunities, thanks to a solid foundation and strong financial position. The primary challenges faced in the reporting year were sea lice and string jellyfish, with estimated financial effects, based on loss of biomass, of approximately 936 million NOK.

Animal Welfare

Animal welfare is the most material topic for SalMar, serving as a core operational principle that emphasizes the importance of operating in alignment with the salmon's needs. The foundation of the company's approach is centred around maintaining high fish welfare standards and systematically creating an environment where salmon can thrive and remain healthy. The company has identified both the positive and negative impacts of its operations, as well as the associated financial risks and opportunities concerning animal welfare.

SalMar has identified negative impacts with regards to fish welfare. The mortality rate of SalMar's salmon was 7.0% in 2024, an increase from 6.8% in 2023. This is still some way off SalMar's 2030 target of 3%.

Disease and parasites present challenges to fish welfare, as salmon may face various diseases throughout their lifecycle. Parasites, particularly sea lice, pose a direct threat to the salmon, as they clench onto their skin and eat into the flesh.

To safeguard the salmon from sea lice the company carries out mechanical delousing operations. Mechanical delousing operations is typically done by flushing the salmon so that the sea lice fall off the salmon skin. Although mechanical delousing is widely considered the most responsible delousing method, both with regards to animal welfare and the environment, the delousing operations may be stressful and even harmful to the salmon.

2024 has proved that the salmon farming industry is at risk of unforeseen events linked to environmental conditions that may be harmful to the salmon. In the reporting year, the company was heavily impacted by string jellyfish attacks, causing increased mortality rates in several regions. This considered both a negative impact on animal welfare and a financial risk for the company, and is considered the main cause of increased mortality in 2024.

The use of antibiotics and cleaner fish have both been areas of concern, but the use has been significantly reduced over the years – as further detailed in the topical standard.

SalMar further evaluates escape incidents as potential negative impacts on animal welfare, as the farmed salmon is not well equipped for life outside the cages, and their presence in the sea and rivers can affect other species like local wild salmon population. Potential impacts on wild salmon stocks include competition for food and space in rivers, and the possibility of disease transmission and genetic interactions between farmed and wild salmon.

SalMar's presence at sea has presented risks of interacting with other wildlife, most commonly with wild birds. Birds can become curious of the operations and attempt to enter the sea cages. Such events present risks of the birds getting stuck in the bird nets built over the cages and being unable to free itself.

Marine animals like tuna or whales may also try to enter the sea cages, causing risk of their own safety and the structural integrity of the company's net pens.

Negative impacts on animal welfare are strongly linked to financial risk for the company, as the company's main source of income is through the sale of its self-produced salmon.

Elevated sea lice levels bring financial risks including the costs of delousing operations and increased mortality rates. The company may also face financial challenges if industry-wide efforts to limit biodiversity loss, particularly due to fish escapes, result in demands for closed cage technologies, which would significantly increase operational costs compared to traditional open cage systems.

SalMar did not identify impacts, risks or opportunities that were new in the reporting year. More information about each material impact, risk and opportunity will follow in the topical standards.

SalMar's approach to identifying material impacts, risks, and opportunities began with a thorough examination of topics, sub-topics, and sub-sub-topics outlined in ESRS 1 AR 16. The internal team selected the topics most relevant to SalMar's operations, business model, value chain, and strategic goals. Throughout this process, SalMar sought to find the optimal level of detail for analysis, ensuring that both the analyses and outcomes would be meaningful and easily understandable to stakeholders. The team also considered that these assessments would be SalMar's first under the CSRD framework, recognizing that, as both SalMar and its stakeholders gain experience, more detailed analysis will become feasible.

After determining the appropriate level of detail, SalMar reviewed whether there were any entity-specific topics not addressed by the standard. The company identified that although animal welfare was covered as a sub-topic under G1 – Business conduct, the disclosure requirements relating to animal welfare was not sufficient under G1 for SalMar's sustainability statement. Therefore, SalMar chose to extract animal welfare from G1 into an entity-specific topic, allowing for more holistic reporting on a vital sustainability topic for the company.

In analysing sustainability matters, SalMar collaborated with internal and external experts to gain a comprehensive understanding of impacts, risks, and opportunities. The team identified and evaluated the most significant impacts, risks, and opportunities within SalMar's operations as well as in its supply chain. Affected stakeholders were engaged and their views were considered in the evaluation of impacts, risks and opportunities. All impacts – whether actual or potential, direct or indirect – were subjected to the same rigorous analysis, though with varying data availability.

Actual impacts were assessed on, and prioritized by, scale, scope, and, where applicable, the degree of irremediability of negative impacts. For potential impacts, likelihood was also factored into the evaluation. Both impacts and financial risks and opportunities were assessed with attention to different time horizons.

Financial risks and opportunities were estimated and prioritized based on their scale and likelihood and applied quantitative thresholds consistent with SalMar's established definitions in risk management. Certain risk and opportunities arise from, or are significantly affected by, SalMar's dependencies and impacts. These include access to production area, dependency on supply chain services, and impacts on the environment and people. Such risks and opportunities were evaluated by considering scenarios and weighting likelihood and financial impact. Rather than using specific risk assessment tools, SalMar relied on expert judgment, internal risk assessment practices and stakeholder feedback to inform its analysis.

The assessment focused on specific activities, business relationships and geographies where the company directly or indirectly contributed to heightened risk of adverse impacts, e.g., the production of soy in Brazil used in SalMar's fish feed. SalMar gained valuable insights by involving relevant business partners to evaluate the impacts, risks and opportunities inherent in the activities carried out in SalMar's supply chain.

SalMar engaged its stakeholders to obtain their evaluations of materiality for each sustainability matter. The executive management identified stakeholders representing diverse interests, including investors, customers, suppliers, financial institutions, regulatory bodies, local communities, NGOs, research institutes, subsidiaries, internal representatives, and the executive management itself. Stakeholders participated in a survey, providing 1-to-5 ratings of the positive and negative impact materiality, as well as the materiality of financial risks and opportunities for each of the relevant sustainability matters.

In total, 31 different stakeholders responded to SalMar's approach, while some stakeholders chose not to engage in the assessment. None of the invited NGOs or regulatory bodies responded. To ensure these perspectives were not excluded, and to include the views of silent stakeholders like wildlife ecosystems, forests, water bodies, biodiversity, and indigenous lands, SalMar conducted sensitivity analyses to assess how potential responses from these groups could influence materiality results. Furthermore, the executive management are well informed on these stakeholders' perspectives and included this in their evaluations.

The executive management led the decision-making process, guided by recommendations from experts in each sustainability area. The Audit and Risk Committee reviewed the process and results to ensure completeness, and external auditors verified compliance with standards as per the Independent Accountant's Assurance Report.

SalMar's process for identifying, assessing, and managing impacts, risks, and opportunities is fully integrated into its overall risk management practices and will be re-evaluated annually. The process has been given increased priority following the CSRD implementation.

SalMar prioritizes impacts and risks relative to each other on a case-by-case basis. Employee training emphasizes that human safety must never be compromised and remains the highest priority in all situations. Additionally, salmon welfare is a core focus, with all decisions that affect the fish made with their well-being as the primary consideration.

Climate Change

SalMar has carefully evaluated climate-related considerations, focusing on its greenhouse gas (GHG) emissions and climate risks and opportunities. The company's carbon footprint is comparatively low relative to other protein producers, which serves as a strategic advantage rather than a vulnerability. Nonetheless, SalMar is steadfast in its commitment to reducing emissions and has been rewarded with several acknowledgements for its ability to reduce emissions.

SalMar has not currently implemented technologies that allows for extraction, collection or storage of greenhouse gas emissions. The company also considers a portion of its GHG emissions to be locked-in emissions in the short term, making reductions more challenging.

In its climate scenario analysis, SalMar assessed three mitigation scenarios – high, medium, and low – to evaluate potential risks and opportunities. The details of this process is provided in E1 – Climate Change.

Water and marine resources

SalMar has identified various impacts, risks, and opportunities related to water and marine resources across its operations and value chain. Given its proximity to aquatic environments, the potential for significant environmental interactions is considerable. Key identified impacts include:

• Feed spillage and faeces from cages: Such loading can affect marine ecosystems, particularly the seabed and surrounding water column. • Monoculture production: Farming activities may displace native marine species within farming zones, altering local biodiversity. • Extraction of wild fish stocks for feed: The use of wild fish stocks for production of fish meal and fish oil may negatively affect the fish stocks. • Freshwater usage: Freshwater is withdrawn for smolt production, potentially affecting local water and marine resources. • Wastewater discharge: Filtered wastewater from smolt production may carry substances that influence marine ecosystems near discharge areas.

SalMar's operations are based in Norway and Iceland, regions characterized by favourable water-related conditions.

Assessments from both the Aqueduct Water Risk Atlas and the WWF Water Risk Filter indicate:

• Low water stress • Low water scarcity • Low coastal eutrophication potential • Low regulatory risk • Low reputational risk

However, the tools diverge in their evaluation of certain risks:

• Flood risk: The Aqueduct Water Risk Atlas identifies a high flood risk, while the WWF Water Risk Filter suggests a low flood risk. • Drought risk: The Aqueduct Water Risk Atlas points to low drought risk, whereas the WWF Water Risk Filter indicates medium to high drought risk.

