Viking Line

The role of the administrative, management and supervisory bodies

Reference: pages 21-23 (Tables 1-3).

The Board of Directors consists of "the Chair and six members as well as three deputy members" and "has not appointed any committees" (page 21). The Board sets the strategic sustainability priorities, approves objectives related to material impacts, risks and opportunities, and approves the risk management principles.

Independence and composition (Tables 1-3, pages 21-22): 6 of 7 Board members (86%) independent of the Company, 4 (57%) independent of significant shareholders; 1 executive and 6 non-executive Board members; Group Management is 7 executive members. Gender split: 2 women / 5 men on the Board, 1 woman / 6 men in Group Management. "Viking Line has no employee representation or representation of other workers on the Board."

A governance change is disclosed openly: the CEO was elected to the Board on 24 April 2025 and "held a dual role as both Chief Executive Officer and Board member until November 3, 2025"; the former CEO remains employed until 31 March 2026 "and is therefore to be regarded as a Board member not independent of the Company" (page 21).

Responsibility runs CEO to Board, with the CFO leading internal control and the Sustainability Manager compiling the statement (pages 22-23).

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

Reference: pages 22-23 (Table 4).

"At each monthly meeting, Group Management is informed of material sustainability-related impacts, risks and opportunities." The CEO reports regularly to the Board, which "approves the Company's priority areas and sustainability-related targets annually" (page 23).

Table 4 (page 23) lists the material risks and opportunities addressed by the governing bodies during the period, by topic and sub-topic: climate change (mitigation, energy, adaptation), pollution of air, waste, own workforce working conditions and corporate culture. For each, the risk categories named are financial effects, availability of technologies, time horizon, partnerships, local community and stakeholder requests.

Trade-offs are disclosed rather than glossed: "During the reporting period, trade-offs were made between financial conditions and the ability to implement various emission reduction measures or other sustainability-related investments. These trade-offs formed part of the Company's ordinary strategic and financial considerations by its governing bodies" (page 23).

Integration of sustainability-related performance in incentive schemes

Reference: page 24.

A complete nil return. "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" (page 24).

The Company has a compensation policy describing its main compensation principles for remunerating administrative, management and supervisory bodies, which "is presented to and approved by Viking Line's Annual General Meeting every four years at a minimum" (page 24).

No percentage of variable remuneration linked to sustainability or climate targets is disclosed, because none exists. The index (Table 13, page 39) lists ESRS 2 GOV-3 twice, once as a cross-cutting disclosure and again under ESRS E1, both referred to the ESRS 2 section.

Statement on due diligence

Reference: page 24 (Table 5).

Viking Line reports a gap rather than a process: "Viking Line currently has no formal tracking procedure for identifying and assessing adverse impacts on an ongoing basis" (page 24).

Table 5 maps the core elements of due diligence to sections of the statement:

Two of the five core elements are therefore marked "Not reported" by the company itself (page 24). This is a self-declared shortfall against the ESRS 2 GOV-4 mapping table and is worth reading alongside S1-1 (page 64), where the Company states it "does not have a formal mechanism for remediation of human rights impacts".

Risk management and internal controls over sustainability reporting

Reference: page 24.

Sustainability reporting sits inside the Company's existing internal control framework and "follows the principles applied to financial reporting" (page 24). For quantitative datapoints "a structured risk assessment method is applied, whereby risk is assessed based on likelihood and potential impact on the accuracy of the report". Datapoints involving manual processes, identified data quality deficiencies or external data sources are prioritised for enhanced controls.

The limitation is stated plainly: "A methodology for risk assessment of qualitative information has not yet been established" (page 24).

Data collection sits with process owners, review with designated control owners, consolidation with the sustainability function; the CFO approves the content before final Board approval. During the reporting period "particular emphasis was placed on controls within ESRS E1 and E5, resulting in the introduction of additional verification steps and a strengthened application of the four-eyes principle in the validation and approval of data" (page 24). That emphasis is consistent with the two prior-year errors corrected retrospectively and disclosed under BP-2 (page 20).

Strategy, business model and value chain

Reference: pages 24-26 (Table 6). The index records that "Viking Line has chosen to omit paragraphs 40(b) and 40(c)" (page 39).

Viking Line operates scheduled passenger and freight services and cruises in the northern Baltic Sea, with Finland, Sweden, Aland and the Baltic countries as main markets; the Turku-Stockholm and Helsinki-Tallinn routes "are part of the EU's TEN-T transport corridors" (page 25). Three market segments: cargo, passenger services in scheduled traffic, and cruise passengers. Sales offices in Finland, Sweden, Estonia and Germany; subsidiary Viking Line Buss Ab; a joint venture with Destination Gotland operating M/S Birka Gotland (pages 24-25).

Total revenue for the period was EUR 483.6 (484.4) million and headcount 2,730 (2,583) employees (Table 6, page 25). "Viking Line is not active in the fossil fuel sector, chemical production, controversial weapons or the cultivation and production of tobacco" (page 25).

Ambition: "Viking Line's long-term ambition is to provide fossil-free transport services by 2050." The Company notes that during the period renewable fuel prices were "significantly higher than for fossil alternatives" and that "Emission-free fuels were not available at all" (page 25).

Value chain (page 26): supplier flows split into commercial goods, consumables and services; logistics partners are the main suppliers; "The main outflow from the Company's operations is waste."

Interests and views of stakeholders

Reference: pages 26-27 (Table 7). The index heading reads "SBM-2 - Interests and views of stakeholders (including S1, S4)" (page 18).

