Solstad Offshore

Composition and Diversity

The Board of Directors of SOFF comprises five members, with a gender distribution of three men (60%) and two women (40%). Currently, the Board does not include other diversity aspects or employee representatives. Of the five members, three are independent (60%). The Audit Committee includes three Board Members. Audit Committee Meetings includes Management representation through the CFO, Sustainability Director and relevant members from the Finance and Accounting departments.

The Board of Directors members have a broad experience from the business sectors Solstad operates in, such as the global energy sector, finance, and international shipping. Additionally, one of the Audit Committee Members have previous experience as the Sustainability Lead in a major shipping company. A summary of the Board Members' relevant experience can be found at Board of Directors of Solstad.

The Executive Management team consists of four members: the CEO, CFO, COO and CCO. All members are men (0% female). There are no non-executive members represented (directors that do not engage in the day-to-day operations of the company).

Roles and Responsibilities

The Board of Directors has the ultimate responsibility for monitoring, assessing, and managing Solstad's strategy, impacts, risks, and opportunities related to sustainability. The Board's Audit Committee oversees sustainability matters and reporting, in addition to financial reporting. During regular meetings, the committee reviews action plans, targets and results related to sustainability, such as Solstad's identified material impacts, risks and opportunities. The Sustainability Director provides updates on these initiatives, ensuring progress in mitigating adverse impacts and risks, and capitalizing on opportunities within relevant sustainability matters, is continuously addressed. Additionally, a Sustainability Committee has been established by the Administration, consisting of both executive and administrative members.

The Sustainability Director has the ongoing responsibility for overseeing all sustainability initiatives, ensuring that our organization remains committed to its environmental, governance and social targets. The Sustainability Director reports to the COO, who then reports to the CEO. This structure ensures that progress on sustainability matters is monitored and addressed at the appropriate management level. The Board reviews Solstad's strategy, plan, and status for achieving long-term sustainability goals at least annually.

Developing the Appropriate Skills and Expertise on Sustainability Matters

Developing and maintaining the appropriate skills and expertise on sustainability topics, as well as addressing the company's impacts, risks, and opportunities, is crucial to the Board and Executive Management's ability to oversee Solstad's sustainability matters effectively. To ensure that they have the necessary competency in relevant areas, Solstad uses a company competency matrix that outlines key skills. To fill any competency gaps, and stay updated on new regulations and requirements, a combination of external and internal training is provided throughout the year. This training includes external CSRD courses for managers and key personnel involved in preparing the sustainability statement. Mandatory completion of sustainability-related courses for key personnel is monitored though relevant KPIs. For sustainability-related topics, courses such as ISO14001 and ISO50001 are required for sustainability professionals, thus enhancing internal competency and expertise available to the Board and Executive Management.

Additionally, the Executive Management and Board of Directors can access extensive expertise on sustainability matters through external consultants and auditors, including those from EY, Deloitte, and DNV.

Solstad's Sustainability Committee is mandated to discuss sustainability issues, including material impacts, risks and opportunities, and to oversee the implementation of measures to address these issues. The committee comprises the CEO, CFO, COO, Sustainability Director, Communications and Administration Director, and a Sustainability Advisor. They meets quarterly to discuss impacts, risks and opportunities and related policies, actions and targets. Insights and proposed follow-up actions (including updates to the DMA assessment) are presented to the Audit Committee, and, when necessary, the full Board.

This process and a dedicated Sustainability Committee ensures that both the Board and Executive Management are consistently updated on the company's sustainability efforts. Given the diverse representation within the committee, including members from finance and top management, key sustainability impacts, risks and opportunities can be discussed and addressed efficiently.

The Audit Committee has the authority to approve the list of material topics and impacts, risks and opportunities., which is presented for approval annually, after first being reviewed by the Sustainability Committee.

The Executive management, in collaboration with the Board of Directors, will annually review the company's strategy. The strategy includes impacts, risks and opportunities related to sustainability matters such as Climate Change mitigation. Any significant changes to the strategy or major planned transactions will undergo a company risk evaluation using a high-level risk matrix, considering potential trade-offs between impacts, risks and/or opportunities. Throughout this process, relevant stakeholders, including key suppliers and clients from the value chain, will be consulted to ensure that the new strategy is both realistic and achievable.

The company has implemented a performance-based incentive scheme for Key Management personnel, which is detailed in the renumeration report. This scheme aligns with the company's strategic goals and priorities, although it does not currently include specific sustainability-related targets. The Board of Directors reviews and approves the incentive schemes for the Executive Management team on an annual basis.

Annually, the company carries out two due diligence processes encompassing sustainability matters. Firstly, in accordance with the Norwegian Transparency Act, Solstad asses human rights and decent working conditions within its global supply chain and its own operations. This assessment results in a due diligence statement, signed by the CEO and the Chairman of the Board, which is published on the company's website. Secondly, a due diligence process is performed in accordance with the ISO 14001 certification. All identified environmental impacts and relevant new regulations affecting the company's operations are evaluated and documented in Solstad's SIMS management system, with DNV serving as the supervisory body for this process.

The responsibility over the Sustainability reporting lies with the Sustainability department. This includes also the DMA process. However the sustainability data comes from a variety of operational systems and departments.

Key Sustainability data reporting such as environmental data is collected and reported by the Sustainability department. Data collection is supported by advanced software systems used on the vessels by the crew and in the offices to ensure high data quality on a daily basis. Other sustainability data such as safety statistics is managed by the HSEQ department on a daily basis and reported monthly. Key systems here are the «HSE» database and the «Daily Report» systems. For HR (S1) related data the onshore HR Administration department and the Crewing department uses «OCS HR» for data handling and reporting. Value chain reporting is primarily done by use of the purchasing system «TM». Governance reporting such as whistle blower data is handled through a dedicated external platform, but by Solstad personnel.

Excel spreadsheets controlled by the Sustainability department is used to consolidate all data and transfer controlled data to the company annual reports. Over the past year we have tried to utilize newly developed CSRD reporting tools, but with limited success, hence we are still in the process to see how we can optimize, improve and reduce risk for errors in the reporting process.

All implemented systems and reporting processes are linked to the Solstad Integrated Management System (SIMS). This is designed to manage and support all requirements within the business including sustainability reporting. It is designed in modules for ease of access and increased functionality, and accessible to all employees both onshore and offshore. SIMS is manged by the HSEQ department, and all documentation is approved by the CEO, with delegation to the HSEQ Director as necessary.

The company's top six policies are signed by the CEO and published on all office and vessel locations worldwide. Each department director is responsible for creating and updating processes or revisions, which are subsequently approved by the HSEQ Director on behalf of the CEO. The objectives of the SIMS platform are:

1. To outline the Companies Policies
2. To outline the Companies Processes
3. To outline all employee's roles and responsibilities in the company based on position in the organization
4. To describe the Companies Organisational Structure
5. To form a robust document control platform in which to manage all necessary documentation, tools and systems for the smooth and efficient management of the SOFF operations
6. To form a database for HSEQ activities where the quality cycle is carried out to ensure all information is on the one integrated platform
7. To enable and promote "best practice" in order to demonstrate operational excellence
8. To ensure compliance to legislative and internationally recognised standards is achieved and monitored
9. To provide a platform to recognize and capture areas for continuous improvement including setting KPI's with goals and targets
10. To strive to achieve deliverables above and beyond the expectations of the standards we have certification

Business Model

Solstad Offshore ASA is a publicly traded company based in Norway, governed by Norwegian laws and regulations. The Company owns, constructs, leases and operates offshore vessels. Its shipping certification is issued by DNV on behalf of the Norwegian Maritime Authority, as well as other local ship certification bodies in regions where local flags are needed, such as Brazil's Maritime Authority and the Isle of Man (UK) flag.

Solstad Offshore in cooperation with Solstad Maritime Holding operates a diversified fleet of high-end offshore vessels primarily for the energy sector. The business model focuses on providing tailored marine solutions and leveraging expertise in offshore operations. Despite the relatively high average age of its vessels, Solstad fleet remains one of the most high-end in the global offshore segment.

The company provides a range of services, including chartering, staffing, and technical maintenance, through its worldwide offices. Solstad Offshore's core activity is to offer high end offshore vessels manned by highly skilled marine crews, delivering a wide array of services to the offshore and renewables industries. Solstad's fleet consists of Construction Service Vessels (CSV) and Anchor Handling Tug Supply vessels (AHTS), with the majority of revenue coming from the Oil & Gas sector. The fleet operating globally, is well-regarded for its considerable role in international offshore operations.

In 2023, the company undertook a strategic sale of its Platform Supply Vessel (PSV) fleet. This move impacted emissions (reduction), number of employees, supply chain, and various key performance indicators (KPIs). On January 16, 2024, the company was split into two entities. The new holding company, Solstad Maritime Holding AS (SMH), acquired the majority of assets (31 vessels) and the bulk of employees (around 1,555), with SOFF retaining a 27% ownership in SMH. Consequently, this sustainability report pertains only to SOFF, which now retains 6 owned and 7 leased vessels employing and around 569 FTE's.

To expand beyond vessel rental services, a new "Services" business unit was recently established. This unit offers clients a broad array of additional services, including ROV services, tooling rentals, and both onshore and offshore personnel.

Value Chain

As a global offshore vessel operator, Solstad's value chain is extensive and multifaceted. In the upstream value chain, the company focuses on sourcing high-quality inputs to deliver specialized marine solutions tailored for the energy sector. Solstad's own operations are focused on achieving operational excellence through effective vessel management, comprehensive crew training and reliable maintenance services. Downstream activities include the various operations of Solstad's clients in the oil & gas industry as well as the renewable energy sector, and the end-of-life ship recycling.

Solstad does not source or use raw materials directly in its value chain. The majority of outflows (such as segregated operational waste) is delivered for recycling whenever possible worldwide. Outflows from vessel recycling, such as steel, copper, and reusable parts, are processed at facilities such as Green Yard in Norway, with steel often sold to Norwegian steel smelters.

Solstad's headquarters is in Norway, but Brazil currently has the highest activity. The Brazilian market, led by local energy companies like Petrobras, requires high local content in contracts. Most goods and services for Brazil operations come from local suppliers. For global vessel operations, most supplies come from Norway or hubs like Singapore or the Netherlands, except for fuel and fresh food.

Organisational Principles

SOFF uses a matrix organizational structure to facilitate horizontal operational information flow and knowledge sharing on a daily basis. This allows Management to create functional teams while maintaining cohesive disciplines and departments.

Daily operations of the SOFF fleet of owned and leased vessels, including crewing services, continue to be managed by the Solstad Maritime Holding Holding AS. SMH owns the onshore fleet management system and most of the onshore organisation, excluding Brazil. However, SOFF rents all onshore management services from SMH for its vessels, except for local support in Brazil. The IMO ISM certificate needed to operate its ships is owned by SMH, but used by SOFF to operate vessels.

Solstad's employees are hired through the regional offices around the world. For SOFF the offices are in Brazil. SOFF is supported by SMH that have offices in Norway (HQ), Singapore, the Philippines, Australia and UK.

Sector Classification

As a global offshore vessel operator in the energy sector, the company primarily operates in the "Mining - Oil & Gas - Upstream & Services (MOU)" and the "Energy - Energy Production & Utilities (EEU)" sectors.

The company is not involved in chemicals production, controversial weapons or cultivation and production of tobacco.

EU Taxonomy Alignment

Key Stakeholders and Engagement

Solstad maintains an overview of the company's Interested Parties (key internal and external stakeholders) in the Solstad Integrated Management System. The stakeholder lists includes the categories of stakeholders, the types of engagement the company maintains with them and the stakeholders' needs and expectations and provide valuable input to the continuous development of Solstad's strategy and refinement of our business model. The lists are subject to continuous review (and at least annually), influenced by the company's strategy and business model, reflecting our understanding of the business context Solstad operates in.

In daily operations, the Integrated Management system ensures that stakeholder interests are effectively addressed, by highlighting relevant stakeholder-associated risks, opportunities and impacts associated with these operations. The Management Review and stakeholder reviews are managed by the Executive Management team with assistance from the respective department directors (HR Director, HSEQ Director etc.). The final report is approved by the CEO and published to all employees.

Recognizing and addressing the needs and expectations of our stakeholders is fundamental to the effective execution of our operations. Such acknowledgment is crucial for Solstad to adequately manage risks, ensure compliance and achieve our strategic operations. This approach not only fosters trust and collaboration with stakeholders but also enhances the company's ability to anticipate challenges and capitalize on opportunities.

To ensure essential input from the various stakeholders and actors in the value chain, management and/or contract meetings are regularly held, typically on an annual basis. The company's annually prepared "Management Review" document summarises input from these stakeholders and provides metrics, goals and action plans per department. This document is published to all employees during the first quarter every year.

Supply Chain Overview

During the reporting period, the company had about 1,500 suppliers in the upstream value chain. Below is an overview of key stakeholders, their contributions, and the contractual relationships that govern how the company gathers and secures essential inputs.