For SalMar's upstream value chain, feed production has the largest potential impacts, risks and opportunities. The production of marine ingredients for the feed depends on healthy marine species making transparency, traceability and certifications important focus areas for the company.

SalMar's downstream value chain, primarily encompassing transportation and distribution does not present notable impacts, risks, or opportunities related to water or marine resources.

Business conduct

When assessing impacts, risks, and opportunities related to business conduct, SalMar examined all relevant sub-topics of the standard independently. These include corporate culture, the protection of whistleblowers, political engagement and lobbying activities, management of relationships with suppliers including payment practices, and corruption and bribery. Animal welfare was, as previously mentioned, extracted into an entity-specific topic.

Corporate culture was evaluated based on its influence on employees and the associated risks and opportunities, as well as its contribution to SalMar's reputation as a recognized and professional business partner.

Whistleblower protection was assessed in terms of enabling employees within SalMar's workforce and value chain to report misconduct effectively, as well as the company's capacity to handle such cases while safeguarding the whistleblowers' identities.

Political engagement and lobbying practices were reviewed in relation to the company's involvement in political activities and the potential effects on its reputation and strategic positioning.

The management of supplier relationships was assessed based on internal reviews and feedback from suppliers and business partners, focusing on SalMar's professionalism and its ability to maintain robust partnerships. Payment practices were evaluated in terms of reliability and timeliness.

Lastly, corruption and bribery risks were analysed primarily by the nature of employees' roles, recognizing that certain functions may be more susceptible to bribery or corruption than others. Geographic exposure was also considered, as employees working with foreign entities or in remote locations may face heightened vulnerability.

Animal Welfare

Animal welfare was analysed with a focus on the company's ability to uphold high standards for its livestock and the potential impact on other animals, both within SalMar's operations and throughout the value chain.

The survival rate was evaluated as a key metric reflecting overall fish welfare within the company, serving as both an internal performance indicator and a benchmark for comparing aquaculture companies and other farmed land animals in terms of animal welfare. Salmon mortalities present a clear negative impact on animal welfare as well as a financial risk for the company. This is detailed further in the topical standard.

The use of antibiotics was reviewed in relation to the threat of antibiotic and antimicrobial resistance, considering the company's ambition to prevent resistance and its commitment to avoiding routine antibiotic use in fish health management. The negative impact is considered small due to the miniscule usage in the company and the industry.

The use of cleaner fish was assessed as a preventive strategy against sea lice, with consideration given to the ethical debate surrounding animal welfare, including handling practices, mortality rates, and overall fish welfare. The use of cleaner fish in salmon farming is considered to present possible negative impacts on the cleaner fish welfare.

Parasites and disease outbreaks were analysed for their impact on fish welfare throughout the salmon lifecycle, particularly the risks associated with high sea lice levels and known diseases for salmonids.

In this context, delousing operations were evaluated, with attention to factors such as starvation periods, stressful handling, and treatments — all of which present negative impacts on animal welfare. Additionally, both parasites and disease outbreaks were assessed for their associated financial risks to the company.

Interactions with wild animals were assessed to understand SalMar's potential impact on local species, including birds and predators, as well as the risk of escape incidents affecting wild salmon populations. This was done by considering the company's current negative impact on wild animals, and the current trend, as well as any effects seen from mitigating actions.

Each identified impact, risk and opportunity is presented in greater detail in the topical standard.

The results of the double materiality assessment, establishing the company's reporting duty for 2024, was presented in SBM-3 Material impacts, risks and opportunities and their interaction with strategy and business model.

The final assessment did not include all sub-topics and sub-sub-topics outlined in ESRS 1 AR 16, as less relevant topics were excluded during the initial evaluation. Every topic retained in the final assessment was evaluated by each stakeholder, and the resulting matrix directly reflects this engagement.

The materiality boundary, deciding what topics were deemed material for SalMar for 2024, was proposed by the Executive Management prior to stakeholder engagements. No changes were made to the level of this boundary after receiving the results, and the SalMar team confirmed that the reporting duty relating to the results of the double materiality assessment are reasonable for the initial year of aligning with the CSRD.

The material topics for SalMar in 2024 are: [Material topics visualization showing ESRS 2, E1, E3, S1, S4, G1, and Animal Welfare]

Based on the double materiality assessment results, SalMar aims to share insights into the underlying evaluations that led to deeming certain topical standards as non-material for 2024. While all sustainability topics hold importance for SalMar, it was essential in this initial CSRD reporting period to establish a practical and focused level of reporting, leading to some topics being classified as less material than others.

E2 – Pollution

SalMar assessed the relevant sub-topics under the broader topic of pollution, but all were ultimately deemed non-material. The greatest impact materiality was identified in water pollution, as effluents from SalMar's operations disperse and may settle on the seabed. The highest financial materiality was found in soil pollution, given that the production of vegetable ingredients is sensitive to soil quality, which could result in increased input costs.

E4 – Biodiversity and Ecosystems

In SalMar's assessment of biodiversity and ecosystems, the company captured a comprehensive view of impacts, risks, and opportunities across its operations and supply chain. The most significant impacts were associated with land-use change, occasionally required to expand crop production for vegetable ingredients in fish feed. Additionally, fish escape incidents were identified as a key impact within direct operations. Financial risks were noted in potential regulatory restrictions on growth, as governing bodies may increasingly favour technologies that minimize ecosystem impacts.

The stakeholder engagement positioned E4 – Biodiversity and Ecosystems outside the material region of SalMar's materiality matrix, a conclusion also supported by SalMar's internal assessment of impacts, risks, and opportunities. Recognizing the importance of biodiversity and ecosystems for the aquaculture industry, SalMar conducted a peer benchmarking analysis to verify the reasonableness of this classification. Key findings from this benchmarking support the topic designation:

• SalMar's operations are situated in regions with lower regulatory risk compared to other areas where, for example, rapid transitions to exclusively closed containment systems have been proposed. • Fish escapes have become a less significant issue due to advancements in equipment and technical standards, and SalMar has reported very few incidents in recent years. • A high proportion of benthic testing indicates that the overall impact of aquaculture on the seabed in Norway remains low.

Furthermore, SalMar conducted additional analysis on silent stakeholders and those who did not respond to the company's stakeholder engagement during the double materiality assessment. The sensitivity analysis indicated that even if the majority of these stakeholders had rated this topic as highly relevant for both impact materiality and financial materiality, it would still not have crossed the materiality threshold.

These factors collectively affirm that biodiversity and ecosystems can reasonably be considered below the materiality threshold for SalMar in this reporting period. SalMar will re-evaluate this assessment next year and conduct a new peer benchmarking analysis.

E5 – Circular Economy

In its assessment of circular economy practices, SalMar identified the use of polystyrene boxes as the most significant negative impact. Recycling rates for these boxes are uncertain in some countries, as customers assume ownership upon receiving the salmon, and reliable recycling channels for polystyrene are not well-established in all markets.

Potential regulations on circular material design and usage were flagged as a financial risk, as they could increase material costs for SalMar. The company is closely monitoring ongoing developments in the European Union regarding these regulations.

S2 – Workers in the Value Chain

SalMar's direct suppliers are primarily based in Norway, where engagement is typically straightforward, as high-quality information on workforce conditions is accessible. However, some of SalMar's suppliers source materials from regions where obtaining reliable workforce data can be more challenging, introducing potential risks related to workers' rights. To address this, SalMar conducts risk-based due diligence across multiple levels of its supply chain, utilizing both surveys and site visits. While no severe risks to workers' rights have been identified in the supply chain to date, SalMar remains committed to ongoing verification efforts.

Both stakeholder engagement feedback and SalMar's internal assessment of impacts, risks, and opportunities indicate that S2 – Workers in the Value Chain is non-material for SalMar in 2024.

S3 – Affected Communities

SalMar is deeply rooted in local communities along the Norwegian coast and is committed to ensuring a positive impact on affected communities. SalMar employs more than 3,000 people in rural regions along the Norwegian and Icelandic coasts, contributing significantly to the communities' economic security. SalMar holds regular stakeholder meetings with local populations to ensure the communities' civil and political rights.

The identified financial risks primarily relate to incomplete insights into the effect of suppliers' activities on local communities in other parts of the world. SalMar aims to increase its insights of the impacts of its supply chain through continuous dialogue with suppliers, audits, and certifications.

The stakeholder engagement feedback told SalMar that all 31 stakeholders believe that SalMar's positive impact is larger than its negative impact on affected communities, and the impact materiality was close to, but did not cross, the materiality threshold set for 2024.

Transition plan for climate change mitigation

Disclosure scope and alignment statement

Although SalMar has an established transition plan, involving targets for Scope 1, 2 and 3 reductions and correlating actions, the company does not consider its transition plan to be fully aligned with the ESRS standard, but aims towards alignment by 2025 reporting. SalMar will present its alignment with the disclosure requirements under E1-1 except 16. (b), (c), (e), and (j). The company has not established an explicit investment plan for each decarbonization lever nor quantified the expected outcome of these investments in relation to its reduction targets.