Table 7 sets out eight stakeholder groups and how contact is organised: customers, employees and trade unions, suppliers and partners, local communities, trade associations, shareholders, financiers, the public sector and non-profit organisations (pages 26-27). Engagement runs through surveys, feedback channels, collective bargaining, dialogue meetings and trade association committee work.

A notable nil finding: "During the reporting period, no changes to the Company's strategy or business model were made explicitly as a result of stakeholder engagement" (page 27).

Own workforce: views are taken into account "through annual employee surveys, cooperation with trade unions and continuous dialogue", which have produced strategic priorities on collective agreements, competitive remuneration, fair scheduling and competence development (page 27).

Consumers and end-users: customer feedback "influences decisions relating, inter alia, to service offerings, product assortments and traffic planning", and customer expectations have led to "investments in energy-efficient vessels and alternative fuels". "Viking Line has not identified any specific consumer group as being at heightened risk of adverse impacts" (page 27).

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

Reference: pages 28-35 (Tables 8, 9, 10). The index records that "Viking Line has chosen to omit paragraph 48(e)" (page 39).

Material IROs "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" (page 28).

Three tables carry the IRO inventory, each row typed and rated:

• Table 8 - financial materiality (page 28): seven risk/opportunity rows. E1 climate change mitigation (Critical), E1 energy (Critical), E1 climate change adaptation (Significant and Important), E2 pollution of air (Significant), S1 working conditions as both a risk and an opportunity (Important).
• Table 9 - actual impacts (page 29): eight rows. E1 GHG emissions and energy dependence in own operations and in the value chain; E2 "Combustion of diesel oil generates SOX, NOX and particulate matter emissions"; E5 "Operations generate waste"; and one positive impact, "Viking Line provides secure, stable working conditions".
• Table 10 - potential impacts (page 29): two rows. S4 personal safety of consumers, and G1 corporate culture, both negative and Important.

The narrative on pages 30-35 works through each topic, including EU ETS and FuelEU effects.

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

Reference: pages 35-38 (Table 12).

All topical ESRS were screened, covering own operations and the upstream and downstream value chain (page 35). Each sustainability topic was scored on "the scope, scale, irremediable nature and likelihood of the impact under the double materiality principle"; impacts were treated as material where the combined points exceeded 50%. Table 12 (page 36) publishes the five-band scoring scale (Critical, Significant, Important, Informative, Minimal) with numeric ranges, and "The threshold value for materiality is >= Important" (page 35).

The Board approves the updated assessment annually; the process is run jointly by Group Management and the Sustainability Manager, with external expertise consulted (page 36). During the period the method was formalised: "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" (page 36). Next update planned for 2026.

Topic-specific process descriptions follow for climate, pollution, water, biodiversity, resource use and business ethics (pages 36-38), several with explicit boundaries, for example: "Viking Line has not yet analyzed emissions to soil or water in the upstream value chain since relevant data for such an assessment is not available" (page 37).

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

Reference: pages 39-46 (Tables 13 and 14).

Table 13, "List of disclosure requirements complied with based on the results of the materiality assessment", runs from ESRS 2 BP-1 through G1-6 across pages 39-41. Each row carries either a section reference, "Not material", or an explicit omission statement in the form "Viking Line has chosen to omit ESRS [code]".

What the index shows. Material standards are ESRS 2, E1, E2, E5, S1, S4 and G1. Whole standards marked "Not material" are ESRS E3, E4, S2 and S3 (pages 40-41). Individual DRs marked "Not material" are E1-7, E1-8, E2-5, E5-4, S1-9, S1-10, S1-14, S1-16, G1-2, G1-3, G1-4, G1-5 and G1-6. Seven DRs are expressly omitted: E1-9, E2-6, E5-6, S1-7, S1-11, S1-12 and S1-13. Note that the five S4 rows are referred to the ESRS 2 section rather than to a standalone S4 chapter, consistent with the contents page heading "SBM-2 - Interests and views of stakeholders (including S1, S4)" (page 18).

Table 14 (pages 42-46) lists the datapoints derived from other EU legislation, each mapped to SFDR, Pillar 3, Benchmark Regulation or EU Climate Law references and given the same three-way treatment.

Basis of preparation: the statement applies the ESRS phase-in provisions in Annex C and, per BP-2, "material phase-in provisions as amended by Commission Delegated Regulation (EU) 2025/1416 (Omnibus 'Quick Fix' Regulation)" (pages 20-21).

Transition plan for climate change mitigation

Reference: page 52.

There is no transition plan, and the Company says so directly. "Viking Line has not established a formal transition plan for climate change mitigation. This is because of the structural challenges faced by the maritime transport sector, where the possibility of implementing a transition in line with the 1.5 C target set out in the Paris Agreement depends on advances in sustainable energy carriers" (page 52).

"There are currently no commercially available fossil-free fuel alternatives on a scale required to enable maritime transport to achieve climate neutrality by 2050... so Viking Line could not confirm during the reporting period when a transition plan will be established" (page 52). No plans or targets have been set to make economic activities taxonomy-aligned.

Locked-in emissions get a dedicated sub-heading, "Qualitative assessment of potential locked-in greenhouse gas emissions from significant assets" (page 52). They "could potentially arise in the form of vessels that are not maintained on a regular basis", or where FuelEU or the EU ETS make fossil-only vessels unprofitable. "Viking Line believes that none of its significant assets runs the risk of becoming locked-in greenhouse gas emissions."

Targets, levers, actions and progress do exist, but under E1-3 and E1-4 (pages 53-54) rather than inside a plan.

