Solstad Offshore

The role of the administrative, management and supervisory bodies

Reference: pages 35-36; board diversity and independence datapoints also indexed at page 35 (Appendix B, page 108).

The Board of Directors comprises five members, with a gender distribution of three men (60%) and two women (40%). "Currently, the Board does not include employee representatives. Of the five members, three are independent (60%)" (page 35). The Audit Committee includes three Board Members, with the CFO, Sustainability Director and finance staff attending.

Executive Management consists of four members, the CEO, CFO, COO and CCO, and "All members are men (0% female). There are no non-executive members represented" (page 35).

The Board holds ultimate responsibility for sustainability strategy, impacts, risks and opportunities; the Audit Committee oversees sustainability matters and reporting alongside financial reporting, and reviews action plans, targets and results. The Sustainability Director reports to the COO, who then reports to the CEO (page 35). The Board reviews strategy, plan and status for long-term sustainability goals "at least annually".

Competence is managed through a competency matrix plus external CSRD courses for managers and key personnel, and ISO 14001 and ISO 50001 courses for sustainability professionals. External expertise is available "through external consultants and auditors, including those from EY, Deloitte, and DNV" (page 35). The management framework is the Solstad Integrated Management System (SIMS), certified to IMO ISM, ISO 9001, 14001, 45001 and 50001, MLC and ISPS, verified annually by DNV (page 36).

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

Reference: pages 36-37 (Table 1).

A Sustainability Committee comprising "the CEO, CFO, COO, Sustainability Director, Communications and Administration Director, the Group Compliance Office and the Sustainability Advisor" 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, are presented to the Audit Committee and, if necessary, the full Board (page 36).

"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" (page 36).

Table 1 (page 37) logs which sustainability topics reached the Sustainability Committee in the reporting year and in which quarters:

Executive Management, with the Board, reviews the Company strategy annually; significant changes undergo a risk evaluation using a high-level risk matrix (page 37).

Integration of sustainability-related performance in incentive schemes

Reference: page 37.

Solstad Offshore discloses a nil position. "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" (page 37).

"The Board of Directors reviews and approves the incentive schemes for the Executive Management team on an annual basis" (page 37).

No percentage of variable remuneration linked to sustainability or climate-related considerations is disclosed, because none is applied. This is unchanged from the FY2024 statement.

Statement on due diligence

Reference: page 37 (Table 2); datapoint indexed to page 37 in Appendix B (page 108).

"Annually, the Company carries out two due diligence processes encompassing sustainability matters." First, under the Norwegian Transparency Act, the Company assesses human rights and decent working conditions in its global supply chain and own operations; the resulting statement is "signed by the CEO and the Chairman of the Board" and published on the Company's website. Second, a due diligence process is performed "in accordance with the ISO 14001 certification", with all identified environmental impacts and new regulations documented in the management system and "DNV serving as the supervisory body for this process" (page 37).

Table 2 (page 37) maps the core elements of due diligence to the statement:

Risk management and internal controls over sustainability reporting

Reference: pages 38-39 (Table 3, page 38).

Solstad Offshore is candid about the maturity of its controls. "The Company plans to start implementing the Internal Control over Financial Reporting (ICFR) and Internal Control over Sustainability Reporting (ICSR) standards during 2026. Until this framework is in place the Company uses internal defined processes and policies in the SIMS system" (page 38). "Over the past year, the Company has tried to utilize newly developed CSRD reporting tools, but with limited success due to immature Systems", and "Excel spreadsheets controlled by the sustainability department is used to consolidate all data and transfer controlled data to annual reports" (page 38).

Source systems are named: environmental data via the sustainability department; safety statistics via HSSQ using "Unisea HSE" and "Unisea Daily Report"; HR (S1) data via "OCS HR"; value chain reporting via the "TM" purchasing system; whistleblower data via the external platform "IntegrityLog" (page 38).

Table 3 (page 38) lists four high-level sustainability risks for 2025 with named owners and mitigation plans: HSE statistics (COO); human rights and working conditions (Sustainability Director); ability to take market share in renewables (CCO); and climate risk (Sustainability Director).

Strategy, business model and value chain

Reference: pages 39-43 (Figure 1 page 33, Figure 2 page 42, Tables 4-7 pages 41-42).

Solstad Offshore ASA is a Norwegian-listed owner and operator of offshore vessels. After the January 2024 split, "This sustainability report pertains only to Solstad Offshore, which at year-end retains 6 owned vessels. Up to nine vessels were leased from Solstad Maritime at year-end 2025" (page 39), plus one CSV held through a 50% JV. The fleet is construction service vessels (CSV) and anchor handling tug supply (AHTS) vessels.

Revenue by significant sector (Table 5, page 41): Mining - Oil & Gas - Upstream & Services (MOU) USD 290,350,310, 100%; Energy - Energy Production & Utilities (EEU, renewable activity) USD 0, 0%.

Fossil fuel and controversial-sector datapoints: "The Company is not involved in chemicals production, controversial weapons or cultivation and production of tobacco" (page 40, indexed to page 39 in Appendix B).

Headquarters is Norway; the main operational office is Brazil (Rio de Janeiro and Macae), supported through management service agreements by Solstad Maritime offices in Norway, Singapore, the Philippines, Australia and the UK (page 40). "During the reporting period, the Company had about 1,500 suppliers in the upstream value chain" (page 40). "The Company does not source or use raw materials directly in its value chain" (page 40). Clients are located "mainly Brazil, Italy and Sweden" (page 43).

Workforce (Table 4, page 41): SOFF 905 (833 crew, 72 onshore), all Brazil; SOMA 1,364.

Interests and views of stakeholders

Reference: pages 43-45 (Figure 3 page 43, Table 8 page 45, Table 10 page 51); topic-level SBM-2 for own workforce page 84 and for value chain workers page 96.

Stakeholder categories are maintained in SIMS and reviewed "at least annually" (page 43). Table 8 (page 45) sets out eight interested parties with their interests and engagement type: customers (annual satisfaction surveys), shareholders/investors (AGM, stock exchange reporting), suppliers (regular meetings, supplier code of conduct, supplier audits), employees and unions (general meetings, two-yearly working environment survey, annual appraisal talks, union follow-up), regulators, NGOs (principally the Norwegian Shipowners' Association), local communities, and mortgagees.

"The Company's interested parties also include silent stakeholders, such as wildlife and nature, which cannot express their needs... The Company's engagement with such stakeholders occurs though proxies, such as non-governmental organizations" (page 44).

Amendments made in response to stakeholder views include employing own staff rather than contracted labour, prioritising health and safety, increasing the proportion of women, entering renewable vessel rental, installing ballast water treatment systems and advancing Solstad Green Operations (page 44).

Table 10 (page 51) records the DMA engagement: digital surveys with key clients (8), key suppliers (6), unions (12), employees (32), banks and investors (4) and NGOs/regulators (2), all marked "Re-used for FY 2025".