Paris alignment and SBTi validation

SalMar has established greenhouse gas (GHG) reduction targets aligned with the goal of limiting global warming to 1.5 °C, in accordance with the Paris Agreement, and have been validated by the Science Based Targets initiative (SBTi). The Group SBTi-validated GHG reduction targets are:

• 42% reduction in absolute Scope 1+2 from 2020 to 2030
• 42% reduction in absolute Scope 3 emissions from 2020 to 2030

The actions and resources dedicated to achieving these targets are outlined in section E1-3.

Scope of the plan

The transition plan covers the company's own operations (Scope 1+2) and operations in its value chain (Scope 3). The Scope 3 target includes categories 1, 3, 4, 5, and 6, with calculation methods aligned with the Greenhouse Gas Protocol.

GHG emissions profile

SalMar reports both GHG emissions in its own operations (Scope 1+2) and operations in its value chain (Scope 3). The GHG emissions in Scope 1+2 make up only 2.4% of the company's gross GHG emissions, while 97.6% lies in Scope 3. Sourcing of the company's fish feed is the largest contributor to GHG emissions, followed by transportation and distribution of the company's products to its intended markets. Air freight dominates the transport-related emissions, as this mode of transportation is much more carbon intensive than its alternatives.

Well-boat and service boats are external vessels used for various operations at the company's sea sites. These operations include transporting smolt to the sites, performing delousing operations, net cleaning, inspections, maintenance, and transporting the adult fish to harvest. In sum, these activities contribute to 5% of the company's total emissions. The production of the packaging used to contain the company's products contribute to 3% of the company's gross emissions.

CapEx / investment commitments and green financing

SalMar is committed to aligning its CapEx and OpEx with its GHG emission targets and has done so through its green bonds and credit facilities. SalMar holds green bonds of 7.85 billion NOK aligned with the company's Green Bond Framework for 2024. Further, the company holds sustainability-related credit facilities of 16 billion NOK linked with core ESG KPIs for the Group. These KPIs are:

• GHG emission intensity of Scope 1+2+3
• Share of local processing
• Survival rate at sea
• Biological feed conversion ratio

The company's transition plan is central to the investments made through the allocation of proceeds from the sustainability-linked financing. One notable investment highlighted in the report is the construction of the InnovaNor processing facility. This new facility enhances local processing capabilities and reduced SalMar's carbon footprint by 30,000 tons of CO₂ equivalent in 2024. The allocated proceeds for this project, as specified in the Green Bonds Report, amounted to NOK 1,192 million.

Decarbonization levers and priorities

Supply chain (Feed)

SalMar's fish feed is its main source of GHG emissions, and the company prioritizes this area for engagement and improvements in its transition plan. The company works alongside its feed suppliers to ensure that feed ingredients are sourced responsibly and that ingredients are assessed for their climate impacts. The company has seen its greatest reductions in GHG emissions in this segment, and expect continued reduction in its feed supply chain to be a core part of its reductions towards its climate targets.

Supply chain (Local processing and transport)

Another central part of transitioning to a low-carbon economy is allowing for low-carbon transport methods in its downstream supply chain. The company foresees investments in increased capacity of local processing and moving volumes from airfreight to seaborne transport as the second most material actions in its transition plan.

Energy and low-carbon operations (Scope 1+2)

SalMar considers transitioning its own operations to a low carbon economy important, albeit the GHG emissions in this segment only comprising 2.4% of the Group's gross emissions. The company expects investments into low carbon vessels and supplying barges with hybrid solutions will be important in this transition.

These initiatives focus on various decarbonization levers, including improving energy efficiency, switching to low-emission fuels, increasing the use of renewable energy, decarbonizing the supply chain, and implementing product-related measures.

Locked-in emissions and transition risks

SalMar acknowledges that its diesel-fuelled fleet of vessels and vehicles represents locked-in GHG emissions for its near-term reduction targets. These factors are considered to pose risks to achieving the near-term Scope 1+2 targets due to diesel-fuelled vessels dominating SalMar's fleet of workboats and the lifespan of some of these vessels surpassing the near-term target year.

The related transition risk of these diesel-fuelled vessels could involve increased operational expenditures due to increased fuel prices and potential negative impact on the company's reputation, both presenting financial risks to SalMar. These financial risks are, however, considered small relative to other climate-related financial risks as detailed under Annual Climate Risk Assessment.

These sources are not deemed to present locked-in emissions with respect to long-term targets, like the EU's 2050 targets due to the transition period surpassing the lifespan of most diesel-fuelled vessels and equipment, but any new investments in diesel-fuelled vessels would create new locked-in emission sources. SalMar is committed to pursuing a low-carbon procurement strategy.

SalMar did not invest significant CapEx in coal, oil, or gas-related economic activities during the reporting period. SalMar is not excluded from EU Paris-aligned benchmarks.

Carbon pricing

Carbon pricing is used in select processes where relevant to validate investment strategies, e.g., when investing in new vessels. Although SalMar has applied internal carbon pricing in select assessments, it has not yet been fully integrated into all relevant evaluations. The company aims to expand the use of carbon pricing schemes in the coming year, which could enable reporting on this topic in the next reporting period.

Carbon credits / removals

The targets do not include GHG removals, carbon credits or avoided emissions, and are therefore considered gross targets. SalMar contributes to reducing emissions through substantial tactical and strategic initiatives but does not engage in GHG removals as defined by the ESRS, nor does it finance GHG mitigation projects through carbon credits. As a result, this topic is considered non-material. SalMar has not purchased credits from emission trading schemes.

Integration with strategy and governance

SalMar's transition plan is a key component of the company's overall strategy. It focuses on investments that allow for low carbon operations, reducing greenhouse gas emissions and supporting sustainable practices across operations. Financial planning takes these GHG reduction targets into account, planning for the integration of various decarbonization efforts, such as energy efficiency improvements, fuel switching, and the adoption of renewable energy sources, ensuring that SalMar continues to evolve towards a more sustainable future.

SalMar's GHG reduction commitments in their transition plan are approved by the Board of Directors and, as will be outlined in section E1-6, the company is making notable progress toward achieving these targets.

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

Phase-in exemption applied

SalMar has opted to activate the phase-in option applicable to all companies. This includes E1-9, E3-5, S1-7, S1-13, S1-14_06, and S1-14_07.

As stated in the report:

Omitted chapters due to the eligible phase-in option: • E1-9 – Anticipated financial effects from material physical and transition risks and potential climate-related opportunities

Current financial impact estimate from physical climate risks

While detailed anticipated financial effects are omitted under the phase-in exemption, SalMar provides an estimate of current financial impacts from climate-related events in 2024:

• Climate-related events (extreme weather events including marine heatwave in Central Norway and jellyfish bloom in the Northern region) resulted in lowered volume guidance by approximately 40,000 tons
• Estimated current financial impact: 936 MNOK (calculated by multiplying reduced volume by year's average margin of 23.4 NOK/kg)
• Note: This estimation assumes the entirety of biomass lost was due to climate-related impacts, which cannot be stated with certainty and is likely an over-estimate
• Both events are considered physical risks

CapEx and OpEx alignment with climate targets

SalMar is committed to aligning its CapEx and OpEx with its GHG emission targets:

• Green bonds: 7.85 billion NOK aligned with the company's Green Bond Framework for 2024
• Sustainability-related credit facilities: 16 billion NOK linked with core ESG KPIs for the Group

The company expects investments into low carbon vessels and supplying barges with hybrid solutions will be important in the transition. The company is also exploring investments in various production methods to improve climate resilience, including farming fish in closed, submerged or offshore cages, which require significant investments.

Scenario analysis methodology

SalMar's resilience analysis evaluated three climate pathways with different time horizons:

The Optimistic Route – Aligned with the IEA Net Zero Emissions 2050 and RCP 2.6 pathways

• Assumes high levels of climate mitigation, with strict regulations and taxation creating significant transitional risks and high initial costs as economies shift to low-carbon models
• This route does not pose severe impacts in the medium to long-term but rather contributes to improved operational conditions for fish farming

The Realistic Route – Aligned with the RCP 4.5 pathway

• Assumes moderate climate mitigation efforts, with both transitional and physical risks requiring management to maintain business resilience
• Associated with moderate climate risk in the short, medium and long terms
• Physical risks are considered dominant to transitional risks in all time horizons

The Pessimistic Route – Aligned with the RCP 8.5 pathway

• Assumes a business-as-usual approach, prioritizing short-term financial gains over climate action
• Physical risks dominate in all time horizons, with both acute and chronic climate impacts creating challenging operating conditions
• SalMar considers this scenario a serious long-term threat to its business model

Uncertainties

There are uncertainties in the resilience analysis related to:

• Technology development
• Regulatory advancements
• The actual impacts of climate change on the company's biological assets

The company's assets, including physical assets and biological assets, have been assessed in the resilience analysis and evaluated for sensitivity towards dynamic environments.

E3-1 – Policies related to water and marine resources

SalMar has implemented several policies and initiatives directly related to water and marine resource management. As a fish farming company operating in marine environments, SalMar's policies emphasize sustainable use of water resources and protection of marine ecosystems.

Key policy areas include:

• Marine environment protection: Policies focused on minimizing environmental impacts from aquaculture operations on marine ecosystems • Water quality management: Guidelines for maintaining optimal water conditions for fish welfare while protecting surrounding marine environments • Responsible feed sourcing: Policies ensuring sustainable sourcing of marine ingredients and reducing dependency on wild fish stocks • Waste management: Procedures for managing organic waste and preventing pollution of marine environments

The company's approach to water and marine resources is integrated into its overall sustainability strategy and business operations. SalMar recognizes that healthy marine ecosystems are fundamental to its business model and long-term success.