Identification of climate-related risks and scenario analysis

Back-filled from ESRS 2 IRO-1 (pages 36-37) and SBM-3 (pages 30-31). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Physical versus transition classification is explicit. Table 11, "Material climate-related physical and transition risks" (page 30), types all four material E1 risks as "Climate-related transition risk", across mitigation, energy and adaptation. Physical risks were screened but did not clear the threshold: "physical climate-related risks were not considered to exceed the threshold of materiality during the reporting period" (page 37).

Physical hazards identified (page 36): changes in wind patterns "which could affect routes, fuel consumption and operational efficiency"; rising sea levels affecting port infrastructure; and "Cold spells and storms, which create risks for operational disruptions".

Scenario analysis is incomplete. "During the reporting period, Viking Line began a climate-related scenario analysis to identify and evaluate physical and transition-related risks and opportunities in the short, medium and long term. Since the analysis has not yet been completed, the Company based its assessment on available data and expert analyses" (page 36). No scenario is named, no temperature pathway given, no high-emission or 1.5 C-aligned scenario identified. The Company "intends to complete" it (page 37).

Resilience in relation to climate change

Back-filled from ESRS 2 SBM-3 (page 30) and IRO-1 (page 37). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

No ESRS resilience analysis was performed. "Viking Line did not carry out any detailed resilience analysis of its strategy or business model concerning climate change during the reporting period" (page 30). That is the finding; it is stated by the Company, not inferred.

What was done instead: "To ensure long-term business resilience, Viking Line carried out a continuity analysis of climate-related transition risks, which provides Group Management and the Board with information in making decisions on strategic adaptation" (page 37).

Adaptive capacity, in the Company's own words (page 30): "the Company assesses that its assets and business activities are not particularly sensitive to the identified climate-related physical risks". On transition risk it considers that "price increases in the value chain as a result of transition risks will not jeopardise its financial position over time", although "investments in new technology constitute mandatory mitigation measures in order to achieve the Company's long-term objectives".

Uncertainty is acknowledged in the strategy discussion: the price and availability of renewable or emission-free fuels is "uncertain", and emission-free fuels "were not available at all" (page 25).

Policies related to climate change mitigation and adaptation

Reference: page 53.

Another declared gap. "During the reporting period, Viking Line had no established policies with climate-related targets that addressed climate change mitigation or change, energy efficiency or development of renewable energy. The targets and policies that the Company applies related to climate change are not formally adapted to the requirements set out in ESRS E1" (page 53).

The Company describes what it does instead: "Viking Line has to date focused on carrying out a gradual reduction in greenhouse gas emissions through technological and operational measures but has not adopted an overall climate policy or climate targets in line with ESRS requirements" (page 53).

Forward intent is expressed without a date: "The Company intends to further develop its work with climate-related policies and targets in step with technological advances in the maritime transport sector and regulatory changes affecting the sector's long-term transition" (page 53).

The disclosure gives no policy scope, no most senior accountable level and no third-party standards, because no policy exists to describe. Related environmental governance does exist elsewhere: the head office and all vessels are ISO 14001 certified (pages 47, 60).

Actions and resources in relation to climate change policies

Reference: page 53.

Quantified spend. "During the reporting period, Viking Line invested approximately EUR 1.1 million in measures to improve energy efficiency and reduce emissions from the Company's vessels and properties" (page 53). E2-2 adds the longer run: "Between 2018 and 2025, Viking Line invested a total of approximately EUR 8.6 million in energy efficiency improvements" (page 59). Most measures completed in the period, "with the exception of certain vessel-related technical upgrades that will continue until 2027".

The headline action is fuel switching. Under an agreement with its LNG supplier to generate FuelEU compliance credits, "since July 2025, Viking Line has replaced fossil LNG with renewable bio-LNG in a volume corresponding to 50% of each vessel's total annual fuel consumption" (page 53). Use of bio-LNG "amounted to 6,978 (686) tonnes, corresponding to approximately 97,000 (9,500) MWh of energy. This contributed to an estimated reduction in gross greenhouse gas emissions of approximately 47,700 (5,600) tonnes of CO2e WtW", on Viking Grace and Viking Glory. The credits generated were transferred to the fuel supplier.

Future resources are not quantified: "The future financial and other resources that Viking Line intends to invest in implementing measures to reduce its climate footprint and dependence on fossil fuels have not yet been quantified" (page 53).

Targets related to climate change mitigation and adaptation

Reference: pages 53-54 (Table 19).

Scope 1: "The Company's Scope 1 emissions of carbon dioxide (CO2), methane (CH4), and nitrous oxide (N2O) will be reduced to zero by 2050, with 2008 as the base year" (page 53). The target is absolute "but may include greenhouse gas removals, carbon credits or avoided emissions in order to achieve net zero emissions" (page 54). "A target for 2030 and other interim targets will be established in connection with the Company's development of its transition plan."

Intensity pathway: the Company adopts the FuelEU Maritime trajectory, base year 2020 at 91.16 g CO2e/MJ. Table 19 (page 54) gives the reductions: 2% by 2025, 6% by 2030, 14.5% by 2035, 31% by 2040, 62% by 2045 and 80% by 2050.

Scope 2: an ambition of fossil-free electricity in land-based functions, base year 2024, "Although the target year had not yet been determined during the reporting period". Progress: the fossil share of land-based energy fell "from 30% in 2024 to 18.9%" (page 54).

Scope 3: "No quantitative targets for Scope 3 emissions were established during the reporting period" (page 54).

Targets are not science-based or externally validated. Note an internal inconsistency: footnote 1 to Table 22 states "During the reporting period, Viking Line had not established any targets or interim targets" (page 58), which sits awkwardly with the E1-4 text.