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

Reference: pages 45-49 (Table 9); topic-level SBM-3 at pages 66-67 (E1), 84-86 (S1) and 96-97 (S2).

"The Company's material IROs have been assessed to be from the topical standards E1 Climate Change, E2 Pollution, E4 Biodiversity, S1 Own Workforce, S2 Workers in the Value Chain and G1 Governance" (page 45). "The majority of the Company's material risks, impacts and opportunities are linked to activities in its own business model" (page 45). "There are no significant changes to the IROs this year compared to previous years. The Company use entity-specific disclosures for S1-6 and S1-14 for TRCF and LTIF calculations due to industry standard requirements" (page 45).

Table 9 (pages 46-49) sets out each material sub-topic with its value chain position, impact, risk and opportunity and time horizons. Eleven material matters are shown in Figure 4 (page 53) against "78 - ST/SST: Not material".

The phase-in for SBM-3 paragraph 48(e) (anticipated financial effects) is used: "SOFF utilizes the phase-in provision for SBM-3 48 e, also for this year's Sustainability Statement" (page 86; repeated for S2 at page 97; recorded as omitted in Appendix A, page 106).

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

Reference: pages 50-52 (Tables 10 and 11); topic-level IRO-1 at pages 62-63 (climate), 79-80 (pollution) and 103 (business conduct).

The DMA "was carried out in five steps": mapping and initial steps; stakeholder engagement and use of external experts and systems; detailed evaluation and stakeholder validation; prioritization of material matters; monitoring and internal control (page 50).

The generic product categories analysed were marine gasoil fuelled ship freight transport services for construction of offshore oil rigs, offshore rig moving services, and the same freight service for offshore wind power plants. Financial categories analysed were revenue, CapEx and OpEx (page 50).

"a science-based analysis has been used where we have employed the data engine from Upright, a recognized impact data company" as a top-down starting point (page 50). "The materiality level thresholds are based on Uprights' database comprising more than 50,000 companies" (page 51). Impact materiality is scale x scope x irremediability x likelihood, each scored 1-3, "where minimum impact would be 1 and maximum impact would be 81". Financial materiality is magnitude x probability using a 5x5 matrix "categorized from A (low=no cost) in steps to E (Very high > USD 1 000 000)" (page 51).

Table 11 (page 52) gives the thresholds: impact materiality low <20, medium 20-50, high >50; financial materiality low <8, medium 8-40, high >40. "Where the materiality score is medium or high, the sustainability matter is considered material."

"During 2024/2025 the Norwegian Shipowners' Association surveyed a range of shipping companies in Norway to compare DMA results in the first year of CSRD. The conclusion was that our DMA is consistent with the results from similar companies" (page 51).

"S1 and S2 does not have ESRS 2 IRO-1 requirements" (page 52).

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

Reference: pages 52-53; Appendix A - Reporting Scope by Topic, Table 40, pages 106-107; Appendix B - list of datapoints deriving from other EU legislation, Table 41, pages 108-111.

Appendix A is the statement's concordance. It lists, per topic, the material sub-topics, the disclosure requirements in the topical standard, which cover policies/actions/targets and which cover metrics, the phase-in and "quickfix" reliefs available to an undertaking with fewer than 750 FTE, and a final column, "Disclosure Requirements Omitted by SOFF due to 'phase in' or 'not material'". That column reads: ESRS 2 - SBM-3 paragraph 48(e) (phase in); E1 - E1-9 (phase in); E2 - E2-5 (not material), E2-6 (phase in); E3 - All (not material); E4 - All (phase-in); E5 - All (not material); S1 - S1-8, S1-10, S1-11, S1-12, S1-13, S1-15 (all not material); S2 - None; S3 - All (not material); S4 - All (not material); G1 - G1-2, G1-5, G1-6 (all not material).

Immateriality is explained in the body: "ESRS E3: Though the Company's ships operate in a marine environment, their impact on water and marine resources is considered to be minor"; "ESRS E5: The process to recycle ships at the end of their life was first considered to be material. However, as the Company has not recycled any vessels in the reporting period... this topic was excluded for this reporting year"; "ESRS S3... the impact, risks and opportunities connected to this are considered not material"; "ESRS S4... the Company has a very low number of clients at any given time (20-30 total word-wide and about 5-10 strategic)" (pages 52-53).

Note that Appendix A carries no page numbers; page-level cross-references appear only in Appendix B, and only for datapoints derived from other EU legislation.

Transition plan for climate change mitigation

Reference: pages 63-66; datapoint indexed to page 63 in Appendix B (page 108).

Solstad Offshore states plainly that it has no transition plan under the ESRS. "However, at this point the Company has not developed a ESRS compliant transition plan" and "the Company has yet to defined a detailed transition plan for the company" (page 63).

What is disclosed instead: "In line with investor and industry expectations within the shipping sector, the Company has set a long-term ambition to reach net-zero greenhouse gas emissions for 2050, aligned with limiting global warming to 1.5°C" (page 63). Since 2010 all vessel GHG emissions have been publicly reported.

The reasons given are technological and regulatory: "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. In addition, with the announced revised CSRD reporting thresholds applicable most likely from 2026 or 2027 for SOFF, this work has been put on hold until new regulations are adopted by the commission and publicly available" (page 66).

Key decarbonisation measures "expected to be included" in a future plan (page 66): operational measures (Solstad Green Operations, since 2010); existing technology retrofit (battery hybrid and shore power); drop-in biofuels (HVO or FAME); and fleet renewal with dual-fuel engines or fuel cells and green/blue/bio methanol or ammonia.

The statement also says the 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" (page 66). The sentence is ambiguous as printed, and no locked-in emissions figure appears anywhere in the report.

Identification of climate-related risks and scenario analysis

Back-filled from ESRS 2 IRO-1 for climate (pages 62-63), the scenario table (Table 25, page 64), the risk taxonomy (Table 26, page 66) and ESRS 2 SBM-3 (pages 66-67), where this content is disclosed in the FY2025 report. This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Risk classification (adopted ESRS paragraph 15). Physical and transition risks are separated. "In the double materiality assessment process, no identified physical climate-related risks were assessed as material. However, the assessment found that the Company is faced with material transitional risks through changes in the demand and supply of its services, the regulatory and policy environment, the availability and cost of capital, and through altered reputation and stakeholder expectations" (page 66). Table 26 (page 66) itemises chronic and acute physical hazards and transition risks under policy and legal, technology, market and reputation headings.

Methodology and exposure (paragraph 16). "the company has conducted a Climate Scenario Analysis by use of the publicly available TCFD tools", drawing on "the Intergovernmental Panel of Climate Change's 6th Assessment Report (IPCC6, 2021)" (page 62). "The climate scenario analysis encompassed all parts of the Company's value chain" (page 63). Time horizons differ by risk type: physical 2025-2030, 2031-2050 and 2051-2100; transition 0-5, 5-10 and 10-30+ years (page 63).