The company's strategic decisions include primarily employing its own staff rather than relying on contracted labour, addressing concerns about poor working conditions in the temp industry and respecting employees and union interests. Employee health and safety are prioritized in the strategy to align with stakeholder interests.

Solstad has identified the following Sustainability matters to be material (see details on policies, actions, metrics and timebound targets in the table 8 page 43 and ESRS 2 SBM-3 page 44 and 45).

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

Process Overview

The processes for identifying and assessing material impacts, risks, and opportunities are integral to Solstad's daily operations and are formally embedded within the Integrated Management System especially the annual Management Review process. This internal control system clearly outlines the processes, methodologies, roles, and responsibilities associated with these activities.

Solstad's material impacts, risks and opportunities are also identified and evaluated through a structured double materiality assessment, which considers both how our activities impact people and the planet (impact materiality) and how people and the planet affect Solstad's business (financial materiality). The double materiality assessment was carried out in five steps:

1. Mapping and initial steps
2. Stakeholder engagement and use of external experts and systems
3. Detailed evaluation and stakeholder validation
4. Prioritization of material matters
5. Monitoring and internal control

Step-by-Step Methodology

1. Mapping and Initial Steps

The double materiality assessment begins with a comprehensive mapping of our activities, business relationships, and affected stakeholders. Following this, a long list of sustainability topics related to Solstad either through our own operations or through Solstad´s business relationships was created. This mapping ensures a clear understanding of the context in which the double materiality assessment is conducted.

Solstad has meticulously mapped, and maintains, an overview of Interested Parties—key internal and external stakeholders whose needs and expectations can significantly influence our organizational sustainability if not adequately addressed. The following stakeholder categories were considered to be most relevant:

• Affected stakeholders: employees/unions, customers, suppliers, local communities and society/nature as a silent stakeholder.
• Users of the sustainability report: customers, suppliers, investors, governments and NGOs.

Solstad's generic product categories used in the analysis were:

• Marine gasoil fuelled ship freight transport services for construction of offshore oil rigs
• Offshore rig moving services
• Marine gasoil fuelled ship freight transport services for construction of offshore wind power plants
• Hybrid engine ship freight transport services for construction of offshore oil rigs
• Hybrid engine ship freight transport services for construction of offshore wind power plants
• Fleet management services for the oil and gas industry

Financial risks and opportunities categories analysed: Revenue, Cost of capital and Operative costs

2. Stakeholder Engagement and External Experts

A critical component of the double materiality assessment is engaging with representatives of potentially affected stakeholder groups through surveys and interviews. This engagement provides essential input for the assessment process. The identification of impacts, risks and opportunities related to our operations and value chain (both upstream and downstream) has been a thorough effort, where stakeholders have been asked through digital surveys to score how they view Solstad's impacts, risks and opportunities according to our thresholds. In addition, meetings have been arranged with key suppliers and clients to exchange relevant input for both parties participating.

Stakeholder engagement overview:

To strengthen the double materiality assessment process, a science-based analysis has been used where we have employed the data engine from Upright, a recognized impact data company. This tool integrates input from multiple data sources, including company-specific data points, a wide selection of scientific articles, public databases and stakeholder surveys, to generate preliminary results for the double materiality assessment. This "top-down approach" serves as the starting point for our detailed evaluation. Upright's software also provides a methodology to calibrate and prioritize between the different IROs.

3. Detailed Evaluation and Stakeholder Validation

Based on the initial results, the identified impacts, risks and opportunities were further evaluated internally in the CSRD implementation team and compared to relevant industry standards to ensure alignment on critical issues within the shipping sector. Subsequently, sustainability thresholds were set to prioritize the most significant issues, focusing on areas where Solstad can make the most substantial impact. A company-specific calibration ensures that the identified sustainability matters remain pertinent to Solstad's distinct circumstances. The next step involved discussions with the company's auditors to refine the process outcome.

Finally, the IRO's were discussed and agreed upon in the company's Sustainability committee and later presented to the Audit Committee.

The double materiality assessment process will be subject to continuous improvement, adapting to internal and external changes such as regulatory updates, new data, and stakeholder feedback.

4. Prioritization of Material Matters

Material topics were prioritized based on their threshold values and Solstad's internal assessment of their relative importance. The highest priorities were given to sustainability-related risks, following the same principles used for other risk assessments at Solstad.

The materiality level thresholds are based on Uprights' database comprising more than 50,000 companies and their materiality results. Scale, scope, irremediability and likelihood have all been assessed on the basis of levels from 1-3, defined as low, medium and high. Impact materiality is calculated for each of the identified IROs by multiplying the scores given to the scale, scope, irremediability and likelihood of the impact, where minimum impact would be 1 and maximum impact would be 81.

Financial materiality is calculated for each risk and opportunity by multiplying magnitude and probability.

Solstad used its standard risk matrix that includes sustainability-specific consequences to form the basis of initial and residual financial risk values for risk and opportunities. A 5x5 risk matrix is used that defines the financial impacts categorized from A (low=no cost) in steps to E (Very high > USD 1 000 000) outcome/consequences.

Materiality thresholds:

Where the materiality score is medium or high, the sustainability matter is considered material. The quantitative thresholds are calibrated annually to determine how sensitively material matters should be triggered to achieve a sensible amount of sustainability matters.

One example of a topic that was prioritized to be more material than the initial scoring indicated was "Corruption and bribery" ("Prevention and detection including training" and "Incidents"). The calculated materiality score was below the medium threshold for both Financial and Impact materiality, but through the company-specific adjustment it was placed in the medium category. Reason being that Corruption and Bribery incidents is both considered high risk and potentially high impact for the company. International shipping and operation in countries high on the public anti-corruption and bribery Index ratings is a generic risk (i.e. Brazil and other countries). It is therefore considered to be one of Solstad's material topics.

5. Monitoring and Internal Control

The sustainability committee assists management and the Board (via the audit committee) in monitoring the performance and key impacts, risks and opportunities the company faces in relation to sustainability matters. The sustainability committee oversee the processes and systems connected to Solstad's sustainability policies and other corporate requirements on the subject.

The sustainability committee:

• Review sustainability related policies, strategy, budgets and plans.
• Evaluate sustainability risk issues.
• Evaluate and agree on Solstad's double materiality assessment.
• Report status to the Audit Committee and compile annual Sustainability statement.

The company has policies and processes in place to ensure that agreed Sustainability related plans, projects and reports are executed and followed up on a daily basis.

The company made a detailed mapping of operations, geographies, business connections and stakeholders in the process of identifying the company's impacts, risks and opportunities. A representative sample of stakeholders was consulted, providing valuable insights on sustainability issues. Additionally, impact data from scientific sources have been used to provide further context to the assessment.

Inputs to the Assessment

• ESRS guidance: The assessment followed ESRS requirements and sector guidance
• Sector benchmarks: Industry standards for shipping sector were reviewed
• Scientific sources: Impact data from scientific articles, public databases
• External consultants: Upright data engine (impact data company) providing science-based analysis from over 50,000 companies
• Internal experts: CSRD implementation team, Sustainability Committee, Executive Management
• Stakeholder consultation: Digital surveys and interviews with key clients, suppliers, unions, employees, banks/investors, NGO's/regulators (62 survey responses total)
• Value chain mapping: Detailed mapping of operations, geographies, business connections and stakeholders across upstream and downstream value chain

Scoring Criteria

Impact Materiality

Dimensions assessed:

• Scale (levels 1-3: low, medium, high)
• Scope (levels 1-3: low, medium, high)
• Irremediable character (levels 1-3: low, medium, high)
• Likelihood (levels 1-3: low, medium, high)

Calculation: Impact materiality score = Scale × Scope × Irremediability × Likelihood (minimum score = 1, maximum score = 81)

Financial Materiality (for risks and opportunities)

Dimensions assessed:

• Magnitude/Size of effect (5x5 risk matrix with categories A-E, where A = low/no cost to E = Very high > USD 1,000,000)
• Probability/Likelihood

Calculation: Financial materiality score = Magnitude × Probability

Threshold for Materiality

Impact materiality:

• Low: <37
• Medium: 37-50
• High: >50

Financial materiality:

• Low: <15
• Medium: 15-40
• High: >40

Where the materiality score is medium or high, the sustainability matter is considered material.

Frequency / When Last Reviewed

The double materiality assessment was conducted in 2024 (this is the first full CSRD report).

The materiality assessment is reviewed annually. The Audit Committee has the authority to approve the list of material topics and impacts, risks and opportunities, which is presented for approval annually, after first being reviewed by the Sustainability Committee.

The quantitative thresholds are calibrated annually to determine how sensitively material matters should be triggered to achieve a sensible amount of sustainability matters.

Use of Value Chain Mapping

The company made a detailed mapping of operations, geographies, business connections and stakeholders in the process of identifying the company's impacts, risks and opportunities.

The company's value chain is extensive and multifaceted. In the upstream value chain, the company focuses on sourcing high-quality inputs to deliver specialized marine solutions tailored for the energy sector. Solstad's own operations are focused on achieving operational excellence through effective vessel management, comprehensive crew training and reliable maintenance services. Downstream activities include the various operations of Solstad's clients in the oil & gas industry as well as the renewable energy sector, and the end-of-life ship recycling.

During the reporting period, the company had about 1,500 suppliers in the upstream value chain.

The scope of the assessment encompasses all workers in the value chain that are likely to be materially affected by operations, both in upstream and downstream activities.

Material Topics Identified

Through the double materiality assessment process the company has concluded that the following ESRS' are material:

Material topics:

• E1 Climate change - Climate change mitigation, Climate change adaptation, Energy
• E2 Pollution - Pollution to air
• E4 Biodiversity and ecosystems - Invasive alien species
• S1 Own workforce - Health and safety, Gender equality and equal pay for work of equal value
• S2 Workers in the value chain - Adequate wages, Health and safety
• G1 Business conduct - Prevention and detection including training, Incidents

Non-material ESRS:

• ESRS E3: Water and marine resources - impact on water and marine resources considered minor
• ESRS E5: Resource use and circular economy - no vessels recycled in reporting period
• ESRS S3: Affected communities - impacts not considered material
• ESRS S4: Consumers and end-users - IROs not considered material for reporting

Determining Material Information

It is the company's judgement that all the mandatory material disclosure requirements under the relevant topical standards have been addressed in accordance with the principles set out in ESRS 1 section 3-2 Material matters and materiality of information. Thresholds for materiality, as previously described, were applied to assess which IROs are material for reporting, thereby guiding which disclosure requirements were applicable under the topical ESRS standards. Phase-in provisions have been applied to certain disclosure requirements in topical standards, to concentrate reporting efforts towards the most pressing sustainability matters in the first year of CSRD reporting, with the goal of gradually improving of the quality of the CSRD report.

Transition plan for climate change mitigation

Status of transition plan

Solstad aims to be a key player in the energy transition and continuously explore and create business opportunities that align with our commitment to sustainability. As a major player in the offshore energy industry, we recognise the challenges we face as a global society and our role in both creating and solving them. We are aware that the increasing global temperatures and aim to take considerable actions to reduce emissions from our operations. However, at this point the company has not developed a CSRD compliant Transition plan.

The company is currently in a transitional period, operating 13 vessels (6 owned and 7 on lease from SMH) and a 50% owned JV vessel) out of the previously 39-vessel fleet after January 16 in the reporting year.

Solstad is detailing a transition plan for climate change mitigation, estimated to be completed, adopted and approved by the Management by end of 2027. The main work in this process will take place in the second half of 2027.

Target year for net zero

Since 2010, Solstad has publicly reported all vessel GHG emissions to maintain transparency. We are committed to a global long-term net-zero target for 2050, aligned with the goal of limiting of global warming to 1.5C. However, we have yet to defined a detailed transition plan for the company.

Scope of the plan

All actions apply to Solstad's fleet of owned and leased vessels, ensuring that climate mitigating and adapting measures are implemented in their operations. All vessels are on Time/Chart contract to our customers and under operational control by Solstad's customers, the scope of actions will also extend downstream in the value chain where feasible.

Key decarbonisation levers

Solstad has been working on various decarbonisation actions since 2010, with several new initiatives underway. In the detailing of a Transition plan, Solstad has identified key decarbonisation measures expected to be included:

• Operational measures: Solstad Green Operations® (SOFF spesific campaign since 2010/operational measures done daily on vessels to reduce emissions)
• Existing technology/retrofit: Battery hybrid and shore power systems
• Drop in bio-fuels on existing and new build vessels: HVO (or FAME)
• Fleet renewal: Adapted to use new low emission technologies and fuels:
  • New technology: Dual fuel internal combustion engines and/or fuel cell technology
  • Future fuels: Green/Blue/Bio Methanol or Ammonia

Detailed decarbonisation actions

Investment commitments and financing

Financing for this transition will come from the company's annual and five-year operating budgets. No significant operational or capital expenditures are expected in the short and medium term. However, future vessel new buildings may require external financing, with additional cost for low emission technology estimated to increase newbuild cost by 5-15% depending on vessel type, operational area and size.