E3-2 – Actions and resources related to water and marine resources

SalMar has implemented various actions and allocated resources to protect and sustainably manage water and marine resources:

Actions taken:

• Benthic monitoring: Regular seabed assessments to monitor environmental impacts, with 91% of benthic/seabed assessments achieving good or very good scores in 2024 • Feed optimization: Continuous improvement of feed conversion ratios to reduce organic loading and environmental impact • Certification programs: Working with certified marine ingredients (98% certification rate in 2024) and ensuring 100% certification of soy ingredients • Site selection and management: Strategic placement of farming operations to minimize environmental impact on marine ecosystems • Research and development: Investment in novel feed ingredients including algae, insect meal, kelp, salmon oil, and seafood trimmings to reduce reliance on wild fish stocks

Resources allocated:

SalMar dedicates significant financial and human resources to water and marine resource management, including specialized teams for environmental monitoring, feed research, and sustainability initiatives. The company collaborates with research institutes and contributes several million NOK annually to research and development projects focused on sustainable aquaculture practices.

E3-3 – Targets related to water and marine resources

SalMar has established specific targets related to water and marine resource management:

Freshwater usage targets: • Target: Reduce absolute freshwater withdrawal by 20% from 2022 to 2030 • 2024 performance: 50 million m³ (compared to 63 million m³ in 2022) • Intensity target: Continue reducing freshwater intensity per ton of salmon produced

Marine ingredient certification targets: • Target: 100% certification of marine ingredients • 2024 performance: 98% certification achieved

Environmental assessment targets: • Target: 100% of benthic/seabed assessments with good or very good scores • 2024 performance: 91% achieved

Feed efficiency targets: • Fish Meal FFDR: Target below 1.20 (achieved 0.43 in 2024) • Fish Oil FFDR: Target below 2.52 (achieved 1.13 in 2024)

Water risk management: • Target: Zero freshwater withdrawal from water risk areas • 2024 performance: 0 m³ from water risk areas (target achieved)

These targets are designed to minimize SalMar's impact on water and marine resources while maintaining operational efficiency and supporting sustainable aquaculture practices.

E3-4 – Water consumption

SalMar's water consumption is primarily related to freshwater usage in smolt production facilities. The company tracks both absolute and intensity metrics for freshwater withdrawal:

Absolute freshwater withdrawal (million m³):

Freshwater intensity (m³/ton salmon):

Water withdrawal from water risk areas: • 2024: 0 m³ • 2023: 0 m³ • 2022: 0 m³

SalMar's operations are located in Norway and Iceland, regions characterized by favorable water-related conditions with low water stress and scarcity. The company has achieved significant reductions in both absolute and intensity water consumption since 2022, demonstrating progress toward its 2030 target of reducing absolute freshwater withdrawal by 20% from 2022 levels.

The higher intensity figures for Iceland reflect different operational characteristics and scale compared to Norwegian operations. SalMar maintains strict monitoring of water sources to ensure no withdrawal from areas identified as water-stressed or at risk.

Anticipated financial effects from material water and marine resources-related impacts, risks and opportunities

Phase-in exemption applied

SalMar has opted to activate the phase-in option applicable to all companies. This includes E3-5.

The company has omitted this chapter due to eligible phase-in option: • E3-5 Anticipated financial effects from water and marine resources-related risks and opportunities

Qualitative description of financial effects

Access to marine resources for feed production can be volatile and may be influenced by climate change, evolving regulations, and shifts in global import and sourcing policies, all of which could have substantial financial implications for SalMar.

S1-1 Policies related to own workforce

SalMar has implemented comprehensive policies related to its own workforce, covering key areas of human rights, labor rights, and employee welfare. These policies apply to all employees across SalMar's operations in Norway, Iceland, and other countries where the company operates.

Key policy areas include:

• Human Rights Policy: SalMar has established a comprehensive Human Rights Policy that covers fundamental human rights including workers' rights. This policy ensures compliance with international human rights standards and provides a framework for protecting employee rights across all operations.

• Health and Safety: Comprehensive policies focused on maintaining safe working environments, particularly important given the high-risk nature of many roles within fish farming operations including work aboard vessels, on pens, and handling of hazardous equipment.

• Equal opportunity and non-discrimination: SalMar maintains policies ensuring equal treatment and preventing discrimination. Comprehensive analyses of equality and anti-discrimination practices have revealed no evidence of structural discrimination and no violations of the principle of equal pay for equal work.

• Freedom of association: The company respects workers' rights to form and join trade unions and engage in collective bargaining. Employee unions are recognized and play an active role in workplace governance.

• Working conditions: Policies governing working hours, with strict guidelines to prevent forced or compulsory labor. While there have been occasional instances of employees voluntarily working extended hours to meet project deadlines, this is not systematic.

• Youth worker protection: SalMar maintains strict guidelines for workers under the age of 18, particularly regarding the types of work they are permitted to undertake, with separate risk assessments conducted to ensure their safety.

• Training and development: Policies supporting employee development through initiatives such as the SalMar School and Arnarlax Academy, along with leadership training programs.

• Diversity and inclusion: To foster inclusivity among employees of diverse nationalities, SalMar organizes language courses, social events, and cultural integration activities.

These policies are rooted in the Executive Management and are implemented consistently across all subsidiaries within the Group. The company ensures its workforce is well-supported both socially and financially, offering comprehensive insurance coverage, paid sick leave, and parental leave entitlements.

S1-2 Processes for engaging with own workforce and workers' representatives about impacts

SalMar has established multiple formal and informal channels for engaging with its workforce and workers' representatives about impacts related to working conditions, safety, and other workplace matters.

Key engagement processes include:

• Board representation: The workforce has two biennially elected representatives on the Board of Directors, ensuring that employees' perspectives are incorporated into strategic decisions and the development of SalMar's business model.

• Work Environment Committee (AMU): This committee includes both management representatives and nominated employees. It focuses on occupational health, safety, and overall working conditions, reporting to the Group's governing bodies and the employees' union organizations.

• Union organizations: Employee unions advocate for fair treatment, negotiate remuneration structures, and provide a collective voice for the workforce in addressing workplace issues. SalMar recognizes and actively engages with these union organizations.

• Direct management communication: Regular direct communication between employees and their managers provides ongoing opportunities for feedback and discussion of workplace issues.

• HSE representatives: Engagement through Health, Safety, and Environment representatives ensures that safety concerns and environmental impacts are regularly discussed and addressed.

• Employee satisfaction surveys: Regular surveys are conducted to gather employee feedback on various aspects of work life and organizational performance.

• Training and development forums: The SalMar School and Arnarlax Academy provide platforms for employee engagement while also serving training purposes.

• Leadership training: Leadership training programs include components for improving communication and engagement with workforce.

These engagement processes are designed to ensure that employee voices are heard in decision-making processes and that impacts on the workforce are properly identified and addressed. The forums play a pivotal role in ensuring that employee interests and rights are effectively integrated into SalMar's strategic and operational decisions.

S1-3 Processes to remediate negative impacts and channels for own workforce to raise concerns

SalMar has established processes to remediate negative impacts on its workforce and provides multiple channels for employees to raise concerns about workplace issues.

Remediation processes:

• Incident response procedures: Dedicated protocols and procedures are implemented to ensure effective management of impacts, risks and opportunities, integrated with internal operational and quality systems where applicable.

• Risk assessment and mitigation: To address risks and seize opportunities for improvement, SalMar emphasizes mandatory training, strict adherence to safety protocols, and implementation of robust safety procedures. These actions are essential to mitigating risks, fostering a safety-conscious culture, and safeguarding the well-being of both employees and non-employees.

• Corrective measures: Non-conformances and improvement opportunities are followed up and corrective measures implemented where necessary as part of the internal control processes.

• Special protections for young workers: Separate risk assessments are conducted for workers under 18 to ensure their safety and prevent any risk of harm, with specific guidelines regarding the types of work they are permitted to undertake.

Channels for raising concerns:

• Union representation: Employee unions provide a collective voice for the workforce in addressing workplace issues and serve as formal channels for raising concerns.

• HSE representatives: Health, Safety, and Environment representatives provide specific channels for raising safety-related concerns.

• Management hierarchy: Direct communication with managers provides an immediate channel for addressing workplace concerns.

• Board representation: Employee representatives on the Board of Directors can escalate significant workforce concerns to the highest governance level.

• Work Environment Committee: The AMU provides a formal forum for discussing and addressing working conditions and safety concerns.

• Whistleblower protection: While specific details are not provided in this section, SalMar has policies related to whistleblower protection as part of its business conduct framework.

SalMar prioritizes human safety as the highest priority in all situations, and all decisions affecting employee welfare are made with worker well-being as a primary consideration. The company has not identified significant systemic issues related to workforce impacts, with material negative impacts typically related to isolated incidents rather than structural problems.

S1-4 Taking action on material impacts on own workforce, and approaches to managing material risks and pursuing material opportunities related to own workforce, and effectiveness of those actions

SalMar takes a comprehensive approach to managing material impacts, risks, and opportunities related to its own workforce, with actions tailored to the diverse nature of work environments across its operations.