Scenarios (paragraph 17). Physical risk used "the SSP5-8.5 scenario. This a a high-emission scenario assuming extensive fossil fuel usage and limited mitigation" (page 63). Transition risk used "SSP1-1.9 and SSP2-4.5"; the first "envisions CO2 emissions reaching net zero around 2050" (page 63). Table 25 (page 64) gives temperature alignment and very likely end-of-century rise per scenario: SSP1-1.9 (1.5°C alignment, RCP2.6, 1.0-1.8°C), SSP2-4.5 (RCP4.5, 2.1-3.5°C) and SSP5-8.5 (RCP8.5, 3.3-5.7°C), with likely sea level rise ranges.

Assumptions. "a key assumption in the analysis was that the transition to a low-carbon economy would impact fuel supply and costs", with technological innovation assumed to play an important role. Two uncertainties are named: "the pace at which the global market will transition from fossil fuels" and "how quickly greener fuel alternatives will become commercially viable" (page 63).

One inconsistency: page 63 states the SSP5-8.5 scenario leads to "a global warming of 8.5°C by 2100", which conflicts with Table 25's own figure of 3.3-5.7°C for the same scenario.

Resilience in relation to climate change

Back-filled from ESRS 2 SBM-3 (pages 66-67), with supporting material from the climate IRO-1 section (page 63). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Results of the analysis (paragraph 19(a)). "The analysis found that our assets, operations, and supply chain face low to moderate risks from the potential impacts of climate change, including extreme weather events, sea level rise, ocean acidification, and biodiversity loss. These risks are more pronounced in the SSP5-8.5 scenario" (page 67). Counter-intuitively for the business model, "In a high-emission scenario, vessel operations might be frequently affected by weather conditions, primarily due to increased waiting time. This could potentially increase the Company's revenue, as the business model is primarily based on time charter contracts" (page 67). "The SSP1-1.9 scenario poses the greatest challenges for the Company's current business model, while the SSP5-8.5 scenario offers the most growth opportunities" (page 67).

Strategy and business model response. "Over the previous decade, Solstad Offshore has adjusted its business model to focus on renewable energy, establishing joint ventures with strategic partners", naming the Windstaller Alliance with Aker Solutions and Deep Ocean and Remota AS, "set to commence operations in 2026 with significantly (>90%) lower emissions impact". The statement then qualifies this: "following the company split in 2024 the Solstad Offshore share of renewables activities has been considerably reduced and for FY2025 this was 0%" (page 67).

Uncertainty (paragraph 19(b)). "Overall, the analysis indicates that financial risks to the Company in the short- to medium-term are low, but long-term consequences are more uncertain and difficult to quantify" (page 67).

Capacity to adjust (paragraph 19(c)). "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 newbuilds 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" (page 67).

No resilience analysis carried out specifically to the ESRS E1-3 definition is described, and the statement does not use the word resilience as a defined analysis.

Policies related to climate change mitigation and adaptation

Reference: pages 67-69.

All policy and procedure documents sit in the Solstad Integrated Management System (SIMS), "audited and certified by DNV according to relevant international standards, particularly the ISO 14001 Environmental Management and the ISO 50001 Energy Management systems. The SIMS system and its policies apply to all our employees, vessels and office locations worldwide" (page 67).

Four instruments are described:

• The Company Philosophy, Objectives, and Strategy document, which "emphasises the objective of minimizing impacts on the environment and utilizing energy efficiently and responsibility" (page 67).
• The Sustainability Policy, which "addresses avoiding any kind of unwanted pollutants and enhancing vessels and facility designs and operations to reduce environmental impacts and increase energy efficiency... mandates compliance with, and the aim to exceed, relevant environmental legislation, and promotes the procurement of environmentally friendly and energy efficient products and services". It "is governed, and ultimately implemented, by the Company's CEO and applied at all organizational levels" (page 69).
• The annual management review process, whose output document "is signed by the CEO and sets the KPIs and goals for the company on an annual basis", covering mitigation, adaptation, energy efficiency and renewable energy deployment (page 69).
• The SIMS Environmental control processes, plus a named operational example, the Hull Cleaning Procedure, which contributes to mitigation "through reducing fuel consumption and corresponding emissions, as well as reducing the risk of transferring invasive species between discrete geographical areas" (page 69).

The Company's strategy is revised annually with Board-level involvement, but "The strategy document is not public" (page 69).

Actions and resources in relation to climate change policies

Reference: pages 69-70 (Table 27, page 70).

The principal action is the internal Solstad Green Operations (SGO) campaign, "Initiated back in 2010... It is only related to operational measures that can be done on a daily basis on all vessels, with initial tagline being 'We do what we can when possible'." A monthly KPI target is set for each vessel, and "The SGO campaign does not have any cost associated with it (neither OpEx or CapEx) as this is operational measures such as reducing vessel speed, anchor if possible, or reducing lights in use etc" (page 69).

Table 27 (page 70) sets out the levers and what was actually done in 2025:

Resourcing: "The OpEx/CapEx needed for the decarbonization levers are incorporated in the Company's annual budgets and long-term (5-years) projections... No significant other OpEx (net cost) is expected related to the measures above in the short to medium term perspective" (page 69).

One named R&D commitment: since 2023 Solstad has participated in the EU-funded NEMOSHIP project on marine battery systems, "The project budget is 11.4 MEUR" with 11 European partners; the Solstad share is "MEUR 2.6 over four years", but ownership passed to Solstad Maritime in January 2024, "hence there is no cost or funding related to Solstad Offshore in the reporting year" (page 70).

Targets related to climate change mitigation and adaptation

Reference: pages 71-74 (Table 28 and Graph 2, page 72); GHG emission reduction target datapoint indexed to page 71 in Appendix B (page 108).

The Company has set no GHG reduction target. "The Company has currently not set GHG emission reduction targets for 2030" (page 71). Three reasons are given: "more than 95% of these emissions occur when the customer has operational control over the vessels"; "Solstad Offshore cannot upgrade a vessel with new technology or change fuel without client concent"; and "Since the Solstad Offshore company split January 17 2024, the Company has been in a transitional period, and it has been concluded that the setting of GHG emission reduction targets currently would not be expedient" (page 71).

"There is currently no available sectorial guidance or sector-specific emissions reduction pathways relevant for the Company... As more than 50% of the Company's revenue stems from activities in the oil and gas sector (no income from coal), Solstad Offshore is excluded from the EU Paris-aligned Benchmarks and not eligible for the Science Based Target initiative (SBTi) tools" (page 71).

Four proxy metrics are tracked instead: annual fleet GHG emissions; SGO actions per vessel per month; share of revenue outside oil and gas; and taxonomy-eligible revenue (page 71).

Table 28 (page 72):

Reduction potential is estimated but not committed: operational measures "total reduction potential is probably in the range of 25% towards 2030-35 (measured against a 2010 baseline)"; SGO has delivered "an average fuel and emission reduction of about 20%" since launch; and the initial biofuel goal "is to power one vessel with 50% HVO. This can yield an estimated emission annual reduction of 1% in the combined Solstad Offshore/Solstad Maritime fleet of 39 vessels" (page 72).

