SalMar

Reference: page 28

SalMar's Board of Directors oversees the Group's sustainability matters. The Board has seven members (three female, four male; 43%/57% split), including two employee representatives; among the five shareholder-elected members, three are independent (60% independence). The Audit and Risk Committee (ARC) has overseen the identification and assessment of impacts, risks and opportunities (IROs) on behalf of the Board, with the Executive Management Team (EMT) also actively involved and coordination led by the Head of Sustainability. Board members bring sustainability expertise: Chair Gustav Witzøe in food safety, marine resources, biodiversity, climate change and animal welfare; Arnhild Holstad in biodiversity and forest management from her role at Statskog; Margrethe Hauge and Morten Loktu in product development and innovation. Business conduct, including corporate culture and animal welfare, is a joint Board/EMT responsibility, and the EMT is responsible for day-to-day IRO oversight, escalating relevant developments to the Board (page 28).

Reference: page 28

For the 2025 Double Materiality Assessment (DMA) update, the Executive Management Team (EMT) was informed of the process and findings and involved in verifying accuracy. The Audit and Risk Committee (ARC) was informed of the results and discussed their validity, with the EMT and ARC receiving regular updates at least annually. The Board of Directors is informed of DMA results at least annually and validates alignment with the Group's strategic goals. The EMT addresses implementation of due diligence, and the results and effectiveness of policies, actions, metrics and targets, both as issues arise and at least annually; this assessment covers impacts on animal/fish welfare, biological risk, climate change mitigation and adaptation, water and marine resources, own workforce, food safety and business conduct (page 28).

Reference: page 28

SalMar's short-term incentive scheme (bonus) for leaders and key personnel is weighted 70% financial and 30% non-financial targets. Non-financial targets are activity-specific: sea farms are assessed on fish welfare and climate metrics such as survival rate and feed conversion ratio, while processing facilities use product quality, recall rates and customer satisfaction. Climate-related targets apply to EMT members with relevant operational responsibility, including the COO of Farming (fish feed usage) and the COO of Sales & Industry (climate impact of product routing). The Board approves the CEO's incentive metrics; the CEO approves metrics for other EMT members. SalMar also runs a longer-term Restricted Share Unit Plan tied to financial performance over three vesting periods, not directly linked to sustainability targets. The Board receives fixed compensation only and is not eligible for incentive schemes (pages 28-30).

Reference: page 30

SalMar maps the core elements of due diligence directly onto its ESRS 2 and topical disclosures: embedding due diligence in governance/strategy is addressed under the administrative bodies and incentive-scheme disclosures and ESRS 2 Relation to Strategy and Business Model; engaging affected stakeholders under ESRS 2 Stakeholder Interests and Views and the Process for Assessing Materiality; identifying and assessing negative impacts under the Process for Assessing Materiality and Relation to Strategy and Business Model; taking action under the range of actions and transition plans described in the topical ESRS chapters; and tracking effectiveness under the metrics and targets disclosed in each topical chapter (page 30).

Reference: page 31

SalMar's Head of Sustainability is responsible for conducting the Group's sustainability reporting; targets and metrics are decided by the EMT (for example, biological performance metrics are proposed by the COO of Farming and approved by the EMT). Risks were assessed using the EFRAG Implementation Guidance for the materiality assessment and prioritised by relevance. The Audit and Risk Committee (ARC) monitors the sustainability reporting process, with day-to-day internal control achieved through management and process-owner follow-up and ARC supervision; non-conformances are followed up with corrective measures. SalMar also works with external experts to align its reporting with relevant standards. No significant risks in the sustainability reporting process were identified in the prior period, though an opportunity to improve readability and clarity was identified and incorporated into this year's report. The Board is informed of material internal-control findings as matters arise and at least annually (page 31).

Reference: page 31

SalMar is the world's second-largest salmon producer. In 2025 consolidated harvest volume was 284,500 tonnes, sold to 52 countries, with Europe the main market followed by Asia and North America; total Group revenue was NOK 27,394 million. The Group employed 3,574 people, 95% in Norway and Iceland (Nordics segment), with small sales offices in Japan, Vietnam, Republic of Korea, Thailand, Taiwan and Singapore. An active market ban applies to salmon exports from Europe to Russia and Belarus due to the war in Ukraine. SalMar is not active in fossil fuels, chemical production, controversial weapons or tobacco. SalMar owns and controls every stage of the salmon lifecycle from roe to finished product, and maintains multiple suppliers per input category (technical equipment, vaccines, feed, vessel contracts, packaging) to ensure redundancy and pricing leverage; downstream, distribution partners deliver product via truck, train, boat and plane (pages 31-33).

