Viking Line

The Board of Directors consists of the chairman and six members as well as three deputy members. The Board is responsible for the administration of Viking Line's affairs, sets the strategic sustainability priorities and oversees operational management. The Board appoints and dismisses the chief executive officer (CEO) and members of Group Management, approves the Company's strategic objectives and risk management principles and also ensures that its management systems function effectively. The Board establishes the Company's vision and values, which shall be embedded in operations. The Board has not appointed any committees.

The Board members are independent of the Company and have no executive role or participation in day-to-day operations. Table 1 shows that 100% of the Board members are independent of the Company, while 71% are independent of significant shareholders. Viking Line has no employee representation or representation of other workers on the Board or other administrative, management or supervisory bodies.

Table 1. Share of independent Board members, 2024

Operational management consists of the CEO and Group Management. Group Management meets on a regular basis and is responsible under the CEO's leadership for performance management, operations, risks and resources as well as the development of the functions that the different members of Group Management are responsible for.

The diversity of the composition of the Board and of Group Management is presented in the tables below. Table 2 shows the gender breakdown for the Board and Group Management. The ratio of women to men was 2:5 (40% women) on the Board and 1:6 (17% women) in Group Management.

Table 2. Gender breakdown for the Board and Group Management.

Table 3 shows that the Board consists solely of non-executive members, while Group Management consists solely of executive members.

Table 3. Number of executive and non-executive members on the Board and in Group Management.

Board members and Group Management have extensive experience in the maritime transport sector, the Baltic Sea market area, sustainability matters and responsible business conduct. Group Management members have wide-ranging skills in the maritime transport and cruise sector and have extensive knowledge about risk management and regulatory compliance related to sustainability. A number of Board members have extensive experience in managing sustainability-related impacts, risks, opportunities and business conduct matters, both through operational roles and in current or previous positions of trust.

The Board has ultimate responsibility for ensuring that Viking Line conducts its operations in accordance with ethical business principles and relevant regulations for responsible business conduct. Group Management is responsible for implementing strategies and processes that ensure compliance with the Company's business conduct guidelines, including policies against corruption and bribes.

The CEO has ultimate responsibility for supervising the Company's risk management, sustainability targets and progress related to material impacts, risks and opportunities. The CEO reports on these to the Board, which approves the updated materiality assessment annually. The CEO is also responsible for governance processes, controls and procedures used to monitor, manage and exercise supervision over sustainability-related matters. The CEO may delegate operational responsibility to the different members of Group Management, who ensure that appropriate and effective controls, such as regular reporting and follow-up, are implemented in their particular area of responsibility.

Group Management has operational responsibility for developing strategies and targets related to managing material sustainability-related impacts, risks and opportunities. Members of Group Management monitor their own areas of responsibility and report to the CEO on progress towards achieving set targets in Group Management meetings.

The Group's Senior Vice President of Finance manages the Company's business and internal control function, which is responsible for risk management and governance of internal control processes and tools. The Senior Vice President of Finance is also responsible for sustainability matters specifically related to financial effects, risks and opportunities.

The Sustainability Manager is responsible to the Senior Vice President of Finance for updating the materiality assessment and compiling the sustainability statement. The Sustainability Manager reports directly to the Senior Vice President of Corporate Communications, who has operational responsibility for Viking Line's sustainability work and presents sustainability matters to Group Management.

Group Management deals with sustainability matters in its regularly held meetings and may if necessary use external expertise to support decision-making on sustainability-related matters. Viking Line's CEO and Senior Vice President of Corporate Communications have positions of trust with the Finnish and Swedish shipowners' associations, which serve as national stakeholder organizations for the maritime transport sector and have expertise in sustainability matters, including material impacts, risks and opportunities for maritime transport.

Group Management sets focus areas and targets annually with respect to the Company's sustainability matters. Group Management examines targets and progress in its monthly meetings as well as annually on a consolidated basis. Members of Group Management have operational responsibility for the Company's directives and policies that concern their own Group functions, and the CEO is ultimately responsible for compliance with the Company's directives and policies. The Company's policies and directives are revised and designed as needed.

The Sustainability Manager, finance function and in-house legal counsel inform Group Management about material impacts, risks and opportunities, which management takes into account when they carry out oversight of the Company's strategy, its decisions on major transactions and its risk management process. The CEO presents the Company's material sustainability matters to the Board on a regular basis and as needed. The Board approves the Company's focus areas, sustainability-related targets and revisions of existing or implementation of new strategies annually.

A list of the material risks and opportunities addressed by the Company's executive, management and supervisory bodies during the reporting period is presented in Table 4.

Table 4. List of material risks and opportunities addressed by executive, management and supervisory bodies during the reporting period.

Viking Line has a compensation policy that describes the Company's main compensation principles for remunerating its administrative, management and supervisory bodies. The compensation policy is presented to and approved by Viking Line's Annual General meeting every four years at a minimum. Viking Line has no incentive or bonus programme and no share-option or share-based incentive programme. Climate-related considerations are not taken into account in compensation to members of the Company's administrative, management and supervisory bodies.

Viking Line currently has no formal tracking procedure for identifying and assessing adverse impacts on an ongoing basis.

Table 5. Mapping of information provided in the sustainability statement about the due diligence process.

The implementation of CSRD and ESRS during the reporting period entails changes in Viking Line's overall processes for risk management and internal control of sustainability reporting which had not yet been completed during the reporting period. To ensure reliable risk management and reporting, responsibility for compiling the sustainability statement during the reporting period was assigned to a centralized function, with other staff at Viking Line taking part in carrying out controls.

Viking Line's core offering includes transport and on-board services with the northern Baltic Sea, Finland, Sweden and the Baltic countries as its main markets. Consumers of transport services consist of both passenger and cargo customers. On-board services include entertainment, restaurants, conference services, cafés and bars, retail shops, spa and gym facilities, and accommodation. The Company's core services are cruises and passenger and cargo transport.

Viking Line has sales offices in Finland, Sweden, Estonia and Germany. The subsidiary Viking Line Buss Ab also provides bus transport based in Åland. Viking Line owns and operates warehouse operations where incoming flows, such as fashion products, are managed and distributed to the Company's vessels. Viking Line also owns and operates a technical warehouse for spare parts and maintenance materials.

In 2023, Viking Line formed a joint venture in partnership with Destination Gotland with the mission of developing and providing cruises with the vessel M/S Birka Gotland on the Stockholm–Mariehamn and Stockholm–Mariehamn–Visby routes. Under the framework for the joint venture arrangement, Viking Line is in charge of M/S Birka Gotland's commercial operations. Service with M/S Birka Gotland was launched during the reporting period.

Viking Line's sales during the reporting period totalled EUR 484.4 M. Viking Line is not active in the sectors for fossil fuels, chemical production, controversial weapons or the cultivation and production of tobacco. The Tobacco Products Directive (EU) 2014/40 prohibits the sale of tobacco products for oral use such as snuff, with an exemption for Sweden. Snuff sales on board the Company's vessels only take place in Swedish territorial water.

Viking Line is Finland's biggest maritime employer and had a total of 2,583 employees at the end of the reporting period. The number of employees at Viking Line is presented in Table 6 by country of residence on December 31, 2024.

Table 6. Number of employees by geographical region on December 31, 2024.

Viking Line's long-term ambition is to provide fossil-free transport services by 2050, which requires a transition from fossil to renewable energy carriers. Currently, the main source of greenhouse gas (GHG) emissions in maritime transport is the combustion of fuels for vessel propulsion. As a result, GHG emission reductions are dependent to the greatest extent on what fuels are used on board the vessels. During the reporting period, prices for renewable or low-emission fuels, such as bio-LNG and biodiesel, were considerably higher than for fossil alternatives. Emission-free fuels were not available at all. The Company believes that prospects for the future are uncertain regarding the price and availability of renewable, low-emission or emission-free fuels.

The key sustainability matters that affect Viking Line's strategy are climate change and climate change adaptation. Viking Line's key challenges concerning sustainability matters are affected by the lack of renewable energy carriers, technologies that use them and constantly evolving laws and policy decisions from the EU and the International Maritime Organization (IMO).

Business model

Viking Line operates scheduled service for passengers and goods transport plus cruises on the northern Baltic Sea, with Finland, Sweden, Åland and the Baltic countries being the main markets. The Company's operations constitute a significant share of the transport infrastructure between these countries, and both the Turku-Stockholm and Helsinki-Tallinn routes are EU Trans-European Transport Network (TEN-T) corridors.

Viking Line's fleet is adapted to combine cruise operations with car deck capacity and create value by enabling leisure travel and commercial transport at the same time. The Company's operations are organized into three market segments: cargo, passengers in scheduled service, and cruise passengers. Primary sales revenue is generated from on-board restaurant and shop operations, the sale of passenger tickets and accommodation, and the sale of vehicle and goods transport.

Throughout its existence, Viking Line has been characterized by a focus on performance and cost-effectiveness. The Company has decentralized responsibility for commercial performance, moving it to the vessels and thus closer to the customer, with the objective being to more quickly pursue new opportunities to drive growth and profitability. The Company's objective is to offer the best value for money in the industry. Internally, this requires good cost control and an optimized revenue stream in operations. This is achieved through high capacity utilization for the transport of both cargo and passengers with products that appeal to a broad customer base. By maintaining high capacity utilization on the vessels for both passenger and cargo transport, conditions are created for an optimized revenue stream.

The Company works on a continuous basis to make both internal and external processes more efficient, including by maintaining large-scale operations that provide purchasing cost advantages. The Company has established centrally managed procurement operations, which contribute to efficient, well-planned resource allocation and monitoring as well as extensive and meticulous cost and result monitoring. The Company also strives to always have capital costs relative to tonnage that are as low as possible.

Viking Line creates values for its customers, investors and other stakeholders by providing scheduled, safe and comfortable travel as well as secure employment conditions and long-term business relations. The Company's operations create economic contributions to local communities by promoting tourism and trade and creating jobs. Viking Line's long-term business model also generates stable profitability and growth.