Energy consumption and mix

Reference: pages 54-55 (Tables 20 and 21).

Viking Line operates in a high climate impact sector, NACE section H transport and warehousing, 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" (page 54).

Table 20, energy consumption and mix (MWh), 2025 (2024):

The renewable share rose from 1.5% to 11.2% in one year, driven by bio-LNG. Energy intensity was unchanged at 0.0019 MWh/EUR of net sales (Table 21, page 55).

Gross Scopes 1, 2, 3 and Total GHG emissions

Reference: pages 55-58 (Table 22).

Calculated under the GHG Protocol, with AR6 100-year GWPs and MRV tank-to-wake emission factors for vessel fuels (page 55).

Table 22, tonnes CO2e, 2025 (2024):

Intensity: 0.0009 tCO2e/EUR location-based, 0.0008 market-based (page 58).

Only three Scope 3 categories were assessed as significant; twelve were excluded and each exclusion is reasoned (page 57). Data quality is disclosed: 20.5% of Scope 3 from primary supplier data, 41.6% spend-based, 37.9% activity-based with secondary factors. Biogenic CO2 from renewable fuel was 19,190 (1,886) tonnes (page 56). The 2024 Scope 1 figure was restated by -1,886 tCO2e and Scope 3 category 3 by +2,987 tCO2e (page 58).

Policies related to pollution

Reference: page 59.

"Viking Line has no formally adopted policies specifically for managing pollution, but the Company's strategy includes measures to prevent and minimize air pollution from its own operations" (page 59). The Company works systematically to reduce SOx, NOx and particulate matter, "which are mostly generated in the combustion of vessel fuels".

The gap is stated against the standard: "The targets that Viking Line applies related to pollution are not formally adapted to the requirements specified in ESRS E2... Viking Line's strategy has primarily been focused on complying with and exceeding existing legal requirements rather than establishing its own internal policy framework" (page 59).

On substances of concern: "Viking Line does not have a specific policy for the substitution and minimisation of substances of concern (SHC) or substances of very high concern (SVHC), or for the phase-out of such substances, as the Company's operations do not include the production, distribution or commercialisation of these substances. However, during 2024, Viking Line carried out a mapping of the presence of SHC and SVHC in its own operations. Consequently, Viking Line is evaluating the possibilities of substituting or minimising the use of these substances where this is practical and economically feasible" (page 59).

Actions and resources related to pollution

Reference: page 59.

Pollution management runs through certification rather than a standalone policy: processes "are integrated into the Company's ISO 14001-certified environmental management system, which includes systematic risk assessments, continuous internal and external reviews", and the fleet and organisation are certified under the ISM Code (page 59).

Named actions (page 59):

• A strategic decision "to use low-sulphur or sulphur-free fuels instead of installing scrubber systems". "By avoiding scrubber systems, emissions of sulphur-containing pollutants and heavy metals that would otherwise be discharged through scrubber water are prevented."
• Viking Grace and Viking Glory operate on LNG, "which eliminates SOx emissions and significantly reduces NOx and PM emissions".
• "To reduce air pollution in port areas, Viking Line's vessels use shore power while docked where such infrastructure is available."
• Engines modified to meet IMO Tier III NOx provisions, and heavy fuel oil eliminated (page 32).

Resources: "During the reporting period, the Company invested approximately EUR 1.1 (1.8) million in such measures", and "Between 2018 and 2025, Viking Line invested a total of approximately EUR 8.6 million in energy efficiency improvements" (page 59). Certain vessel technical upgrades continue into 2026 and 2027. Measures are selected against best available technology and the vessels' dry-docking schedules.

Targets related to pollution

Reference: page 59.

A nil return with a reason. "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" (page 59).

The Company explains the boundary: "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" (page 59).

So air pollution is managed as a by-product of the fuel-efficiency and fuel-switching work reported under E1-3 and E2-2, without a dedicated pollution reduction target, baseline or target year. No ecological thresholds, no entity-specific allocation and no stakeholder consultation on targets are described, because no target exists. This is consistent with E2-1, where the Company states its pollution work is not formally adapted to ESRS E2 (page 59).

Pollution of air, water and soil

Reference: pages 59-60.

Regulatory frame: Viking Line complies with the IMO MARPOL Convention, and its operating area, the Baltic Sea, "is classified as an Emission Control Area (ECA), which means that stringent emission limits are in place for both NOX and SOX" (page 59).

SOx: "Viking Line uses low-sulphur or sulphur-free fuel, and total SOX emissions from the Company's vessels during the reporting period did not exceed the limits set in MARPOL Annex VI and Annex II of Regulation (EC) No 166/2006" (page 59). No tonnage is given for SOx.

NOx: "During the reporting period, Viking Line's total NOX emissions from its vessels was 3,113 (3,177) tonnes" (page 60). Method disclosed by fuel type: for diesel vessels, fuel consumption with BIMCO Shipping KPI Standard factors; for gas vessels, factors from direct measurements under the IMO NOx Technical Code 2008. "Continuous NOX measurements have not been implemented since such systems entail high costs and are currently not a regulatory requirement."

PM: "The MARPOL Convention currently includes no specific limits for PM emissions, which means that Viking Line has no obligation to measure or report these emissions" (page 60). No PM figure is disclosed.

Microplastics: "The Company does not create or use any microplastics in its operations" (page 60). Water and soil: no direct emissions to water, and all wastewater is pumped ashore for municipal treatment (pages 32, 37).

Policies related to resource use and circular economy

Reference: page 60.