Reference: page 33

SalMar engages stakeholders through in-person meetings, media outreach, interim/annual reports, stock market notices, R&D initiatives and its website. The workforce is represented via two biennially elected Board representatives (plus two observers), the Work Environment Committee (AMU), and union organisations. The report sets out a stakeholder-engagement table across own workforce, customers/consumers/end-users, suppliers, investors, public policy officials and trade/civil associations, NGOs, and local communities, each with objectives, engagement approach and examples of value created (e.g. supplier audits and improvement plans; investor capital markets days; public consultations with policymakers). SalMar initiated a CSRD Roundtable for industry peers and is a member of the Norwegian Seafood Federation, Norwegian Seafood Council and Norwegian Seafood Association, and engages NTNU and the Blue Center of Competence. There were no significant changes to the stakeholder engagement strategy in 2025, and engagement outcomes are briefed to the Board (pages 33-35).

Reference: page 35

SalMar's material-IRO summary by topic: for E1 Climate Change, principal risks are transitional (carbon taxation, low-carbon transition bottlenecks, stakeholder expectations) and physical (storms, floods, marine-ecosystem disruption including the 2023-24 string jellyfish surge); feed and downstream transport dominate the emissions profile. For E3, feed production carries the largest water/marine IROs, including freshwater dependency for smolt and reliance on wild-stock marine ingredients. For E4, upstream feed-ingredient agriculture and fish escapes/seabed impacts are the main own-operations IROs, alongside a new regulatory framework for aquaculture growth presenting both risk and opportunity. For S1, own-workforce IROs centre on working-environment safety at sea and in processing, and equality/diversity. For S3, positive local-community impact and social-licence considerations are material. For S4, food safety is the dominant IRO. For G1, corporate culture, whistleblower protection, political engagement and corruption/bribery risk are material; fish welfare (ES1) is SalMar's most material topic overall, with mortality, handling, disease and sea lice as principal negative impacts (pages 35-41).

Reference: page 35

SalMar's 2025 DMA update followed the same methodology as prior years, beginning from the topics/sub-topics in ESRS 1 AR 16. The Group again separated Fish Welfare out as an entity-specific topic from G1, judging the standard's animal-welfare sub-topic insufficient to capture its focus. Actual impacts were assessed by scale, scope and severity/irremediability; potential impacts also factored in likelihood; financial risks and opportunities were assessed by scale and likelihood against SalMar's internal risk-management thresholds. Stakeholders (investors, customers, suppliers, financial institutions, regulators, local communities, NGOs, research institutes, subsidiaries and the EMT) rated impact and financial materiality on a 1-5 scale; 34 stakeholders responded in 2025 (up from 31 in 2024), with no regulatory-body responses, so SalMar used proxy answers informed by prior interactions to represent silent stakeholders such as ecosystems and biodiversity. The EMT led decision-making, the ARC reviewed for completeness, and external auditors verified compliance with standards (pages 35-36).

Reference: page 41

SalMar's 2025 DMA added E4 - Biodiversity and Ecosystems and S3 - Affected Communities as newly material topics, alongside the Protection of Whistleblowers and Political Engagement sub-topics within G1; no topic moved from material to non-material. All other 2024 material/non-material classifications were unchanged. SalMar activated ESRS "quick-fix" phase-in options applicable to all companies (it is not eligible for the sub-750-employee phase-in) for E1-9, E3-5, S1-7, S1-13, and the S1-14 sub-datapoints numbered 06 and 07. Separately, under the Appendix C phase-in available following the July 2025 "Quick Fix" amendments, SalMar elected to omit the full E4 and S3 topical chapters and instead summarise the most material information for those two topics under ESRS 2; by contrast, SalMar chose not to use the equivalent phase-in for S4, its second most material topic for both impact and financial materiality, reporting S4 in full against the topical standard instead (pages 41-44).

Reference: page 54

SalMar's transition plan covers Scope 1, 2 and 3 reduction targets and related actions but is not considered fully ESRS-aligned; the Group states it follows E1-1 "except 16. (b), (c), (e), and (j)," lacking a full assessment of investment/operating costs to 2030, and aims to publish an ESRS-aligned plan in 2026. Targets are SBTi-validated and aligned with 1.5°C: 42% reduction in Scope 1+2 and Scope 3 non-FLAG absolute emissions, and 30.3% in Scope 3 FLAG emissions, all from a 2020 base to 2030. Feed (48%) and downstream transport (40%) dominate the gross emissions profile, with Scope 1+2 a small share. SalMar holds sustainability-linked credit facilities of NOK 16 billion tied to core ESG KPIs (GHG intensity, share of local processing, survival rate, feed conversion ratio) and issued four new green bonds totalling NOK 6.35 billion in 2025. Decarbonisation levers are prioritised as: feed supply chain, local processing/downstream transport mode shift, and own-operations electrification/hybridisation. The plan is approved by the Board of Directors and integrated with financial planning; SalMar did not invest significant CapEx in coal, oil or gas activities and is not excluded from EU Paris-aligned benchmarks (pages 54-55, 61-62).