Energy consumption and mix

Reference: pages 74-75 (Tables 29 and 30, page 75); datapoints indexed to page 75 in Appendix B (page 108).

"As a share of the Company's total annual energy consumption, more than 99% stems from energy produced by the combustion of marine gas oil on the fleet's vessels" (page 74).

Table 29 - energy consumption and mix (MWh):

Coal, natural gas, other fossil sources, renewable fuel including biomass, and self-generated non-fuel renewable energy are all reported as zero.

Table 30 - energy intensity (high climate impact sectors): net revenue USD 290,350,310 (2024: USD 244,609,517); total energy consumption from high climate impact sectors 589,316 MWh (2024: 520,071), footnoted "100% of total Energy consumption"; intensity 0.0020 MWh/USD (2024: 0.0021), -4.8%.

Worth checking: the 589,316 MWh in Table 30 does not reconcile to the 570,832 MWh total in Table 29 on the same page, despite the footnote stating it is 100% of total energy consumption.

Gross Scopes 1, 2, 3 and total GHG emissions

Reference: pages 75-78 (Table 31 page 77, Graphs 3 and 4 and Table 32 page 78); datapoints indexed to pages 77-78 in Appendix B (page 108).

"From 2024 the calculation of gross scopes 1,2, and 3 and total GHG emissions was changed to use a financial approach to comply with ESRS requirements" (pages 75-76). Vessels owned by SOFF and those leased from Solstad Maritime are in Scope 1; upstream production and transport and JV vessels sit in Scope 3 categories 3 and 15.

Table 31 (page 77), tCO2eq:

Largest Scope 3 categories: 15 financial investments 130,157 (2024: 129,606); 3 fuel and energy-related activities 36,352; 1 purchased goods and services 16,904; 2 capital goods 773; 6 business travel 704; 5 waste 152; 4 upstream transport 122; 7 commuting 99. Categories 8-14 are all zero, marked "Nothing to report". Category 15 comprises 50% of Normand Installer (JV), 27.3% of SOMA excluding vessels leased back, and from 2025 35.8% of Omega Subsea AS.

Graph 3 (page 78): Scope 1 45.80%, Scope 3 54.20%, Scope 2 0.003%.

Table 32 (page 78) intensity: total GHG per net revenue 0.00118 tCO2eq/USD location- and market-based (2024: 0.00124).

Method: "tons MGO fuel x 3.206 tCO2/ton fuel", with N2O and CH4 at factors of 0.00018 and 0.00005 tCO2/ton fuel; MGO production carries "a GHG footprint of 17.7 gCO2eq/MJ". Primary data sources cover 92% of Scope 3, spend-based estimates the remaining 8% (page 76).

Note that Graph 4 on page 78 labels the Scope 3 total as 130,157 tCO2eq, which is the category 15 figure rather than the 185,299 total in Table 31, and gives business travel as 740 against Table 31's 704.

GHG removals and GHG mitigation projects financed through carbon credits

Reference: Appendix B, Table 41, page 108.

This is a nil return recorded in the index and nowhere else. Appendix A (page 106) lists E1-7 among the E1 disclosure requirements covering metrics for the energy sub-topic and does not place it in the "Disclosure Requirements Omitted by SOFF" column. Appendix B then states, against "ESRS E1-7 GHG removals and carbon credits paragraph 56": "Nothing to report" (page 108).

There is no E1-7 heading or narrative in the climate chapter (pages 62-78), no removals figure, and no purchase or retirement of carbon credits is described anywhere in the statement. Consistent with that, the net-zero 2050 ambition at page 63 is stated without reference to offsets, and the decarbonisation levers at page 66 are all operational, fuel or fleet measures.

A reader wanting to confirm the nil position has only the single index line to rely on.

Policies related to pollution

Reference: page 80.

"The Company's Sustainability Policy outlines all strategic overarching objectives relating to our sustainability efforts. It states that the goal is zero oil spill incidents to sea, and includes a statement on avoiding any kind of unwanted pollutants and discharges. Furthermore, it states that the Company supports the procurement of environmentally friendly and energy-efficient products and services" (page 80). The policy "is published at places easily available onboard the vessels as well as in all office locations. They are also part of the employee induction and training programs".

Supporting processes named at page 80: voyage planning; maintenance "according to the IMO NOx Technical Code"; environmental reporting tools for all vessels and onshore locations; the annual management review process for setting KPIs and targets; and monthly reporting and KPI follow-up.

Oil spill preparedness: "a range of processes are in place to ensure proper handling of unwanted oil spill incidents to sea. These are vessel specific, and dedicated equipment is in place to ensure that the crew may initiate first line measures if oil spill occurs. Crew training on this work is mandatory on all vessels. An agreement with international insurance company is in place to provide swift assistance worldwide if needed" (page 80).

The section closes with the substances position: "A value chain evaluation found no substances of concern or substances of very high concern that are generated, procured, or used across our locations" (page 80).

Actions and resources related to pollution

Reference: pages 80-82 (Table 33, page 81).

"More than 95% of the pollution to air associated with the Company occurs when our clients have operational control over the vessels, resulting in very limited direct emissions of pollutants by the Company" (page 80).

Table 33 (page 81) gives six actions with quantified effects and actual deployment:

"All these measures have been carried out in the reporting year by all or some of the vessels, except for the installation of battery-hybrid and selective catalytic reduction (SCR) plants, as there were no candidate vessels available for retrofitting during the year" (page 80).

Costs: SCR "typical installation cost is MUSD 1-2", with urea at "about USD 0.5 per litre or around USD 10,000 per vessel a year when actively used"; HVO costs "typically 50-100% higher than that of standard ship fuel", with "no cost for this during the reporting year"; 17 shore power systems installed over ten years "at a cost of about USD 100K per system", nine since sold or transferred, none installed this year (pages 80-81).

Targets related to pollution

Reference: page 82.

No pollution target is set. "As described under ESRS E1 Climate change mitigation, the Company has in place a range of measures to reduce emissions including air pollutants, but a specific target on air pollution reduction has not been set" (page 82).

The company argues the targets are indirect: "NOx and SOx emissions are linked to the level of GHG emissions, as the pollution source is fuel use. This means that all GHG reduction levers and actions are also relevant for air pollution reduction... The Company has estimated that an annual reduction of fleet fuel consumption will reduce emitted NOx and SOx pollution by the same amount (in %)" (page 82). That chain rests on the E1 targets, which are themselves not set (page 71).

A forward commitment is given: "Specific emissions targets will be established as part of the development of the climate transition plan that is part of ESRS E1 (planned from 2027)" (page 82).

In the interim, regulatory limits act as the reference point: "The International Maritime Organization has established regulated maximum limits for pollutants, which the Company strictly adhere to... The Company views these regulated limits as upper thresholds and strive to operate well within them as a proxy for our environmental targets" (page 82).