"Viking Line has no established policies that expressly address resource use and a circular economy. The strategies that the Company applies in this area are not formally adapted to the requirements specified in ESRS" (page 60). The Company has "focused on optimizing raw material use and improving the resource efficiency of operations through technological and operational measures rather than adopting a general policy".

What it does apply is the EU waste hierarchy: "Viking Line's environmental work endeavours to apply the EU waste hierarchy, with the Company prioritizing the minimization of waste volumes, reuse of materials and recycling of secondary resources" (page 60). This sits inside the ISO 14001-certified environmental management system (page 60).

Forward intent, again undated: "In step with the tightening of regulations in resource use and circular economy at the EU level, Viking Line will follow developments and evaluate the need to adopt more formalized targets and policies in the area" (page 60).

The pattern across E1-2, E2-1 and E5-1 is consistent - management practice without a formally adopted ESRS-aligned policy, disclosed as such rather than dressed up.

Actions and resources in relation to resource use and circular economy

Reference: pages 60-61 (Table 23).

Actions target waste reduction, reuse and recycling of secondary raw materials, applying the waste hierarchy through the ISO 14001 system and "by establishing networks with business partners that can use waste as a raw material" (page 60).

Table 23, actions and quantities in tonnes, 2025 (2024):

The printed-material figure is an "Estimated quantity based on orders of printed material in previous years" (page 61). SBM-3 adds a textile recycling partnership, "which reduces waste and the need for new raw materials" (page 33).

Resources: "These efforts were carried out without requiring significant financial investments since they were mostly based on process improvements and efficiencies rather than capital-intensive measures" (page 61). Planned next steps: more recycled and bio-based materials in procurement, further digitisation, new waste-to-raw-material collaborations, and better data collection on material flows.

Targets related to resource use and circular economy

Reference: pages 61-62.

Two quantified, time-bound targets - the only numeric environmental targets in the statement besides the E1 pathway.

Mixed waste per passenger: "a 10% reduction in mixed waste per passenger between 2023 and 2026 compared with the base year 2022. The base value was 426 grams per passenger and the target value 383 grams. During the reporting period, the amount of mixed waste per passenger was 416 grams, corresponding to a reduction of 2.3% compared with the base year and 1.0% compared with the previous period (420 grams in 2024)." Mixed waste from the vessels fell 190 tonnes, or 9.0%, from 2,107 to 1,917 tonnes (page 61). The per-passenger measure is behind trajectory.

Food waste per restaurant guest: a 10% reduction by 2026 on the two vessels with the highest restaurant volumes, base year 2024 at 151 grams per guest, target 136 grams. "The target was exceeded during the reporting period, as food waste amounted to 95 grams per guest, representing a reduction of approximately 37%" (page 61). The approach will extend to all vessels in 2026, with base and target values not yet defined.

The Company is explicit about scope limits: "All targets are voluntary and not mandated by legislation"; external stakeholders were not consulted; there are no targets on circular product design, renewable resources or recycled content; and the targets "apply only to its own operations" (pages 61-62).

Resource outflows

Reference: page 62 (Table 24), with waste volumes in Table 25 (page 63).

Viking Line reports a products nil return and a waste positive: "Viking Line produces no goods, which means that resource outflows for products and materials are not considered material in the materiality assessment. However, waste management in the Company's own operations is considered a material sustainability matter. The primary outflow from Viking Line's operations consists of waste generated on board the vessels" (page 62).

Nothing is therefore disclosed on durability, reparability, recyclability or recycled content of products, because there are no products.

Wastewater is reported as a sector-specific outflow. "For the maritime transport sector, wastewater - including grey and black water as well as bilge water - is considered a relevant waste stream. This waste is reported following the industry practice in volume metrics (m3) rather than weight" (page 62).

Table 24, wastewater pumped ashore to municipal waterworks (m3), 2025 (2024): grey and black water 224,646 (220,599); bilge water 5,117 (5,492).

Other outflows named for the period are cardboard and paper, metal, biological waste, glass, energy waste and incinerable waste. A data-quality caveat is given: waste volumes "are based on supplier data from direct measurements. These measurements have not been validated by a third party" (page 62).

Waste

Reference: page 63 (Table 25), with the outflow narrative on page 62.

Table 25, total waste in tonnes, 2025 (2024):

Total waste fell 10.5% year on year and non-recycled waste fell from 882 tonnes to 1 tonne. That step change is partly a reclassification rather than an operational change: three footnotes record that "Supplier statistics have been adapted to ESRS during the reporting period", moving outflows previously reported as incineration into other recovery operations, and preparation for reuse into material recycling or other recovery (page 63). Composition and prior-year comparability should therefore be read with care.

Policies related to own workforce

Reference: page 64.

"No material changes were made to Viking Line's policies related to its own workforce during the reporting period. The Company's primary policies in this area are the Code of Conduct, the Equality Policy and the Anti-Corruption Policy" (page 64), applying to the entire workforce in all countries of operation.

Alignment gaps are disclosed, not hidden:

• "Viking Line respects fundamental human rights but had not yet aligned its policies with the UN Guiding Principles on Business and Human Rights during the reporting period" (page 64), though it meets the ILO Declaration through collective bargaining.
• "Viking Line's policies do not contain specific commitments regarding inclusion or positive measures for vulnerable groups within the workforce", relying instead on competence-based selection.
• "Viking Line has therefore not established specific policies to prevent forced or child labour within its own operations, as these risks have not been identified as material", given collectively agreed conditions in Finland, Sweden and Estonia.
• "The Company has not implemented mechanisms for independent third-party evaluation of the effectiveness of the policies."
• "Viking Line does not have a formal mechanism for remediation of human rights impacts."