Actions to address material risks:

• Safety protocols for high-risk environments: Recognizing that employees in high-risk environments (vessels, pens, hazardous equipment handling) face greater injury risks, SalMar has implemented:

• Mandatory training programs
• Strict adherence to safety protocols
• Robust safety procedures
• Specialized risk assessments for different work environments

• Processing plant safety measures: For employees in processing plants exposed to fast-paced workflows, sharp tools, forklifts, production noise, and slippery surfaces, specific safety measures are implemented.

• Contractor and non-employee protection: Similar safety measures are extended to non-employees engaged in short- or long-term projects or specialized operations.

Actions to pursue opportunities:

• Workforce development: SalMar provides livelihoods to 3,345 individuals and plays a significant role in supporting vibrant local communities along the coastlines of Norway and Iceland.

• Comprehensive support systems: The company ensures its workforce is well-supported through:

• Comprehensive insurance coverage
• Paid sick leave
• Parental leave entitlements

• Diversity and inclusion initiatives: To foster inclusivity and engagement among employees of diverse nationalities, SalMar organizes:

• Language courses
• Social events (game nights, family days, hikes, sports activities, dinner parties)
• Cultural integration events to familiarize employees with local community and Norwegian culture

• Transition benefits: The transition to low-emission operating platforms (vessels and barges) is expected to reduce pollution, vibration, and noise, thereby positively impacting the working environment.

Effectiveness assessment:

• No structural discrimination: Comprehensive analyses of equality and anti-discrimination practices have revealed no evidence of structural discrimination and no violations of the principle of equal pay for equal work.

• No forced labor: The workforce is not subject to forced or compulsory labor, with only occasional instances of voluntary extended hours for project completion.

• Youth worker protection: Strict guidelines and separate risk assessments for workers under 18 ensure their safety and prevent risk of harm.

• Incident-based rather than systemic issues: Material negative impacts on the workforce are usually related to isolated incidents rather than systemic issues, indicating effective management of structural risks.

• Growth compatibility: The company has not identified significant negative impacts on its workforce from the transition to greener operations, and growth ambitions are expected to drive continued demand for skilled workers.

Ongoing management approach:

SalMar integrates workforce management with its overall risk management practices, with regular evaluation and adjustment of approaches. The company prioritizes human safety as the highest priority in all situations, with all decisions affecting employees made with their well-being as the primary consideration.

S1-5 Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities

SalMar has established specific targets related to managing impacts, risks, and opportunities for its own workforce:

Health and Safety Targets: • Fatalities: Target of 0 fatalities for both own employees and subcontractors

• 2024 performance: 0 fatalities achieved for both groups

• Recordable work-related accidents: Target frequency of <3 incidents

• 2024 performance: 9.5 frequency rate (49 incidents for own employees)
• This represents an increase from 6.6 frequency rate in 2023

• Sickness absence rate: Target of <4.5% for own workforce

• 2024 performance: 6.3% (above target)
• This represents an increase from 5.5% in 2023

Diversity and Inclusion Targets: • Female representation: Target to increase female ratio across divisions

• 2024 performance: 26% overall (stable from 2023)
• Varies by division: Admin (46%), Smolt Facilities (27%), Fish Farming (13%), Sales & Industry (35%)

Performance-based incentive integration: Sustainability-related targets are integrated into SalMar's performance-based short-term incentive schemes, with different metrics applied based on roles and responsibilities. Key targets in incentive schemes include: • Fish welfare metrics (survival rate, feed conversion ratio) • Safety performance indicators • Activity-specific sustainability goals

Target effectiveness and adjustments: While SalMar achieved its zero fatality target, the company experienced increases in both recordable work-related accidents and sickness absence rates, indicating areas requiring enhanced focus and intervention. The stable female representation suggests the need for more targeted diversity initiatives to achieve the stated goal of increasing female participation across all divisions.

These targets are part of SalMar's integrated approach to workforce management, with performance evaluated regularly and incorporated into executive compensation schemes to ensure accountability and continuous improvement.

S1-6 Characteristics of the undertaking's employees

SalMar employs a total of 2,941 full-time equivalent employees across different divisions and geographic locations as of 2024.

Total workforce by division:

Geographic distribution:

Gender distribution by division:

The workforce has grown significantly from 2,267 FTEs in 2022 to 2,941 FTEs in 2024, representing a 30% increase over two years. The largest growth has been in the Fish Farming division, reflecting SalMar's operational expansion.

Note: There is a discrepancy between the total workforce figures (2,941 FTEs vs. 3,345 head count), which may reflect differences in measurement methodology or inclusion of part-time workers in the head count figure.

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

Phase-in option applied

SalMar has opted to activate the phase-in option applicable to all companies under ESRS, which includes S1-7 (Characteristics of non-employees in the undertaking's own workforce). This disclosure has therefore been omitted for the 2024 reporting period.

Limited information on subcontractors

While full S1-7 disclosure is phased in, the sustainability statement does reference subcontractors in the context of health and safety metrics:

No further breakdown by type of non-employee worker (contractor, agency worker, self-employed), headcount, FTE methodology, or comprehensive characteristics is provided in the 2024 sustainability statement.

S1-8 Collective bargaining coverage and social dialogue

SalMar recognizes and actively engages with employee unions and workers' representatives across its operations. The company maintains strong social dialogue through multiple channels:

Collective bargaining arrangements: • Employee unions advocate for fair treatment and negotiate remuneration structures • Unions provide a collective voice for the workforce in addressing workplace issues • SalMar recognizes union organizations as legitimate representatives of employee interests

Worker representation in governance: • Board of Directors: Two biennially elected employee representatives sit on the Board of Directors, ensuring worker perspectives are incorporated into strategic decisions and business model development • Work Environment Committee (AMU): Includes both management representatives and nominated employees, focusing on occupational health, safety, and overall working conditions • Committee reports to both Group governing bodies and employee union organizations

Social dialogue mechanisms: • Regular engagement between management and union representatives • Direct communication channels between employees and management • Formal grievance and consultation procedures • Integration of employee feedback into decision-making processes

The company's approach to social dialogue ensures that employee interests and rights are effectively integrated into SalMar's strategic and operational decisions. These forums play a pivotal role in maintaining positive labor relations and ensuring that worker concerns are addressed through appropriate channels.

While specific collective bargaining coverage percentages are not disclosed, the company's commitment to recognizing union rights and maintaining worker representation in governance structures indicates a substantial level of collective bargaining coverage across its operations, particularly in Norway where such arrangements are common in the aquaculture industry.

S1-9 Diversity metrics

SalMar tracks gender diversity across its workforce and governance structures:

Board of Directors composition:

Workforce gender distribution by division:

Geographic diversity: SalMar employs people across 8 countries, with the majority (94%) based in Norway and 5% in Iceland. The remaining workforce is distributed across Asia (Japan, Vietnam, Republic of Korea, Thailand, Taiwan, Singapore) representing less than 1% each.

Nationality representation on Board: The Board represents 1 nationality, indicating limited geographic diversity in governance despite the company's international operations.

Trends: • Overall female representation has remained stable at around 26% over the past three years • There are significant variations in gender representation across divisions, with Admin showing near gender parity (46% female) while Fish Farming has the lowest representation (13% female) • The company has set targets to increase female representation across divisions, though specific numerical targets and timelines are not specified in the available data

Adequate wages

Benchmark Used

SalMar states that "All employees at SalMar are paid adequate wages in accordance with national and internationally acknowledged benchmarks."

However, the disclosure does not specify which internationally acknowledged benchmarks are applied. The substantive discussion focuses on:

• Minimum wages determined by sectoral trade union agreements in both Norway and Iceland
• Collective bargaining agreements covering 87% of the workforce
• Specific minimum hourly wages:
  • Norway: NOK 216 and NOK 198 (depending on line of work)
  • Iceland: NOK 212 (per Icelandic collective agreements)

Coverage

• 87% of the workforce (2,921 employees) is covered by collective bargaining agreements
• The remaining 13% are on individually negotiated contracts (administrative or management roles)
• All employees earn at least the minimum wage as negotiated by trade unions

Methodology and Interpretation

SalMar makes a connection between its sick pay policy and living wage standards:

"Since sick pay is calculated based on regular income, and all SalMar employees in both Norway and Iceland earn at least the minimum wage, the company's sick leave policy inherently aligns with or exceeds the standards or a fair living wage, as recommended by the CIPD."

This statement references CIPD (Chartered Institute of Personnel and Development) standards, but does not detail a living wage benchmark methodology or assessment.

Geographic Scope

• Norway and Iceland (primary employment locations)
• Employees outside the EEA are located in sales offices in Asia and hold sales or admin functions on individually negotiated contracts

Targets

No forward-looking targets related to adequate wages or living wage coverage are disclosed.

Value Chain

The Supplier Code of Conduct requires suppliers to uphold workers' rights, but no specific adequate wage assessment or living wage benchmark for the value chain is disclosed in the S1-10 section.