The OpEx/CapEx needed for the decarbonization levers are incorporated in the company's annual budgets and long-term (5-years) projections. Any cost is bundled into the normal day-to-day operating cost of the company and linked to specific vessels. Long term investments (upgrades) are normally planned on a 2-year horizon to align with the vessel's 5-year planned Main Class Renewal work to avoid any extra operational downtime for the upgrades.

Upgrade projects may be partly funded by clients, national (Norway) or international (EU) funding arrangements. OpEx for man-hours and another administrative resources needed to execute these measures are included in the company budgets. No significant other OpEx (net cost) is expected related to the measures above in the short to medium term perspective.

CapEx for any future new builds will be allocated on a case-by-case basis – normally together with an end-client where a long-term contract is part of the financing prospect.

EU funded R&D project: Solstad is in the period 2023-2027 involved with the EU funded R&D project NEMOSHIP (New modular Electrical architecture and digital platform to optimise large battery systems on SHIPs) to support the development of new and more efficient marine battery concepts. The project budget is 11,4 MEUR. A total of 11 partners all over Europe is involved in the project. One of Solstad's vessels will have a hybrid battery system installed for testing purposes during 2025, as one the most important milestones in the project. Solstad's share of the budget is 2,6 MEUR over 4 years.

Decarbonisation pathway and estimated contributions

The top three levers identified to reach the targets are 1) Operational measures, 2) Fuel switching and 3) Fleet-renewal.

The Solstad Green Operations® campaign focuses on operational measures to enhance fuel and energy efficiency, tracked monthly per vessel (SGOs/month/vessel). Since its launch, Solstad has observed an average fuel and emission reduction of about 20%. Although fleet emissions are primarily under customer control during time-charter contracts, where clients cover fuel costs and set operational parameters, through the SCO campaign Solstad actively encourages fuel-saving practices.

Even though operational measures for GHG emissions reduction are the least costly and provides strong results, there is a limit to these. Its reduction potential is probably in the range of 25% over the next 5-10 years (measured against a 2010 baseline).

Fuel switching is another lever identified as key for Solstad's emission reduction efforts. Alternative fuels are emerging, and currently fuel switching is done through introduction biofuel to the fleet, consisting of Hydrotreated Vegetable Oil (HVO). Due to the considerably higher cost with this fuel and uncertainty how our clients will embrace this cost, the initial goal is to power one vessel with 50% HVO, yielding an estimated 1% emissions reduction in the overall Solstad Companies fleet of 39 vessels annually. As advanced green fuel technologies (biofuels, hydrogen, ammonia or methanol) become more accessible, Solstad expects to see a strong increase in our capacity to cut emissions by cooperation with our clients through newbuild-and/or retrofit projects.

Barriers and technology/fuel availability

The cost and timeline for the availability of the technologies and fuels needed to decarbonize the offshore fleet is not yet commercially available or mature enough for implementation. Consequently, creating a detailed transition plan is challenging at this point.

Alignment with 1.5°C and SBTi status

Solstad is committed to a global long-term net-zero target for 2050, aligned with the goal of limiting of global warming to 1.5C.

There is currently no available sectorial guidance or sector-specific emissions reduction pathways for Solstad to base an emissions reduction plan on. As more than 50% of the company's revenue stems from activities in the oil and gas sector (no income from coal), Solstad is excluded from the EU Paris-aligned Benchmarks and not eligible for the Science Based Target initiative (SBTi) tools.

Taxonomy alignment

The ESRS E1-1 reporting includes key elements of the transition plan requirements such as actions/levers, Taxonomy alignment including relevant Capex, info about EU Paris-aligned Benchmarks omitting detailed specific GHG targets, and a detailed decarbonization plan including allocated OpEx/CapEx and information about locked in GHG emissions.

Carbon credits and removals

Not specifically disclosed in the E1-1 section.

Policies related to climate change mitigation and adaptation

Solstad has implemented a range of policies and procedures to support its climate change related impacts, risks and opportunities, including emissions to air and energy use, existing fleet considerations and market risks and opportunities.

All policy and procedure documents are maintained in the Solstad Integrated Management System (SIMS), which is audited and certified by DNV according to relevant international standards, particularly ISO 14001 Environmental Management system and ISO 50001 Energy Management. The SIMS system and its policies apply to all Solstad employees, vessels and office locations worldwide, guiding the company's approach to climate-related impacts, risks, and opportunities throughout the value chain.

Company Philosophy, Objectives, and Strategy

Scope: All Solstad operations
Key content:

• Core business involves providing services to the oil and gas, and renewable energy markets
• Continuous focus on the environment, aiming to meet targets by allocating adequate resources and necessary information
• Objective of minimizing impacts on the environment and utilizing energy efficiently and responsibly
• Commitment to measurable improvements through the Solstad Green Operations® program

Governance: The document is approved and signed by the CEO

Sustainability Policy

Scope: All organizational levels
Key content:

• Dedication to conducting business sustainably without compromising future needs
• Avoiding any kind of unwanted pollutants
• Enhancing vessels and facility designs and operations to reduce environmental impacts and increase energy efficiency
• Compliance with, and the aim to exceed, relevant environmental legislation
• Procurement of environmentally friendly and energy efficient products and services
• Improvements of sustainability performance through continuous monitoring, analysis of key indicators and open communication with all stakeholders

Governance: Governed and ultimately implemented by the company's CEO and applied at all organizational levels. Continuously monitored and revised based on stakeholder input to ensure relevance and effectiveness.

Management Review process

Key content:

• Main process for identifying impacts, risks and opportunities on an operational level (involving all departments)
• Reviews the company's entire operations on an annual basis
• Evaluation includes climate change mitigation, adaptation, energy efficiency and renewable energy deployment related topics as well as stakeholder and value chain considerations
• Evaluation of need for training is included
• Sets KPIs and goals for the company on an annual basis

Governance: Output document is signed by the CEO. Shared with all employees.

SIMS Environmental control processes

Key content:

• Outlines the company's work on climate mitigation including day to day follow up
• Annual tasks such as revision of the company Environmental assessment and the double materiality assessment

Hull Cleaning Procedure

Key content:

• Describes all relevant activities to assess whether hull- and propeller cleaning is to be completed
• Contributes towards climate mitigation through reducing fuel consumption and corresponding emissions
• Reduces the risk of transferring invasive species between discrete geographical areas
• Involves analysis of the vessel's past fuel performance, previous hull cleaning initiatives, and post-cleaning fuel performance

Strategy review

Key content:

• Revised on an annual basis
• Includes board level involvement
• Sets out the overall goals for the company both on mitigation (operations) and adaptation (business)
• Includes impacts, risks and opportunities related to sustainability matters such as Climate Change mitigation

Governance: The Executive management, in collaboration with the Board of Directors, will annually review the company's strategy

Public availability: The strategy document is not public.

Monitoring implementation:

The company monitors implementation through:

• The Sustainability Committee, which is mandated to discuss sustainability issues, including material impacts, risks and opportunities, and to oversee the implementation of measures to address these issues
• Monthly environmental data collection and reporting by the Sustainability department, supported by advanced software systems
• Monthly safety statistics managed by the HSEQ department and reported monthly
• Annual Management Review process that evaluates the entire operations and sets KPIs
• Continuous focus on reducing emissions through operational measures (Solstad Green Operations/KPI)

Link to international standards:

The SIMS is audited and certified by DNV according to:

• ISO 14001 Environmental Management system
• ISO 50001 Energy Management

Actions and resources in relation to climate change policies

Overview

Solstad has been working on various decarbonisation actions since 2010, with several initiatives underway. The company is in the process of detailing a transition plan for climate change mitigation, estimated to be completed, adopted and approved by Management by end of 2027. Main work will take place in second half of 2027.

Key decarbonisation measures identified:

• Operational measures: Solstad Green Operations® (SOFF specific campaign since 2010/operational measures done daily on vessels to reduce emissions)
• Existing technology/retrofit: Battery hybrid and shore power systems
• Drop in bio-fuels on existing and new build vessels: HVO (or FAME)
• Fleet renewal: Adapted to use new low emission technologies and fuels:
  • New technology: Dual fuel internal combustion engines and/or fuel cell technology
  • Future fuels: Green/Blue/Bio Methanol or Ammonia

Scope

All actions apply to Solstad's fleet of owned and leased vessels. All vessels are on Time/Charter contract to customers and under operational control by customers, so the scope of actions will also extend downstream in the value chain where feasible.

1. Solstad Green Operations® (SGO)

Action description:
Initiated in 2010, this campaign sets the standard and expectations for each vessel crew. It relates only to operational measures that can be done on a daily basis on all vessels, with initial tagline "We do what we can when possible". Operational measures include reducing vessel speed, anchoring if possible, or reducing lights in use, etc.

Scope: Own operations (all owned and leased vessels)

Time horizon: Ongoing since 2010; short/medium/long term. KPI goals to be increased over time.

Resources allocated:

• Financial: No cost associated (neither OpEx nor CapEx) as these are operational measures
• Non-financial: Vessel crews track actions through simple records in the environmental management system

Expected outcomes / KPIs:

• Company tracks number of SGO actions over time on all vessels
• Monthly KPI target set for each vessel
• Excellent parameter on crew's attitude and actions towards sustainability-enhancing measures

Link to policy/target:
Links to Company Core Values, Sustainability Policy and climate change mitigation objectives. Supports overall GHG reduction programme.

2. Shore Power Installation

Action description:
Installation of shore power capabilities on vessels to reduce emissions while in port.

Scope: Own operations

Time horizon:

• Past: Installed on 7 SOFF vessels in the fleet prior to Jan 16th; no vessels after Jan 16th
• Future: Install on vessels operating in areas/harbours with onshore capabilities (i.e. Norway). No set plan yet for upgrades in coming years.

Resources allocated:
Typical 1-2% annual fuel reduction per vessel achieved.

Expected outcomes / KPIs:
1-2% annual fuel reduction per vessel.

3. Battery-Hybrid Upgrades

Action description:
Retrofit of vessels with battery-hybrid systems to reduce fuel consumption and emissions.

Scope: Own operations

Time horizon:

• Past: 10 vessels upgraded since 2017 (one vessel prior to Jan 16th); no vessels after this date
• Future: One SOFF vessel under conversion per Jan 16th (for installation in 2025). Vessel now transferred to SMH.

Resources allocated:
Not specified in detail.

Expected outcomes / KPIs:
Typical 10-12% annual emission reduction per vessel.

4. Upgrade of Electrical Propulsion Systems to RIM-drive Type

Action description:
New technology upgrade for electrical propulsion systems.

Scope: Own operations

Time horizon:

• Short term: Ongoing
• Future: Evaluate other vessels relevant for this technology based on trial results

Resources allocated:
Not specified.

5. Drop-in Biofuels (HVO or FAME)

Action description:
Ongoing process to convince clients to use biofuels on existing and new build vessels.

Scope: Own operations and downstream (client cooperation required)

Time horizon:
Ongoing; continue to promote and increase use.

Resources allocated:
Not specified.

6. Hull Cleaning Programme

Action description:
Regular hull and propeller cleaning to reduce fuel consumption and emissions, and reduce risk of transferring invasive species. Hull Cleaning Procedure describes all relevant activities to assess whether hull- and propeller cleaning is to be completed. Involves analysis of vessel's past fuel performance, previous hull cleaning initiatives, and post-cleaning fuel performance.

Scope: Own operations

Time horizon: Ongoing

Resources allocated:
Not specified.

Expected outcomes / KPIs:
Reduced fuel consumption and corresponding emissions.

Link to policy/target:
Contributes towards climate mitigation; specific procedure in place (Hull Cleaning Procedure).

Financial Resources Overview

Short to medium term:
No additional CapEx or OpEx is expected in the short to medium term periods related to Taxonomy aligned activities except normal class renewal costs and maintenance (booked as CapEx). These costs are already part of the normal day-to-day operational budgets.

General approach:
The OpEx/CapEx needed for the decarbonization levers are incorporated in the company's annual budgets and long-term (5-years) projections. Any cost is bundled into the normal day-to-day operating cost of the company and linked to specific vessels. Long term investments (upgrades) are normally planned on a 2-year horizon to align with the vessel's 5-year planned Main Class.

Future new-builds:
Future vessel new buildings may require external financing, with additional cost for low emission technology estimated to increase newbuild cost by 5-15% depending on vessel type, operational area and size.

Financing source:
Financing for this transition will come from the company's annual and five-year operating budgets.

Progress Tracking

To track progress on climate change mitigation measures, Solstad tracks the following metrics over time:

1. Annual fleet GHG emissions (scope 1 and 3): Changed from 375,724 tCO2 in 2010 to 156,703 tCO2 in 2024 (a 58% reduction mainly due to reduction in fleet size, sale of vessels, operational and technical measures, offset by activity increase)
2. Number of SGO actions per vessel per month
3. Share of revenue outside oil & gas
4. Taxonomy-eligible revenue

New-Build Projects

New-build projects are executed by the Newbuild and Technology Director department. GHG emission reduction options for new-build projects are always evaluated by these departments in close cooperation with key suppliers and end clients to find the best solution in all projects undertaken.