The Code of Conduct prohibits discrimination on grounds including ethnic origin, gender, sexual orientation, religion, political opinion and disability (page 64).

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

Reference: page 65.

Engagement is structured around trade unions and collective bargaining. "Trade union representation is a central part of the consultation structure, and Viking Line conducts collective bargaining negotiations with union representatives and trade unions", supplemented by continuous discussions with employee representatives (page 65).

Accountability: the HR functions, which are separate for shore-based and shipboard employees, hold operational responsibility for ensuring engagement takes place; "The CEO has ultimate responsibility for ensuring that the outcomes of these dialogues are considered in the Company's strategic decisions"; and "Group Management continuously evaluates the effectiveness of the Company's consultation processes" (page 65).

Coverage: "The entire Viking Line workforce is covered by collective agreements, and all employees have the right to join trade unions... This ensures that all employees have an institutionalized opportunity to raise their interests and influence working conditions." No global framework agreement exists (page 65).

A stated limitation: "The Company has not implemented specific procedures to identify or collect feedback from employees who may be at particular risk of being negatively affected by the operations or who belong to marginalized groups" (page 65).

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

Reference: page 65, with the whistleblowing channel described under G1-1 (page 70).

Employees are encouraged to raise matters first with their immediate supervisor, then with the HR functions, and if necessary "directly with Group Management or the CEO" (page 65). Union representatives and collective bargaining provide a parallel route, and anonymous feedback is collected through regular employee surveys and career development discussions.

A system gap is disclosed: "The HR function for shore-based employees uses a case management system that enables systematic registration and follow-up of cases, while the HR function for shipboard employees does not yet have a corresponding system" (page 65). Since the great majority of the workforce is seagoing, this is a material limitation, and it recurs in S1-17 (page 69).

Handling is a prompt assessment, a decision on actions and feedback to the employee. "Viking Line conducts regular follow-up and analysis of submitted cases in order to identify recurring issues" (page 65).

Effectiveness tracking is planned rather than in place: "Going forward, employee surveys will also be used to collect feedback on whether employees are aware of and trust the reporting channels, whether they feel safe using them" (page 65). Retaliation protection sits in the whistleblowing policy under G1-1 (page 70).

Taking action on material impacts on own workforce

Reference: page 66.

The material impact is the positive one: "In the materiality assessment, secure employment was identified as a material positive impact for Viking Line's own workforce" (page 66).

The working model is treated as both the impact and the lever. "The working model for shipboard employees, where work is carried out in longer shifts followed by extended periods of leave, is a central part of the Company's operational structure and a strategic advantage in recruitment. It enables the Company to recruit employees from a wider geographical area... At the same time, the working model may create challenges in maintaining work-life balance, which in turn may affect the Company's attractiveness as an employer" (page 66).

Three named actions for the period (page 66): structured scheduling for shipboard employees to strengthen predictability; continued competence-based HR processes for equal treatment in recruitment and promotion; and follow-up through employee surveys. For shore-based staff, part-time remote work and an equality plan supporting the balance between work and parenthood. "During the 2026 reporting period, work will continue in these three areas; no extensive new action plans have been considered necessary."

Resourcing is not ring-fenced: actions run "through existing functions such as HR, the safety organization and line managers, without a separate budget item" (page 66).

Targets related to own workforce

Reference: page 67.

A declared nil return. "Viking Line had not established any time-bound and outcome-oriented targets for managing material impacts, risks or opportunities related to its own workforce during the reporting period" (page 67).

In place of targets the Company points to processes and measures: structured scheduling for shipboard employees, part-time remote work for shore-based employees, and an equality plan aimed at facilitating the balance between work and parenthood. "These measures are monitored through employee surveys, the results of which are used as a basis for adapting strategies and employment conditions" (page 67).

The Company keeps the question open: "Viking Line continuously evaluates the need to establish formal and time-bound targets in this area. During the reporting period, no additional material risks or opportunities were identified, and therefore no specific targets or new initiatives were established" (page 67).

No baseline year, no target values and no stakeholder involvement in target setting are disclosed, because no target exists. Effectiveness tracking in the absence of targets rests on the employee survey, which is the MDR-T alternative limb. Note that the only quantified workforce-adjacent measures in the statement are the S1-6, S1-8, S1-15 and S1-17 metrics, none of which carries a target.

Characteristics of the undertaking's employees

Reference: pages 67-68 (Tables 26-29).

Headcount at 31 December 2025 was 2,730 (2,583). "During the reporting period, 129 (151) employees left the Company, corresponding to an employee turnover rate of 4.7% (5.8%)", calculated as voluntary leavers over closing headcount (page 67).

By gender (Table 26): men 1,551 (1,495), women 1,179 (1,088); no employees recorded as other or not indicated.

By country (Table 27, countries with at least 50 employees representing at least 10% of the total): Finland 2,286 (2,101), Sweden 399 (433).

By contract type (Table 28), 2025 (2024): permanent 2,114 (2,069); temporary 563 (470); non-guaranteed hours 53 (44); full-time 2,638 (2,485); part-time 39 (54). Temporary employment rose 19.8% year on year.

Method and limitations (page 67): data comes from payroll and HR systems, on a headcount rather than full-time-equivalent basis. "Historically, Viking Line has reported employee data as of 31 December each year, which does not reflect an average number of employees over the reporting period. The Company is therefore evaluating the possibility of adapting the reporting method in the future to better align with ESRS requirements."