Value chain

Viking Line purchases goods and services in order to provide an offering of on-board services to its customers. These supplier flows are characterized as commercial goods, including retail products and food; consumable goods, including textiles, tableware, toiletries, spare parts and other equipment; and services. Key services include cleaning and laundering, dry-docking, entertainment and other services. Viking Line signs purchasing agreements directly with producers, wholesalers and logistics partners. Logistics partners are designated as key suppliers and provide the majority of commercial goods purchases in accordance with the Company's purchasing agreements as well as warehousing and distribution of most categories of incoming goods. Viking Line's hotel and restaurant operations use consumable goods, which are either provided through direct business relations or procured through logistics partners. Entertainment services are procured directly from artists or through representative agencies.

Viking Line's customers are divided into passenger and cargo customers. Passenger customers consist of conference guests, pleasure cruise passengers and transport passengers. Cargo customers consist of transport and logistics companies that transport goods on behalf of the owners of goods. The key outflow from the Company's operations is waste products. The Company's value chain also includes suppliers of commuter transport to and from the Company's operational sites, such as bus transport from port terminals to other destinations. Downstream activities for cargo customers include goods transport on behalf of the owners of goods.

Viking Line has ongoing dialogues with all of its most important stakeholders on a number of levels in the organizational hierarchy. Contacts with stakeholders are maintained on a continuous basis through questionnaires, surveys, and sales and feedback channels as well as through direct dialogue with stakeholders or their representatives. The primary aims of stakeholder contacts are to build trust and increase transparency, identify opportunities, address concerns and areas for improvement, identify trends and market signals, and promote responsible business practices. Table 7 presents how Viking Line has organized its stakeholder contacts.

Table 7. Stakeholder groups and stakeholder contacts.

Group Management obtains information through regular updates about the views and interests of stakeholders affected also concerning the Company's sustainability-related impacts. The CEO reports as needed to the Board on the views of stakeholders affected. Viking Line takes into account the results of its shareholder contacts by making modifications in the Company's business strategy or business model, to ensure that operations remain relevant and continue to satisfy its stakeholders' needs. During the reporting period, no changes were made in the Company's strategy or business model expressly as a result of shareholder contacts. The views and interests of stakeholders will continue to be taken into account in the annual materiality assessment process, after which they will be presented to Group Management and the Board.

Viking Line's own workforce is a key stakeholder group for the Company and constitutes the basis for the Company's success. Viking Line integrates the interests, views and rights of employees in strategic decisions through regular dialogue, responsible employment policies and investments in the working environment and development. Respect for human rights is a fundamental principle in Viking Line's operations and is embedded in both the Company's working conditions and corporate culture. Viking Line ensures that the interests and views of employees are taken into account in annual employee surveys, collaboration with trade unions and continuous dialogues. Due to insights gained from regular exchanges, the following strategic priorities have been set in employment policies: safe, secure and fair working conditions through collective bargaining agreements, competitive wages and fair scheduling as well as skills development through in-house training programmes and leadership development to enhance long-term opportunities for employees.

Customers are another key stakeholder group for Viking Line, and their views, interests and rights have a direct impact on the Company's business model and strategy. Viking Line integrates these aspects in its sustainability work through continuous customer dialogue, service development and measures to ensure responsible operations. Viking Line conducts regular customer surveys and dialogues with stakeholders in order to understand expectations and needs of both passengers and cargo customers. Customer views affect decisions concerning the range of services and products on offer as well as traffic planning. Viking Line has implemented principles to ensure that customers' rights and human rights are respected in all aspects of operations, including principles for data protection and integrity, security and safety as well as responsible marketing and transparency. Due to increased customer awareness about climate and sustainability matters as well as customer demands for safety and fair working conditions, Viking Line has modified its business model through investments in energy-efficient vessels and alternative fuels, expanded digitization and customer experiences, and development of new services. Viking Line has not identified any specific consumer group that runs a heightened risk of being subject to negative impacts.

Material impacts, risks and opportunities identified in the materiality assessment are related to climate change, pollution, resource use and circular economy as well as the Company's own workforce and consumers and end-users. The material impacts are concentrated primarily in the Company's own operations and secondarily in the upstream value chain. Impacts in the value chain are realized mainly through the generation of emissions in the production of products and services that the Company uses.

Material impacts, risks and opportunities identified in the materiality assessment as being related to Viking Line's own operations are described below. The information reported under ESRS 2 SBM-3 is covered by ESRS standards and no topic-specific disclosures have been included.

The material risks and opportunities identified in the materiality assessment are presented in Table 8. Table 9 shows the actual material impacts and Table 10 shows the potential material impacts identified in the materiality assessment.

Table 8. Financial materiality

Table 9. Impact materiality, actual.

Table 10. Impact materiality, potential.

Viking Line took into account impacts, risks and opportunities for all topical ESRS in its materiality assessment. The assessment included the Company's own operations and the upstream and downstream value chain. No specific operations, business relations or geographical areas with a heightened risk of negative impacts were given particular priority in the process. Instead the analysis focused on risks in the Company's own operations and impacts that the Company is involved in through its own business operations.

The materiality assessment process was based on Viking Line's business knowledge and key stakeholder views gathered in stakeholder dialogues. External experts were also involved in this work. In assessing the materiality of impacts, each sustainability topic has been scored based on the scope, scale, irremediable nature and likelihood of the impact under the double materiality principle. Negative effects were given priority based on their relative severity and likelihood. For financial materiality, the potential scope and likelihood of financial effects were taken into account in the assessment. Viking Line has also analyzed links between potential impacts and dependencies and the risks and opportunities that could arise as a result of them. However, no such dependencies were identified that could trigger material impacts.

The materiality assessment was carried out in accordance with the criteria and scoring methodology described in ESRS 1. The purpose of scoring is to identify what sustainability matters could have a high impact on the environment, people or the Company's financial position. Impacts were considered material if the combined points for scope, scale, irremediable nature and likelihood exceeded 50%. For financial materiality, the likelihood of occurrence and potential financial effect were taken into consideration in setting priorities. Table 12 shows the scoring system used to determine materiality. The threshold value for materiality is ≥ Important.

Table 12. Materiality scoring

Viking Line has integrated the materiality assessment in its existing risk management process. The Company classifies risks into four main categories: strategic risks, operational risks, damage risks and financial risks. During the reporting period, there was no separate category for sustainability-related risks; instead the material sustainability risks identified were categorized under one of the existing risk categories. The process for identifying material impacts, risks and opportunities is part of Viking Line's strategy work and is conducted in collaboration between Group Management and the Sustainability Manager. Risk management is led by the Senior Vice President of Finance, who is also responsible for sustainability matters associated with financial effects, risks and opportunities. The Board of Directors monitors and approves the updated materiality assessment annually. To ensure compliance with processes and internal control procedures, the assessment is examined on a regular basis under the Senior Vice President of Finance's direction. External expertise is consulted as needed to verify the quality and relevance of the assessments.

Viking Line has applied double materiality by assessing the materiality of impacts alongside financial materiality. In this process, priority was given to negative impacts based on their potential scope, scale, irremediable nature and likelihood. For financial materiality, potential financial effects were taken into account in the assessment based on their likelihood and the magnitude of their effect. For example, pollution to air was identified as a material impact both in the Company's own operations and in the upstream value chain, and this impact was also considered to be associated with the Company's financial risks in the form of future costs for regulations and emission reduction.

Viking Line's materiality assessment is based on a combination of internal and external data sources, with business knowledge, regulatory requirements, industry practice and stakeholder views providing this base. The process included all of the Company's operations and the value chain, where there was data available. The analysis was carried out using both qualitative and quantitative methods, such as expert assessments and ongoing scenario analyses, from which preliminary results were used in the assessment. To ensure a robust quantification of emissions and resource use, Viking Line applied emission factors from international standards and other generally accepted and reliable data sources as well as data obtained from suppliers. Risk assessments associated with business ethics matters were carried out through an analysis of the Company's Code of Conduct, anticorruption and whistle-blowing policies, and internal reviews. To assess environmentally-related risks, Viking Line based the work on its ISO 14001-certified environmental management system.

During the reporting period, Viking Line further developed its materiality assessment method in line with ESRS 1 and ESRS 2. The Company formalized the process for introducing a systematic scoring model to assess the materiality of impacts and financial materiality. Unlike in previous years, Viking Line included an analysis of climate-related risks and opportunities as well as a more detailed analysis of impacts in the value chain. The Company also expanded its stakeholder dialogues in order to ensure that sustainability matters identified reflect both internal and external perspectives. Viking Line plans to update its materiality assessment annually, and the next update is planned for 2025.

Table 13. List of disclosure requirements complied with based on the results of the materiality assessment.

Viking Line's long-term ambition is to provide fossil-free transport services by 2050, which requires a transition from fossil to renewable energy carriers. During the reporting period, the Company began developing a roadmap to achieve this ambition, but the roadmap was not complete during the reporting period.

The Company's strategy for achieving climate neutrality by 2050 is based on the International Maritime Organization's (IMO) principles for the maritime shipping sector and consists of:

• Implementing technology for more efficient use of fuel • Phasing in low-emission fuels • Optimizing traffic operations • Phasing in carbon-neutral fuels

Viking Line's approach is based on the IMO's three-tier framework for reducing greenhouse gas emissions from maritime shipping:

1. Energy efficiency improvements and technical measures: Viking Line continuously improves the energy efficiency of its fleet through regular maintenance, technology upgrades and optimization of the vessels' operations.

2. Operational energy efficiency measures: The Company optimizes voyage planning, speed optimization and other operational practices to minimize fuel consumption.

3. Alternative fuels: Viking Line is transitioning to alternative fuels, including liquefied natural gas (LNG) and in the long term, fossil-free energy sources.

Viking Line's two most recent vessels, Viking Grace and Viking Glory, are dual-fuel vessels that can run on both LNG and marine diesel oil (MDO). This gives the Company operational flexibility and reduces emissions compared to conventional marine diesel.

The Company recognizes that achieving climate neutrality by 2050 requires significant technological developments in the maritime industry, particularly in the availability and affordability of fossil-free fuels. Viking Line is actively monitoring developments in hydrogen, ammonia, methanol and other potential fossil-free fuel alternatives.

The transition plan is aligned with the EU's climate targets and the IMO's greenhouse gas reduction strategy for international shipping. The Company's approach takes into account the specific challenges of maritime transport, including the need for high energy density fuels for long-distance operations and the current limited availability of fossil-free alternatives.