Targets related to climate change mitigation and adaptation

Net Zero 2050 Target

Target metric: Net zero GHG emissions

Target year: 2050

Baseline year and value: Not disclosed

Scope: Own operations (vessel operations)

Type: Absolute emissions target

Science-based/validation: Not specified as SBTi-validated. Company states it is "excluded from the EU Paris-aligned Benchmarks and not eligible for the Science Based Target initiative (SBTi) tools" due to more than 50% of revenue from oil and gas sector.

Progress to date: Not quantified. Company states: "The company has at present not set GHG emission reduction targets for the year 2030." Company notes that "95% of these emissions occur when the customer has operational control over the vessel" and cites "limited control over the downstream activity" as a reason for not setting interim targets.

Decarbonisation pathway: Company provides an estimated decarbonisation pathway through three main levers:

1. Operational measures (est. 25% reduction potential over next 5-10 years vs 2010 baseline)
2. Fuel switching (biofuel HVO; initial goal is to power one vessel with 50% HVO yielding est. 1% emissions reduction in overall fleet)
3. Fleet renewal (zero/low-emission technology for all new vessels)

Gender Equality Targets (2030)

Target metric: Female seafarers and female onshore management representation

Target values:

• 10% female seafarers in general
• 30% female onshore employees in management positions

Target year: 2030

Baseline year and value: Not disclosed; 2024 female FTE portion reported as "not reported"

Scope: Own workforce

Type: Intensity-based (percentage)

Health & Safety Targets

Target metrics: TRCF (Total Recordable Case Frequency) and LTIF (Lost-Time Injury Frequency)

Target values:

• TRCF: 1.00 incidents per million working hours
• LTIF: 0.00 incidents per million working hours

Target year: 2025

Baseline and progress:

• 2022: TRCF 1.24, LTIF 0.29
• 2023: TRCF 1.25, LTIF 0.25
• 2024: TRCF 1.10, LTIF 0.27

Scope: Total workforce including own employees and non-employees

Type: Intensity-based (per million working hours)

Energy consumption and mix

Scope and methodology

As a share of Solstad's total annual energy consumption, more than 99% stems from energy produced by the combustion of Marine Gas Oil on the fleet's vessels. Onshore electricity consumption represents a minimal share of total energy consumption. About 95% of the fleet is leased out on Time/Charter contract, meaning only a minimal share of the fleet's energy consumption falls under the operational control of Solstad. The company's own energy consumption and mix thus primarily consists of scope 1 fuel consumption and scope 2 electricity usage onshore.

Reporting boundary changed significantly on 16 January 2024 following company restructuring. Prior to this date, SOFF operated 39 vessels; from 17 January 2024, SOFF operates 14 vessels (6 owned, 7 leased from SMH, 1 50% owned JV vessel).

Energy consumption and mix (2024)

Energy intensity per net revenue (2024)

Note: Approximately 88.25% of total energy consumption is from activities in high climate impact sectors (Mining - Oil & Gas - Upstream & Services).

Gross Scopes 1, 2, 3 and Total GHG emissions

Solstad Offshore reports GHG emissions following a financial control approach in accordance with ESRS E1. The reporting boundary changed significantly on 16 January 2024 when the company was split: Solstad Offshore (SOFF) retained 6 owned vessels, 7 leased vessels (from Solstad Maritime Holding, SMH), and a 50% JV vessel. For the first 16 days of 2024, metrics include 39 vessels; from 17 January onwards, 14 vessels.

Scope 1: All vessels owned or leased by SOFF generating revenue are reported in Scope 1. Emissions are calculated by multiplying Marine Gas Oil (MGO) fuel consumption by the internationally recognised emission factor of 3.206 tCO2/ton fuel.

Scope 2: Location-based only. Covers electricity consumption at the Rio and Macae offices. Market-based figures are reported as identical to location-based.

Scope 3: Includes upstream fuel and energy-related activities (production and transport of MGO), purchased goods and services (spend-based analysis), business travel, waste, employee commuting, and financial investments (50% of GHG emissions from the Normand Installer JV and 27% of SMH total GHG emissions excluding leased vessels). Primary data sources (fuel, food, transport, waste, investments) represent ~94% of Scope 3. Secondary data (spend-based and commuting) ~6%. Fuel upstream emissions use a factor of 17.7 gCO2eq/MJ. Categories 2, 8, 9, 10, 11, 12, 13, 14 are reported as not applicable or zero.

Boundary and methodology notes:

• Reporting year 2024 reflects the fleet change on 16 January 2024.
• GHG emissions from vessels under Time/Charter contracts (client operational control) are reported in Scope 3 from FY 2023 onwards, in line with Norwegian Shipowners Association guidance and GHG Protocol operational control approach.
• In 2024, Solstad switched from operational control to financial control methodology for ESRS compliance. This represents a significant change in definition for 2024 figures.
• Upstream fuel emissions (Category 3) are included in Scope 3 regardless of operational control.
• Biogenic CO2 is not reported separately.
• Regulated emissions (EU ETS) are not disclosed.
• No sub-breakdown of Scope 1 into stationary combustion, mobile combustion, process emissions, or fugitive emissions is provided.

GHG Emissions by Scope (2024)

GHG Intensity

Multi-year comparison (Note: 2022 and 2023 figures cover different fleet boundaries and are not directly comparable to 2024):

• 2010: 375,724 tCO2 (entire fleet)
• 2024: 156,703 tCO2 (reduced fleet, primarily Scope 1+3 per previous methodology)
• 58% reduction from 2010 to 2024, mainly due to fleet reduction (company restructuring, vessel sales), offset by activity increases.

Target: Long-term net-zero target for 2050. No interim 2030 target set.

Phase-in provisions: Solstad has used phase-in provisions for certain eligible disclosures under ESRS E1 in the first CSRD reporting year (2024).

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

Phase-in exemption statement

Solstad utilizes the phase-in provisions for ESRS 2 SBM-3 paragraph 48 (e) for the 2024 Sustainability Statement (Omitting the anticipated financial effects).

Solstad has made use of phase-in provisions for certain eligible disclosures due to having less than 750 FTE in the reporting year. This applies to E1-6, E1-9, E2-6, E4, S1 (partially) and S2 (partially).

Time horizons

The time horizons defined in ESRS will be used for reporting purposes, which are short-term (1 year), medium-term (2-5 years), and long-term (more than 5 years). In certain cases, a "very-long term" horizon of 10-year or more is used. This extended horizon applies to ESRS E1, due to the current uncertainty surrounding suitable GHG reduction technologies for offshore vessels globally. By utilising this longer time horizon, we aim to provide a more relevant assessment of our sustainability impacts, risks and opportunities.

Material risks and opportunities identified

As stated in the materiality assessment table (Table 9), Solstad identified climate change mitigation and energy-related impacts, risks and opportunities as material for reporting. The risks are valid on all time-horizons (Short Term, Medium Term, Long Term) and apply to Up- and downstream operations.

Financial effects disclosure

No quantified financial effects (€) are disclosed for the 2024 reporting year due to the application of the phase-in exemption under ESRS 2 SBM-3 paragraph 48 (e).

Policies related to pollution

Sustainability Policy

Solstad's Sustainability Policy outlines all strategic overarching objectives relating to the company's sustainability efforts.

Key content and principles:

• Goal of zero oil spill incidents to sea
• Statement on avoiding any kind of unwanted pollutants and discharges
• Support for procurement of environmentally friendly and energy-efficient products and services that impact sustainability performance

Scope:

• Published at places easily available onboard the vessels as well as in all office locations
• Part of employee induction and training programs

Implementation and monitoring: The Sustainability Policy is supported by the company's processes for handling the impacts, risks and opportunities linked to pollution, including:

• Voyage planning
• Maintenance processes (according to the IMO NOx Technical Code)
• Environmental reporting tools (vessel and onshore)
• Annual review process for evaluation and setting new KPIs and targets (Management review process)

Public availability: The policy is published at places easily available onboard vessels and in all office locations. No specific URL or external publication location is mentioned.

Links to standards:

• The company complies with International Maritime Organization (IMO) regulated maximum limits for pollutants
• Complies with pollutant limits set by regional and national authorities in operating areas
• Maintenance processes follow IMO NOx Technical Code

Actions and resources related to pollution

More than 95% of pollution to air associated with Solstad occurs when clients have operational control over vessels, resulting in very limited direct emissions of pollutants by Solstad. All measures outlined below have been carried out in the reporting year by all or some vessels, except for installation of battery-hybrid and SCR plants (no candidate vessels available for retrofitting during the year). Retrofit projects need to fit within planned five-year Main Class Renewal projects.

Key actions to address and mitigate pollution to air

Use of low-sulphur fuels

• Scope: Own operations (vessel operations)
• Description: All fuel used by the company is low-sulphur Marine Gas Oil. Maximum sulphur limit on fuels is 0.5% globally and maximum 0.1% in EU and other areas with stricter local regulations (by weight).
• Expected outcome: Relatively low SOx emissions
• Regulatory link: Regulated internationally by IMO and national regulators

Use of renewable biofuels (HVO)

• Scope: Own operations (vessel operations)
• Description: Use of Hydrotreated Vegetable Oil (HVO) introduced as drop-in fuel for existing fleet as part of Solstad revised strategy (2024) on emission reduction
• Time horizon: Introduced in 2024
• Resources allocated: Cost typically 50-100% higher than standard ship fuel; most cost forwarded to clients (100% when vessels on contract). No cost for SOFF in reporting year, but may generate cost in coming years.
• Expected outcome: Slightly reduced NOx emissions; reduces SOx emissions by upwards of 70% due to extremely low sulphur content (<0.03%)
• Status: No HVO was used by SOFF in the reporting year

Use of NOx scrubbers (SCR plants)

• Scope: Own operations (vessel operations)
• Description: Use of Selective Catalyst Reducer (SCR) plants. Since 2005, Solstad Offshore has installed SCR scrubbers on newly constructed vessels.
• Resources allocated:
  • CapEx: Typical installation cost 10-20 MNOK (mostly only available during vessel construction)
  • OpEx: NOK 4-5 per litre of Urea; around NOK 100,000 per vessel per year when actively used (most cost forwarded to end client, leaving limited net cost)
• Expected outcome: Approximately 90% reduction of NOx emissions when in use
• Status: SCR scrubbers currently installed on 2 vessels in SOFF fleet of 14 vessels. Usually applies only to operations out of Norway as urea fluid not readily available elsewhere. Very limited use in remaining SOFF fleet following sale of vessels January 16.

Use of shore electrical power

• Scope: Own operations (vessel operations in harbour)
• Description: Shore power connection systems installed on vessels. Over previous 10 years, 17 systems installed in fleet (9 later sold or transferred to SMH). Shore power presently only available in some harbours in Norway.
• Resources allocated:
  • CapEx: About 1 MNOK per system
  • OpEx: May currently be higher than diesel-fuelled electricity-production onboard due to high electricity prices over last two years
• Expected outcome: 100% reduction of NOx and SOx when in use, as all engines stopped. Most effective air pollution reduction lever.
• Status: 8 vessels on combined SOFF/SMH fleet have systems installed (zero in SOFF fleet after Jan 16). Very limited use for SOFF vessels during reporting period. No new systems installed in reporting year. Company chooses to use electricity whenever available to reduce air pollution in harbour area.

Battery hybrid conversion

• Scope: Own operations (vessel operations)
• Description: Installation of battery-hybrid systems. Since 2017, 10 vessels converted by Solstad Offshore.
• Expected outcome: Estimated 10% reduction in NOx and SOx
• Status: All but one vessel has been sold. Last vessel with battery hybrid installed was transferred from SOFF to SMH January 16 in reporting year.

Planned downstream value chain projects (2025)

Two projects planned for 2025 in Solstad Offshore's downstream value chain through Solstad Maritime Holding:

Battery-hybrid upgrade with SCR installation

• Scope: Downstream value chain (Solstad Maritime Holding)
• Description: Battery-hybrid upgrade including SCR installation on AHTS vessel (new battery concept, part of large EU-funded project)
• Time horizon: Planned for 2025
• Expected outcome: Estimated 10% fuel and emission reduction on annual basis
• Other benefits: Learning effects of applying new technology expected to be relevant for Solstad Offshore

Propulsion system upgrade

• Scope: Downstream value chain (Solstad Maritime Holding)
• Description: Upgrade of propulsion system on large CSV vessel
• Time horizon: Planned for 2025
• Expected outcome: Estimated 20% fuel and emission reduction on annual basis
• Other benefits: Learning effects expected to be relevant for Solstad Offshore

Resources and technical investments

No relevant technical upgrade projects for emission reduction in Solstad fleet of owned and leased vessels in the reporting year. First two key actions (low-sulphur fuels and voyage planning/maintenance) do not require any additional OpEx/CapEx.