Identification of climate-related risks and scenario analysis

Back-filled from the E1 Climate Change chapter's "Facing Climate Change" resilience assessment, where this content is disclosed in the FY2025 report (pages 67-68). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

SalMar's annual TCFD-aligned risk assessment classifies material climate risks as physical (acute: storms, floods; chronic: marine-ecosystem disruption, e.g. the 2023-24 string jellyfish surge) or transitional (carbon taxation, low-carbon-transition bottlenecks, stakeholder expectations), covering own operations plus upstream and downstream value chain "from roe to plate" (pages 56-57).

Scenarios used (page 68): three pathways were evaluated - an optimistic route aligned with IEA Net Zero Emissions 2050 and RCP 2.6 (high climate mitigation, dominant transition risk); a realistic route aligned with RCP 4.5 (moderate mitigation, physical risk dominant across horizons); and a pessimistic route aligned with RCP 8.5 (business-as-usual, physical risks dominating medium to long term). No explicit global-average-temperature-projection figure is stated for any pathway; the disclosure names scenarios only.

Key assumptions are described only generally, as "recognised and anticipated consequences associated with each level of mitigation" combined with internal impact assessments; no detailed public-policy, macroeconomic or technology assumptions are itemised (page 68). The assessment is annual, and time horizons follow ESRS 2 Basis for Preparation.

Resilience in relation to climate change

Back-filled from the E1 Climate Change chapter's Resilience Assessment, where this content is disclosed in the FY2025 report (page 68). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

SalMar's resilience analysis, run by an internal task force of climate/sustainability experts and EMT members, concludes the pessimistic (RCP 8.5) scenario is a "long-term threat to its business model," and this conclusion "has informed the Group on significant short- and long-term physical and transitional risks" and shaped the established GHG reduction targets, which are stated to be "aligned with the conclusions of the resilience assessment" (page 68).

Uncertainties: technology development, regulatory advancement, and the actual impacts of climate change on biological assets (page 68).

Capacity to adjust: SalMar states its "robust financial position enhances its resilience to external challenges, providing greater flexibility to adapt operations" (SBM-3, page 36), and that it "monitors external factors... to make informed decisions at an early stage" (page 68). The Group does not consider a transition of its product portfolio to alternative proteins material, given salmon's low-carbon-protein positioning. The resilience analysis was refreshed for the 2025 reporting year.

Reference: page 58

SalMar's Climate Change Policy sets Group-wide commitments to align strategy with national/international climate policy and to set short-term and long-term net-zero targets aligned with the Paris Agreement, underpinned by reliable metrics and effective actions; it also defines the operational measures used to address material climate IROs. A second policy, the Deforestation and Responsible Sourcing Policy, requires feed suppliers to deliver only feed certified deforestation- and conversion-free by an accredited third party (ProTerra or Europe Soya) and commits SalMar to full soy traceability to farm of origin, given deforestation's material climate impact. Both policies are referenced throughout the E1 chapter's actions, metrics and targets (share of certified soy, feed conversion ratio, local processing, renewable-energy sourcing) and are published in full on the company website (page 58).

Reference: page 59

Actions are prioritised by SalMar's largest emission sources. In own operations, SalMar is connecting more sea sites to onshore electrical power or hybrid solutions (79% of sites by 2025, up from 72%) and pursuing a long-term fleet transition away from diesel-fuelled workboats. In the value chain, SalMar prioritises local (Norwegian) secondary processing over shipping whole fish - 39% of Norwegian volume in 2025, with a scenario model estimating a 96,243-tonne CO2e saving versus whole-fish transport - and precision feeding (AI-assisted) to cut feed conversion ratio. On feed, SalMar collaborates with suppliers on regenerative agriculture and rotating crops, reducing feed-related emissions 39% since 2020, and requires deforestation- and conversion-free certification. On transport, SalMar has shifted volume from air to sea freight (Icelandic subsidiary approximately 70% by sea) and is adopting enhanced logistics software in 2026 to improve downstream routing decisions. No CapEx quantification is disclosed for these actions against the 2030 target (pages 59-61).

Reference: page 61

SalMar holds three SBTi-validated, 1.5°C-aligned, gross (no removals/credits) absolute GHG reduction targets from a 2020 base to 2030: 42% reduction in Scope 1+2, 42% in Scope 3 non-FLAG, and 30.3% in Scope 3 FLAG emissions (following SBTi's FLAG requirement to split land/agriculture-linked feed emissions from other Scope 3). It also holds GHG-intensity targets on gross production and additional operational targets covering certified soy (100% by policy), feed conversion ratio (bFCR of 1.10 by 2030; 1.13 in 2025), local processing (40% of Norwegian volume by 2030; 39% in 2025), and share of sites with electrical/hybrid power (target: all sites). Targets were set in consultation with internal and external stakeholders and via scenario analysis, concluding the 1.5°C pathway "would be most beneficial for SalMar's business model." SalMar has not yet quantified each action's contribution to the 2030 target but intends to expand on this as part of a planned ESRS-aligned transition plan (pages 61-62).