Viking Line's transition plan also considers the potential impacts of EU legislation, including the EU Emissions Trading System (ETS) and the FuelEU Maritime Regulation, which will require ships to use an increasing share of renewable and low-carbon fuels.

Viking Line has integrated climate change considerations into its environmental management system, which is certified according to ISO 14001. The Company's environmental policy addresses both climate change mitigation and adaptation.

The Company's climate policy is based on:

• Continuous improvement of energy efficiency in operations • Transition to lower-emission fuels and ultimately fossil-free fuels • Investment in energy-efficient technologies and vessels • Compliance with all applicable climate-related regulations • Monitoring and reporting of greenhouse gas emissions

Viking Line's climate adaptation policy focuses on ensuring operational resilience to climate-related physical risks, including:

• Preparation for potential changes in weather patterns that could affect operations • Maintaining robust infrastructure to handle extreme weather events • Ensuring continuity of operations during climate-related disruptions

The Company's policies are regularly reviewed and updated to ensure they remain aligned with evolving climate science, stakeholder expectations, and regulatory requirements.

Viking Line has implemented several actions and allocated resources to support its climate change policies:

Energy efficiency measures: • Regular maintenance and optimization of vessel engines • Use of energy management systems to monitor and optimize energy consumption • Investment in energy-efficient technologies during vessel upgrades and refurbishments

Alternative fuels: • Operation of two dual-fuel vessels (Viking Grace and Viking Glory) capable of running on LNG • Elimination of heavy fuel oil from the Company's fuel mix • Use of low-sulphur marine diesel oil across the fleet • Pilot projects with biofuels and other alternative fuel options

Operational optimization: • Speed optimization and efficient voyage planning • Port optimization to reduce time in port and associated emissions • Capacity optimization to maximize passenger and cargo loads

Technology investments: • Installation of advanced navigation and communication systems • Investment in energy-efficient lighting and HVAC systems • Consideration of new technologies for future vessel investments

Monitoring and reporting: • Implementation of systems to monitor and report greenhouse gas emissions • Regular assessment of energy consumption and efficiency metrics • Participation in industry initiatives to share best practices

The Company allocates significant financial resources to these initiatives as part of its annual capital expenditure program and operational budget. Viking Line also participates in industry research and development projects to advance the availability of fossil-free fuels and related technologies for the maritime sector.

Viking Line has established the following climate-related targets:

Long-term target: • Climate neutrality by 2050: Viking Line aims to provide fossil-free transport services by 2050, in alignment with the IMO's greenhouse gas reduction strategy and the EU's climate neutrality target.

Medium-term targets: • Energy efficiency improvements: Continuous improvement in energy efficiency through operational optimization and technology upgrades • Fuel transition: Progressive increase in the share of low-emission fuels in the Company's energy mix

Operational targets: • Emission monitoring: Comprehensive monitoring and reporting of all greenhouse gas emissions from the Company's operations • Regulatory compliance: Full compliance with the EU Emissions Trading System and FuelEU Maritime Regulation

The Company acknowledges that achieving its 2050 target depends significantly on the development and availability of fossil-free marine fuels and related technologies. Viking Line regularly reviews its targets and progress, taking into account technological developments, regulatory changes, and stakeholder expectations.

Progress toward these targets is monitored through regular measurement of energy consumption, greenhouse gas emissions, and operational efficiency metrics. The Company reports on its progress annually and adjusts its strategies and actions as needed to maintain progress toward its targets.

Energy consumption and mix

Viking Line conducts operations in sectors with a high climate impact, in line with what is listed in sections A–H of the NACE classification of economic activities and L (as defined in Commission Delegated Regulation (EU) 2022/1288). The Company conducts operations in maritime transport, which are classified under the section for transport and warehousing (H) in NACE.

Viking Line takes a conservative approach regarding the distinction between renewable and fossil or nuclear energy sources, and classifies energy as renewable only in cases where the Company has received guarantees of origin or has an explicit agreement to purchase renewable energy. If the energy source is unknown, the energy was classified as fossil.

Energy consumption and energy mix (2024)

¹ Viking Line has estimated its consumption of renewable vehicle fuels based on Finnish and Swedish distribution obligations in effect during the reporting period. For vehicle fuel purchased in Estonia, no estimate of the proportions of renewable energy content is used.

Energy intensity

Energy intensity is calculated as the sum of energy consumption in Viking Line's operations divided by sales in the Company's consolidated income statement.

Gross Scopes 1, 2, 3 and Total GHG emissions

Viking Line's calculation of gross greenhouse gas emissions follows the principles, requirements and guidelines of the GHG Protocol Corporate Accounting and Reporting Standard, GHG Protocol Scope 2 Guidance and GHG Protocol Corporate Value Chain (Scope 3) Accounting and Reporting Standard. The calculation includes all greenhouse gases covered under the GHG protocol. Greenhouse gases not included under the Kyoto Protocol, such as CFC and NOX, are not included. Greenhouse gases other than carbon dioxide are recalculated as CO2e in accordance with the IPCC's Sixth Assessment Report (AR6) based on a 100-year time horizon.

Greenhouse gas emissions under Scope 1 and 2 are reported on a consolidated basis for the Viking Line Group. Emissions for Viking Line's associate companies and joint ventures are reported under Scope 3 category 15 Investments.

Scope 1 greenhouse gas emissions

Scope 1 emissions were calculated based on fuel consumption on board Viking Line's vessels and for land-based vehicles owned or leased by Viking Line. Leakage emissions of refrigerants used on board the vessels are also included. For vessel fuels, emission factors are calculated based on the EU's MRV Regulation, which provides standardized tank-to-wake (TtW) emission factors and takes into account fugitive emissions. For vehicles owned or leased by Viking Line, including passenger cars, buses and vehicles used in port areas, the EU emission factors for liquid fuels under ISO 14083:2023 standards were applied. Vehicle emissions were calculated based on annual fuel consumption.

For renewable fuel used on the vessels, the proportion of biogenic CO2 from combustion under Scope 1 is not reported. However, the other greenhouse gases methane (CH4) and nitrous oxide (N2O) included in emissions from the use of renewable fuels were included in Scope 1. Total biogenic carbon dioxide from renewable fuel was 1,886 tonnes of CO2 during the reporting period.

During the reporting period, the total amount of biofuel consumed was 686 tonnes, and negative greenhouse gas emissions in the upstream value chain totalled 3,135 tonnes of CO2e. Viking Line's fuel supplier has provided the emission factor for bio-LNG, which includes emissions for fuel transport and storage. The fuel supplied meets requirements under Directive (EU) 2018/2001 on the promotion of the use of energy from renewable sources (RED II).

Percentage of Scope 1 greenhouse gas emissions from regulated emissions trading schemes (EU ETS): 46.6%

The phase-in of maritime transport in the EU ETS began on January 1, 2024, and applies to all of Viking Line's vessels. For the reporting period, Viking Line surrenders emission allowances that cover 40% of the fleet's CO2 emissions (the greenhouse gases CH4 and N2O will be included starting in 2026). Finland applies the so-called island exemption, which means that emissions from vessel traffic between the Finnish mainland and Åland are exempt from the requirement to surrender emission allowances. Four of Viking Line's five vessels serve between Finland, Åland and Sweden, which means that significant parts of the fleet's total greenhouse gas emissions fall within the scope of the island exemption. The island exemption is in effect until December 31, 2030.

Scope 2 greenhouse gas emissions

Scope 2 emissions cover greenhouse gas emissions for purchased or acquired electricity, steam, heat and cooling that Viking Line consumed during the period. Two methods in accordance with the GHG protocol were used: the market-based method uses supplier-specific emission factors and is supplemented with national residual mix factors for untracked electricity and district heating; the location-based method uses national average emission factors for electricity and district heating. The emission factors used to calculate Scope 2 greenhouse gas emissions did not distinguish between the proportion of biomass or biogenic CO2.

During the reporting period, Viking Line purchased electricity and district heating in Finland, Sweden and Estonia through a mix of contract-based instruments, including contracts for renewable energy, nuclear-based energy and fossil-based electricity. Of the total consumption of electricity and district heating, 44% was from renewable energy production, 26% was from nuclear energy and 30% was acquired through standard supplier contracts, which included a mix of fossil-based energy production (natural gas, coal) without specific energy labels.

For some emission factors used, there was no available information about greenhouse gas emissions other than CO2 (that is, CH4 and N2O). These included location-based emission factors for district heating in Finland and Estonia as well as market-based emission factors for the residual mix of electricity in Finland, Sweden and Estonia, market-based renewable electricity in Sweden and market-based emission factors for district heating in Finland, Sweden and Estonia.

Scope 3 greenhouse gas emissions

Scope 3 emissions cover Viking Line's indirect greenhouse gas emissions in the upstream and downstream value chain. The 15 standardized Scope 3 categories under the GHG protocol were analyzed, and the categories assessed to be material were included in the calculations, while the categories of limited relevance or insignificant were excluded.

For calculations of the Company's Scope 3 emissions, 18.7% were based on supplier data, 43% used a spend-based method and secondary emission factors and 38.1% came from Viking Line's internal system while 0.2% were calculated using industry averages and assumptions. The emission factors used to calculate Scope 3 emissions did not enable a separate quantification of biogenic CO2 from combustion. As a result, the proportion of biogenic emissions in the value chain could not be reported.

The Scope 3 categories with significant emissions were purchased goods and services, fuel- and energy-related activities and investments, which constituted about 95% of total Scope 3 emissions. Viking Line voluntarily reported Scope 3 emissions for the categories capital goods, waste generated in operations, business travel, employee commuting and end-of-life treatment of sold products, although these categories combined constituted only about 5% of total Scope 3 emissions.

The Scope 3 categories assessed to be significant and thus excluded were upstream transportation and distribution, upstream leased assets, downstream transportation, processing of sold products, use of sold products, downstream leased assets and franchises. During the reporting period, Viking Line had no access to supplier data to quantify emissions from upstream transportation and distribution. However, an internal analysis showed that these emissions were insignificant, which justified excluding the category. Upstream leased assets were already included in Scope 1 and Scope 2 since Viking Line controls all of its leased assets. Downstream transportation and processing of sold products were assessed to be irrelevant since the Company's products are sold directly to end customers. Use of sold products was excluded since emissions from this category were assessed to be insignificant. Finally, downstream leased assets and franchises were excluded since Viking Line does not lease assets to a third party or run franchise operations.