Supporting processes and systems

• Voyage planning (no additional OpEx/CapEx required)
• Maintenance processes according to IMO NOx Technical Code (no additional OpEx/CapEx required)
• Environmental reporting tools (vessel and onshore)
• Annual review process for evaluation and setting new KPIs and targets (Management review process)
• Zero oil spill incidents goal as stated in Sustainability Policy
• Procurement of environmentally friendly products and services supporting sustainability performance

Targets related to pollution

Solstad Offshore has not set specific quantified targets for pollution reduction (NOx and SOx). The company states:

"As described under ESRS E1 Climate change mitigation, the company have in place a range of measures to reduce emissions including air pollutants, but a specific target on air pollution reduction has not been set."

Indirect linkage to GHG targets

The company notes that NOx and SOx emissions are linked to fuel consumption and GHG emissions:

• Approach: "Any targets are indirectly linked, and reductions in fleet fuel consumption which reduces GHG emissions, will also reduce emitted amount of NOx and SOx."
• Estimation: "Solstad has estimated that an annual reduction of fleet fuel consumption will reduce emitted NOx and SOX pollution by the same amount (in %)."

Future target development

• Timeline: "Specific emissions targets will be established as part of the development of the Climate transition plan that is part of ESRS E1 (next year)."

Compliance approach

• The company views IMO regulated maximum limits for pollutants as upper thresholds and strives to operate well within them as a proxy for environmental targets.

Historical emissions data (reference only)

*Not audited.

Note: The 75% reduction over 3 years is attributed to fleet reductions (PSV sale in 2023 and transfer of vessels to SMH in January 2024), not to specific pollution reduction targets.

Pollution of air, water and soil

Emissions to Air

Solstad's performance tracking system automatically calculates the emitted amounts of NOx and SOx caused by vessel operation. The methodology is derived from resolutions by the IMO's Marine Environment Protection Committee, using internationally recognized emissions factors. The calculation considers the engine type and make, the specific density of the fuel used as well as its sulphur content (for SOx calculation) and whether the vessel has an SCR scrubber installed (for NOx calculation).

The amount of SOx pollution emitted by the vessel is calculated by multiplying given fuel type consumption expressed in metric tons and sulphur content factor expressed in kg/metric ton. The methodology used can be found in the IMO MEPC Regulation 14 on Sulphur oxides (SOx) and Particulate Matter (PM), and the IMO GHG Study Annex 6 Details for Section 2: other GHG emissions and relevant substances. The fixed factor used is 20 kgSOx/ton fuel.

Fleet Exhaust Gas Emissions

*) Not audited.

Emission levels over the previous 3 years show a strong reduction (75%), mainly due to the fleet reductions PSV sale in 2023 and transfer of vessel from SOFF to SMH January 16, 2024.

For the majority of operations out of Norway a NOx-tax have to be paid for same of the NOx-emissions (10 USD/kg / cost covered by our clients).

Methodology Notes

Direct measurement of emitted NOx and SOx pollutants necessitates advanced technical sensor equipment, which requires ongoing maintenance and calibration. Given that the company adheres to the stringent maximum limits for emitted pollutants set by the International Maritime Organization and relevant local authorities in the regions where vessels operate, Solstad has determined that adopting direct measurement is not essential at this time.

The vessels with Selective Catalyst Reducer (SCR) technology installed are required to be checked for NOx-emissions at regular intervals using a 3rd party specialist company that brings a mobile sensor system onto the vessel and provides a certificate on the results.

Emissions to Water

The company has operational emissions of pollutants to sea from the vessels such as wastewater and sewage. The screening revealed that Solstad has no significant onshore activities emitting pollutants to soil. Marine vessel operation produce minimal water pollutants, and subject to stringent international and national regulations. Campaigns to limit single-use plastics on vessels address microplastic pollution, reducing the risk of plastics being discarded or releasing microplastics in the ocean. This aspect was deemed non-material.

Emissions to Soil

Solstad has no significant onshore activities emitting pollutants to soil.

E-PRTR Reference

ESRS E2-4 requires disclosure of the amount of each pollutant listed in Annex II of the E-PRTR Regulation (European Pollutant Release and Transfer Register) emitted to air, water and soil (paragraph 28). This disclosure is listed in the ESRS compliance table but no quantified E-PRTR pollutants beyond NOx and SOx are disclosed in the reporting year.

Substances of concern and substances of very high concern

E2-5 is marked as not material in Solstad Offshore's ESRS disclosure roadmap (Table 41). The company has applied the transitional provisions and phase-in approach for this disclosure requirement.

In the materiality assessment narrative (E2 Pollution section), the company states:

"While the company's vessels use substances of concern that may lead to pollution, particularly from harmful substances released over time due to ship paint and underwater hull coatings, limited research exists on its significance. Consequently, this topic remains on a 'watchlist', with plans to enhance data collection for future reassessment."

No quantitative data on total amounts of substances of concern (SoC) or substances of very high concern (SVHC) generated, used, or procured have been disclosed for the reporting year. No breakdown by hazard class (CMR, endocrine disruptor, PBT, vPvB) is provided. The company has not disclosed specific monitoring procedures, REACH compliance measures, or management approaches related to SoC/SVHC beyond the general statement that the topic is under watch for future data collection and reassessment.

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

Phase-in exemption

Solstad has used the phase-in provisions for E2-6 for the first year of reporting under CSRD. The company states: "The ESRS topical standards E1, E2, E4, S1, S2 and G1 were assessed as material for the company, and Solstad has used the phase-in provisions for some of the topic standards' respective disclosure requirements for the first year of reporting under CSRD. This applies to E1-6, E1-9, E2-6, E4, S1 (partially) and S2 (partially)."

The company further clarifies: "Applying the phased-in approach allows the company to gather the necessary information for comprehensive reporting on the topic standards' disclosure requirements in future reporting periods."

For all ESRS where Solstad has decided to use phase-in provisions, there are already in place policies, actions and metrics in the management system for most disclosure requirements and this is incorporated in the business model. However, there are some challenges to generate all the required information and reporting structure for the first reporting year, hence phase-in provision has been used.

Material impacts, risks and opportunities related to pollution

From the material impacts, risks and opportunities table:

Financial risks

The company has identified a risk of increased taxes on pollutants. However, the company notes that such taxes would result in higher prices on their services, suggesting cost pass-through mechanisms.

Business opportunities

Having assets with pollution reduction technologies installed provides some business advantages in certain markets.

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

E4-1 is disclosed as not material for Solstad Offshore.

According to the materiality assessment table, E4 Biodiversity and ecosystems disclosures E4-1 to E4-6 are assessed as not material. The disclosure requirement E4-1 specifically is shown with "All (phase-in)" in the disclosure requirements column, indicating the company is using the phase-in exemption for this requirement.

Policies related to biodiversity and ecosystems

The company has assessed E4 (Biodiversity and ecosystems) as material. According to the materiality assessment table, E4-2 is listed among the material disclosure requirements.

However, the disclosure requirement E4-2 regarding policies related to biodiversity and ecosystems is marked as "Material - Phase-in" in the appendix tables. This indicates that while the topic is material, detailed policy disclosures under E4-2 are subject to phase-in provisions and are not yet fully reported in this sustainability statement.

No specific policies related to biodiversity and ecosystems, sustainable land/agriculture practices, sustainable oceans/seas practices, or deforestation are disclosed in the provided excerpts. The appendix indicates that the following policy elements under E4-2 are material but subject to phase-in:

• Sustainable land/agriculture practices or policies (paragraph 24(b))
• Sustainable oceans/seas practices or policies (paragraph 24(c))
• Policies to address deforestation (paragraph 24(d))

Impact metrics related to biodiversity and ecosystems change

Operations in or Near Biodiversity-Sensitive Areas

Solstad reports that operations have not been executed in or near biodiversity-sensitive areas:

To our knowledge these operations have not been executed in or near biodiversity-sensitive areas (including the Natura 2000 network of protected areas, UNESCO World Heritage sites and Key Biodiversity Areas, as well as other protected areas).

Solstad notes that clients are responsible for these assessments prior to work commencing according to international and regional regulations. The company is implementing a second layer of risk mitigating software tool through cooperation with HUB Ocean.

Invasive Species Risk

Solstad's vessels operate globally and risk transporting local species in ballast water or vessel areas, with potential impacts to ecosystems and biodiversity related to invasive species. The company addresses this through:

• Installation of Ballast Water Treatment plants
• Implementation of approved procedures for ballast water exchange
• Compliance with all international regulations

No quantified metrics on species impacts, land use footprint, deforestation, or restoration activities are disclosed.

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

Phase-in exemption applied

According to the materiality assessment table, E4-6 (Anticipated financial effects from material biodiversity and ecosystem-related impacts, risks and opportunities) is subject to a phase-in exemption. The disclosure requirement is marked as "All (phase-in)" in the table.

Policies related to own workforce

Solstad has in place various policies and operational procedure descriptions to guide its work on addressing own-workforce related issues.

Health and Safety policy

Scope: All employees

Key content:

• Solstad never compromises on safety. Safety is one of our core values and is always a priority for all employees.
• The cornerstone is the Solstad Incident Free Operations (SIFO) program.
• Focus on evaluating, facilitating, planning and preventive measures to avoid all types of personnel-related injuries and incidents that negatively impact the working environment.
• Extensive management system that includes a process-based quality system, HSE reporting system with incident and positive feedback reporting, risk handling, Management of Change, Drills management and audit/investigations portal.

Public availability: Available through the Solstad Integrated Management System (SIMS)

Governance: All documentation is approved by the CEO, with delegation to the HSEQ Director as necessary

Links to international standards:

• Complies with legal requirements and recognized standards/guidelines
• Subject to the Seafarers' Employment Agreement (SEA) as defined by the Maritime Labour Convention
• Terms approved by the International Transport Workers Federation (ITF) and affiliated seafarers' national unions

Monitoring: The company's top six policies are signed by the CEO and published on all office and vessel locations worldwide. Each department director is responsible for creating and updating processes or revisions, which are subsequently approved by the HSEQ Director on behalf of the CEO. SOFF is audited annually by internal resources and externally by DNV on its policies, processes, records and other relevant documentation to verify compliance with all relevant rules and regulations.

Code of Conduct

Scope: All employees

Key content:

• Commitment to upholding human rights as defined by the UN
• Most relevant human-rights commitments regards non-discrimination, just and favourable conditions of work, as well as equal pay for equal work
• Promotes equal opportunities and the elimination of all types of discrimination, including on the grounds of religion, skin colour, sex, sexual orientation, age and disability
• Supports the United Nations Global Compact over many years, committed to integrating the 10 principles of ethical business conduct into business strategy and operations
• Mandatory for all employees to follow

Public availability: Available through SIMS (Solstad Integrated Management System)

Governance: Approved by the Board of Directors

Links to international standards:

• UN Guiding Principles on Business and Human Rights
• ILO Declaration on Fundamental Principles and Rights at Work
• OECD Guidelines for Multinational Enterprises
• UN Global Compact
• International Bill of Rights
• Universal Declaration of Human Rights

Monitoring: Annual training on Code of Conduct including Anti-corruption and Bribery is mandatory for all employees. All policies undergo continuous improvement to address evolving expectations and requirements.

Company Philosophy, Objectives and Strategy policy

Key content:

• Anchors the company's work on human rights and decent working conditions
• In alignment with the UN Guiding Principles on Business and Human Rights
• Considers the Guiding Principles of the International Bill of Rights, including the Universal Declaration of Human Rights and the two Covenants
• Considers the International Labour Organisation's Declaration on Fundamental Rights and Principles at Work and its core conventions

Links to international standards:

• UN Guiding Principles on Business and Human Rights
• International Bill of Rights
• Universal Declaration of Human Rights
• ILO Declaration on Fundamental Rights and Principles at Work

Procedure: Transparency on Human Rights and Working Conditions

Key content:

• Promotes ethical business practices
• Strictly prohibits any infringement of human rights, while actively promoting their respect along with decent working conditions across all activities
• Explains how Solstad annually conducts due diligence according to the OECD Guidelines and the Norwegian Transparency Act, prioritizing based on severity and likelihood
• Specific procedures to ensure discrimination is prevented and/or mitigated

Links to international standards:

• UN Guiding Principles on Business and Human Rights
• ILO Declaration on Fundamental Principles and Rights at Work
• OECD Guidelines for Multinational Enterprises

Diversity initiatives

Governance: Working Group for Diversity oversees initiatives related to the inclusion of groups at particular risk within own workforce

Key content:

• "Women in Solstad" project aimed at supporting gender equality and encouraging more women to join the company

Employee Relations procedure

Key content:

• Procedure for handling employee grievances, complaints, and feedback suggestions impacting workforce
• Includes collecting and mapping feedback from the entire organisation
• Working Environment Survey administered biennially

Marine Mammals Avoidance process

Scope: Vessel bridge crew

Key content:

• Mitigates the risk of harming marine mammals when operating in certain areas where this is considered high risk

Recruitment Onshore procedure

Key content:

• Supports the policy objectives of gender equality and mitigating potential negative impacts

Grievance mechanisms

Key content:

• Group-wide grievance mechanism for complaints about detrimental behaviour regarding a variety of ethics, integrity and compliance issues (including human rights, labour rights, corruption, bribery)
• Complaints can be submitted anonymously, by internal as well as external stakeholders
• Treated confidentially and in a timely manner
• Regular evaluation of incoming complaints and assessment of necessary adjustments to procedures
• Onboard Familiarization process allows seafarers to file written complaints regarding breaches of the Maritime Labour Convention 2006

Public availability: www.solstad.com/whistleblowing/

Links to international standards:

• Maritime Labour Convention 2006

Taking action on material impacts on own workforce

Overview

Solstad addresses material impacts on its own workforce through various actions, as outlined in its Corporate Risk Assessment regarding human rights and working conditions. The actions taken are part of the company's efforts to mitigate material risks and pursue opportunities.