Reference: page 70

SalMar discloses full ESRS-aligned energy consumption and mix data for 2025 versus 2024. Total energy consumption rose 13.6% year-on-year to 364,577 MWh (320,870 MWh in 2024), while harvest volume grew 22.7%, implying an improvement in energy efficiency per tonne. Fossil energy consumption was 216,662 MWh (59% of total, unchanged share versus 2024), comprising 133,709 MWh from crude oil/petroleum products and 82,953 MWh from purchased fossil-sourced electricity/heat; there is no coal, natural gas or nuclear consumption. Renewable energy consumption was 147,915 MWh (41% of total): 136,314 MWh purchased renewable electricity/heat, 10,202 MWh renewable fuel, and 1,400 MWh self-generated (the new Tjuin smolt-facility solar installation). SalMar reports all its energy consumption and revenue as deriving from a high-climate-impact sector (NACE A3.2), giving an energy intensity of 13.3 MWh per NOK million of revenue (page 71).

Reference: page 63

SalMar reports gross Scope 1, 2 and 3 emissions aligned with ESRS E1 AR 48. Gross Scope 1 was 36,242 tCO2e in 2025 (27,887 in 2024, +30%; 28,689 in base year 2020, +26%). Gross location-based Scope 2 was 2,967 tCO2e (4,377 in 2024, -32%); market-based Scope 2 was 63,488 tCO2e (65,714 in 2024). Total Scope 1+2 (location-based) was 39,209 tCO2e, +22% versus both 2024 and the 2020 base year, against a 2030 target of 18,588 tCO2e (4.2% annual reduction pathway). Total Scope 3 was 1,282,094 tCO2e (+10% vs 2024, -21% vs base year), against a 944,054 tCO2e 2030 target; the largest categories are Category 1 Purchased goods and services (678,111 tCO2e) and Category 4 Upstream transportation and distribution (591,080 tCO2e, under which SalMar classifies downstream salmon transport per GHG Protocol convention). Total GHG emissions (location-based) were 1,321,303 tCO2e, +10% versus 2024. SalMar applies the location-based method for its Scope 2 target and did not use contractual instruments for Scope 2 in 2025 (pages 63-64).

Reference: page 72

Two policies anchor E3. The Water Management Policy commits SalMar to responsible freshwater sourcing, use and discharge that safeguard fish welfare, water quality and ecosystems, applying to hatcheries, processing plants and feed suppliers. For marine ingredients, the Deforestation and Responsible Sourcing Policy requires feed suppliers to purchase fish meal and fish oil certified under MSC, MarinTrust or via credible Fishery Improvement Projects, and to document traceability to country/fishery of origin, reducing pressure on wild fish stocks. A Circular Economy Policy also applies to marine-ingredient offcut recovery. The Supplier Code of Conduct additionally requires suppliers to manage water responsibly and set their own water-reduction targets. All policies are published on the company website (pages 72, 78).

Reference: page 73

SalMar's freshwater actions centre on the shift from flow-through to recirculating aquaculture systems (RAS) in smolt production, which reuses 96-99% of water, and on replacing water-based ice with dry ice for salmon transport cooling, cutting direct water use in logistics. On marine resources, the Feed and Analysis Team works with suppliers to substitute forage-fish-based inputs with trimmings, by-products and novel ingredients (e.g. chicken by-products, salmon hydrolysate), including through the Råvareløftet partnership platform; offcuts are systematically routed to partners such as Nutrimar for conversion into fish oil and fish meal; and SalMar requires certified-fishery sourcing (MSC, MarinTrust, FIPs) and has joined the North Atlantic Pelagic Advocacy Group (NAPA) to support fisheries certification. Upstream, feed suppliers commission external water-risk assessments and run water-stewardship programmes in high-stress regions, guided by the ProTerra Water Management Principles (pages 73-74, 78-79).