Pollution of air, water and soil

Reference: pages 82-83 (Table 34, page 82); E-PRTR datapoint indexed to page 82 in Appendix B (page 109).

Table 34 - fleet exhaust gas emissions (tonnes):

*2022 and 2023 not audited. "Emission levels over the previous three years shows a strong reduction (75%), mainly due to the PSV fleet sale in 2023 and transfer of vessels from Solstad Offshore to Solstad Maritime January 16, 2024" (page 82).

Methodology: emissions are calculated, not measured. "The methodology used is derived from resolutions by the IMO's Marine Environment Protection Committee... 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)" (page 82). For SOx, "The fixed factor used here is 20 kgSOx/ton fuel", per IMO MEPC Regulation 14 (page 82).

The company states why it does not measure directly: "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... the Company have determined that adopting direct measurement is not essential at this time" (pages 82-83). Vessels with SCR installed are, however, "required to be checked for NOx-emissions at regular intervals" by a third-party specialist providing a certificate (page 82).

A NOx tax of "10 USD/ kg" applies to most operations out of Norway, with the majority of the cost covered by clients (page 82).

Soil and water pollution were screened and found immaterial: "The screening revealed that the Company has no significant onshore activities emitting pollutants to soil. Marine vessel operations produce minimal water pollutants... deeming it a non-material aspect" (page 80).

Substances of concern and substances of very high concern

Reference: page 83; scope position at Appendix A, page 106; related material at page 80.

Solstad Offshore prints an E2-5 heading with a nil return: "The value chain was assessed, and no substances of concern or substances of very high concern were identified as being generated, procured, or used across our operations" (page 83). The same sentence appears under E2-1 with "across our locations" (page 80).

Read against ESRS E2 paragraph 34, this answers the first limb (amounts generated, used or procured) with nil. The outflow limb (amounts leaving facilities as emissions, as products or as part of products or services) is not addressed separately, though a nil inflow leaves nothing to report against it. Paragraph 35 on substances of very high concern is answered in the same sentence.

The nil return sits in tension with the company's own E2 IRO-1 narrative three pages earlier, which says: "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" (page 80).

Appendix A separately records E2-5 in the omitted column as "E2-5 (not material)" (page 106). Following the rule that the disclosure outranks the table, the printed E2-5 section is treated here as the company's answer. A reader should note that the statement contains three positions on the same question: not material per the scope table, nil per E2-5, and on a watchlist per E2 IRO-1.

Policies related to own workforce

Reference: pages 86-87; human rights datapoints indexed to page 86 in Appendix B (page 110).

The policies named as most relevant to the material IROs are the "Health and Safety policy" and the Code of Conduct, which "states Solstad Offshore's commitment to upholding human rights as defined by the UN... the most relevant human rights commitments regards non-discrimination, just and favourable conditions of work, as well as equal pay for equal work" (page 86).

Non-discrimination. The Code of Conduct "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". A working group for diversity oversees inclusion initiatives, one of which is the "Women in Solstad"-project (page 86). Recruitment procedures "Recruitment Onshore Personnel" and "Pre-Employment Process" build gender balance, diversity and inclusion into hiring (page 87).

Health and safety. The "superior 'Health and Safety' policy is in place, applicable to our entire workforce", operated through SIMS. "The cornerstone of this effort is the 'Solstad Incident Free Operations' (SIFO) program" (page 87).

Human rights. A procedure titled "Transparency on Human Rights and Working Conditions" "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" and prohibits any infringement of human rights (page 87). Due diligence is conducted annually under the OECD Guidelines and the Norwegian Transparency Act, with the statement published on the company website (page 87). Crew are additionally covered by "the Seafarers' Employment Agreement (SEA) as defined by the Maritime Labour Convention", with terms approved by the ITF and affiliated national unions (page 87).

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

Reference: pages 87-88 (Table 35, page 88).

Table 35 (page 88) lists nine engagement channels with frequency and the senior role responsible: general meetings (monthly, COO); crew conferences (annually, HR Director); department meetings (monthly, Directors); KPI reviews (annually, COO); the reporting system including whistleblower channels (continuously, COO); management review input (annually, COO); working environment surveys (bi-annually, Administration and Communication Director); appraisal talks for office employees and captains (annually, relevant leader); and employee evaluation and Working Environment Committee attendance for vessel crew, "Varies between offices and vessels (several times annually)".

Two limitations are disclosed candidly: "Currently, the Company has not entered into any formal global framework agreement related to the respect of workers' human rights. The effectiveness of our engagement with the workforce is not yet systematically assessed but can addressed during appraisal talks" (page 87).

Worker representation runs through the Brazilian working environment committee: "Our employees, primarily located in Brazil, have appointed a workers' representative and a Protection & Environment Supervisor as permanent members of the working environment committee ('CIPA'), serving the entire fleet", with monthly meetings reviewing safety minutes from each vessel with Brazilian crew (page 88).

"Solstad Offshore has direct engagement with three Brazilian unions for seafarers (officers and ratings) whereas Solstad Maritime engages with the four Norwegian unions, the Filipino union (one) and the three Australian unions" (page 88).

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

Reference: pages 88-90; grievance mechanism datapoint indexed to page 88 in Appendix B (page 110).

Normal reporting channel. Concerns can be raised "directly in the HSE reporting system (provided from software company UniSea) or through an analogue paper-based alternative", with reports assigned by the HSEQ Manager, who then verifies follow-up (page 89).

Whistleblower channel. Reports go through "the company's whistleblower portal on our website www.solstad.com/whistleblowing/", are "reviewed by qualified personnel, including an internal legal expert and one external lawyer from Wikborg & Rein", and are managed by the Group Compliance Officer as single point of contact. "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" (page 89). The "Anti-Bribery, Corruption, Fraud and Whistle Blower Policy" protects users against retaliation and permits anonymity. "All stakeholders may report on this channel without risk of retaliation" (page 89).

On Board Complaint Procedure. Seafarers may file written complaints about breaches of the 2006 Maritime Labour Convention, escalating superior officer to head of department to captain with "five days to resolve" at each level, then ten days to escalate to the MLC Shipowner, a further twenty days for resolution, and twenty more to bring the matter to the Flag State (page 89).

Designated Person Ashore, mandated by the ISM Code, is accessible to all marine crew with direct access to top management (pages 89-90).

Awareness is measured: "The effectiveness (reporting frequency) of the Normal Reporting Channel is subject to one of the Company's corporate KPIs, where the target is set as one report per person per month" (page 90).

Remediation includes P&I insurance covering injury, illness or death of crew, passengers or third parties, plus health insurance, with risk-based follow-up "adhere to the as low as reasonably practicable-principle (ALARP)" (page 90).

Taking action on material impacts on own workforce

Reference: pages 90-91.

The framing procedure is the internal "Employee Relations" process, with a biennial working environment survey as its central input. "The working environment surveys cover several topics, including the categories 'workplace safety and inclusion' and 'working environment and satisfaction', which historically have been the categories with the best (positive) score (respectively 4,1 of 5 and 4,1 of 5 in the last survey done in 2024 with a positive trend compared to previous surveys)" (page 90). An annual safety campaign survey and an annual appraisal talk for every employee supplement it.