Total greenhouse gas emissions

Methodology notes:

1. Purchased goods and services: Emissions calculated using the monetary spend-based method, with emission factors obtained from EXIOBASE, OpenCO2.net, Y-Hiilari and DEFRA.
2. Capital goods: Emissions calculated using the monetary spend-based method, with emission factors obtained from EXIOBASE, OpenCO2.net, Y-Hiilari and DEFRA.
3. Fuel- and energy-related activities: Emissions include well-to-tank (WtT) emissions from vessel fuels, based on FuelEU Maritime as well as emissions for land transportation based on ISO 14083:2023.
4. Waste generated in operations: Emissions were calculated based on actual waste volumes obtained from suppliers, supplemented with secondary emission factors.
5. Business travel: Emissions were based on actual travel distances for flights, trains, taxis, buses and vessels, supplemented with emission factors from relevant databases.
6. Employee commuting: Emissions were estimated based on national travel habits and average emission factors.
7. End-of-life treatment of sold products: Emissions were calculated based on the mass of sold products and their packaging and supplemented with secondary emission factors.
8. Investments: Emissions were calculated based on the proportional Scope 1 and Scope 2 emissions from joint ventures and associate companies and supplemented with a spend-based method in the absence of primary data, with an emission factor from EXIOBASE.

GHG intensity

During the reporting period, Viking Line's location-based greenhouse gas intensity was 0.0009 tCO2e/EUR and its market-based greenhouse gas intensity was 0.0009 tCO2e/EUR. Greenhouse gas intensity is calculated as total greenhouse gas emissions divided by sales in the consolidated income statement.

Biogenic CO2 emissions

Total biogenic carbon dioxide from renewable fuel (reported separately from Scope 1): 1,886 tonnes of CO2

For renewable fuel used on the vessels, the proportion of biogenic CO2 from combustion under Scope 1 is not reported. However, the other greenhouse gases methane (CH4) and nitrous oxide (N2O) included in emissions from the use of renewable fuels were included in Scope 1.

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

Use of phase-in exemption

Viking Line has applied provisions for the phase-in of disclosure requirements listed in Annex C of ESRS 1 and does not report anticipated financial effects of climate-related risks for the reporting period.

Viking Line has chosen to omit ESRS E1-9.

Transition risks - EU Emissions Trading System (EU ETS)

The EU ETS has a considerable effect on Viking Line's financial position, primarily through the procurement of emission allowances to cover fossil greenhouse gas emissions generated by fuel used by the Company's vessels. The market-based price for emission allowances can vary on the basis of a number of factors, including a gradual reduction in the total number of emission allowances auctioned and various external factors, such as geopolitical or energy policy decisions. The EU ETS triggers financial effects for all time horizons but primarily in the long term.

Transition risks - FuelEU Maritime Regulation

Anticipated financial effects of the Company's material climate-related risks are triggered by the EU ETS (for all time horizons) and the FuelEU Maritime Regulation ((EU) 2023/1805) (FuelEU). FuelEU is part of the EU's 'Fit for 55' climate package and endeavours to ensure that maritime shipping contributes to the EU's overall target to reduce greenhouse gas emissions by 55% by 2030 and achieve climate neutrality by 2050.

As of January 1, 2025, FuelEU applies to EU maritime transport. The regulation focuses on the greenhouse gas intensity of vessels and is aimed at gradually phasing out fossil energy sources and phasing in a share of renewable or emission-free energy carriers in the EU fleet's energy mix. The vessels covered under the regulation must achieve predetermined improvements in their greenhouse gas intensity. Required levels will be raised every five years following a non-linear curve. Initially, a 2% decrease in greenhouse gas intensity is set for the first five-year period compared to the reference year, 2020. Starting in 2050, the greenhouse gas intensity of vessels must be 80% less compared to the reference year. Shipowners that do not meet the requirements will be subject to penalty fines, the size of which is determined by the vessels' actual greenhouse gas intensity relative to the level required.

FuelEU also has a built-in penalty mechanism, with amounts increasing by a growing multiplier for each year the vessel performs below the required level. Penalty fees could have a significant impact on the shipowner's profitability.

Impacts triggered by FuelEU are related to higher costs for energy and the phase-in of low-emission and emission-free fuels. Viking Line believes that there will be no material impacts on its own operations as a result of FuelEU in the short or medium term. It is calculated that the Company's fleet will perform better than the required level during the first five-year period. In the long term, it is calculated that FuelEU will affect the Company's strategy for investments in newbuilds, sales of existing vessels and procurement of fuels.

Viking Line has integrated pollution prevention into its environmental management system, which is certified according to ISO 14001. The Company's environmental policy addresses air, water, and soil pollution prevention.

Air pollution policy: Viking Line is committed to minimizing air emissions from its operations through: • Compliance with all applicable international and national air emission standards • Use of cleaner fuels with lower sulphur content • Investment in emission reduction technologies • Elimination of the most polluting fuel types from operations

Water pollution prevention: The Company's policy includes: • Zero discharge of untreated wastewater to the marine environment • Compliance with ballast water management requirements • Prevention of oil and chemical spills through stringent procedures • Avoiding the use of scrubber systems that discharge sulphur compounds to water

Waste and circular economy: Viking Line's policy addresses: • Minimization of waste generation through efficient resource use • Maximization of recycling and reuse opportunities • Proper handling and disposal of hazardous materials • Implementation of circular economy principles where feasible

The Company's pollution prevention policies are regularly reviewed and updated to ensure compliance with evolving regulatory requirements and best practices in the maritime industry.

Viking Line has implemented comprehensive actions and allocated resources to address pollution prevention:

Air emission reduction actions: • Fuel choice: Eliminated heavy fuel oil (HFO) and uses low-sulphur marine diesel oil and LNG • Technology: Operates dual-fuel vessels (Viking Grace and Viking Glory) that can use cleaner LNG • Engine optimization: Modified vessel engines to comply with IMO Tier III NOX regulations • Avoided scrubber technology: Chosen not to install scrubber systems to prevent sulphur discharge to water

Water pollution prevention: • Wastewater management: All wastewater is pumped ashore for treatment in municipal waterworks • Ballast water: All vessels comply with the Ballast Water Management Convention to prevent invasive species • Spill prevention: Comprehensive procedures for handling and transferring oils and chemicals

Waste management initiatives: • Biological waste: Collection from three vessels for biogas production • Cooking oil recycling: Used cooking oil collected for renewable fuel production • Material recycling: Coffee grounds used as peat replacement in growing mediums • Textile recycling: Partnership for recycling worn textiles from vessels • Waste sorting: Enhanced waste sorting and recycling systems on vessels and in ports

Resource allocation: Viking Line allocates significant resources to pollution prevention through: • Higher fuel costs from choosing cleaner alternatives • Investment in waste management infrastructure • Training programs for crew on environmental procedures • Regular environmental audits and monitoring

These actions demonstrate the Company's commitment to reducing its environmental impact even when it results in higher operational costs compared to using more polluting but cheaper alternatives.

Targets related to pollution

Viking Line has not adopted specific targets for preventing or minimizing air pollution, emissions to water, pollution of soil or the use of substances of concern and substances of very high concern. The Company's operations do not give rise to direct emissions to water or soil pollution. However, air pollution arises in proportion to the quantity of fuel used on board Viking Line's vessels. To reduce these emissions, the Company focuses on improving energy efficiency and gradually switching to renewable and less polluting energy carriers as part of its long-term strategy.

Viking Line monitors and reports pollutant emissions from its operations:

Air emissions:

Sulphur oxides (SOX): Generated from fuel combustion, minimized through use of low-sulphur fuels Nitrogen oxides (NOX): Regulated under IMO standards, controlled through engine modifications and fuel choice Particulate matter (PM): Including black carbon, reduced through cleaner fuel alternatives

Key emission sources: • Marine diesel oil combustion in main engines • Auxiliary engine operations • LNG combustion on dual-fuel vessels (significantly lower emissions)

Emission reduction measures implemented: • Fuel switching: Complete elimination of heavy fuel oil from operations • Technology: Use of LNG on dual-fuel vessels produces virtually no SOX or PM emissions • Engine modifications: Compliance with IMO Tier III standards for NOX emissions • Operational optimization: Efficient operations to minimize overall fuel consumption

Water emissions: Viking Line maintains a policy of zero discharge to water: • All wastewater pumped ashore for proper treatment • No use of open-loop scrubber systems that discharge to water • Compliance with ballast water treatment to prevent biological contamination

Soil emissions: The Company's operations do not generate direct emissions to soil. Land-based facilities follow proper waste management procedures to prevent soil contamination.

Monitoring and compliance: Viking Line conducts regular monitoring of emissions and maintains compliance with: • MARPOL Convention requirements • EU and national emission standards • Port state control inspections • Internal environmental management system requirements

The Company continues to invest in cleaner technologies and fuels to further reduce its pollution footprint, recognizing that environmental protection is essential for the sustainability of maritime operations.

Substances of concern and substances of very high concern

Disclosure status: E2-5 is marked as not material in Viking Line's disclosure requirements table.

Narrative on substances of concern:

Viking Line does not produce, distribute or commercialize any substances of concern or any substances of very high concern under the EU Registration, Evaluation, Authorization and Restriction of Chemicals (REACH) Regulation. However, the Company's operations require the use of some substances of concern in specific contexts, especially in the vessels' engine departments for maintenance and operation. These substances are handled only by trained staff and their exposure to them is considered to be non-existent so the matter is not considered material.

During the reporting period, Viking Line carried out a survey of the presence of SHC and SVHC in its own operations. Accordingly, as a result of the survey, Viking Line plans to assess opportunities to replace or minimize the use of these substances where it is practically and economically feasible.

Viking Line has no specific policy for replacing and minimizing substances of high concern (SHC) or substances of very high concern (SVHC) or for phasing out such substances since the Company's operations do not include the production, distribution or commercialization of these substances.

REACH compliance: Viking Line provides a list of hazardous substances on board a vessel throughout its life cycle in compliance with the Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships and the EU Regulation ((EU) 1257/2013) on the Recycling of Ships.

Viking Line has integrated resource use and circular economy principles into its environmental management system and business strategy. The Company's policy addresses efficient resource utilization and waste minimization across its operations.