Reference: page 75

SalMar holds several water/marine targets. Freshwater withdrawal and discharge: a 20% reduction from 2022 to 2030 (aligned with UN SDG 6.4); 2025 withdrawal was 47 million m3, down 25% from the 63 million m3 2022 base year. Water quality/discharge: zero confirmed non-compliance incidents and wastewater at or below 1000 mg/L Total Dissolved Solids (achieved in 2025, aligned with UN SDG 6.3). Water footprint in feed farming: year-over-year reduction (0.34 m3-eq/kg feed in 2025, down from 0.38 in 2024). Forage Fish Dependency Ratio (FFDR): year-over-year reduction while staying below ASC thresholds (FFDRm below 1.2, FFDRo below 2.52) - 2025 values of 0.45 and 1.26 both increased from 2024 due to lower trimmings availability. Marine-ingredient certification: 100% from certified fisheries or credible FIPs (aligned with UN SDG 14.4; achieved in 2025, up from 98% in 2024). These targets are voluntary, except the mandatory water quality/discharge-permit compliance target (pages 75, 80-81).

Reference: page 75

SalMar reports freshwater withdrawal, discharge and consumption for its own operations. In 2025, freshwater withdrawal was 47 million m3 (50 million in 2024; 63 million in base-year 2022), of which 28 million m3 was surface water and 18 million m3 groundwater; withdrawal intensity fell 44% versus the base year to 123 m3/tonne salmon. Water consumption (water not returned to the environment - incorporated into products, sludge, ice production and personal use) was 99,000 m3 in 2025 (87,000 m3 in 2024), none of it in areas of water risk; water consumption intensity was 3.61 m3/MNOK revenue. Water recycled/reused was 25,443 m3 (27,270 m3 in 2024). No deviations from water-quality or discharge permits were recorded in 2025, and all wastewater met the 1000 mg/L Total Dissolved Solids standard (pages 75-76).

Reference: page 90

SalMar's own-workforce policies comprise the HSE Policy (safe/healthy working environment, accident prevention, roles, training, audits, zero-harm ambition), Human Rights Policy (freedom of association, collective bargaining, social protection, built on the UN Universal Declaration of Human Rights, ILO conventions, the Norwegian Transparency Act and OECD Guidelines), Whistleblowing Policy (24/7 independent reporting channel administered by BDO AS, confidentiality/anonymity, no-retaliation), Non-Discrimination and Equal Opportunities Policy (prohibits discrimination on race, ethnicity, origin, disability, age, gender, sexual orientation, language, religion or other status; grounded in ILO conventions and the Norwegian Equality and Anti-Discrimination Act), and the Remuneration Policy (fixed and variable pay structure for the Board, CEO and Group Management, incentives linked to financial, operational, sustainability and HSE performance) (pages 90, 97).

Reference: page 93

SalMar engages its workforce through daily dialogue with managers, employee representatives and employee-elected Board members (two representatives plus two observers), the Work Environment Committee (AMU, meeting quarterly), and Norwegian unions (Fellesforbundet, NNN, Lederne) and Icelandic unions (VR Union, SGS). The Board convenes at least ten times a year. SalMar states it is not engaged in European Works Council-type agreements, but is covered by worker representatives in all countries with "significant employment" under the ESRS definition. Effectiveness is evaluated qualitatively through employee feedback and daily dialogue rather than formal targets for most actions; remediation follows a case-by-case process, with local management resolving working-environment issues directly and HR (or an independent third party where needed) investigating human-rights, workers'-rights or discrimination matters (pages 92-93).

Reference: page 91

SalMar operates a dedicated whistleblowing channel, available in local languages and English and administered independently by BDO AS, open to reports submitted anonymously or with full identification; all employees are trained on the procedure and protection against retaliation. Reports are handled by a Whistleblowing Committee (chaired by the Director of Human Resource Management, including the HR Director, HSE Lead, Personnel Administration Lead and an external specialist), which investigates and recommends actions to the EMT; closing meetings confirm satisfaction with the resolution before a case is formally closed. Human-rights-related incidents or complaints are investigated and documented, and a case is not considered resolved until corrective/preventive actions have been implemented and validated by affected parties (page 91).

Reference: page 90

Actions address SalMar's material own-workforce IROs. On health and safety (work-related injuries, hazardous conditions), mandatory HSE training, an HSE leadership programme, systematic near-miss follow-up and site-level HSE representatives feeding a quarterly HSE committee contributed to a fall in recordable accidents. On human rights, SalMar conducts risk-based due diligence under OECD Guidelines and the Norwegian Transparency Act and provides mandatory training on child/forced-labour prohibition, harassment, freedom of association and fair wages. On work-life balance and periodic high workload, careful workload planning and clear off-hours expectations are used; on discrimination and harassment, monitoring runs through the EMT, segment leadership and the AMU, informed by Great Place to Work survey results and whistleblowing trends; leading processing-facility personnel received updated Human Rights Policy and gender-based-violence-identification training aligned with SMETA (pages 90-91, 98).