Actions taken from the "Corporate Risk Assessment regarding human rights and working conditions" (page 90) include: an established process for managing identified actual and potential adverse impacts; an updated Code of Conduct; established whistleblowing channels; the "Women in Solstad" program; employing the majority of vessel crew directly; limiting the number of crewing agencies used; mandatory training and development programs for all personnel onboard; maintaining relationships with seafarers' unions; and "Courses on handling lithium-ion batteries or other novel technologies that may pose a risk for crew if installed on the vessel".

Remedy is prioritised by involvement: caused, contributed to, then associated with, and by severity and likelihood. "No actual and potential adverse impacts have been identified in 2025" (page 91).

Resources named are a dedicated sustainability department working with HSSQ, plus the Group Compliance Officer and Corporate Secretary position in finance (page 91).

Targets related to own workforce

Reference: pages 91-92 (Table 36, page 92).

Two target sets are disclosed. On safety, "the Company has a continuous zero-incident policy regarding both total recordable case frequency (TRCF) and lost-time injury frequency (LTIF)". On gender, "the Company's long-term targets are to achieve 10% female seafarers in general and 30% female onshore employees in management positions by 2030. These targets and KPIs are set annually at the highest management level, by Executive Management" (page 91).

Table 36 (page 92) reports performance against them. Total TRCF, in incidents per million working hours, was 1.25 in 2023 (not audited), 1.10 in 2024 and 0.87 in 2025, against a 2026 target of 1.00. The table also disaggregates TRCF and LTIF between own employees and non-employees, and reports the female FTE portion at 13% and the turnover rate of seafarers at 2%.

Governance of the targets: "Directors and managers conduct an annual evaluation of targets and KPIs. Following this review, new targets are established for the coming year. Targets and KPIs (performance) are updated and monitored monthly through the corporate KPI Centre", reviewed at the monthly general meeting and communicated by circular letters (page 91). "monthly KPI performance results are regularly displayed on the Company's communication platforms, including bulletins, the intranet, and notice boards", and employees may suggest targets through the reporting system under the category "Experience Transfer" (page 91).

Method note: TRCF and LTIF use "a number of 24 hours per day per person on the vessels... (industry standard)", counting fatalities plus lost time incidents plus restricted work cases plus medical treatment cases for TRCF, and fatalities plus LTIs for LTIF (page 92).

Characteristics of the undertaking's employees

Reference: pages 92-93.

Solstad Offshore reports 905 employees, all in Brazil (page 92). "All Solstad Offshore employees are hired directly in one of its Brazilian crewing companies (all fully owned by the Company)", and "The employee base has grown by nearly 30% during the reporting year as new contracts in Brazil necessitate local content crews" (page 92).

Headcount by gender (page 92): male 786, female 119, other 0, not reported 0, total 905.

By contract type (page 93), headcount:

Turnover (page 93): 16 employees left; turnover rate 2%, calculated on the "INTERTANKO method, excluding retirements and fatalities".

S1-6 was excluded in FY2024 under a phase-in and reinstated this year: "The disclosure requirements S1-6 and S1-16 was excluded in FY2024 (phase-in), however these disclosures are included this year" (page 34). The company uses entity-specific disclosures under S1-6 for the TRCF and LTIF calculations "due to industry standard requirements" (page 45).

Characteristics of non-employee workers

Reference: page 93.

This disclosure is voluntary in materiality terms. The basis of preparation notes that S1-7 "has been included this year despite not being identified as material in the DMA, to ensure a holistic perspective on the company data" (page 34), and S1 SBM-3 repeats the point (page 84).

"The total number of non-employees (in head count) in the Company is ~70 non-employees, representing around 7% of the total workforce (NACE Code 78 personnel)" (page 93). The breakdown:

• Hired crew: ~5 headcount, "aboard vessels in Brazil, the North Sea, and Southeast Asia. They operate under Solstad Offshore's HSEQ protocols and are integrated into onboard safety systems."
• Contractors: ~55 headcount, "supporting offshore ROV operations, onshore IT infrastructure, financial- and project-based services."
• Consultants: ~10 headcount, "contributing to strategic development and input as well as regulatory alignment."

Methodology and caveats are stated: "The data is reported in headcount as of the end of the reporting period. Hired crew numbers were compiled from vessel rotation logs and internal staffing records. Contractor and consultant data were sourced from our HR records"; and "The number of non-employees fluctuates throughout the year due to vessel activity, seasonal demand, and project cycles" (page 93).

"All non-employees are subject to the Company's safety standards and have access to grievance mechanisms either directly or via their contracting entity" (page 93). The ESRS non-employee population is identified elsewhere as personnel "provided primarily by the Norwegian company Omega Subsea" supplying ROV operators (page 85).

Diversity metrics

Reference: page 93.

"The Company's top management c-suite positions consist of four persons whereof all are male. These are hired in from Solstad Maritime (through a management agreement), and these positions also represents the top management in Solstad Offshore on a Company level. Locally in Brazil the top management consist of four males and one female. The metrics below only cover the Solstad Offshore employees" (page 93).

Employees by age band and gender (page 93):

The percentage column is unlabelled beyond the heading "Percentage"; it does not correspond to the share of the workforce in each band. The three bands sum to 905, matching the total employee headcount reported under S1-6 (page 92).

Board and executive gender composition is disclosed under GOV-1 rather than here: the Board is three men (60%) and two women (40%), and Executive Management is four members, "All members are men (0% female)" (page 35). The gender equality target set under S1-5 is 10% female seafarers and 30% female onshore employees in management positions by 2030 (page 91), against a current female FTE portion of 13% (page 92).

Health and safety metrics

Reference: page 94 (Table 37); datapoints indexed to page 94 in Appendix B (page 110).

"All of our own workforce (100%) is covered by Solstad Integrated Management System based on legal requirements and/or recognised standards/guidelines" (page 94).

Table 37 (page 94):

The company's own notes to the table: the accident count "Includes other workers working on Solstad's sites (such as value chain workers in the Company's own workforce)"; the rate is "based on number of cases divided by the number of total hours worked multiplied by 1 000 000"; and days lost refers to lost time incidents (page 94).

S1-14 is one of two S1 disclosures where "The Company use entity-specific disclosures for S1-6 and S1-14 for TRCF and LTIF calculations due to industry standard requirements" (page 45). The underlying method uses 24 hours per day per person on the vessels as the exposure basis, counts fatalities, lost time incidents, restricted work cases and medical treatment cases for TRCF, and includes hired personnel on the vessels (page 92).

The rate of 0.87 sits below the 2026 target of 1.00 set under S1-5 (page 92), against a continuous zero-incident policy.

Compensation metrics (pay gap and total compensation)

Reference: page 94; datapoints indexed to page 94 in Appendix B (page 110).