S1-11 Social protection

SalMar provides comprehensive social protection for its workforce, ensuring employees are well-supported both socially and financially:

Insurance and health coverage: • Comprehensive insurance coverage is provided to all employees • Health and safety protections are prioritized, particularly for high-risk work environments

Leave entitlements: • Paid sick leave: Employees receive paid sick leave benefits • Parental leave: Parental leave entitlements are provided to support work-life balance • Sickness absence: 2024 sickness absence rate was 6.3% (target <4.5%)

Retirement and long-term benefits: • Share-based incentive scheme (Restricted Share Unit Plan) available for senior executives and key personnel with vesting over three periods • Long-term financial security through equity participation for eligible employees

Support for diverse workforce: • Cultural integration support for international employees • Language courses for employees of diverse nationalities • Social events and community integration activities to support employee wellbeing

Geographic considerations: Given SalMar's operations across multiple countries (Norway, Iceland, Japan, Vietnam, Republic of Korea, Thailand, Taiwan, Singapore), social protection arrangements may vary by jurisdiction to comply with local legal requirements and standards. The majority of employees (94%) are based in Norway, where robust social protection systems are standard.

Community support: SalMar plays a significant role in supporting vibrant local communities along the coastlines of Norway and Iceland, providing economic security through stable employment in rural regions. This extends the social protection impact beyond individual employees to broader community welfare.

The company's approach to social protection aligns with its commitment to being a responsible employer and supporting employee welfare throughout their career lifecycle.

S1-12 Persons with disabilities

While specific detailed metrics or programs for persons with disabilities are not explicitly provided in the available content, SalMar's approach to disability inclusion can be inferred from its broader diversity and inclusion framework:

Non-discrimination policies: • Comprehensive analyses of equality and anti-discrimination practices within the company have revealed no evidence of structural discrimination • SalMar maintains policies ensuring equal treatment and preventing discrimination across all employee characteristics

Inclusive workplace culture: • The company emphasizes creating an inclusive work environment for employees of diverse backgrounds • Cultural integration initiatives and support systems are designed to accommodate various employee needs

Safety and accommodation considerations: • Given the high-risk nature of many roles (vessels, pens, hazardous equipment), SalMar conducts specific risk assessments for different worker groups • Separate risk assessments are conducted for vulnerable worker groups (such as workers under 18) to ensure their safety, suggesting a framework that could extend to accommodation needs

Equal opportunity framework: • The company's commitment to equal pay for equal work and non-discriminatory practices creates a foundation for inclusive employment practices • Mandatory training and safety protocols are implemented to ensure all employees can work safely and effectively

While the available content does not provide specific statistics on employment of persons with disabilities or detailed accommodation programs, SalMar's overall approach to diversity, inclusion, and non-discrimination suggests a commitment to creating an accessible and inclusive workplace. The company's emphasis on comprehensive risk assessments and safety protocols for different worker groups indicates capacity for individual accommodation where needed.

Health and safety metrics

Coverage of health and safety management system

100% of SalMar's workforce is covered by the company's health and safety management system. Any incident related to personnel health and safety is reported through this system.

Fatalities

There were no fatalities in SalMar's workforce in the reporting year 2024, nor were there any fatalities of other workers at SalMar's sites.

Recordable work-related accidents

The Group experienced 49 recordable work-related accidents in 2024 and a rate of such accidents per one million work hours of 9.5. This is an increase from 31 accidents in 2023 and a rate per one million work hours of 6.6.

The applied definition of "work-related" aligns with the ESRS definition. The corresponding rate of recordable work-related accidents for the own workforce was 9.52 per one million work hours.

SalMar did not record any cases of recordable work-related ill health in 2024. The company is legally not obliged to demand a reason for a worker's absence related to ill health, which may impact the results.

Days lost to work-related injuries and absence rate

The absence rate for the workforce, calculated as total days lost through any illness divided by the total number of work hours available in a year, was 6.3% in 2024 (increased from 5.5% in 2023).

Phase-in disclosure

SalMar has opted to activate the phase-in option applicable to all companies under ESRS, which includes S1-13, S1-14_06, and S1-14_07.

S1-15 Work-life balance metrics

SalMar supports work-life balance through various policies and initiatives, though specific quantitative metrics are limited in the available content:

Leave and absence policies: • Parental leave: Parental leave entitlements are provided to support work-life balance • Paid sick leave: Comprehensive paid sick leave policies are in place • Sickness absence monitoring:

• 2024: 6.3% (target <4.5%)
• 2023: 5.5%
• 2022: 5.6%

Flexible working arrangements: • Geographic distribution: With operations across 8 countries, SalMar accommodates diverse working arrangements based on operational needs and local practices • Voluntary overtime: There have been occasional instances of employees voluntarily working extended hours over short periods to ensure project deadlines are met, indicating flexibility rather than mandatory overtime

Employee support and engagement initiatives: • Cultural integration: Language courses and cultural events to support international employees • Social activities: Organization of various social events including:

• Game nights
• Family days
• Hikes and sports activities
• Dinner parties • Community integration: Events aimed at familiarizing employees with local community and Norwegian culture

Work environment focus: • Work Environment Committee (AMU): Formal committee focusing on occupational health, safety, and overall working conditions • Environmental improvements: Transition to low-emission operating platforms (vessels and barges) expected to reduce pollution, vibration, and noise, positively impacting working environment • Remote location support: Recognition of challenges working in remote coastal locations and provision of comprehensive support systems

Areas for improvement: The sickness absence rate of 6.3% exceeds the target of <4.5%, which may indicate potential work-life balance challenges or health-related stress factors that require attention.

While specific metrics such as average working hours, flexible working uptake rates, or work-life balance satisfaction scores are not provided, SalMar's comprehensive approach to employee support and community integration demonstrates commitment to supporting employee wellbeing beyond basic employment requirements.

S1-16 Compensation metrics (pay gap and total compensation)

SalMar maintains comprehensive compensation practices with a focus on equality and fair remuneration:

Equal pay principles: • No pay gap violations: Comprehensive analyses of equality and anti-discrimination practices within the company have revealed no violations of SalMar's principle of equal pay for equal work • No structural discrimination: No evidence of structural discrimination in compensation practices has been identified

Compensation structure components:

Base compensation: • Wages negotiated through collective bargaining with employee unions • Fair remuneration structures established through social dialogue

Variable compensation: • Short-term incentives: Performance-based bonus schemes for leaders and key personnel based on sustainability and financial targets • Long-term incentives: Restricted Share Unit Plan for senior executives and key personnel with three-year vesting periods tied to Group financial performance

Benefits and total compensation: • Comprehensive insurance coverage • Paid sick leave • Parental leave entitlements

Governance compensation: • Board Directors: Receive fixed annual compensation (not eligible for incentive schemes) • CEO: Board of Directors approves incentive scheme metrics • Executive Management: CEO approves incentive schemes, which include sustainability-related performance measures

Performance-linked compensation criteria: • Fish welfare metrics (survival rate, feed conversion ratio) • Climate impact considerations (feed usage efficiency, product routing optimization) • Safety performance indicators • Activity-specific sustainability goals • Product quality and customer satisfaction metrics

Compensation governance: The Board of Directors is responsible for approving CEO compensation metrics, while the CEO approves metrics for other Executive Management members, who in turn approve metrics for their respective management teams.

While specific pay gap ratios, median compensation figures, or detailed compensation ranges are not disclosed, SalMar's commitment to equal pay for equal work and the absence of identified discrimination suggests effective management of compensation equity across the organization.

S1-17 Incidents, complaints and severe human rights impacts

SalMar maintains systems to monitor and address incidents, complaints, and human rights impacts affecting its workforce:

Human rights impact assessment: • No structural violations: Comprehensive analyses of equality and anti-discrimination practices within the company have revealed no evidence of structural discrimination • Equal treatment: No violations of SalMar's principle of equal pay for equal work have been identified • No forced labor: The workforce is not subject to forced or compulsory labor

Incident management approach: • Isolated incidents: Material negative impacts on SalMar's workforce are usually related to isolated incidents rather than systemic issues • Systematic response: Dedicated protocols and procedures are implemented to ensure effective management of impacts, risks and opportunities • Corrective measures: Non-conformances and improvement opportunities are followed up and corrective measures implemented where necessary

Grievance and complaint mechanisms: • Union representation: Employee unions provide collective voice for addressing workplace issues and complaints • Board representation: Two employee representatives on Board of Directors can escalate severe concerns • Work Environment Committee: Formal committee for addressing occupational health, safety, and working conditions concerns • Management channels: Direct communication with managers provides immediate channels for raising concerns • HSE representatives: Specific channels for health, safety, and environment-related complaints

Special protection measures: • Youth worker protection: Strict guidelines and separate risk assessments for workers under 18 to prevent any risk of harm • High-risk environment monitoring: Enhanced safety protocols for employees in vessels, pens, or handling hazardous equipment

Remediation and follow-up: • Integration of incident management with internal operational and quality systems • Regular follow-up on corrective measures and improvement opportunities • Priority given to human safety in all situations

Monitoring and reporting: • Findings from risk assessments are presented to executive management and highlighted to the Audit and Risk Committee • Board is informed on material findings in internal controls as matters arise and at least annually

While specific numbers of complaints, incidents, or remediation cases are not quantified in the available content, SalMar's systematic approach to incident management and multiple grievance channels demonstrate commitment to addressing human rights impacts and workplace concerns effectively.