Reference: page 95

SalMar's own-workforce targets include: zero work-related fatalities and a recordable-work-accident (RWA) frequency below 3 per million work hours (2025: 3.5, down from 9.5 in 2024); a sickness-absence rate below 4.5% (2025: 5.3%, down from 6.3% in 2024, still above target); zero human-rights violations and zero discrimination events; and that all entitled employees take family-related leave in a manner suited to their situation (fully achieved in 2025). On diversity, SalMar has not set a quantified female-ratio target but "monitors developments closely to evaluate the effectiveness of ongoing diversity and inclusion actions" (page 101); the workforce female ratio was 27% in both 2025 and 2024, and the EMT female ratio fell from 14% to 13% (pages 95, 100-102).

Reference: page 88

SalMar employed 3,574 people at year-end 2025 (2,622 male, 952 female; 27% female), up from 3,345 in 2024. By segment: Sales & Industry 1,825 (33% female), Fish Farming 1,437 (16% female), Smolt Farming 197 (31% female), Admin 115 (50% female). By country: Norway 3,389 (95%), Iceland 158 (4%), and small numbers across Japan, Republic of Korea, Vietnam, Thailand, Taiwan and Singapore. By contract type: 3,066 full-time, 508 part-time; 2,987 permanent, 334 temporary, 253 non-guaranteed-hours (NGHE). Turnover was 555 departures (17% turnover rate, though this figure covers permanent Norwegian employees plus all Iceland/Asia/Vikenco AS staff, limited by data availability during a 2025 HR-system transition) (page 88).

Reference: page 94

97% of SalMar's workforce is covered by a collective bargaining agreement in 2025 (up from 87% in 2024). Employees not covered are in administrative or management functions with individually negotiated contracts under SalMar's internal remuneration guidelines and applicable national law; employees outside the EEA (sales/admin staff in Asian offices, 0.8% of the workforce) are also on individually negotiated contracts. In Norway, agreements are negotiated with Fellesforbundet, NNN and Lederne; in Iceland, with VR Union and SGS. SalMar states it is not party to European Works Council, SE Works Council or SCE Works Council agreements (pages 93-94).

Reference: page 101

SalMar's workforce female ratio was 27% in 2025 (unchanged from 2024); the Executive Management Team's female ratio was 13% (down from 14% in 2024). The Group cites evidence of a positive correlation between diversity, equity and inclusion and business outcomes, and works to increase female representation through school/university/industry engagement and visible female role models, though it has not set a quantified female-ratio target. The workforce age-interval table (page 88) also reports headcount by age band (below 30, 30-50, above 50) and by country, though the source extraction available did not resolve every cell of that table to a specific value (pages 88, 101).

Reference: page 92

SalMar states all employees receive wages meeting national and internationally recognised benchmarks, covering employees in Norway and Iceland. Wage levels are set primarily through collective agreements between employer organisations and trade unions. In Norway, the two relevant unions have negotiated minimum hourly wages of NOK 226 and NOK 230 depending on line of work; in Iceland, the minimum hourly rate under Icelandic collective agreements is NOK 215. Because all SalMar employees in both countries earn above these statutory/sectoral minimums, the Group states its sick-pay practices (calculated on regular income) align with or exceed adequate-income-protection standards recommended by professional bodies such as the CIPD (page 92).

Reference: page 91

All SalMar employees are covered by insurance mechanisms mitigating income loss during major life events (sickness, employment injury, disability, parental leave, unemployment during active employment, retirement), combining statutory entitlements, collective agreements and company-provided benefits. In Norway, SalMar follows the National Insurance Act, covering 100% of income during the 16-day employer liability period, after which NAV compensates income for up to one year; in Iceland, sick leave and income protection follow national legislation and collective agreements, with full paid sick leave through the employer or union provisions (most commonly VerkVest). SalMar also provides supplementary treatment insurance offering fast access to medical services, including online mental-health support (page 92).

Reference: page 95

SalMar targets zero work-related fatalities and a recordable-work-accident (RWA) frequency below 3 per million work hours. In 2025, recordable work-related accidents among own employees fell to 20 (49 in 2024), with a frequency of 3.5 (9.5 in 2024); subcontractor accidents were 5 (8 in 2024). There were zero fatalities among own employees and subcontractors in both years. Days lost to work-related injuries fell sharply to 186 (1,115 in 2024). 100% of the workforce is covered by a health and safety management system. Note: SalMar activated the ESRS phase-in for the S1-14 sub-datapoints numbered 06 and 07 (page 27), so two of the standard's prescribed granular datapoints are not disclosed even though the core metrics above are reported in full (page 95).

Reference: page 101

SalMar measures family-related leave (maternity, paternity, parental and carer's leave): in 2025, women took an average of 16.4 weeks and men 12.6 weeks, and the Group states all entitled employees took their family-related leave in accordance with national legislation. The target is not a numeric quota but that leave is taken "in a way that is suitable to each family's situation." SalMar also separately reports its 2025 sickness absence rate of 5.3% (target: below 4.5%; 6.3% in 2024) as part of its work-life-balance/periodic-high-workload metrics (page 101).