Both required ratios are given, in two sentences:

"The Company's pay gap-ratio is -4.3%. This represents the percentage gap in pay between its female and male employees."

"The Company's annual total remuneration ratio is 12.875. This is the ratio between the highest-paid individual and the median paid employee." (page 94)

A negative pay gap indicates female employees are on average paid above male employees on the measure used. No further disaggregation, methodology note, adjustment basis or scope statement accompanies the figures, and no comparative for 2024 is given, because S1-16 was excluded last year: "The disclosure requirements S1-6 and S1-16 was excluded in FY2024 (phase-in), however these disclosures are included this year" (page 34).

Appendix B indexes both the "Unadjusted gender pay gap paragraph 97 (a)" and "Excessive CEO pay ratio paragraph 97 (b)" datapoints to page 94 (page 110).

The related material IRO is "Unequal pay and/unfair treatment, for equal work for both for onshore and offshore workers may negatively affect employee well-being", with the risk of "Legal fees and potential fines if gender equality policies are not properly implemented or if discrimination claims arise" (Table 9, pages 46-47).

Incidents, complaints and severe human rights impacts

Reference: page 94 (Table 38); datapoints indexed to page 94 in Appendix B (page 110).

Table 38 (page 94):

The movement worth noting is complaints, from zero in 2024 to three in 2025 through the whistleblower channel and DPA cases, with no discrimination or harassment incidents and no sanctions recorded against them.

"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" (page 94).

Consistent with the table, S1 SBM-3 states "In the reporting year, no incidents of forced labour or child labour were registered" and assesses the risk of both as negligible (pages 85-86).

Policies related to value chain workers

Reference: pages 98-99; datapoints indexed to page 98 in Appendix B (page 110).

Policy is anchored in the "Company Philosophy, Objectives and Strategy"-policy, "which is in alignment with the UN Guiding Principles on Business and Human Rights, also considering... 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" (page 98).

The operative instrument is the Supplier Code of Conduct (SCoC), "directed at all our suppliers, including sub-suppliers, contractors, sub-contractors, agents and consultants and therefore cover all our upstream value chain workers" (page 98).

A gap is disclosed rather than glossed: "The policy explicitly addresses forced and compulsory labour, but not trafficking of human beings or child labour" (page 98). On pay, "suppliers shall meet, as a minimum, national or industry standards, whichever affords the greatest protection. Wages should be enough to meet basic needs", with written employment agreements in an understandable language and payments made timely and fully documented (page 98).

A Group Procurement Policy applies "For all purchases over USD 50,000", committing the company to "integrating sustainable practices into its procurement processes, minimizing environmental, social, and governance (ESG) risks throughout its supply chain" and to "Responsible Sourcing" (page 98).

Monitoring: audits "can be triggered by reported incidents related to the supplier through the company internal 'HSE system' or through the 'TM Purchasing systems' or due to high risk identified as part of the onboarding processes"; "Project leaders also perform spot checks on yards during maintenance projects" (page 98).

"During the reporting 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" (page 99).

Processes for engaging with value chain workers about impacts

Reference: page 99.

Solstad Offshore discloses that it has no such process. The disclosure is short enough to quote in full:

"The Company has not yet adopted a general process to engage directly with value chain workers. This process will be evaluated and implemented over the next one to two years as part of the supply chain follow up work. If the evaluation finds such process usefull and relevant, a way forward might be to implement communication channels for workers at key suppliers in the supply chain starting with suppliers and regions where the risk is found to be the highest" (page 99).

Appendix A places S2-2 among the S2 disclosure requirements covering metrics and records the S2 omitted column as "None" (page 107), so this nil answer is presented as the company's S2-2 disclosure rather than as an omission.

Engagement that does occur is with suppliers rather than with their workers: "we conduct value chain surveys, require supplier self-assessments on key sustainability matters including workers health and safety and other fundamental human rights topics to gather information on the interests and views of the value chain workers" (page 96). The company also notes it collaborates with industry peers and NGOs and participates in multi-stakeholder initiatives (page 100).

The commitment is repeated under S2-5: "as mentioned in S2-2, we aim to strengthen the process to engage more directly with value chain workers on these topics over the next years" (page 101).

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

Reference: page 99.

Another explicit nil position. "The Company has not yet uncovered any material negative impacts it has caused or contributed to in regard to its value chain workers, and we have not yet adopted an approach to providing or contributing to remedy for such cases. Therefore, the Company has not made any assessments of the effectiveness of such an approach" (page 99).

One channel does exist: "Solstad Offshore has a general whistleblower channel allowing value chain workers to communicate directly to us. A detailed description of how we track and monitor issues raised through this channel, ensuring its effectiveness and stakeholder engagement as well the policies in place to protect users of the channel against retaliation, is stated under ESRS G1-1" (page 99). The channel is the portal at www.solstad.com/whistleblowing/, open to all stakeholders without risk of retaliation and permitting anonymity (page 89).

The company then discloses the limit of that channel: "We have not yet implemented any process for assessing whether value chain workers are aware of and trust the whistleblower channel" (page 99).

The whistleblower channel recorded three complaints in the reporting year across the Whistle Blower Channel and DPA cases, reported under S1-17 (page 94); the statement does not disaggregate whether any originated from value chain workers.

Taking action on material impacts on value chain workers

Reference: pages 99-100; human rights incidents datapoint indexed to page 99 in Appendix B (page 110).

The description is scoped to upstream workers, "as client-related downstream workers' IROs are less challenging, and we have less influence on them" (page 99). Yard workers are identified as the highest risk group: "the use of shipyards around the world may pose one of the highest risks of breaches to human rights for the Company, and it came out with high materiality during our double materiality assessment process" (page 97).

Six measures are listed (page 100):

• "Requiring all suppliers to adhere to the 'Solstad Supplier Code of Conduct'."
• "Conducting a yard qualification procedure and holding pre-meetings with shipyard management."
• "Using only preselected, trusted shipyards from various global regions for planned maintenance."
• "Having project managers (typically technical superintendents) perform spot checks for human rights breaches as part of their project execution checklist, and report on them after project completion."
• "Auditing selected shipyards at any given time during their work for us."
• "Collaborate with Sea1 ASA (another Norwegian offshore vessel owner and competitor, previously called Siem Offshore ASA) to share information and lessons learned about shipyards."

Two limits are stated. "We have not yet uncovered any actual material impacts on our value chain, and therefore, we have not yet taken initiatives aimed at remediation" (page 100). And "We do not currently have detailed processes in place for tracking and assessing the conditions of our value chain workers, however a supply-chain software system called 'Ignite' has been implemented to improve on parts of this process" (page 100).

Resourcing: "Our team, comprising over 50 individuals from various departments within the Company (including purchasing, HSSQ and technical departments), engage in these activities periodically" (page 100). "There has not been reported any severe human rights issues and incidents connected to our upstream and downstream value chain" (page 100).

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

Reference: page 101.

The tracked measure is supplier qualification rather than a worker outcome: "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" (page 101).