Actions Taken

Based on the Risk Assessment, the following actions have been implemented:

• Established process for managing identified actual and potential adverse impacts
• Updated Code of Conduct
• Established channels for Whistle Blowing
• Established the "Women in Solstad" program to promote gender equality
  • This is a specific initiative aimed at supporting gender equality and encouraging more women to join the company
  • More information available at: www.solstad.com/opportunities/women-in-solstad/
• Employ the majority of vessel crew directly
• Limit the number of crewing agencies we use
• Invest in training and development programs which are mandatory for all personnel onboard our vessels
• Maintain and promote a good working relationship and cooperation with seafarers' unions
• Courses on handling lithium-ion batteries or other novel technologies that may pose a risk for crew if installed on the vessel

Health and Safety Programme

Solstad Incident Free Operations programme

• Risk owner: COO
• Time horizon: Long term
• Target: Zero-incident goal
• KPIs: Set and monitored
• Current performance: TRCF target 1.00 (2025), LTIF target 0.00 (2025)

Grievance and Engagement Processes

The company has established procedures for handling employee grievances, complaints, and feedback through:

• Normal reporting channels via HSE reporting system (UniSea software)
• Dedicated whistleblower channel via company website
• Working Environment Survey conducted biennially

Performance Monitoring

Action plans and performance against targets are:

• Continuously monitored and reported to all relevant personnel
• Reviewed during regular department meetings where all employees participate
• Displayed monthly via KPIs on company communication sites (Bulletins, Intranet, Notice Boards)
• Each employee has responsibility to be informed about relevant KPIs and contribute to meeting set targets

Resources Allocated

No specific financial resources (capex/opex amounts) are quantified in the disclosure. Non-financial resources include:

• Working Group for Diversity overseeing initiatives for inclusion
• Dedicated HSEQ department and Manager for managing reporting systems
• HR Administration and Crewing departments using OCS HR system
• Multiple software systems (HSE database, Daily Report systems, TM purchasing system)

Link to Targets

Targets related to own workforce

Health and Safety Targets

Total Recordable Case Frequency (TRCF)

• Metric: TRCF - Total recordable incidents per 1 million working hours
• Target value: 1.00 incidents per 1 million working hours
• Target year: 2025
• Baseline year: Not disclosed
• Scope: Own workforce
• Type: Intensity-based (per working hours)
• Progress to date:
  • 2022: 1.24
  • 2023: 1.25
  • 2024: 1.10
• Long-term policy: Continuous zero-incident policy regarding both total recordable case frequency (TRCF) and lost-time injury frequency (LTIF)

Gender Diversity Targets

Female Seafarers

• Target value: 10% female seafarers
• Target year: 2030
• Baseline year: Not disclosed
• Baseline value: Not disclosed
• Scope: Own workforce (seafarers)
• Type: Absolute percentage

Female Onshore Management

• Target value: 30% female onshore employees in management positions
• Target year: 2030
• Baseline year: Not disclosed
• Baseline value: Not disclosed
• Scope: Own workforce (onshore management)
• Type: Absolute percentage

Target Setting and Monitoring Process

Targets and KPIs are set annually at the highest management level by Executive Management. Directors and Managers conduct annual evaluations, and performance is monitored monthly through the corporate KPI Centre and reviewed in monthly General Meetings.

Characteristics of the undertaking's employees

Total headcount and FTE

As of 31 December 2024, the company's own workforce consisted of 569 FTE (502 crew FTE + 67 onshore FTE). This represents the total for Solstad Offshore ASA (SOFF) following the company split on 16 January 2024.

Geographical breakdown at year-end:

Note: The table includes hired/temporary personnel engaged in SOFF operations. For context, Solstad Maritime Holding (SMH) employed 1,618 FTE at year-end 2024 (reported separately).

Headcount by gender

Onshore administration:

• Men: 38 (57%)
• Women: 29 (43%)

Marine crew:

• Total: 502
• Women: 39 (8%)
• Men: 463 (92%)

Note: The company reports: "The Company focuses on diversity and has equal opportunities for all employees, regardless of their gender, ethnic background, nationality, descent, color, language, religion and lifestyle."

Board of Directors:

• Total members: 5
• Women: 2 (40%)
• Men: 3 (60%)
• Independent members: 3 (60%)

Executive Management team:

• Total members: 4 (CEO, CFO, COO, CCO)
• Women: 0 (0%)
• Men: 4 (100%)
• Non-executive members: 0

Headcount by country/region

SOFF operations are concentrated in Brazil with 569 total FTE. The company has offices in Rio de Janeiro and Macae, Brazil, and a headquarter address in Skudeneshavn (Norway). Supportive management services are obtained from Solstad Maritime offices located in Perth (Australia), Singapore, Manila (Philippines), and Aberdeen (UK).

Headcount by employment contract type and employment type

The company's own workforce "mainly consists of full-time employees, but also some part-time and temporary employees as well as personnel provided by crewing agencies."

No quantitative breakdown by permanent/temporary or full-time/part-time is provided in the excerpts.

Employee turnover and new hires

Not disclosed in the provided excerpts.

Prior year comparison

The company underwent a significant restructuring on 16 January 2024, whereby Solstad Offshore ASA was divided into two separate structures. Prior to this split, SOFF operated 39 vessels with approximately 1,500 employees. Following the split, SOFF retained 6 owned vessels, 7 leased vessels, and a 50% owned JV vessel with around 569 FTE.

Direct prior year (2023) FTE figures for the current SOFF entity are not disclosed, as the 2024 report reflects the post-split structure.

Methodology notes

The report states: "This report's management system and organization references pertain to the joint onshore management team and systems. Metrics and relevant information about fleet operations for the first 16 days of 2024 are included. Since January 17, 2024, there have been no significant changes in the vessel portfolio."

The company distinguishes between "employees" (full-time and part-time staff) and "non-employees" (personnel provided by crewing agencies and ROV operators from Ocean Subsea).

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

Not disclosed.

The sustainability statement does not provide specific information about the number, characteristics, or types of non-employee workers (contractors, agency workers, self-employed) in Solstad Offshore's own workforce. While the company discusses value chain workers extensively in ESRS S2 disclosures (including upstream yard workers and downstream client personnel), these are categorized as value chain workers rather than non-employees in the own workforce.

The closest reference states that client personnel work onboard Solstad vessels but are "hired directly or indirectly by the client" and are explicitly classified as downstream value chain workers rather than part of Solstad's own workforce.

Diversity metrics

Gender diversity at top management

Board of Directors:

• Total members: 5
• Men: 3 (60%)
• Women: 2 (40%)
• Other: Not disclosed
• Independent members: 3 (60%)

Executive Management team:

• Total members: 4 (CEO, CFO, COO, CCO)
• Men: 4 (100%)
• Women: 0 (0%)
• Other: Not disclosed
• Non-executive members: 0

Age band distribution

Age band distribution of the total workforce is not disclosed in the provided excerpts.

Notes

The company states in the appendix table (page 105) that S1-9 is "not material" and therefore not reported. Gender composition is provided only for governance bodies (Board of Directors and Executive Management) as part of GOV-1 disclosure requirements, not as part of S1-9 workforce diversity metrics.

Adequate wages

Material impact identification

Solstad has identified adequate wages as a material impact for workers in the value chain (S2), particularly upstream workers including yard workers. The company states that "adequate wages" and "health and safety" are the most prominent impacts regarding workers in the value chain in their global vessel operations.

Benchmark approach

Solstad's Supplier Code of Conduct requires that suppliers meet, as a minimum, national or industry standards, whichever affords the greatest protection. The policy states: "Wages should be enough to meet basic needs."

However, no specific living wage benchmark (such as Fair Wage Network, WageIndicator, Anker Methodology, or similar) is disclosed in the sustainability statement. The focus is on suppliers providing wages that meet basic needs and comply with national/industry minimum standards.

Coverage and assessment

Solstad does not disclose:

• What percentage of value chain workers have been assessed against a living wage benchmark
• What percentage earn at or above a living wage
• Specific methodology for determining if wages "meet basic needs"

The company acknowledges: "within our business, as we conduct global operations, there is always uncertainty regarding the presence of adequate wages within our value chain. However, as the majority of our value chain operates in industrialized countries where employees typically receive adequate compensation, the likelihood is considered low."

Own workforce

For Solstad's own workforce, adequate wages is assessed but determined to be not material (S1-10 marked as "not material" in the disclosure table on page 105).

Geographic scope

Global operations, with particular focus on shipyards "around the world" identified as having "one of the highest risks of breaches to human rights."

Targets and commitments

The company has not set specific targets for adequate wages. The statement explicitly notes: "The company has not set other specific targets for value chain workers related to reducing negative impacts on value chain workers, advancing positive impacts on value chain workers or managing material risks and opportunities related to value chain workers."

However, Solstad commits to: "Over the next two years we plan to initiate programs aimed at delivering positive impacts for value chain workers to focus on improving workers' skills, providing better working conditions, and enhancing their overall well-being."

Monitoring approach

• Supplier approval process requires self-assessment on sustainability matters including working conditions
• Project managers perform spot checks during maintenance projects
• No specific adequate wage metrics are tracked beyond supplier compliance declarations

Incidents

"During the report year there has not been registered any cases of non-respect of the UN Guiding Principles on Business and Human Rights, ILO Declaration on Fundamental Principles and Rights at Work or OECD Guidelines for Multinational Enterprises that involve value chain workers."

Training and skills development metrics

Anti-Corruption and Bribery Training

The Anti-Corruption and bribery e-learning course takes about 15 minutes to complete and is mandatory for all employees and other workers including managers and executive management (however board members are not enrolled in this course).

All employees have at least received one training invitation and about 90% have completed training by YE 2024. The course needs to be refreshed by all yearly.

Individual Competency Development Plans

All Solstad employees create an individual competency development plan, in cooperation with their immediate leader. The competency development plan is assessed and revised during the annual performance review.

Mandatory E-learning

E-learnings on sustainability topics is mandatory for all employees. Solstad has a development team devoted to developing internal e-learning courses for specific topics, such as Sustainability, Anti-corruption, sanctions, cyber security, among others.

Note: The company discloses the existence of individual competency development plans and annual performance reviews, and provides training completion data for anti-corruption training (90% completion rate). However, specific average training hours per employee (overall, by gender, or by employee category) and percentage of employees who received performance and career development reviews (with gender breakdown) are not quantitatively disclosed. Total investment in training is not disclosed.

Health and safety metrics

Coverage

All of Solstad's own workforce (100%) is covered by Solstad Integrated Management System based on legal requirements and/or recognised standards/guidelines.

Work-related incidents and injuries

Safety metrics by workforce category and trend

*2022 and 2023 numbers are not audited

Methodology

To calculate the TRCF and LTIF a number of 24 hours per day per person on the vessels is used as the basis (industry standard). The total number of work related Fatalities+Lost Time Incidents (LTI's) + Restricted Work Cases (RWC) + Medical Treatment (MT) cases is used for the TRCF. Fatalities + LTI's for the LTIF. The numbers are per million hours. Office personnel work hours is included using an average number for overtime for all onshore employees. Incidents and work hours is also included for hired personnel on the vessels (non-employees) using the same methodology.

Compensation metrics

Pay gap

Not disclosed.

Remuneration ratio

Not disclosed.

Phase-in statement

Solstad Offshore has utilized the phase-in provisions for ESRS S1-16 in the 2024 reporting year. The company states: "Solstad utilizes the phase-in provisions for ESRS 2 SBM-3 paragraph 48 (e) for the 2024 Sustainability Statement." In Appendix A (Table 40), S1-16 is explicitly listed with "Phase-in (< 750 FTE)" noted, though individual sub-metrics are not broken down.

Methodology

No specific methodology for pay gap or remuneration ratio is disclosed. The company confirms having fewer than 750 FTEs (569 total FTE as of year-end 2024 for SOFF) and has applied phase-in provisions accordingly. General remuneration governance is described in the Corporate Governance section and Note 12 on Personnel Expenses, including executive remuneration structures, but quantitative S1-16 metrics are omitted under phase-in allowance.