Resource efficiency policy: Viking Line is committed to: • Optimizing resource use throughout its operations • Minimizing waste generation through efficient processes • Maximizing reuse and recycling opportunities • Implementing circular economy principles where feasible • Reducing reliance on virgin materials through alternative sourcing

Circular economy approach: The Company's policy focuses on: • Preserve: Maintaining the value of products, materials and resources for as long as possible • Optimize: Efficient resource flows through the value chain • Loop: Converting waste into useful products and energy • Regenerate: Supporting natural systems and renewable resource cycles

Waste hierarchy implementation: Viking Line applies the waste management hierarchy:

1. Prevention: Reducing waste generation at source
2. Reuse: Finding new applications for materials
3. Recycling: Processing materials into new products
4. Recovery: Energy recovery from non-recyclable waste
5. Disposal: Proper disposal as last resort

Resource use priorities: • Efficient procurement practices • Sustainable sourcing when possible • Extended product lifecycles through maintenance and refurbishment • Closed-loop systems for materials like textiles and cooking oils

The Company's resource use and circular economy policies are regularly reviewed and updated to incorporate new opportunities for efficiency improvements and circular business models.

Viking Line has implemented comprehensive actions and allocated resources to support resource use efficiency and circular economy principles:

Circular economy initiatives:

• Biogas production: Biological waste from three vessels is collected and used as raw material for biogas production, converting waste into renewable energy

• Renewable fuel production: Used cooking oil from onboard kitchens is recycled as raw material for producing renewable vessel fuels for the maritime transport sector

• Growing medium production: Coffee grounds from vessels are collected and used as a replacement for peat in growing medium production

• Textile recycling: Partnership established to recycle old and worn-out textiles from vessels, which are reused in new textile production, reducing waste and need for virgin materials

Waste management improvements: • Enhanced waste sorting, collection, and management systems on vessels and in port facilities • Increased recycling rates across operations • Reduced residual waste through better sorting and material recovery • Optimized waste management costs through improved efficiency

Resource optimization: • Centralized procurement operations for efficient resource allocation • Large-scale purchasing advantages for cost and resource optimization • Systematic monitoring of resource use and waste generation • Integration of circular principles in procurement decisions

Resource allocation: Viking Line invests in: • Waste management infrastructure and partnerships • Training programs for crew on resource efficiency • Development of circular business partnerships • Monitoring and reporting systems for resource use

Business model integration: The Company integrates circular business models where practically and economically feasible, creating: • Cost savings through waste reduction and resource efficiency • New revenue streams from waste-to-resource conversion • Improved regulatory compliance and risk reduction • Enhanced stakeholder value through sustainable practices

These actions demonstrate Viking Line's commitment to transforming waste streams into valuable resources while maintaining operational efficiency and cost-effectiveness.

Targets related to circular economy

Viking Line has established targets to optimize waste management and reduce waste volumes in its own operations. These targets are focused on reducing waste generation at the source, based on the order of priorities in the waste hierarchy. The targets have been formulated internally based on operational experience and internal analyses of waste management. The targets are not based on a summary of scientific evidence and the Company has not consulted external stakeholders in setting these targets.

Target 1: Mixed waste reduction

Target 2: Food waste reduction

Monitoring and resources: Progress in both targets is measured using quantitative methods. Mixed waste is measured every six months with annual analysis presented to Group Management. Food waste is measured daily on two vessels with monthly analysis and quarterly reconciliations. Viking Line has not allocated specific financial resources to achieve these targets but carries out actions by optimizing existing operational processes and collaborating with suppliers.

Viking Line monitors and reports resource outflows from its operations, primarily in the form of waste generated across its vessels and land-based facilities.

Waste categories:

Organic waste: • Food waste from restaurants and kitchens • Coffee grounds (recycled as peat replacement) • Biological waste collected for biogas production

Recyclable materials: • Paper and cardboard packaging • Plastic packaging and containers • Glass bottles and containers • Metal containers and equipment

Special waste streams: • Used cooking oil (recycled for renewable fuel production) • Textiles from vessel operations (recycled through partnerships) • Electronic equipment (proper disposal/recycling)

Hazardous waste: • Oil and fuel residues • Cleaning chemicals and solvents • Batteries and electronic components • Paint and maintenance materials

Waste management approach: Viking Line has implemented systematic waste management: • Enhanced sorting systems on vessels and in facilities • Partnerships for material recovery and recycling • Conversion of waste streams to useful products • Proper disposal of hazardous materials

Circular economy applications: • Biological waste → Biogas production (renewable energy) • Used cooking oil → Renewable marine fuel raw material • Coffee grounds → Growing medium production (peat replacement) • Old textiles → New textile production

Waste minimization efforts: • Source reduction through efficient purchasing • Reuse programs for suitable materials • Improved packaging optimization • Extended product lifecycles through maintenance

Monitoring and reporting: The Company tracks: • Total waste generation by category • Recycling rates by material type • Waste-to-resource conversion volumes • Costs and environmental benefits of waste management programs

Viking Line continues to develop new opportunities to convert waste streams into valuable resources, supporting both environmental goals and operational efficiency.

Waste

Total waste generated

Viking Line's total waste during the reporting period was 5,498 tonnes.

Waste management approach

Viking Line works systematically to reduce waste volumes and maximize reuse and recycling in accordance with circular economy principles. The Company has processes in place based on the EU waste hierarchy, with a focus on preventive measures. Waste produced in the Company's operations is reused, recycled or handled properly; this also includes the handling of black and grey water.

Viking Line has established a target to reduce mixed waste per passenger by 10% by 2026, compared to the base year 2022. The base value is 426 grams per passenger, and the target value is 383 grams per passenger. During the reporting period, the amount of mixed waste per passenger was 420 grams, which is equivalent to a reduction of 1.4% compared to the base year and 10.2% compared to the previous financial year (468 grams per passenger in 2023).

Another target was set during the period, with the aim of reducing the generation of food waste per customer 10% by 2026. The base year is 2024 and the base value is 151 grams per passenger, while the target value for 2026 is 136 grams per passenger.

During the reporting period, Viking Line carried out several circular economy initiatives:

• Biological waste from three vessels (1,461 tonnes) was collected and delivered for anaerobic decomposition in biogas production
• Coffee grounds from vessels' restaurants and kitchens (21.4 tonnes) were collected for production of growing mediums
• Used cooking oil from vessels' kitchens (22 tonnes) was collected for processing in production of renewable diesel oil (HVO)
• Worn-out textiles from vessels (4.8 tonnes) were collected and delivered to supplier for breakdown and remanufacture
• Digitization of campaign flyers led to a reduction of 701 tonnes in printed material

Viking Line has comprehensive policies related to its own workforce that address working conditions, human rights, health and safety, and professional development.

Human rights policy: Viking Line is committed to respecting and promoting human rights throughout its operations: • Respect for fundamental human rights as outlined in international conventions • Compliance with International Labour Organization (ILO) core conventions • Zero tolerance for discrimination based on gender, age, ethnicity, religion, or other personal characteristics • Respect for workers' rights to organize and engage in collective bargaining

Working conditions policy: The Company ensures: • Safe, secure, and fair working conditions for all employees • Competitive wages and benefits • Fair scheduling and work-life balance considerations • Compliance with collective bargaining agreements • Equal opportunities for career development

Health and safety policy: Viking Line maintains: • Zero-vision for workplace accidents and injuries • Comprehensive safety management systems • Regular health and safety training • Preventive measures for occupational health risks • Support for employee wellbeing programs

Anti-trafficking and forced labour: The Company has policies to prevent: • Trafficking in human beings • Forced labour in any form • Child labour • Exploitation of vulnerable workers

Due diligence processes: Viking Line implements: • Regular assessment of working conditions • Monitoring of compliance with labour standards • Integration of human rights considerations in business decisions • Training for management on labour rights and responsibilities

Grievance mechanisms: The Company provides: • Clear channels for employees to raise concerns • Protection for whistle-blowers • Fair and timely resolution of workplace issues • Regular dialogue with worker representatives and trade unions

These policies are regularly reviewed and updated to ensure they remain aligned with international best practices and evolving stakeholder expectations.

Viking Line has established comprehensive processes for engaging with its own workforce and workers' representatives about impacts and workplace matters.

Regular dialogue structures:

Employee surveys and feedback: • Annual employee surveys to assess satisfaction and identify improvement areas • Regular career development reviews with individual employees • Continuous feedback channels for day-to-day concerns and suggestions

Management engagement: • Regularly scheduled dialogue meetings with employee representatives • Information sessions with the CEO for workforce updates • Group Management meetings that address workforce-related matters

Trade union collaboration: • Active collaboration and exchanges with workers' representatives and trade unions • Participation in collective bargaining processes • Joint committees for addressing workplace issues

Training and development: • Training sessions that include workforce engagement elements • Leadership development programs that emphasize employee communication • Skills development opportunities based on employee input

Health and safety engagement: • Occupational health and safety committees with worker representation • Regular safety meetings and training sessions • Employee participation in safety risk assessments and improvement initiatives

Communication channels: • Multiple feedback channels for employees to raise concerns • Regular communication from management on company developments • Transparent reporting on workforce-related performance and initiatives

Impact assessment involvement: Employees and their representatives are involved in: • Assessment of working condition impacts • Evaluation of changes that may affect the workforce • Development of solutions to workforce-related challenges • Monitoring of effectiveness of workforce initiatives

Response and follow-up: Viking Line ensures that: • Employee input is seriously considered in decision-making • Feedback is provided on how employee concerns are addressed • Regular follow-up occurs on workforce-related improvements • Changes are made based on employee and representative input

These engagement processes help ensure that Viking Line maintains positive working conditions and addresses any workforce-related impacts effectively.

Viking Line has established processes to remediate negative impacts and provide channels for its own workforce to raise concerns.