The mechanism: "an extensive self-assessment process where the suppliers will need to report on a range of business-critical processes including sustainability matters. The reporting is done electronically in a web-form system and all important parameters are given a score that are then compared to threshold values that are visualized through a traffic light system" (page 101). Suppliers report on quality management, health and safety management, sustainability and environmental, and policies. "If a supplier for some reason does not comply with our requirements, deeper investigation is conducted to see if improvement can be made. Or we can assess whether another compliant supplier should be utilised" (page 101).

No numeric value or deadline is attached to the approved-supplier measure, and the company confirms the absence of anything further: "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" (page 101).

Public reporting is annual: statements signed by the CEO and Chairman under the Norwegian Transparency Act and the UK Modern Slavery Act, "detail's the company's actions on these topics during the reporting year, including the due diligence outcomes and any reportable cases" (page 101).

Business conduct policies and corporate culture

Reference: pages 104-105; UN Convention against Corruption and whistleblower-protection datapoints indexed to page 104 in Appendix B (page 111).

"At the heart of this culture are our foundational values: safety, reliability, competence, and responsibility" (page 104). All measures are covered by SIMS documents: the Code of Conduct statement, the Company Philosophy, Objectives and Strategy policy and the Sustainability policy.

Culture feedback loop. "an evaluation is mandatory for all employees as part of the annual appraisal process. Furthermore, every two years an employee survey is conducted to get more targeted information on the company culture" (page 104). Key suppliers and clients are asked for feedback on unlawful behaviour "primarily through dialogue meetings at least annually".

Anti-corruption policy. "The Company has implemented a 'Anti-Bribery, Corruption, Fraud and Whistle Blower Policy' consistent with the UN Convention against Corruption. The purpose of this policy is to ensure a non-tolerance for any type of bribery, corruption, fraud and other criminal or unethical behaviour" (page 104). Dedicated zero-tolerance posters are displayed at key locations and on vessels.

At-risk population and training. "Solstad Offshore considers almost all employees to be at risk... Hence, the training is mandatory for all employees. The Board of Directors have not yet been covered by these requirements, but they are covered by our 'rules of procedures' and have signed our Code of Conduct" (page 104). "The total number of employees and other own workers at-risk function in the Solstad Offshore scope is estimated to be around 7-800 FTEs" (page 104). The anti-corruption e-learning "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)"; "about 93% have completed training by year-end 2025. The course needs to be refreshed by everyone yearly" (pages 104-105).

A litigation matter is disclosed under governance: in May 2024 Kistefos AS and Kistefos Investment AS filed a class action claim against the Board and CEO relating to the 2023 refinancing; "No claims have been made by the Kistefos entities against Solstad Offshore" (page 103).

Prevention and detection of corruption and bribery

Reference: page 105.

"The Company has implemented policies and processes to prevent, detect and address allegations of corruption and bribery. Training of all employees is provided... These procedures are mandatory both for crew and onshore employees and applies worldwide. It describes what is considered corruption and bribery, where it applies (business area/department), training required, record keeping and management reporting. The Company's Group Compliance officer and the Administration and Communication Director are responsible for these processes" (page 105).

Detection controls are itemised: "restricted access to relevant ICT systems (depending on role), power of attorney implemented on all purchases to ensure that at least two people approve, contract approvals require at least two approvals, internal control on accounting/finance, wages payment and the employment processes are separated processes on HR etc. There is also a risk assessment system available for all that may be used when needed" (page 105).

Reporting route and independence: "The company's main channel for receiving claims about corruption and bribery is the whistleblower channel. See section S1-3 for further description" (page 105), where reports are reviewed by an internal legal expert and an external lawyer from Wikborg & Rein, with an independent third party handling complaints against senior officers (page 89). "Any cases found to be real are reported to the Board in the quarterly Audit Committee meetings (number of cases and a brief explanation on the cases)" (page 105).

Training design and its limit: "The training is based on a mandatory e-learning course that is made internally to ensure that the content is relevant to our employees. It is updated and revised as needed. This training does not include the board members" (page 105). Coverage stands at about 93% of the roughly 7-800 at-risk FTEs by year-end 2025 (pages 104-105).

Targets related to business conduct

Back-filled from the business conduct chapter, where targets are addressed under the ESRS 2 MDR-A and MDR-T minimum disclosure requirements rather than as a numbered disclosure requirement. G1-3 became a standalone DR only in the 2025/2026 ESRS; Solstad Offshore's FY2025 statement was prepared under the 2023 ESRS, whose G1 had no targets DR.

Reference: page 105 (ESRS 2 MDR-A block); Appendix A, Table 40, pages 106-107.

No measurable business conduct target is stated. Appendix A lists the G1 disclosure requirements covering policies, actions or targets as "G1-1" and those covering metrics as "G1-3, G1-4", with no target named (page 107). MDR-T appears only in the ESRS 2 row of the same table (page 106).

Consistent with MDR-T's alternative limb, effectiveness is tracked in the absence of a target. Under the heading "Metrics and targets / ESRS 2 MDR-A", the company states: "Solstad Offshore is continually enhancing our policies and processes to address material impacts, risks, and opportunities related to corruption and bribery. Serious allegations and incidents are followed up by an action plan detailing necessary resources, timelines and cost estimates for both internal and external follow-up work. Post-incident, the management system's effectiveness is evaluated, and the need for additional training or other measures is considered. There have been no significant costs related to corruption and bribery during the reporting year" (page 105).

Three tracked measures function as the practical proxies: anti-corruption e-learning completion, "about 93% have completed training by year-end 2025", refreshed yearly across roughly 7-800 at-risk FTEs (pages 104-105); confirmed incidents, nil for the second consecutive year (page 105); and whistleblower cases, reported to the Board through quarterly Audit Committee meetings (page 105). Board members remain outside the training population (page 105).

Incidents of corruption or bribery

Reference: page 105; fines datapoints indexed to page 105 in Appendix B (page 111).

A nil return for the second consecutive year: "During the reporting year there have not been any confirmed corruption or bribery incidents in the Company's own operations or in the value chain where our employees are directly involved (same result as previous year)" (page 105).

Appendix B indexes two G1-4 datapoints to page 105: "Fines for violation of anti-corruption and anti-bribery laws paragraph 24 (a)" and "Standards of anti-corruption and anti-bribery paragraph 24 (b)" (page 111). No fines, convictions or public legal cases relating to corruption or bribery are reported.

Cost position: "There have been no significant costs related to corruption and bribery during the reporting year" (page 105).

The escalation route behind the figure is described in the same section: claims arrive mainly through the whistleblower channel, are registered and reviewed by qualified personnel including an internal legal expert and an external lawyer, and "Any cases found to be real are reported to the Board in the quarterly Audit Committee meetings (number of cases and a brief explanation on the cases)" (pages 89, 105). Separately, S1-17 records three complaints filed in 2025 through the Whistle Blower Channel and DPA cases, none of which resulted in sanctions (page 94); the statement does not link any of them to corruption or bribery.