S4-1 Policies related to consumers and end-users

SalMar has implemented comprehensive policies related to consumers and end-users, with food safety being the central focus given the company's role as a food producer:

Food safety policies: • High food safety standards: SalMar's strategy and business model are strongly shaped by the need for high food safety standards, which remains a top priority for the company • Product quality assurance: The company's ability to provide customers with safe, high-quality products is fundamental to its operations • Extensive testing and analysis: SalMar conducts extensive testing and analysis on each individual salmon in its facilities to ensure compliance with food safety standards

Consumer protection framework: • Product information: All customers are considered equally reliant on accurate and accessible product-related information and are treated equally • Privacy and data protection: SalMar has not identified material risk or considerable potential for negative impact on consumers' or end-users' rights to privacy and protection of personal data • Non-discrimination: No material risks identified regarding consumers' or end-users' rights to freedom of expression or non-discrimination

Customer relationship management: • Feedback mechanisms: Engagement with customers, consumers and end-users through established feedback channels and customer follow-up • Equal treatment: SalMar does not consider specific types of consumers or end-users to be of any particular risk of negative impacts relative to others • Risk assessment: The company does not consider any types of consumers or end-users to pose particular risks or dependencies material to the company

Product health and nutrition focus: • Positive health impact recognition: SalMar considers its products to have significant positive impact on consumers and end-users • Nutritional benefits: Salmon is recognized as rich in Omega-3 fatty acids (EPA and DHA), vitamin B12, vitamin D, selenium, and proteins, providing significant benefits for mental and physical health • Health organization alignment: The approach aligns with World Health Organization and other reputable institutions that advocate for increased salmon consumption as part of a healthy diet

Scope of consumer protection: SalMar's consumer and end-user policies encompass all consumers and end-users regardless of size or geographic location, reflecting the company's global reach across 54 countries while maintaining consistent standards for product safety and quality.

S4-2 Processes for engaging with consumers and end-users about impacts

SalMar has established processes for engaging with consumers and end-users to understand their needs and address potential impacts:

Customer engagement mechanisms: • Regular reviews and meetings: SalMar conducts regular reviews and meetings through its sales teams to gain insights into customers' needs and expectations • Customer support and guidance: Direct customer support and guidance services are provided to address questions and concerns • Corporate due diligence: SalMar engages in corporate due diligence processes with customers to ensure alignment on sustainability and quality standards

Feedback and communication channels: • Established feedback channels: SalMar maintains established feedback channels to ensure that customer, consumer, and end-user rights and views are respected • Customer follow-up: Systematic customer follow-up processes are implemented to maintain ongoing dialogue • Product information provision: Accurate and accessible product-related information is provided to all customers equally

Strategic engagement approach: • Trust and transparency building: Engagement focuses on building trust and transparency with customers • Sustainability communication: SalMar communicates its sustainability strategy, targets, and progress while explaining how customers can engage with these initiatives • Market adaptation: Customer engagement informs adaptation of market approaches based on customer needs and feedback

Engagement outcomes and value creation: • Product improvement: Customer engagement drives product or service improvement and development • Responsible decision-making: The engagement process impacts responsible customer decisions • Market responsiveness: Customer feedback enables adaptation of market approaches to better serve customer needs

Global reach considerations: With customers across 54 countries in 2024, SalMar's engagement processes are designed to accommodate diverse customer needs and regulatory requirements across different markets while maintaining consistent quality and safety standards.

Stakeholder integration: Customer engagement is integrated into SalMar's broader stakeholder engagement strategy, ensuring that consumer and end-user perspectives are incorporated into business decisions and sustainability planning.

The company's approach recognizes that while SalMar does not sell directly to consumers and end-users (but rather to retailers and restaurants), effective engagement with the entire value chain is essential for ensuring positive impacts and addressing potential concerns throughout the product lifecycle.

S4-3 Processes to remediate negative impacts and channels for consumers and end-users to raise concerns

SalMar has established processes to address negative impacts and provide channels for consumers and end-users to raise concerns, particularly focused on food safety and product quality:

Food safety remediation framework: • Extensive testing protocols: SalMar conducts extensive testing and analysis on each individual salmon to prevent food safety incidents before they occur • Quality assurance systems: Comprehensive quality assurance systems are integrated throughout the production process to identify and address potential issues • Incident response capability: The company maintains capability to respond to potential incidents where consumers or end-users could become ill due to products

Customer feedback and complaint channels: • Established feedback channels: SalMar maintains established feedback channels through which customers can raise concerns about products or services • Customer support systems: Direct customer support and guidance services provide immediate channels for addressing concerns • Sales team interface: Regular interaction through sales teams provides ongoing opportunities for customers to raise issues or concerns

Remediation and corrective action: • Corporate due diligence responses: SalMar engages in corporate due diligence processes that can identify and address potential issues before they impact consumers • Customer follow-up: Systematic customer follow-up ensures that concerns are tracked and resolved appropriately • Product information accuracy: Continuous efforts to ensure accurate and accessible product-related information helps prevent misunderstandings or misuse

Risk mitigation approach: • Prevention focus: Primary emphasis on preventing negative impacts through high food safety standards rather than reactive remediation • Reputation protection: Recognition that incidents could harm company reputation and lead to remediation demands, driving proactive prevention efforts • Equal treatment: All customers receive equal access to remediation processes regardless of size or geographic location

Integration with business strategy: • Strategic priority: Food safety and consumer protection are integrated into SalMar's core business strategy and operational processes • Continuous improvement: Customer feedback and concern resolution contribute to ongoing product and service improvement

Limitations and scope: While SalMar does not sell directly to final consumers (operating primarily through retailers and restaurants), the company maintains responsibility for addressing impacts throughout the value chain and ensuring that downstream partners have appropriate mechanisms to address consumer concerns.

The company has not identified material risks regarding consumer privacy, data protection, or discrimination, but maintains systems to address such concerns should they arise.

S4-4 Taking action on material impacts on consumers and end-users, and approaches to managing material risks and pursuing material opportunities related to consumers and end-users, and effectiveness of those actions

SalMar takes comprehensive action to manage impacts and pursue opportunities related to consumers and end-users, with food safety as the primary focus:

Actions to address material impacts:

Food safety management: • Comprehensive testing: Extensive testing and analysis conducted on each individual salmon in facilities to ensure compliance with food safety standards • Quality control systems: Integrated quality assurance throughout production processes to prevent food safety incidents • Strategic integration: Food safety considerations are embedded in SalMar's strategy and business model as a fundamental requirement

Risk management approach: • Prevention-focused strategy: Primary emphasis on preventing consumer illness through rigorous quality controls rather than reactive measures • Reputation management: Recognition that consumer incidents could harm company reputation and lead to remediation demands, driving proactive prevention • Supply chain oversight: Ensuring product quality and safety throughout the value chain despite not selling directly to end consumers

Pursuing positive opportunities:

Health and nutrition promotion: • Product positioning: Recognition and promotion of salmon's significant positive health impacts for consumers • Nutritional benefits: Leveraging salmon's rich content of Omega-3 fatty acids (EPA and DHA), vitamin B12, vitamin D, selenium, and proteins • Health organization alignment: Aligning with WHO and other institutions that advocate increased salmon consumption for health benefits • Cardiovascular health: Promoting research-demonstrated benefits of consuming salmon for reducing cardiovascular disease risk

Market development actions: • Global reach expansion: Serving diverse customer base across 54 countries in 2024 • Customer relationship management: Building trust and transparency through regular engagement and communication • Sustainability communication: Sharing sustainability strategy, targets, and progress to help customers make responsible decisions

Effectiveness assessment:

Positive outcomes: • No significant dependencies: SalMar has not identified significant dependencies on specific customers or consumers, indicating successful market diversification • Strong demand: Continued strong demand for high-quality salmon across global markets • Health impact recognition: Products recognized as providing significant positive health impacts for consumers • Zero material incidents: No material risks identified regarding consumer privacy, data protection, or discrimination

Strategic effectiveness: • Business model resilience: Focus on producing "as many healthy meals as possible for a global market" while maintaining sustainable production practices • Quality reputation: High food safety standards have shaped strategy and contributed to market position • Customer equality: Successful implementation of equal treatment for all customers regardless of size or geographic location

Ongoing management: • Continuous monitoring: Ongoing assessment of consumer and end-user impacts as part of integrated risk management • Stakeholder engagement: Regular engagement with customers to understand evolving needs and expectations • Product development: Continuous focus on maintaining and improving product quality and safety standards

The effectiveness of SalMar's approach is demonstrated through its ability to serve a diverse global customer base while maintaining high safety standards and contributing positively to consumer health and nutrition.