Incidents, complaints and severe human rights impacts

Work-Related Human Rights Metrics (2024)

Additional Context

Complaints filed through channels of the National Contact Points for OECD Multinational Enterprises related to the matters defined in paragraph 2 of ESRS S1 has not been applicable for this reporting period. If applicable for the reporting period, the most relevant amount(s) related to reconciliation of fines, penalties, and compensation for damages as result of Human rights incidents is presented in financial statements.

In 2024, no complaints were made related to human rights issues through the Company's grievance mechanism.

Grievance Mechanism

The Company has implemented a group-wide grievance mechanism for complaints about detrimental behaviour regarding ethics, integrity and compliance issues (including human rights topics). Complaints can be submitted anonymously, by internal as well as external stakeholders, and are treated confidentially and in a timely manner. Any person who feels that their human rights have been violated by activities of Solstad or an actor of the value chain can contact the Company through this mechanism.

Policies related to value chain workers

Solstad Offshore addresses policies related to value chain workers through several interconnected policies and codes:

Company Philosophy, Objectives and Strategy Policy

• Scope: Covers the company's overall approach to human rights and decent working conditions
• Governance: Not explicitly disclosed
• Key content/principles: Aligned with the UN Guiding Principles on Business and Human Rights, considering the Guiding Principles of the International Bill of Rights (including the Universal Declaration of Human Rights and the two Covenants), as well as the International Labour Organisation's Declaration on Fundamental Rights and Principles at Work and its core conventions
• Public availability: Not disclosed
• Links to international standards: UN Guiding Principles on Business and Human Rights, International Bill of Rights, Universal Declaration of Human Rights, ILO Declaration on Fundamental Rights and Principles at Work and core conventions

Supplier Code of Conduct

• Scope: Directed at all suppliers, including sub-suppliers, contractors, sub-contractors, agents and consultants; therefore covers all upstream value chain workers
• Governance: Not explicitly disclosed
• Key content/principles:
  • Requires alignment with UN Guiding Principles on Business and Human Rights, ILO Declaration on Fundamental Principles and Rights at Work, and OECD Guidelines for Multinational Enterprises
  • Requires compliance with applicable national and international laws, regulations and standards, both in country of origin and where they operate
  • Explicitly addresses forced and compulsory labour (but not trafficking of human beings or child labour)
  • Requires suppliers to meet, as a minimum, national or industry standards on working hours, breaks, wages and social benefits (whichever affords the greatest protection)
  • Wages should be enough to meet basic needs
  • All employees must be provided with written employment agreements in a language understandable to the individual
  • Payments to be made timely, in legal tender and fully documented
• Public availability: Not disclosed
• Links to international standards: UN Guiding Principles on Business and Human Rights, ILO Declaration on Fundamental Principles and Rights at Work, OECD Guidelines for Multinational Enterprises
• Monitoring: Compliance monitored through encouraging suppliers to inform on the subject and performing audits where and when deemed necessary. Audits can be triggered by reported incidents or high risk identified during onboarding of new suppliers. Internal HSE reporting system allows daily reporting of deviations or breaches from all employees, linking specific suppliers to incidents if possible

Group Procurement Policy

• Scope: All purchases over 500,000 NOK
• Governance: Not explicitly disclosed
• Key content/principles:
  • Committed to integrating sustainable practices into procurement processes
  • Minimizing Environmental, Social, and Governance (ESG) risks throughout the supply chain
  • Driving sustainable development
  • Requires 'Responsible Sourcing' approach aligned with commitment to social responsibility, environmental sustainability, and ethical business practices
  • Prioritizes ethical suppliers who demonstrate adherence to high standards
• Public availability: Supplier Terms and Conditions available at www.solstad.com/procurement/
• Links to international standards: Not explicitly disclosed
• Monitoring: All procurement activities must adhere to Code of Conduct, Supplier Code of Conduct, Sanctions Compliance Program, Power of Attorney, and other applicable policies emphasizing sustainability principles

Code of Conduct

• Scope: Referenced as applicable to procurement activities
• Governance: Not disclosed
• Key content/principles: Must be adhered to in all procurement activities
• Public availability: Not disclosed for value chain context
• Links to international standards: Not disclosed

Health and Safety Policies (for downstream client personnel)

• Scope: Issues concerning health and safety of client personnel (downstream value chain workers) on Solstad vessels
• Governance: Not disclosed
• Key content/principles: Same policies as for own workforce health and safety (referred to ESRS S1)
• Public availability: Not disclosed
• Links to international standards: Not disclosed
• Monitoring: Bridging document signed by both parties at start of contract outlining requirements for both Solstad and client to ensure safe working environment

Non-respect of frameworks

During the reporting year, there were no registered cases of non-respect of the UN Guiding Principles on Business and Human Rights, ILO Declaration on Fundamental Principles and Rights at Work, or OECD Guidelines for Multinational Enterprises that involve value chain workers.

Taking action on material impacts on value chain workers

Overview

Solstad is committed to addressing material impacts on value chain workers and managing related risks and opportunities effectively. The focus is primarily on upstream workers (particularly yard workers during maintenance projects), as client-related downstream workers' IROs are less challenging and Solstad has less influence on them.

Actions Implemented

1. Enhanced Management System (2-year initiative)

Scope: Upstream value chain (suppliers, yard workers)

Time horizon: Past two years (implemented)

Description: Enhanced management system to prevent and mitigate material negative impacts on value chain workers, including:

• Implementing policies and practices ensuring fair treatment
• Safe working conditions
• Respect for worker's rights

2. Supplier Code of Conduct Requirements

Scope: All upstream value chain workers (suppliers, sub-suppliers, contractors, sub-contractors, agents, consultants)

Description:

• Mandatory adherence to Solstad Supplier Code of Conduct
• Alignment with UN Guiding Principles on Business and Human Rights
• ILO Declaration on Fundamental Principles and Rights at Work
• OECD Guidelines for Multinational Enterprises
• Compliance with national and international laws

Key policy provisions:

• Addresses forced and compulsory labour
• Working hours, breaks, wages and social benefits (meeting minimum national or industry standards)
• Written employment agreements in understandable language
• Timely payments in legal tender, fully documented

3. Yard Qualification and Monitoring Programme

Scope: Upstream value chain (shipyards)

Time horizon: Ongoing

Actions include:

• Yard qualification procedure and pre-meetings with shipyard management
• Using only preselected, trusted shipyards from various global regions for planned maintenance
• Project managers (technical superintendents) perform spot checks for human rights breaches as part of project execution checklist
• Regular spot checks by project leaders during maintenance projects
• Auditing selected shipyards at any given time during their work for Solstad
• Collaboration with Sea1 ASA (previously Siem Offshore ASA) to share information and lessons learned about shipyards

Resources (non-financial):

• Team comprising over 50 individuals from various departments (Purchase, HSEQ, Technical)
• Project leaders responsible for monitoring and identifying breaches
• Personnel conducting audits

4. Supplier Approval and Monitoring Process

Scope: Upstream value chain (all key suppliers)

Time horizon: Ongoing

Description:

• Extensive self-assessment process for suppliers
• Electronic web-form system for reporting on business-critical processes including sustainability
• Scoring system with traffic light visualization against threshold values

Key areas monitored:

• Quality Management
• Health and Safety Management
• Sustainability & Environmental
• Policies

Follow-up: Deeper investigation if suppliers do not comply, with potential supplier changes

5. Internal Reporting and Escalation System

Scope: All value chain

Time horizon: Ongoing

Description:

• Daily reporting through internal HSE system linking suppliers to incidents
• Deviations/breaches reported on daily basis
• Short-term urgent follow-up and long-term annual supplier meetings
• TM Purchasing system for monitoring

6. Whistleblower Channel

Scope: All value chain workers

Time horizon: Operational, with planned enhancement by 2025

Description:

• General whistleblower channel allowing value chain workers to communicate directly to Solstad
• Planned inclusion in Supplier Code of Conduct by 2025 (requiring suppliers to have such channels in their workplaces)

Planned Actions (Next 1-2 Years)

7. Positive Impact Programmes

Scope: Upstream value chain workers

Time horizon: Next two years (planned)

Description: Programmes aimed at:

• Improving workers' skills
• Providing better working conditions
• Enhancing overall well-being

Monitoring: Future tracking through continuous dialogue and engagement with value chain workers and their representatives

8. Enhanced Stakeholder Engagement

Scope: Value chain workers

Time horizon: Next 1-2 years

Description: Strengthening processes to engage more directly with value chain workers on material topics

Resources Allocated

Financial: Not quantified

Non-financial:

• Dedicated teams: Over 50 individuals from Purchase, HSEQ, Technical departments
• Partnerships: Collaboration with Sea1 ASA for information sharing
• Systems: SIMS management system, HSE database, TM Purchasing system, external whistleblower platform
• Personnel: Project leaders, technical superintendents, auditors, Group Compliance officer, Administration and Communication Director, Legal position within Finance department

Effectiveness and Continuous Improvement

The company commits to:

• Regular review and update of policies, practices, and initiatives
• Alignment with evolving international standards and stakeholder expectations
• Continuous improvement approach

Current status: No actual material impacts uncovered on value chain to date; therefore no remediation initiatives have been required

Metrics and Targets

Key metric: Number of approved suppliers in internal purchasing system tracked to ensure all key suppliers have completed qualification program and are part of systematic audit and follow-up processes

Note: No specific quantitative targets set for reducing negative impacts, advancing positive impacts, or managing risks related to value chain workers beyond the supplier approval tracking

Reporting and Transparency

Annual disclosure of statements under:

• Norwegian "Transparency Act"
• UK "Modern Slavery Act"

Statements signed by CEO and Chairman detail actions taken during reporting year, due diligence outcomes, and reportable cases (publicly accessible at www.solstad.com/investors/corporate-social-governance/)

Targets related to value chain workers

The company tracks the number of approved suppliers in the internal purchasing system to ensure that all key suppliers have completed the qualification program and are part of systematic audit and follow-up processes. Indirectly, this supplier approval process tracks impacts on to workers in the upstream value chain, as a number of criteria for approval relates to whether the supplier provides decent working conditions and safeguards their human rights.

Specific targets

The company has not set other specific targets for value chain workers related to:

• Reducing negative impacts on value chain workers
• Advancing positive impacts on value chain workers
• Managing material risks and opportunities related to value chain workers

Future plans

As mentioned in S2-2, Solstad aim to strengthen the process to engage more directly with value chain workers on these topics over the next 1-2 years.

Business conduct policies and corporate culture

Solstad Offshore has cultivated a strong corporate culture rooted in core values and ethical standards. The company's business conduct policies are anchored in its foundational values: safety, reliability, competence, and responsibility. These guiding principles are essential in fostering a unified and resilient company culture.

Code of Conduct

Scope: The Code of Conduct is mandatory for all employees to follow and is available through the SIMS (Solstad Integrated Management System). It applies to Board Members, Management and employees of the Solstad Group.

Governance and oversight: Individual managers are responsible for ensuring that the Code of Conduct guidelines are known and followed. The Board of Directors have signed and implemented the Code of Conduct. The company has established a dedicated position in the Finance department for handling legal- and whistle-blower issues, processes related to business conduct and reporting. Any reported issues or breaches are reported to the CEO/CFO for further processing and then to the Sustainability Director for the attention of the Audit Committee.

Key content/principles: The Code of Conduct outlines expected behaviours and practices, emphasizes compliance with laws and regulations, fair treatment of all stakeholders, and ethical decision-making. It promotes equal opportunities and the elimination of all types of discrimination, including on the grounds of religion, skin colour, sex, sexual orientation, age and disability. As outlined in the Code of Conduct, Solstad is dedicated to upholding human rights and ensuring decent working conditions across all its operations. The Code supports the United Nations Global Compact and is committed to integrating the 10 principles of ethical business conduct into business strategy and operations.

Links to international standards: The Code of Conduct is consistent with the UN Guiding Principles on Business and Human Rights, considering the Guiding Principles of the International Bill of Rights (including the Universal Declaration of Human Rights and the two Covenants), as well as the International Labour Organisation's Declaration on Fundamental Rights and Principles at Work and its core conventions. Solstad has supported the United Nations Global Compact over many years.

Public availability: The Code of Conduct is available through the SIMS system. It is part of the company induction courses that is mandatory for all employees and other key stakeholders.

Monitoring implementation: All Solstad employees are kept accountable for behaviour. SOFF is audited annually by internal resources and externally by DNV on its policies, processes, records and other relevant documentation to verify compliance with all relevant rules and regulations. Any deviations lead to Non-Conformities or Observations that are registered in the company's HSE system together with a correction plan for follow up and a deadline. The Code of Conduct is mandatory for all employees and compliance is part of the annual appraisal process. Every two years an employee survey is conducted to get targeted information on the company culture and how the company's values and standards are understood by employees.

Anti-Bribery, Corruption, Fraud and Whistle Blower Policy

Scope: Applies to all Solstad employees both officially and privately.

Key content/principles: The purpose of this policy is to ensure a non-tolerance for any type of bribery, corruption, fraud and other criminal or unethical behaviour in the company. The policy protects individuals using the whistle blower channel against retaliation, stipulating that no retaliatory action will be taken against them. The policy also states that concerns can be expressed anonymously.