Reference: page 102

SalMar's 2025 gender pay gap (pay equality) was 94%, up from 87% in 2024, though the two years are not directly comparable since the 2024 figure included all remuneration while 2025 is based on base salary only, following a 2025 HR-system transition that also prevented deriving a true median salary (average salary used as proxy). The CEO/highest-to-average pay ratio was 11 in 2025 (12 in 2024). The gender pay gap covers employees in SalMar's wholly owned entities (SalMar ASA, SalMar AS, SalMar Farming AS, SalMar Settefisk); Icelandic Salmon and Vikenco AS salary data is excluded for GDPR and materiality reasons. SalMar publishes a fuller remuneration report under the Norwegian Equality and Anti-Discrimination Act's Activity and Duty to Issue a Statement requirements (page 102).

Reference: page 94

SalMar's whistleblowing-based metric recorded 34 total reports in 2025 (28 in 2024), by category: 17 discrimination/harassment (14 in 2024), 9 compliance-standard breaches (3 in 2024), 7 working-environment issues (10 in 2024), and 1 health and safety report (unchanged). Zero complaints were filed to National Contact Points for OECD Multinational Enterprises in either year. SalMar identified no incidents of human-rights breaches within its workforce in 2025, nor in its latest annual value-chain assessment, and paid no fines, penalties or compensation for discrimination, harassment or severe human-rights impacts (page 94).

Reference: page 105

SalMar's consumer-facing policy framework centres on the Food Safety Policy, covering all food-safety-related activities across the value chain, with implementation accountability held by the Director of Quality and HSE under overall CEO responsibility for policy operationalisation. Food safety commitments include regular internal/external audits, supplier pre-screening, and strict internal/partner procedures; all SalMar sites are certified under Global Food Safety Initiative (GFSI)-recognised standards, and food-safety-related suppliers must also hold GFSI certification. The Human Rights Policy is also invoked for consumers, covering the rights to health and safety, information, customer protection (fair marketing, no misleading claims) and participation (feedback channels), aligned with the UN Guiding Principles on Business and Human Rights and OECD Guidelines (pages 104-105).

Reference: page 107

SalMar has limited direct interaction with consumers/end-users, selling primarily to retailers, restaurants and exporters rather than direct to consumer; its business model combines spot sales with fixed contracts for demand/supply predictability. Engagement with customers, who represent consumer/end-user interests as well as their own, happens through daily interactions, phone, chat, email and in-person meetings, aimed at understanding needs and market perception. SalMar also provides a public grievance mechanism on its website allowing consumers/end-users to submit feedback or raise issues, including anonymously. The Chief Operating Officer of Sales and Industry holds operational responsibility for these engagements, with effectiveness measured through the strength and longevity of customer relationships (pages 107-108).

Reference: page 107

If consumers/end-users face risk of severe negative impact from a SalMar product, the product is recalled; the Group states such instances are "extremely rare" given multiple validation checkpoints in production. All claims and recalls are handled case-by-case by the Quality Department, with the Director of Quality and HSE responsible for ensuring appropriate handling and documentation; the recall system comprises a dedicated customer-facing email address and direct sales-team contact points. Issues are tracked and reviewed in leadership meetings at least quarterly, with root-cause identification prioritised; effectiveness is measured through response rates and outstanding-inquiry counts. In a recall, SalMar works with customers on monetary compensation or guidance (pages 107-108).

Reference: page 105

SalMar manages food-safety risk across allergen, biological, chemical and physical hazard categories, using HACCP-based risk assessments, a VACCP framework for food-fraud vulnerability and a TACCP framework for food-defence/deliberate-contamination threats. All products are tested to ensure absence of allergens beyond fish; the Institute of Marine Research's annual monitoring programme ran roughly 30,000 tests for illegal/undesirable substances with no breaches of EU limits identified. SalMar holds IFS and BRCGS certifications (GFSI-recognised), is SEDEX-registered and has completed a SMETA social-compliance audit, and its facilities are inspected by the Norwegian Food Safety Authority (NFSA) and Icelandic Food and Veterinary Authority (MAST). The Group cites a Norwegian Scientific Committee for Food and Environment (VKM) conclusion that the health benefits of fish consumption outweigh contaminant risks across all age groups (pages 105-107).

Reference: page 108

SalMar targets zero incidents of compromised consumer health (achieved in 2025: zero adverse health impacts, zero food-safety recalls, zero human-rights incidents related to consumers, unchanged from 2024); at least one internal food-safety audit annually at all facilities plus external audits per certification-scheme requirements (235 internal audits in 2025 versus 174 in 2024; 214 external audits versus 287, the reduction reflecting increased use of multisite audits); and a 100% corrective-action completion rate within 30 days (achieved in both 2025 and 2024, with no violations of corrective-action deadlines) (pages 108-109).