Estonia is excluded from the significant-employment breakdown: of 128 (120) employees resident there, only 44 (48) hold Estonian contracts, "below 50", so they are grouped with other countries (page 67).

Collective bargaining coverage and social dialogue

Reference: page 68 (Table 30).

"During the reporting period, Viking Line had significant employment in Finland and Sweden. Working and employment conditions were determined or influenced by collective agreements for all of the Company's employees" (page 68).

The metrics: "The share of the Company's employees covered by collective agreements was 100%, and the share of employees represented by employee representatives was 97.3% in all countries where the Company had significant employment" (page 68). Table 30 places both Finland and Sweden in the 80-100% band for collective bargaining coverage and for workplace representatives.

Employees "were part of the social dialogue within the EEA". "Viking Line had no agreements with its employees regarding representation in a European Works Council or in a works council of a European Company (SE) or a European Cooperative Society (SCE)" (page 68).

Full collective agreement coverage is the foundation the Company relies on elsewhere: S1-1 uses it to conclude that forced and child labour risks in own operations are negligible and that no specific policy is needed (page 64), and S1-2 uses it to establish that "all employees have an institutionalized opportunity to raise their interests" (page 65). No coverage figure is given for employees outside the EEA, and none would be expected given the Finland, Sweden and Estonia footprint.

Work-life balance metrics

Reference: page 69 (Table 33).

"During the reporting period, 100% of the Company's employees were entitled to family-related leave through social policy and collective agreements" (page 69).

Table 33, employees taking family-related leave, 2025 (2024):

Take-up fell year on year in both absolute and percentage terms, from 99 employees (3.8%) to 81 (3.0%). Men accounted for 75% of the leave taken in 2025.

Work-life balance is the one own-workforce sub-topic the DMA rates as both a risk and an opportunity: Table 8 records "Working conditions for on-board employees have a negative impact on the Company's attractiveness as an employer" as a risk and the mirror statement as an opportunity, both Important (page 28). S1-4 links the metric to the shift pattern: the model of "longer shifts followed by extended periods of leave... may create challenges in maintaining work-life balance", managed through structured scheduling, part-time remote work ashore and an equality plan supporting the balance between work and parenthood (page 66). No target attaches to the metric (page 67).

Incidents, complaints and severe human rights impacts

Reference: page 69.

The measurement limitation is disclosed first. "During the reporting period, Viking Line did not have a Group-wide systematic approach for recording and monitoring incidents and complaints related to discrimination, harassment or work-related grievances within its own operations. Although established reporting channels were available... there was no common digital system support enabling centralized consolidation of the information. As a result, the reported information is based on cases that were explicitly reported to the HR departments during the period" (page 69).

The figures, on that basis:

• "For the reporting period, one (1) case concerning suspected discrimination or harassment was reported."
• "During the reporting period, Viking Line neither received nor paid any fines, penalties or compensation in relation to cases of discrimination."
• "The Company also did not identify any severe human rights incidents related to its own workforce."

Complaints: "Viking Line did not have unified statistics on the number of complaints submitted by the Company's own workforce." The shore-based HR department has a case management system; "the HR department for shipboard employees does not yet have a corresponding mechanism" (page 69).

A single reported case across 2,730 employees should be read against that gap, not as a settled incidence rate.

Policies related to consumers and end-users

Reference: ESRS 2 section, pages 20, 27 and 34. The ESRS content index refers all five S4 disclosure requirements to the ESRS 2 section rather than to a standalone S4 chapter (Table 13, page 41).

The Company states there is no ESRS-aligned policy, and explains why. "The Company has not established specific targets or policies for consumers and end-users under ESRS requirements, as maritime safety is already subject to strict regulatory frameworks. These statutory requirements govern safety management systems, risk assessments and crisis management procedures applicable to all consumers travelling with Viking Line" (BP-2, page 20).

What governs instead: "Viking Line complies with relevant international and national safety laws and conventions, including the International Safety Management Code (ISM Code) and the International Ship and Port Facility Security Code (ISPS Code). The Company's safety and security policy governs how safety and risk management are implemented in operations" (page 34).

On broader consumer rights: "Viking Line has implemented principles to ensure that customers' rights and human rights are respected in all parts of its operations, including principles relating to data protection and privacy, safety and security, and responsible marketing and transparency" (page 27).

"Viking Line has not identified any specific consumer group as being at heightened risk of adverse impacts" (page 27).

Processes for engaging with consumers and end-users about impacts

Reference: ESRS 2 section, pages 26-27. The ESRS content index refers all five S4 disclosure requirements to the ESRS 2 section rather than to a standalone S4 chapter (Table 13, page 41).

Customers are one of eight stakeholder groups in Table 7, engaged through "Customer letters and newsletters", "Customer satisfaction metrics and surveys", "Feedback channels" and "Collaborations to adapt services or design new solutions" (page 26).

"Viking Line conducts regular customer surveys and stakeholder dialogues to understand the expectations and needs of both passengers and freight customers. Customer feedback influences decisions relating, inter alia, to service offerings, product assortments and traffic planning" (page 27).

Outcomes fed into the business model: customer expectations on climate, safety and fair working conditions "have led Viking Line to adapt its business model through investments in energy-efficient vessels and alternative fuels, increased digitalisation and customer experience enhancements, and the development of new services" (page 27).

Accountability: "Group Management receives regular updates on the views and interests of affected stakeholders... The CEO reports, when necessary, to the Board" (page 27).

No stage, frequency or dedicated function is specified for consumers as affected stakeholders distinct from customers as a commercial audience.