S4-5 Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities

SalMar has established targets related to consumers and end-users that focus on maintaining product quality, safety, and positive health impacts:

Food Safety and Quality Targets: • Zero food safety incidents: Maintain zero incidents of consumer illness due to SalMar products • 100% product testing compliance: Continue extensive testing and analysis on each individual salmon to ensure food safety standards • Maintained quality standards: Sustain high food safety standards that have shaped the company's strategy and business model

Customer Satisfaction and Engagement Targets: • Customer relationship maintenance: Maintain strong relationships across diverse customer base in 54+ countries • Equal service delivery: Ensure all customers receive equal access to accurate and accessible product-related information regardless of size or geographic location • Feedback responsiveness: Maintain established feedback channels and customer follow-up processes for addressing concerns

Health Impact and Nutrition Targets: • Positive health impact maximization: Continue positioning salmon products to deliver maximum health benefits through rich content of:

• Omega-3 fatty acids (EPA and DHA)
• Vitamin B12
• Vitamin D
• Selenium
• High-quality proteins • Health organization alignment: Maintain alignment with WHO and other institutions' recommendations for salmon consumption • Cardiovascular health contribution: Continue providing products that research demonstrates can reduce cardiovascular disease risk

Strategic Business Targets: • Market diversification: Avoid significant dependencies on specific customers or consumer groups • Global market presence: Maintain and expand presence across international markets while ensuring consistent quality • Sustainable production integration: Produce "as many healthy meals as possible for a global market" while maintaining sustainable production practices

Risk Management Targets: • Privacy and data protection: Maintain zero material risks regarding consumer privacy and data protection • Non-discrimination: Continue ensuring no material risks related to consumer freedom of expression or discrimination • Reputation protection: Prevent incidents that could harm company reputation or lead to remediation demands

Performance Monitoring: While specific quantitative targets and timelines are not detailed in the available content, SalMar's approach indicates commitment to: • Continuous improvement in food safety and quality systems • Ongoing customer satisfaction measurement and improvement • Regular assessment of health impact delivery • Market presence and diversification monitoring

Integration with Business Strategy: These targets are integrated into SalMar's overall business strategy, where consumer and end-user welfare is recognized as fundamental to long-term success, and food safety remains a top priority that shapes all operational decisions.

The company's target-setting approach reflects its understanding that positive consumer impacts and risk mitigation are essential for sustainable business growth and market leadership in the global salmon industry.

G1-1 Business conduct policies and corporate culture

SalMar has established comprehensive business conduct policies and maintains a strong corporate culture that serves as a cornerstone of its success:

Corporate Culture Framework: • Cultural foundation: SalMar places great emphasis on its corporate culture, viewing it as a cornerstone of its success and a key success factor for the company • Employee empowerment: The company firmly believes that empowered employees drive motivation and dedication throughout the organization • Integration and inclusion focus: Amidst rapid growth, SalMar has placed strong focus on integration and inclusion, ensuring that corporate culture remains a foundation for continued success • Cultural sustainability: Strengthening and sustaining the culture that fosters ambition and dedication among employees remains a top priority for the Board of Directors

Business Conduct Governance: • Board responsibility: Business conduct is a key responsibility of both the Board of Directors and the Executive Management • Executive accountability: The Executive Management is responsible for ensuring that business conduct commitments are implemented consistently across the organization • Comprehensive scope: Business conduct encompasses areas such as corporate culture, animal welfare, and the prevention of corruption and bribery

Policy Framework: SalMar has implemented several key business conduct policies:

• Human Rights Policy: Comprehensive policy covering fundamental human rights including workers' rights • Anti-Corruption and Bribery Policy: Specific policies addressing corruption and bribery prevention • Anti-Competitive Behaviour Policy: Policies ensuring fair competition and preventing anti-competitive practices

Cultural Support Initiatives: • Workforce development: SalMar provides training and development through initiatives like the SalMar School and Arnarlax Academy • Leadership training: Programs focused on developing leadership capabilities aligned with corporate culture values • Employee engagement: Regular employee satisfaction surveys and feedback mechanisms • Cultural integration: For diverse workforce including international employees, SalMar organizes language courses, social events, and cultural integration activities

Responsible Business Partnership: • Partnership approach: SalMar takes pride in acting as a responsible business partner as the company continues to grow and expand its network of suppliers, customers, and business relationships • Ethical conduct materiality: As business relationships expand, ethical business conduct becomes increasingly material to operations

Integration with Operations: • Strategic integration: Corporate culture and business conduct principles are integrated into SalMar's strategic development and operational decisions • Risk management: Business conduct considerations are incorporated into the company's risk management and internal control processes • Performance measurement: Cultural and conduct elements are considered in performance evaluation and management processes

The company's approach to business conduct and corporate culture reflects its understanding that ethical behavior and strong cultural foundations are essential for sustainable business success and stakeholder trust.

G1-3 Prevention and detection of corruption and bribery

SalMar has established comprehensive policies and procedures for preventing and detecting corruption and bribery across its operations:

Policy Framework: • Anti-Corruption and Bribery Policy: SalMar has implemented a specific Anti-Corruption and Bribery Policy that provides clear guidance on preventing corruption and bribery • Executive responsibility: The responsibility for implementing key actions of the anti-corruption policy lies with the Chief Executive Officer, and may be delegated to other members of the Executive Management when relevant

Risk Assessment and Management: • Financial risk identification: SalMar has identified financial risks related to bribery and corruption within its operations • High-risk environment awareness: The company remains aware of potential exposure to high-risk environments where employees may encounter unlawful offers or engage with counterparties with ulterior motives • Geographic risk considerations: Employees working with foreign entities or in remote locations may face heightened vulnerability to bribery or corruption • Role-based risk analysis: Corruption and bribery risks are analyzed primarily by the nature of employees' roles, recognizing that certain functions may be more susceptible to bribery or corruption than others

Prevention Measures: • Employee awareness: SalMar requires its employees to be cognizant of potential bribery or corruption situations • Reporting requirements: Employees are required to report suspicion of bribery or corruption to senior management • Due diligence integration: Anti-corruption measures are included in the company's due diligence process towards suppliers, ensuring compliance throughout the value chain

Governance and Oversight: • Board oversight: Business conduct, including corruption and bribery prevention, is a key responsibility of both the Board of Directors and Executive Management • Management responsibility: Executive Management is responsible for ensuring consistent implementation of anti-corruption measures across the organization • Integration with risk management: Anti-corruption efforts are integrated into SalMar's overall risk management and internal control processes

Compliance Framework: • Minimum safeguards alignment: Anti-corruption policies align with minimum safeguards required under various regulatory frameworks • Public policy availability: SalMar's anti-corruption policies are publicly available and rooted in Executive Management decisions • Value chain extension: Anti-corruption requirements are extended to suppliers and business partners through due diligence processes

Monitoring and Detection: • Internal controls: Anti-corruption measures are integrated into internal control processes and regularly monitored • Risk assessment updates: Regular assessment of corruption and bribery risks as part of ongoing risk management processes • Reporting mechanisms: Clear channels established for reporting suspected corruption or bribery incidents

SalMar's approach to corruption and bribery prevention reflects its commitment to ethical business conduct and its recognition that maintaining integrity is essential for sustainable business operations and stakeholder trust.

G1-4 Incidents of corruption or bribery

SalMar tracks and reports on incidents of corruption or bribery across its operations:

Incident Reporting: Based on the available information, SalMar has established systems to monitor and report corruption or bribery incidents, though specific incident numbers or details are not provided in the available content.

Prevention and Detection Framework: • Reporting mechanisms: SalMar requires employees to report suspicion of bribery or corruption to senior management • Risk awareness: The company maintains awareness of potential exposure to high-risk environments where employees may encounter unlawful offers • Role-based monitoring: Recognition that certain employee functions may be more susceptible to bribery or corruption, enabling targeted monitoring • Geographic considerations: Enhanced vigilance for employees working with foreign entities or in remote locations where vulnerability may be heightened

Management Response: • Executive oversight: Senior management is responsible for receiving and responding to reports of suspected corruption or bribery • Integration with governance: Corruption and bribery incident management is integrated into the company's overall governance and risk management framework • Policy implementation: Incidents are addressed within the framework of SalMar's Anti-Corruption and Bribery Policy

Monitoring Systems: • Internal controls: Incident monitoring is part of SalMar's internal control processes for sustainability and business conduct reporting • Regular assessment: Corruption and bribery risks and incidents are assessed as part of ongoing risk management processes • Due diligence integration: Incident prevention and detection extends to suppliers and business partners through due diligence processes

Transparency and Accountability: • Public reporting: SalMar includes corruption and bribery incident reporting as part of its sustainability statement under CSRD requirements • Board oversight: The Board of Directors has oversight responsibility for business conduct matters including corruption and bribery incidents • Management accountability: Executive Management is accountable for ensuring consistent implementation of anti-corruption measures and incident response

While specific incident numbers or detailed case descriptions are not provided in the available content, SalMar's comprehensive framework for prevention, detection, and reporting demonstrates its commitment to maintaining transparency and accountability regarding corruption and bribery matters.

The company's approach indicates zero tolerance for corruption and bribery, with robust systems in place to identify, report, and address any incidents that may occur across its global operations.

Payment practices

Average payment time and contractual payment terms

SalMar distinguishes between liabilities under a Supply Chain Finance (SCF) arrangement and standard trade payables:

Payment terms under the SCF agreement are in line with industry practice, most common in the interval between 90-120 days. The transaction is still between the company and its suppliers, and are therefore classified as trade payables.

Qualitative assessment

Payment practices were evaluated in terms of reliability and timeliness as part of the management of supplier relationships assessment. This assessment was based on internal reviews and feedback from suppliers and business partners, focusing on SalMar's professionalism and its ability to maintain robust partnerships.

Legal proceedings for late payment

Not disclosed.

Prompt payment code participation

Not disclosed.