Reference: page 111

SalMar's Ethical Guidelines are the foundational business-conduct policy, covering acceptable/lawful behaviour, conflicts of interest, bribery/corruption (within the organisation and with business partners/authorities), and the process for reporting and investigating unlawful behaviour via the public whistleblowing channel. All new employees confirm they have read and understood the Guidelines during onboarding, and must repeat this if the Guidelines are updated. Corporate culture, built around the "Passion for Salmon" vision, is measured through the Group's ability to achieve its goals and maintain a "dedicated, happy and involved workforce," evaluated in leadership meetings; SalMar flags rapid growth from recent acquisitions as a risk to maintaining this culture, addressed through cultural-integration and training actions described under S1 (pages 110-111, 98).

Reference: page 112

SalMar's Anti-Corruption and Bribery Policy (aligned with the UN Convention against Corruption) and Anti-Competitive Behaviour Policy govern corruption/bribery/competition risk, alongside a Supplier Code of Conduct requiring zero tolerance for corruption, money laundering, competition-law breaches and sanctions violations among suppliers. Employees with significant influence (EMT) or high external exposure (sales staff) are considered highest-risk. Controls include a "four-eyes" invoice-approval process (manager approval for all invoices, EMT approval above a threshold) under SalMar's Delegation of Authority Matrix, independent HR-led investigations for suspected breaches, and escalation of allegations to the EMT and Board. SalMar is involved in an ongoing case concerning allegations of price collusion in the Norwegian aquaculture industry, detailed in Note 4.9 to the Financial Statements (pages 112-113).

Targets related to business conduct

Renumbered from the 2023 ESRS's MDR-T (Minimum Disclosure Requirements for Targets), where this content is disclosed in the FY2025 report (pages 111-116). G1-3 became a standalone disclosure requirement only in the 2025/2026 ESRS.

SalMar sets a small number of concrete business-conduct targets: zero incidents of corruption and bribery every year (achieved in 2025 and 2024 - zero confirmed incidents, breaches, convictions or fines in both years), and full training coverage of at-risk functions (EMT and salespeople) in identifying/mitigating corruption and bribery risk, though "SalMar has not conducted targeted training for at-risk functions during the past two years," relying instead on prior training being deemed sufficient (page 114).

Consistent with MDR-T's alternative limb, effectiveness is tracked in the absence of a target for political engagement: SalMar states no specific target exists for its Political Contributions metric, but "seeks to contribute to a fact-based dialogue concerning the aquaculture industry," and tracks membership fees to the Norwegian Seafood Federation and Fisheries Iceland (NOK 6 million in both 2025 and 2024) (page 116). SalMar made no political-party contributions in 2025.

Reference: page 114

SalMar recorded zero confirmed incidents of corruption or bribery by the Group or its employees in both 2025 and 2024, zero breaches of anti-corruption/bribery procedures or standards, zero convictions, and zero fines paid for corruption/bribery-law violations. The Group's supply-chain due-diligence processes also did not reveal any incidents of corruption or bribery in the supply chain. Share of at-risk functions (EMT, salespeople) formally trained was not separately quantified for 2025, as "SalMar has not conducted targeted training for at-risk functions during the past two years" (page 114).

Reference: page 115

Political Engagement became material for SalMar for the first time in the 2025 DMA (page 42). SalMar's Political Involvement Policy states the Group is "politically independent" and "not connected to or endorses any political party or individual politicians in any country," while openly contributing to public debate on industry-relevant topics, typically through statements by the Chair of the Board or the CEO. SalMar actively participates in industry organisations in Norway and Iceland (membership fees and board seats) to advocate aquaculture-industry interests, including ongoing engagement with policymakers on a new Norwegian aquaculture regulatory framework. SalMar is not listed in the EU's Transparency Register, stating it does not carry out formal EU lobbying or organised interest-representation activities, and confirms no new appointee to its administrative/management/supervisory bodies held a comparable public-administration role in the two years preceding appointment (pages 114-116).

Reference: page 223

SalMar distinguishes payment terms under its Supply Chain Financing (SCF) arrangement from standard trade payables. At 31 December 2025, liabilities under the SCF arrangement (with feed suppliers) totalled NOK 2,534 million (NOK 2,208 million in 2024), of which NOK 2,506 million represented amounts where suppliers had already received early payment via the bank. SCF payment due dates ranged approximately 101-105 days after invoice, compared with 27-42 days for trade payables outside the arrangement (consistent across 2025 and 2024); SCF terms with feed suppliers typically fall within 90-120 days, in line with industry practice. Separately, the Group's trade payables are "normally at net 30 payment terms, except for payables related to the purchase of feed, which has a longer credit time" (Financial Statements, Note 3.11).