Links to international standards: This policy is consistent with the UN Convention against Corruption.

Public availability: Dedicated posters have been made to highlight the company's zero tolerance against corruption and bribery. These posters are displayed at key locations and vessels.

Monitoring implementation: The Group Compliance officer (within the Finance department) and the Administration and Communication Director are responsible for these processes. Training on Anti-corruption and bribery is mandatory for all employees through e-learning courses (see below).

Health and Safety Policy

Scope: Applicable to the entire workforce.

Governance and oversight: The SIMS system serves as the framework for management of all health and safety-related impacts and mitigating activities.

Key content/principles: Solstad never compromises on safety. Safety is one of the core values and is always a priority for all employees. The cornerstone of this effort is the Solstad Incident Free Operations (SIFO) program. Given the inherent safety and security risks related to operations at sea, the company focuses on evaluating, facilitating, planning and preventive measures to avoid all types of personnel-related injuries and incidents that negatively impact the working environment.

Monitoring implementation: The company has developed an extensive management system that includes a process-based quality system, an extensive HSE reporting system with incident and positive feedback reporting, risk handling, Management of Change, Drills management and audit/investigations portal.

Supplier Code of Conduct

Scope: Directed at all suppliers, including sub-suppliers, contractors, sub-contractors, agents and consultants and therefore covers all upstream value chain workers.

Key content/principles: The Supplier Code of Conduct states that alignment with the UN Guiding Principles on Business and Human Rights, ILO Declaration on Fundamental Principles and Rights at Work or OECD Guidelines for Multinational Enterprises is a requirement. Suppliers are required to comply with other applicable national and international laws, regulations and standards, both in their country of origin and where they operate. The policy explicitly addresses forced and compulsory labour. When it comes to working hours, breaks, wages and social benefits, it states that suppliers shall meet, as a minimum, national or industry standards, whichever affords the greatest protection. Wages should be enough to meet basic needs. Suppliers must ensure that all employees are provided with written agreements of employment, setting out employment conditions in a language that is understandable to the individual concerned. Payments are to be made timely, in legal tender and fully documented.

Links to international standards: The policy requires alignment with the UN Guiding Principles on Business and Human Rights, ILO Declaration on Fundamental Principles and Rights at Work, and OECD Guidelines for Multinational Enterprises.

Public availability: General Supplier Terms and Conditions can be found on Solstad's web page at www.solstad.com/procurement/

Monitoring implementation: The company monitors compliance through encouraging suppliers to inform on the subject and performs audits where and when deemed necessary. The Solstad supplier approval process consists of an extensive self-assessment process where suppliers report on a range of business-critical processes including Sustainability matters. Project leaders perform spot checks on yards during maintenance projects. All procurement activities must adhere to Solstad's Code of Conduct, Supplier Code of Conduct, Sanctions Compliance Program, Power of Attorney, and other applicable policies emphasizing sustainability principles.

Training and Implementation

All employees create an individual competency development plan in cooperation with their immediate leader. E-learnings on sustainability topics is mandatory for all employees. Solstad has a development team devoted to developing internal e-learning courses for specific topics, such as Sustainability, Anti-corruption, sanctions, cyber security, among others.

Anti-Corruption and bribery training: The mandatory e-learning course takes about 15 minutes to complete and is required for all employees and other workers including managers and executive management (however board members are not enrolled in this course). Topics covered include: "Definition of corruption", "Policy", "Procedures and Suspicion/Detection", and "Dilemma training". The course needs to be refreshed yearly. About 90% of employees have completed training by year-end 2024. The total number of employees at-risk function in the SOFF scope is estimated to be 800 FTE.

Other Policies and Procedures

Transparency on Human Rights and Working Conditions procedure: To support the commitment to upholding human rights, Solstad has established a thorough procedure to promote ethical business practices. This procedure aligns with the UN Guiding Principles on Business and Human Rights, the ILO Declaration on Fundamental Principles and Rights at Work, and the OECD Guidelines for Multinational Enterprises. It strictly prohibits any infringement of human rights, while actively promoting their respect along with decent working conditions across all activities. The Procedure explains how Solstad annually conducts due diligence according to the OECD Guidelines and the Norwegian Transparency Act.

Company Philosophy, Objectives and Strategy policy: At the highest level, Solstad's work on human rights and decent working conditions is anchored in this policy, which is in alignment with the UN Guiding Principles on Business and Human Rights.

Sustainability policy: Supports the overall framework for business conduct and sustainability management.

Group Procurement Policy: States that "Responsible Sourcing" shall apply, defined as an approach aligning with commitment to social responsibility, environmental sustainability, and ethical business practices. Solstad prioritizes ethical suppliers who demonstrate adherence to high standards.

Statements and Reporting

Every year, the company discloses statements signed by the CEO and Chairman of the Board related to the Norwegian "Transparency Act" and the UK "Modern Slavery Act". These publicly accessible statements detail the company's actions on these topics during the reporting year, including the due diligence outcomes and any reportable cases. Available at: www.solstad.com/investors/corporate-social-governance/

Prevention and detection of corruption and bribery

Solstad Offshore has implemented a corruption prevention programme with control mechanisms based on risk assessment, including geographical and sectoral criteria. Anti-corruption is an integral part of the company's Code of Conduct and Safety and Integrated Management System (SIMS).

Anti-Corruption Policy

Policy name: Anti-corruption policy

Scope: All employees, suppliers, and business partners. The policy applies worldwide and covers both crew and onshore employees.

Key content:

• Published to employees, suppliers, and business partners
• Describes what is considered corruption and bribery
• Specifies business areas/departments where it applies
• Outlines training requirements
• Establishes record keeping and management reporting procedures

Public availability: Published (specific URL not disclosed)

Governance:

• Group Compliance Officer is responsible for the policy
• Administration and Communication Director shares responsibility
• Legal position within Finance department has overall responsibility for following up issues related to corruption and bribery
• Board receives reports on cases in quarterly Audit Committee meetings

Links to international standards:

• Consistent with UN Convention against Corruption
• Part of minimum safeguards aligned with OECD Guidelines for Multinational Enterprises and UN Guiding Principles on Business and Human Rights

Monitoring and implementation:

• Regular training of employees is mandatory
• Specific training for employees identified as exposed to corruption risks
• Mandatory annual e-learning course (approximately 15 minutes) covering: definition of corruption, policy, procedures and suspicion/detection, and dilemma training
• Annual refresher e-learning course mandatory for all employees
• About 90% completion rate by year-end 2024
• Course topics include: definition of corruption, policy, procedures and suspicion/detection, and dilemma training
• Total number of employees at-risk function estimated at 800 FTE
• Board members covered by 'rules of procedures' and have signed Code of Conduct (though not enrolled in e-learning)

Anti-Bribery, Corruption, Fraud and Whistle Blower Policy

Policy name: Anti-Bribery, Corruption, Fraud and Whistle Blower Policy

Scope: All Solstad employees (both official and private behaviour)

Key content:

• Zero tolerance for any type of bribery, corruption, fraud and other criminal or unethical behaviour
• Ensures accountability for employee behaviour
• Dedicated posters displayed at key locations and vessels highlighting zero tolerance

Links to international standards:

• Consistent with UN Convention against Corruption

Code of Conduct

Policy name: Code of Conduct

Scope: Board Members, Management, and employees of the Solstad Group. Also integrated into business contracts and Supplier's Code of Conduct.

Key content:

• Ethical guideline emphasizing integrity, transparency, and accountability
• Anti-corruption and bribery provisions are integral
• Outlines expected behaviours and practices
• Emphasizes compliance with laws and regulations
• Fair treatment of all stakeholders
• Ethical decision-making

Public availability: Available through SIMS system; mandatory for all employees

Governance:

• Approved by the Board of Directors
• Individual managers responsible for ensuring guidelines are known and followed
• Executive Management and Board responsible for fostering compliant working culture
• Executive Management promotes the code

Links to international standards:

• Part of minimum safeguards framework aligned with OECD Guidelines for Multinational Enterprises and UN Guiding Principles on Business and Human Rights

Monitoring and implementation:

• Mandatory for all employees
• Important part of company induction courses for all employees and key stakeholders
• Annual training mandatory for all employees
• Annual appraisal process includes evaluation of company culture implementation
• Employee survey conducted every two years
• Annual management meetings to discuss culture and communicate expectations

Supplier's Code of Conduct

Policy name: Supplier's Code of Conduct

Scope: All suppliers and their employees and subcontractors

Key content:

• Promotes and enforces practices relating to human rights, ethics, protection of the environment and safety
• Expects suppliers to respect the Group's ethical principles
• Minimum safeguards requirements are integral part of business contracts

Monitoring and implementation:

• Supplier selection and evaluation processes include anti-corruption and anti-bribery due diligence
• Regular supplier audits conducted

Control Mechanisms and Prevention Measures

The company has implemented several preventive control mechanisms:

• Restricted access to relevant ICT systems (depending on role)
• Power of Attorney on all purchases ensuring at least two people approve
• Contract approvals require at least two approvals
• Internal control on accounting/finance
• Wages payment and employment processes are separated
• Risk assessment system available when needed
• High-risk functions identified include: Captain/Chief Engineers on vessels, Chartering, Operations, Purchasing, Technical, Crewing, and Executive managers

Grievance Mechanism

The company has implemented a group-wide grievance mechanism:

• Covers complaints about detrimental behaviour regarding ethics, integrity and compliance issues (including the four minimum safeguards topics)
• Complaints can be submitted anonymously by internal and external stakeholders
• Treated confidentially and in a timely manner
• Regular evaluation of incoming complaints
• Assessment of necessary adjustments to procedures
• Whistle-blower channel is main channel for receiving claims
• Dedicated position in Finance department for handling legal and whistle-blower issues
• Reported issues escalated to CEO/CFO then to Sustainability Director for Audit Committee
• External investigators used when necessary for challenging internal investigations
• Management decides investigation outcomes and informs Audit Committee

Performance

In 2024, no allegations of corruption and bribery were reported. During the reporting year there have not been any confirmed corruption or bribery incidents in the company's own operations or value chain where employees are directly involved.

Incidents of corruption or bribery

Confirmed incidents

During the reporting year 2024, Solstad Offshore reported zero confirmed incidents of corruption or bribery in the company's own operations or in the company's value chain where Solstad employees are directly involved.

Convictions and fines

No convictions or legal decisions (criminal or administrative) related to corruption or bribery were reported for the 2024 reporting period. The company explicitly states: "There have been no significant costs related to corruption and bribery during the reporting year."

Disciplinary actions

No employees were dismissed or disciplined due to corruption or bribery during the reporting period.

Contracts terminated

No contracts with business partners were terminated or not renewed due to corruption or bribery issues during the reporting period.

Investigation procedures and speak-up mechanisms

Solstad has implemented a dedicated whistleblower channel available on the company's website (www.solstad.com/whistleblowing/). The channel is well-implemented and communicated both internally and externally, including in the management system, on the company's webpages, and in the annual disclosure on the Transparency Act. All stakeholders may report through this channel without risk of retaliation.

Submitted reports are promptly registered and reviewed by qualified personnel, including an internal legal expert and one external lawyer from Wikborg & Rein. A dedicated Investigation checklist in the management system ensures proper handling of each case, involving relevant personnel as needed. In cases of high importance, external assistance and/or investigation may be required.

The Group Compliance Officer is the single point of contact to manage the response to claims. If the complaint is filed against the Group Compliance Officer, CFO, or other high-ranking officers, an independent third-party, such as an appointed lawyer, handles the claims to ensure impartiality and appropriate follow-up.

Solstad enforces an "Anti-Bribery, Corruption, Fraud and Whistle Blower Policy" to protect individuals using this channel against retaliation, stipulating that no retaliatory action will be taken against them. The policy also states that concerns can be expressed anonymously.

The company has established a Legal position within the Finance department with overall responsibility for following up any issues related to corruption and bribery, supported by key personnel in Solstad and external legal resources.

Training and prevention

All Solstad employees are required to complete mandatory anti-corruption and bribery e-learning training. The Anti-Corruption and bribery e-learning course takes about 15 minutes to complete and is mandatory for all employees and other workers including managers and executive management. By year-end 2024, approximately 90% of employees in at-risk functions (estimated at 800 FTE) had completed training. The course needs to be refreshed yearly and covers topics including "Definition of corruption", "Policy", "Procedures and Suspicion/Detection", and "Dilemma training".

Payment practices

Contractual payment terms

For the majority of contracts, payment is generally due within 30-60 days after the end of each month or 30-60 days after the service is completed. Payment terms for all other services is normally 30 days after services is invoiced.

Additional payment-related information

Revenue recognised in 2024 that was included in the contract liability balance at the beginning of the year amounts to MNOK 11.56 (MNOK 3.6 in 2023).

Amounts in thousands of NOK.

Contract liabilities are invoiced revenues, but where the performance obligation is not fulfilled.