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

Reference: ESRS 2 section, pages 26-27 and 34. The ESRS content index refers all five S4 disclosure requirements to the ESRS 2 section rather than to a standalone S4 chapter (Table 13, page 41).

The channel disclosed for consumers is the commercial feedback route. Table 7 lists "Feedback channels" and "Customer satisfaction metrics and surveys" as the organised means of contact with customers (page 26), and page 27 records that customer feedback influences service offerings, product assortments and traffic planning.

Safety incidents run through a separate, regulated route: "National authorities conduct regular inspections of the Company's vessels, safety systems and fire protection measures", supported by daily on-board safety checks, crew drills and a regularly tested crisis management plan (page 34).

An important limitation sits under G1-1: the Company's misconduct reporting mechanisms "are primarily available to internal stakeholders, while the Company does not provide dedicated reporting channels for external stakeholders to report misconduct" (page 70).

No grievance mechanism specific to consumers is described, no volume or outcome of consumer complaints is given, and no assessment of consumer trust in the channels is reported. The index nonetheless lists S4-3 as covered.

Taking action on material impacts on consumers and end-users

Reference: ESRS 2 section, pages 34-35. The ESRS content index refers all five S4 disclosure requirements to the ESRS 2 section rather than to a standalone S4 chapter (Table 13, page 41).

The material S4 impact is potential, not actual: Table 10 records "Personal safety of consumers and end-users", own operations, negative, rated Important (page 29). "The materiality assessment did not identify any actual adverse impacts on consumers... The potential impacts identified relate to individual incidents concerning the personal safety of consumers" (page 34).

The actions are the safety regime. "Safety management is an integrated part of the Company's strategy and business model and includes safety governance through international regulatory frameworks, proactive risk management and safety training" (page 34). "All vessels and shore-based units comply with the ISM and ISPS frameworks... On-board safety personnel conduct daily safety checks, while the crew undergo weekly, monthly and annual drills", and the crisis management plan is tested on board and ashore (page 34).

Effectiveness is framed commercially: consumer safety is "a business-critical factor" that "builds increased trust among customers" (page 35). No incident count, injury metric or drill completion rate is disclosed, so effectiveness is asserted rather than measured.

Targets related to consumers and end-users

Reference: ESRS 2 section, pages 20 and 34-35. The ESRS content index refers all five S4 disclosure requirements to the ESRS 2 section rather than to a standalone S4 chapter (Table 13, page 41).

A declared nil return with a stated reason: "The Company has not established specific targets or policies for consumers and end-users under ESRS requirements, as maritime safety is already subject to strict regulatory frameworks" (BP-2, page 20).

No measurable, outcome-oriented and time-bound target is therefore set for managing the material potential impact on consumer personal safety, and no baseline or target year is given.

In place of a target the Company relies on regulatory compliance and external verification: ISM and ISPS Code compliance across all vessels and shore-based units, and the fact that "National authorities conduct regular inspections of the Company's vessels, safety systems and fire protection measures" (page 34). Internally, safety personnel "conduct daily safety checks, while the crew undergo weekly, monthly and annual drills" (page 34).

That is effectiveness tracking in the absence of a target, the MDR-T alternative limb, though no metric is published from it. Adverse impacts on consumers' health and safety "are considered unlikely due to the comprehensive safety measures implemented in the operations" (page 34).

Business conduct policies and corporate culture

Reference: page 70.

"Viking Line has an anti-corruption and anti-bribery policy that is aligned with the United Nations Convention against Corruption. The policy is publicly available on the Company's website" (page 70).

Whistleblowing: a policy and "a secure and protected reporting channel through which employees can report misconduct anonymously and with protection against retaliation", under the Finnish Whistleblower Protection Act (1171/2022) implementing Directive (EU) 2019/1937. Reports are handled by the legal and/or finance function "promptly, independently and objectively". "Viking Line has not arranged separate training for employees on the use of the channel" (page 70).

Risk areas and training: "the risk of corruption and bribery is highest within functions that manage relationships with suppliers or authorities, as well as within Group Management. To mitigate these risks, the Company conducted comprehensive training on the anti-corruption policy and ethical business conduct during the reporting period" (page 70).

Stated gaps: no dedicated whistleblowing channel for external stakeholders, on the basis that the business model is "not considered to entail a high level of exposure to risks related to responsible business conduct outside the internal organization"; no explicit animal welfare policy; and no outcome-oriented targets on corporate culture (page 70).

Targets related to business conduct

Back-filled from the business conduct chapter (page 70), where targets are addressed as part of the MDR-T disclosures rather than as a numbered disclosure requirement. G1-3 became a standalone DR only in the 2025/2026 ESRS, and this statement was prepared under the 2023 ESRS.

Viking Line discloses no business conduct targets, and says so twice. "During the reporting period, Viking Line had not established outcome-oriented targets to monitor the effectiveness of the Company's policies and actions in relation to material impacts, risks and opportunities concerning corporate culture" (page 70).

And with the reason: "Viking Line has chosen not to establish quantitative or time-bound targets for responsible business conduct, as the management of responsible business conduct issues is integrated into ordinary governance processes and is continuously monitored" (page 70).

Effectiveness is tracked in the absence of targets, which is the MDR-T alternative limb:

• "Compliance with business ethics policies is regularly evaluated through internal audits and reported to Group Management, which may take additional measures to strengthen compliance where necessary" (page 70).
• "Regular internal controls and external inspections ensure that Viking Line's operations are run in accordance with international standards regulations and best practice principles" (page 35).

Corporate culture actions on page 35 carry no metrics.