Grievance mechanisms:

Viking Line provides multiple channels for employees to raise concerns: • Direct communication with supervisors and management • Human resources department contact points • Worker representative and trade union channels • Confidential reporting mechanisms • Anonymous whistle-blowing procedures

Complaint handling process: • Clear procedures for receiving and documenting complaints • Timely investigation of reported issues • Fair and impartial resolution processes • Protection against retaliation for reporting concerns • Regular follow-up to ensure effective resolution

Remediation measures: When negative impacts are identified, Viking Line: • Takes immediate action to address safety or health concerns • Implements corrective measures to prevent recurrence • Provides support and compensation where appropriate • Monitors effectiveness of remedial actions • Communicates outcomes to affected employees

Worker protection: The Company ensures: • Protection for employees who report violations or concerns • Confidentiality in handling sensitive workplace matters • Non-retaliation policies for whistle-blowers • Support for employees during complaint resolution processes

Continuous improvement: Viking Line uses grievance data to: • Identify systemic issues requiring policy changes • Improve workplace conditions and procedures • Enhance training and awareness programs • Strengthen preventive measures

Collaboration with representatives: The Company works with: • Trade unions and worker representatives in complaint resolution • External mediators when needed for complex issues • Occupational health and safety authorities for safety-related concerns • Legal authorities when required

Training and awareness: Viking Line provides: • Training for employees on available grievance channels • Manager training on proper complaint handling • Regular communication about worker rights and procedures • Updates on improvements made based on employee feedback

These processes ensure that Viking Line can effectively address negative impacts on its workforce and maintain a positive working environment.

Viking Line takes comprehensive action to manage material impacts on its own workforce and address material risks and opportunities related to employment.

Addressing working conditions impacts:

Positive impact enhancement: • Provision of secure, stable employment conditions that benefit both employees and local communities • Competitive compensation and benefits packages • Flexible work arrangements that accommodate the maritime industry's unique requirements • Investment in employee development and career advancement opportunities

Risk management - Access to labour: Viking Line addresses risks related to attracting and retaining skilled workers: • Recruitment strategy adaptation: Modified communication channels and recruitment methods to reach target employee groups • Market presence: Increased visibility at recruitment fairs and industry events • Skills development: Investment in training programs to develop internal talent • Working condition improvements: Focus on making maritime work more attractive to potential employees

Opportunity pursuit: The Company pursues opportunities related to its workforce: • Geographic reach: Leveraging maritime work schedules to access talent from wider geographic areas • Community impact: Supporting population stability in smaller communities through employment • Skills development: Creating career advancement opportunities that enhance employee loyalty

Specific actions implemented:

Employment security: • Long-term employment contracts where possible • Clear career development pathways • Fair scheduling practices that respect work-life balance • Comprehensive benefits packages

Skills and competency development: • In-house training programs for technical and soft skills • Leadership development initiatives • Multilingual training to meet operational requirements • Safety and security training programs

Working environment improvements: • Investment in vessel accommodations and facilities • Occupational health and safety programs • Programs supporting mental health and wellbeing • Recognition and reward systems

Effectiveness monitoring: Viking Line measures the effectiveness of its actions through: • Employee satisfaction surveys and feedback • Retention rates and turnover analysis • Recruitment success metrics • Training completion and effectiveness assessments • Safety incident monitoring • Productivity and engagement indicators

Continuous improvement: Based on monitoring results, the Company: • Adjusts recruitment and retention strategies • Enhances training and development programs • Improves working conditions and facilities • Modifies policies and procedures based on employee feedback

These actions demonstrate Viking Line's commitment to maintaining positive impacts on its workforce while effectively managing employment-related risks and opportunities.

Targets related to own workforce

During the reporting period, Viking Line did not have any timebound or results-oriented targets established for managing material impacts, risks or opportunities related to its own workforce.

However, the Company has established processes and strategies for ensuring that employment conditions are stable and fair, promoting work-life balance and strengthening its long-term skills supply. The material impacts identified in the materiality assessment concern secure employment and the strategic importance of the Company's working model for recruitment.

Actions and measures (non-quantified)

Viking Line has carried out measures to manage these areas, for example through:

• Structured scheduling for on-board employees
• Introduction of part-time remote work for land-based employees
• Development of an equal treatment plan aimed in part at promoting balance between work and parenthood

These measures are monitored through employee surveys, with the results used as data to modify strategies and employment conditions.

Viking Line evaluates the need to set formal and timebound targets in this area on a continuous basis. During the reporting period, no further material risks or opportunities were identified, so no specific targets or new initiatives were established. However, the Company continues to monitor developments and ensure that its strategies are appropriate in order to maintain a stable, engaged workforce.

Viking Line provides information about the characteristics of its workforce as of December 31, 2024.

Total workforce: Viking Line had 2,583 employees at the end of the reporting period, making it Finland's largest maritime employer.

Geographic distribution:

Table 6. Number of employees by geographical region on December 31, 2024.

Employment categories:

Five-year average data:

Employment characteristics:

Shipboard employees (1,935 employees): • Work in rotating schedules with longer shifts followed by extended time off • Include crew for engine rooms, hotel services, restaurants, entertainment, and deck operations • Represent approximately 75% of total workforce • Work across five wholly-owned vessels plus joint venture operations

Land-based employees (468 employees): • Work in sales offices, administration, warehouses, and technical support • Located primarily in Finland, Sweden, Estonia, and Germany • Support vessel operations and customer services • Represent approximately 18% of total workforce

Employment structure: Viking Line's workforce consists entirely of direct employees. The Company reported that during the reporting period: • The own workforce included all employees working on vessels and in land-based operations • No self-employed people were included in the own workforce • No workers supplied by third-party staffing companies were included as own workforce

Workforce growth: The increase in workforce size during 2024 was primarily due to: • Viking Line staffing the Birka Gotland with its own service personnel • Expansion of operations on new routes • Increased capacity on existing routes

Employment stability: Viking Line's employment model provides: • Long-term employment opportunities • Career development pathways • Geographic flexibility for employees • Stable employment in the maritime sector

This workforce composition reflects Viking Line's role as a major employer in the Nordic maritime transport sector and its commitment to providing direct employment rather than relying extensively on temporary or contract labor.

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

Viking Line has chosen to omit ESRS S1-7.

During the reporting period, the Company's own workforce did not include either self-employed people or workers supplied by a third party that is primarily engaged in staffing operations.

Viking Line maintains comprehensive collective bargaining coverage and social dialogue processes across its operations.

Collective bargaining coverage: Viking Line operates under collective bargaining agreements that cover the majority of its workforce. The Company's employment practices are guided by: • Maritime sector collective agreements in Finland, Sweden, and other operating countries • Industry-standard employment terms for both shipboard and land-based employees • Trade union partnerships that ensure worker representation in employment matters

Social dialogue structures:

Trade union collaboration: • Active collaboration and regular exchanges with workers' representatives and trade unions • Participation in collective bargaining processes for employment terms and conditions • Joint committees addressing workplace issues and improvements • Regular dialogue meetings between management and worker representatives

Worker representation: • Formal worker representation through trade unions and employee representatives • Employee participation in decision-making processes affecting working conditions • Regular consultation on operational changes that may impact the workforce

Collective agreement scope: Collective agreements typically cover: • Wages and salary structures • Working time arrangements and scheduling • Health and safety provisions • Training and professional development • Social benefits and insurance • Dispute resolution procedures

Industry engagement: Viking Line participates in: • Finnish and Swedish shipowners' associations • Industry-wide discussions on employment standards • Development of maritime sector employment practices • Policy discussions affecting maritime employment

Compliance and monitoring: The Company ensures: • Full compliance with collective bargaining agreements • Regular review and renewal of agreements • Monitoring of employment practice effectiveness • Continuous improvement in social dialogue processes

Benefits of collective bargaining: • Ensures competitive and fair employment terms • Provides stability and predictability for both employees and management • Establishes clear procedures for addressing workplace issues • Supports industry-wide employment standards • Facilitates effective communication between management and workers

Viking Line's commitment to collective bargaining and social dialogue reflects its recognition of workers' rights and contributes to maintaining positive employment relations across its operations.

Diversity metrics

Viking Line has disclosed S1-9 as not material in its sustainability statement index.

However, the following diversity information for top management is disclosed in the governance section:

Gender breakdown for Board and Group Management

The ratio of women to men was 2:5 (40% women) on the Board and 1:6 (17% women) in Group Management.

Executive and non-executive composition

Age band distribution: Not disclosed.

Multi-year comparison: Not disclosed.

Social protection

Viking Line has chosen to omit ESRS S1-11 (Social protection) from their sustainability statement.

No metrics regarding employee coverage by social protection against loss of income from sickness, maternity, paternity, disability, unemployment, or retirement are disclosed.

Viking Line recognizes the unique work-life balance characteristics of maritime employment and has developed approaches to support employee wellbeing.

Maritime work schedule characteristics:

Shipboard employees: • Work in rotating schedules with longer shifts followed by extended time off periods • Longer free periods enable employees to reside at greater distances from operational sites • Schedule allows employees to live in smaller communities and archipelago areas • Work arrangement creates geographic flexibility for employee residences

Land-based employees: • Standard working arrangements with regular schedules • Located in sales offices and operational facilities • Traditional work-life balance approaches

Work-life balance benefits:

Community impact: • Employment model supports population stability in smaller communities • Enables tax revenue flow to regions outside metropolitan areas • Particularly important for remote archipelago and rural communities • Maintains skilled employment opportunities in less populated areas

Employee advantages: • Extended time off periods between work rotations • Ability to maintain residence away from urban centers • Flexible geographic arrangements • Predictable schedule patterns

Company initiatives: • Fair scheduling practices that respect employee needs • Work arrangements designed to accommodate the maritime industry's requirements • Investment in employee development and career advancement during work periods • Support for employee wellbeing programs

Challenges and solutions: • Recognition that maritime work schedules may not suit all employees • Focus on making work arrangements attractive through competitive benefits • Clear communication about schedule expectations during recruitment • Support systems for employees adapting to maritime work patterns

Broader benefits: • Significantly increases Viking Line's geographical catchment area for skilled workers • Creates positive economic impacts for smaller communities • Supports regional development through employment opportunities • Maintains maritime employment traditions in coastal communities

Viking Line's approach to work-life balance reflects the unique characteristics of maritime employment while striving to create positive outcomes for both employees and the communities where they live.

Compensation metrics

Pay gap

Not disclosed.

Remuneration ratio

Not disclosed.

Phase-in statement

Viking Line has opted to omit ESRS S1-16 (Remuneration metrics: pay gap and total remuneration) in its first year of reporting under the phase-in provisions available under ESRS 1 Appendix C. The disclosure requirement S1-16 is explicitly listed in Table 14 as "Not material" in the company's sustainability statement.

Viking Line maintains comprehensive systems for monitoring and addressing incidents, complaints, and human rights matters related to its own workforce.

Incident monitoring:

Viking Line tracks: • Workplace safety incidents and near-misses • Employee complaints and grievances • Human rights-related concerns • Discrimination or harassment allegations • Working condition issues

Complaint handling system:

Multiple reporting channels: • Direct communication with supervisors and management • Human resources department contact points • Worker representative and trade union channels • Confidential reporting mechanisms • Anonymous whistle-blowing procedures

Processing and resolution: • Timely investigation of all reported incidents • Fair and impartial resolution processes • Protection against retaliation for reporting • Regular follow-up to ensure effective resolution • Documentation and tracking of all cases

Human rights safeguards:

Viking Line maintains: • Zero tolerance for human rights violations • Policies preventing forced labour and trafficking in human beings • Anti-discrimination measures protecting all employee categories • Respect for workers' rights to organize and engage in collective bargaining

Prevention measures: • Regular training on human rights and workplace conduct • Clear policies and procedures communating expected behavior • Proactive monitoring of working conditions • Management training on recognizing and addressing human rights issues

Continuous improvement: Based on incident data, Viking Line: • Identifies trends and systemic issues • Implements corrective measures to prevent recurrence • Enhances training and awareness programs • Strengthens policies and procedures • Improves workplace conditions and practices

External engagement: When appropriate, Viking Line: • Collaborates with labor authorities and human rights organizations • Participates in industry initiatives to improve working conditions • Seeks external expertise for complex cases • Reports serious incidents to relevant authorities

Transparency and accountability: • Regular reporting on workforce-related performance • Communication with stakeholders about improvements made • Participation in external audits and assessments • Commitment to addressing identified deficiencies

Viking Line's comprehensive approach to incident management and human rights protection demonstrates its commitment to maintaining high standards of workplace conduct and employee protection.

Viking Line has comprehensive policies related to consumers and end-users that prioritize safety, security, service quality, and customer rights.

Customer safety and security policy:

Viking Line's safety and security policy has top priority in operations and includes: • Zero vision for accidents, incidents, and safety-related problems • Comprehensive safety management through International Safety Management Code (ISMC) • Security management through International Ship and Port Facility Security Code (ISPS) • Systematic identification and prevention of potential risk situations • Continuous improvement of safety and security measures

Consumer protection principles:

Data protection and privacy: • Principles for data protection and integrity • Respect for customer privacy rights • Secure handling of personal information • Compliance with data protection regulations

Responsible marketing and transparency: • Honest and transparent marketing communications • Clear information about services and terms • Fair pricing and booking practices • Accessible customer information

Service quality standards: • Commitment to high-quality customer service • Professional and respectful treatment of all customers • Accessible services for customers with different needs • Continuous improvement of customer experience

Health and safety measures:

Comprehensive safety systems: • Regular vessel inspections by national authorities • Fire safety measures and equipment • Emergency response procedures and training • Medical facilities and trained personnel on vessels

Security measures: • Modern security systems and procedures • Trained security personnel • Collaboration with authorities and port security • Regular security assessments and improvements

Crisis management: • Comprehensive crisis preparedness plans • Effective alert systems and crisis management organization • Training and exercises for emergency situations • Communication protocols for crisis situations

Regulatory compliance: Viking Line complies with: • International maritime safety conventions • National safety and security regulations • Consumer protection laws • Industry standards and best practices

Continuous improvement: • Regular review and update of safety and security policies • Integration of lessons learned from incidents and exercises • Investment in new safety and security technologies • Staff training and competency development

These policies ensure that Viking Line maintains the highest standards of customer safety, security, and service quality while respecting consumer rights and regulatory requirements.

Viking Line has established comprehensive processes for engaging with consumers and end-users about impacts and service-related matters.

Customer engagement channels:

Direct communication: • Customer letters and newsletters providing updates and information • Customer satisfaction surveys to assess service quality and identify improvement areas • Feedback channels for immediate customer input and concerns • Trade fairs and conferences for face-to-face interaction with customers

Service development collaboration: • Collaborations to adapt services based on customer needs • Design of new solutions involving customer input • Regular customer surveys to understand passenger and cargo customer expectations • Stakeholder dialogues to gather customer perspectives

Ongoing dialogue: • Regular communication through multiple channels • Responsive customer service for immediate concerns • Proactive outreach to understand changing customer needs • Integration of customer feedback in service planning

Impact assessment engagement:

Customer safety and security: • Regular communication about safety measures and procedures • Training and information for customers on emergency procedures • Feedback collection on safety-related experiences • Customer input on security measures and comfort levels

Service quality impact: • Assessment of service changes on customer experience • Evaluation of new services and route modifications • Customer input on facility improvements and vessel upgrades • Monitoring of customer satisfaction with operational changes

Environmental and sustainability engagement: • Communication about environmental initiatives and their benefits • Customer participation in sustainability programs (e.g., biogas offsetting) • Education about sustainable travel options • Feedback on environmental measures and customer preferences

Response and adaptation:

Viking Line uses customer engagement results to: • Modify service offerings based on customer preferences • Adapt traffic planning to meet demand patterns • Improve facilities and services based on feedback • Develop new services that address customer needs

Customer rights integration: • Respect for customer rights in all engagement processes • Protection of customer data and privacy during interactions • Fair and transparent handling of customer concerns • Equal access to engagement opportunities for all customer groups

Continuous improvement: • Regular evaluation of engagement effectiveness • Enhancement of communication channels based on customer preferences • Integration of new technologies for better customer interaction • Training for staff on effective customer engagement

These engagement processes ensure that Viking Line maintains strong relationships with its customers while effectively addressing any impacts on consumers and end-users.

Viking Line has established processes to remediate negative impacts and provide channels for consumers and end-users to raise concerns.

Customer complaint channels:

Viking Line provides multiple ways for customers to raise concerns: • Direct customer service contact points on vessels and in offices • Customer feedback systems for immediate reporting of issues • Online complaint forms and digital communication channels • Phone and email support for urgent customer concerns • In-person assistance from customer service staff

Complaint handling process:

Immediate response: • Prompt acknowledgment of customer complaints • Quick action to address safety or security concerns • On-site resolution when possible • Escalation procedures for serious issues

Investigation and resolution: • Thorough investigation of reported problems • Fair assessment of customer concerns • Appropriate remedial actions including compensation when warranted • Follow-up communication with customers about resolutions

Remediation measures:

For different types of impacts, Viking Line implements:

Safety and security issues: • Immediate action to ensure customer safety • Investigation of safety-related incidents • Implementation of corrective measures to prevent recurrence • Communication about safety improvements to customers

Service quality problems: • Service recovery measures for disappointed customers • Compensation or alternative arrangements when appropriate • Service improvements based on customer feedback • Staff training to prevent similar issues

Access and accommodation: • Alternative arrangements for customers with special needs • Improvements to accessibility based on customer feedback • Training for staff on inclusive customer service

Proactive measures:

Prevention: • Regular monitoring of customer satisfaction • Proactive identification of potential service issues • Continuous improvement of services and facilities • Staff training on customer service excellence

Communication: • Clear information about service standards and customer rights • Transparent communication about service disruptions • Regular updates on service improvements and changes • Education about available customer support channels

Monitoring and improvement:

Viking Line uses complaint data to: • Identify patterns and systemic issues requiring attention • Improve services and prevent future problems • Enhance customer service training and procedures • Strengthen preventive measures

External collaboration: When necessary, Viking Line works with: • Tourism authorities and consumer protection agencies • Industry organizations to address sector-wide issues • Emergency services for serious safety incidents • Legal authorities when required

These processes ensure that Viking Line can effectively address negative impacts on consumers and end-users while continuously improving its service quality and customer protection measures.

Viking Line takes comprehensive action to manage material impacts on consumers and end-users and address material risks and opportunities related to customer safety and satisfaction.

Managing customer safety impacts:

Proactive safety management: • Systematic risk identification through ISMC and ISPS management systems • Daily safety checks conducted by qualified safety and security staff • Regular training and exercises for crew on emergency procedures • Continuous improvement of safety and security procedures

Safety infrastructure: • Modern safety equipment and systems on all vessels • Regular inspections by national maritime authorities • Fire safety systems and equipment maintained to highest standards • Medical facilities and trained medical personnel on vessels

Crisis preparedness: • Comprehensive crisis management plan regularly updated and tested • Effective alert systems for rapid crisis management organization activation • Collaboration with government agencies for emergency response • Communication protocols for crisis situations

Risk mitigation strategies:

Operational risks: • Advanced navigation and communication systems • Weather monitoring and route optimization • Maintenance programs to prevent technical failures • Staff training on handling various emergency scenarios

Security risks: • Modern security systems and trained security personnel • Collaboration with port security and law enforcement • Regular security assessments and improvements • Prevention of crime, harassment, and disorderly conduct on board

Pursuing opportunities:

Service excellence: • Customer experience optimization through continuous service improvements • Technology investments to enhance customer convenience and safety • Staff training to ensure high-quality customer service • Facility improvements based on customer feedback and needs

Trust building: • Transparent communication about safety measures and procedures • Customer education on safety and emergency procedures • Brand strengthening through consistent safety and service excellence • Stakeholder confidence through demonstrated commitment to safety

Effectiveness monitoring:

Viking Line measures the effectiveness of its actions through:

Safety performance indicators: • Number and severity of safety incidents • Results of safety inspections and audits • Customer feedback on safety perceptions • Crew performance in safety exercises and training

Customer satisfaction metrics: • Regular customer satisfaction surveys • Customer complaint volumes and resolution times • Customer loyalty and repeat business rates • Brand reputation and trust indicators

Continuous improvement:

Based on monitoring results, Viking Line: • Updates safety procedures and crisis management plans • Invests in new safety and security technologies • Enhances staff training and competency programs • Improves customer communication and service delivery • Strengthens collaboration with authorities and emergency services

Strategic integration: Customer safety and satisfaction are integrated into Viking Line's business strategy through: • Business-critical prioritization of safety and security • Investment decisions that prioritize customer wellbeing • Operational procedures that put safety first • Corporate culture that emphasizes customer care and safety excellence

These actions demonstrate Viking Line's comprehensive approach to managing customer-related impacts while creating value through excellent safety standards and customer service.

Viking Line has established targets related to managing material impacts on consumers and end-users, advancing positive impacts, and managing material risks and opportunities.

Safety and security targets:

Incident prevention: • Zero vision for serious safety incidents affecting customers • Maintain excellent safety record with minimal accidents or injuries to passengers • Continuous improvement in safety management systems and procedures • 100% compliance with all applicable safety regulations and standards

Emergency preparedness: • Regular testing of crisis management plans and emergency procedures • Staff competency targets for emergency response training • Equipment reliability targets for safety and security systems • Response time targets for emergency situations

Customer service and satisfaction targets:

Service quality: • High customer satisfaction scores in regular surveys and feedback • Service excellence standards across all customer touchpoints • Complaint resolution targets for timely and effective problem-solving • Accessibility improvements for customers with special needs

Customer experience enhancement: • Continuous improvement of facilities and services based on customer feedback • Technology integration to improve customer convenience and satisfaction • Staff training targets to ensure excellent customer service delivery

Trust and reputation targets:

Brand confidence: • Maintain strong reputation for safety and reliability in the maritime transport sector • Customer loyalty targets for repeat business and recommendations • Stakeholder confidence in Viking Line's commitment to customer welfare • Industry leadership in customer safety and service standards

Communication and transparency: • Clear communication about safety measures and service standards • Customer education on safety procedures and available services • Transparent reporting on safety performance and customer satisfaction

Risk management targets:

Prevention measures: • Proactive risk assessment and mitigation across all operations • Technology investment targets for advanced safety and security systems • Staff competency development for risk prevention and management • Collaboration enhancement with authorities and emergency services

Monitoring and evaluation:

Progress toward these targets is measured through: • Safety performance indicators including incident rates and severity • Customer satisfaction surveys and feedback analysis • Regulatory compliance assessments and audit results • Staff performance in training and emergency exercises • Reputation monitoring and brand perception studies

Target review and adaptation:

Targets are reviewed regularly and adjusted based on: • Industry best practices and technological developments • Customer expectations and changing market requirements • Regulatory changes and safety standard updates • Incident analysis and lessons learned from operations • Stakeholder feedback and expert recommendations

Long-term objectives: • Industry leadership in maritime passenger safety and service excellence • Continuous innovation in customer safety and satisfaction measures • Sustainable value creation through excellent customer relationships • Regional development through reliable and safe transport services

These targets reflect Viking Line's commitment to protecting and serving its customers while building long-term value through excellence in safety, security, and customer service.

Viking Line has established comprehensive business conduct policies and corporate culture initiatives that guide ethical behavior throughout the organization.

Business ethics framework:

Viking Line maintains: • Code of Conduct governing employee behavior and business ethics • Anti-corruption policies addressing bribery and irregular business conduct • Whistle-blowing procedures for reporting ethical violations • Business ethics training program including anti-corruption training

Corporate culture development:

Leadership and employee development: • Training for managers and employees in leadership and communication skills • Organizational culture programs promoting positive workplace values • Leadership development initiatives to strengthen management capabilities • Communication training to enhance organizational culture

Employee wellbeing programs: • Work-life balance initiatives supporting employee mental and physical health • Psycho-physical wellbeing programs for employee support • Mental health support and access to assistance when needed • Physical working environment improvements and occupational health measures

Risk management and compliance:

Internal controls: • Regular internal controls and external inspections ensure compliance • Legal counsel involvement in business ethics risk assessment • Internal control function examines and investigates potential violations • Risk assessment processes for business partners and suppliers

Supplier relations: • Operational principles for suppliers including human rights respect • Supplier risk assessments based on country and industry risk factors • Supplier reviews through surveys and site visits • High-risk market identification using global risk indexes

Preventive measures:

Training and awareness: • Business ethics program with anti-corruption and compliance training • Regular training updates on ethical business conduct • Management training on recognizing and addressing ethical issues • Employee awareness of ethical standards and reporting procedures

Policy implementation: • Clear ethical guidelines communicated throughout the organization • Regular policy reviews and updates based on best practices • Consistent enforcement of ethical standards • Documentation and tracking of compliance efforts

Strategic integration:

Corporate culture as business-critical factor: • Long-term strategy includes corporate culture as key success element • Employee engagement enhancement through positive culture development • Customer and stakeholder trust building through ethical conduct • Competitive advantage through strong corporate culture and ethics

Risk mitigation benefits: • Reduced regulatory compliance risks through proactive ethical conduct • Enhanced reputation protection through consistent ethical behavior • Improved employee retention through positive workplace culture • Stronger stakeholder relationships through transparent and ethical practices

Continuous improvement:

Viking Line continuously develops its corporate culture through: • Regular assessment of culture and ethics effectiveness • Employee feedback integration in culture development • Best practice adoption from industry and other sectors • Investment in culture and ethics programs as strategic priorities

Monitoring and evaluation: • Regular monitoring of ethical conduct and culture indicators • Employee surveys assessing workplace culture and satisfaction • Compliance audits and risk assessments • Stakeholder feedback on corporate culture and business conduct

These policies and initiatives demonstrate Viking Line's commitment to maintaining high ethical standards and a positive corporate culture that supports both business success and stakeholder value creation.

Prevention and detection of corruption and bribery

Viking Line has assessed G1-3 (Prevention and detection of corruption and bribery) as not material.

Despite the non-materiality assessment, the company has disclosed some policies and practices related to this topic:

Anticorruption Policy

• Scope: The anticorruption policy applies to the Company's entire workforce in every country the Company operates in.
• Key content: The anticorruption policy establishes guidelines for business conduct principles and is incorporated in governing principles for decisionmakers and operational guidelines and internal instructions.
• Training and implementation: The Company carried out extensive training on its anticorruption policy and ethical business conduct during the period. For new recruitments, employees are informed about these policies, and training is regularly carried out to ensure understanding and compliance.
• Risk assessment: Viking Line has determined that the risk of corruption and bribes is highest in functions that manage relations with suppliers or authorities and in Group Management.
• Monitoring: Compliance with business conduct policies is evaluated on a regular basis through internal reviews and this is reported to Group Management, which takes further actions if necessary to strengthen compliance.

Code of Conduct

• Scope: Applies to the Company's entire workforce in every country the Company operates in.
• Key content: The Code of Conduct establishes guidelines for working conditions, human rights, health and safety as well as business conduct principles. It prohibits discrimination based on ethnic origin, gender, sexual orientation, religion, political views or disability.

Whistleblower Channel

• Availability: Viking Line has implemented a whistleblower channel for employees to report concerns.
• Communication: The Company reminds employees about the whistleblower channel with regular frequency to maintain awareness about reporting opportunities.
• Limitations: Viking Line has not arranged any separate employee training for using the channel. The Company has chosen not to establish any specific whistleblower channels for external stakeholders since the business model and operations do not entail a high exposure to business conduct risks outside the internal organization.

Governance and Oversight

• Responsibility: The CEO has overall/ultimate responsibility for compliance with the Company's policies, while operational management is handled by designated functions.
• Monitoring: Compliance and any anomalies are examined as needed by Group Management.

Operational Principles for Suppliers

• Content: Viking Line applies a zero tolerance policy to forced labour, child labour and human trafficking in the value chain. These matters are governed in Viking Line's operational principles for suppliers.

Business Ethics Culture

• Viking Line actively strives to strengthen its business ethics culture through continuous information, internal guidance and support in making decisions involving business ethics.
• The Company has chosen not to set quantitative or timebound targets for business conduct since the management of business conduct matters is integrated in the regular governance processes and monitored on a continuous basis through internal control functions and training programmes.

Limitations

• The Company has not implemented mechanisms for independent third-party verification of the effectiveness of these policies, but internal evaluations are carried out on a regular basis.
• The Company has no explicit policies for business ethics training in the organization apart from the measures noted above.

Incidents of corruption or bribery

Viking Line has stated that the ESRS G1-4 disclosure requirement (Incidents of corruption or bribery) is not material for the company in the 2024 reporting period.

Materiality assessment

In the list of disclosure requirements derived from ESRS G1 (Business conduct), Viking Line explicitly indicates:

• G1-4: Incidents of corruption or bribery – Not material
• G1-4: Fines for violation of anti-corruption and anti-bribery laws (Indicator no. 17 Table 3 in Annex I, Delegated Regulation (EU) 2020/1816, Annex II) – Not material
• G1-4: Standards of anti-corruption and anti-bribery (Indicator no. 16 Table 3 in Annex I) – Not material

Anti-corruption policies and procedures

While no quantitative incident data is disclosed, Viking Line describes its anti-corruption framework:

Policy framework:

• Viking Line has a policy against corruption and bribes, which is in accordance with the UN Convention against Corruption
• The policy is publicly available on the Company's website
• The Company has established mechanisms for identifying, reporting and investigating conduct that violates the law, the Company's Code of Conduct and other internal rules

Whistleblowing mechanism:

• Viking Line has a whistleblowing policy and provides a safe, secure reporting channel through which employees can report irregularities anonymously and with protection against retaliation
• The Company complies with the Finnish Whistleblower Protection Act (1171/2022), which incorporates Directive (EU) 2019/1937
• The whistleblower channel is available to all employees and ensures anonymity and protection against retaliation
• Viking Line reminds employees about the whistleblower channel with regular frequency
• The channel is primarily available to internal stakeholders; the Company does not provide specific reporting channels for external stakeholders

Investigation procedures:

• The handling of cases and investigations concerning business ethics violations is managed by the Company's legal affairs function and/or finance function
• This ensures that incidents are managed promptly, independently and objectively
• The decisionmakers handling cases are familiar with the whistleblower directive and relevant legal aspects

Risk assessment:

• Viking Line has determined that the risk of corruption and bribes is highest in functions that manage relations with suppliers or authorities and in Group Management
• To reduce these risks, the Company carried out extensive training on its anticorruption policy and ethical business conduct during the period

Governance:

• The CEO has ultimate responsibility for compliance with these policies
• Compliance with business conduct policies is evaluated on a regular basis through internal reviews and this is reported to Group Management

Quantitative disclosure

No quantitative data on confirmed incidents, convictions, fines paid, employees disciplined, or contracts terminated due to corruption or bribery has been disclosed for the 2024 reporting period. The company has invoked the materiality exemption for G1-4 disclosure requirements.